ML20128N989
| ML20128N989 | |
| Person / Time | |
|---|---|
| Issue date: | 09/03/1996 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| SECY-96-152-C, NUDOCS 9610170098 | |
| Download: ML20128N989 (3) | |
Text
_
8 AFFIRMATION VOTE l
RESPONSE SHEET
- 000o0c RELEASED TO THE PDR l
}oJ%l'74 JWh)
TO:
John C.
Hoyle, Secretary date ini
................. tials FROM:
CHAIRMAN JACKSON l
l
SUBJECT:
SECY-96-152 - FINAL RULEMAKING - REVISION TO I
10 CFR PART 34, LICENSES FOR INDUSTRIAL RADIOGRAPHY AND RADIATION SAFETY REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHIC OPERATIONS AND REVISION TO THE NRC l
Approved xx Disapproved Abstain l
l Not Participating Request Discussion COMMENTS:
Based on the staff regulatory analysis that concludes that the benefit of l
two individuals justifies the additional cost, I approve the final rule l
and the inclusion of the two-man requirement. However, the staff should explore applying backfit rule provisions to regulations like Part 34, to ensure detailed analyses of future, similar changes. Additionally, revise l
the Federal Register Notice as shown on the attached.
1 1
. W (SIGNATURE l
Release Vote
/XX /
September 3, 1996 DATE I /
Withhold Vote
/
/
Entered on "AS" Yes XX No i
170021 9610170098 960903 PDR COMMS NRCC l
CORRESPONDENCE PDR i
_p?
1.
Example C.4 is being amended to add a reference to uncertified persons. Conduct of licensed activities by an uncertified person is significant because the certification demonstrates that the person has received training in accordance with 10 CFR Part 34 or equivalent Agreement State regulation, has satisfactorily completed a minimum period of an on-the-job trainir.9, and has received verification by an Agreement State or an NRC licensee that the person has demonstrated the capability of independently working as a radiographer.
2.
Example C.8 is being amended to add a reference to have present Nr tra rwe ouure in w o ms, emergent 3rnatites. A failure, during radiographic operation, to have present y crw rmonnu mo<v.WG emergency-nortires-as required by 10 CFR Part 34 when-onl-y-one. radiographer is-1r fecutba AssunMCE present is significant because thera nande te be-nntun to the public if a Chrt ATIdNPu 1 PAT ie disable %FE7ttvEArde ; : AtJb EMEME7/cY froet was t
,r_adiographer d.
u n et cFrecra vELY ltu LevenTL"D -
3.
Example C.12 is being added to address a failure, during radiographic operation, to stop work after a pocket dosimeter is found to be off-scale, or after an electronic dosimeter reads greater than 200 mrem, and before a determination of the individual's actual radiation exposure has been' made. This example is significant because of the need to evaluate the potential to exceed regulatory limits and the need to take corrective act n.
O & cmiMc.kwgv M M ndL + b AbfN10-0 W "'
The existing examples for Severity Level III violations presen address other significant violations of the amendments to 10 CFR Part 34 such as a failure to perform surveys to determine that the sealed source has been returned to its shielded position, to properly monitoring site boundaries for access control, and to utilize qualified RS0s.
3 l
l
y Therefore, the following revision is made to Supplement VI and will be reflected in the next publication of NUREG 1600:
l SUPPLEMENT VI--FUEL CYCLE AND MATERIALS OPERATIONS l
C.
Severity Level III - Violations involving for example:
l 4.
Conduct of licensed activities by a technically unqualified or uncertified person
/
l l
[
8.
A failure, during radiographic operations, to have present at least two qualified individuals or to use radiographic equipment, radiation l
survey instruments, and/or personnel monitoring devices as required by 10 CFR Part 34;
( IDStit W t ] )*
l0.
y l
- 11. A significant failure to meet decommiss.oning requirements including a failure to notify the NRC as required by regulation or license condition, substantial failure to meet decommissioning standards, failure to l
conduct and/or complete decommissioning activities in accordance with regulation or license condition, or failure to meet required schedules without adequate justificationj or 4