ML20136E272
| ML20136E272 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1982 |
| From: | Brodsky A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Ryan Alexander NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20136D915 | List:
|
| References | |
| FRN-50FR30616, RULE-PR-35 AA73-1, NUDOCS 8206210294 | |
| Download: ML20136E272 (3) | |
Text
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MEMORANDUM FOR: Robert E. Alexander, Chief Occupational Radiation Protection Branch, RES FROM: Allen Brodsky 48 M Occupational Radiation Protection Branch, RES
SUBJECT:
REVIEW 0F PROPOSED 10 CFR Part 35 I have reviewed the proposed revision of 10 CFR Part 35, submitted with the memo of May 5,1982, from R. E. Cunningham, and have discussed a coordinated RES reply with Beth Rodenbeck, who was also requested to review the document. I recommend that we concur in publishing for comment the proposed revision, with a few sub-stantive additions to improve the radiation protection requirements. In general, I agree with the approach in this document, since the essential performance re-requirements would now be listed in one part of the regulations, while leaving the detailed guidance on radiation protection methods in our regulatory guide series as aids to licensees in how to establish the procedures, equipment, facilities and management practices that will ensure compliance with these regulations, and with the concept of maintaining exposures ALARA. There are also some editorial sugges-tions and corrections that I have forwarded to Bill Walker on a copy of the document.
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v While the revised regulation would certainly make most medical licensing easier on the applicant s.s well as more efficient for the licensing staff, the staff paper should point out more clearly the additional effort needed for proposed post-licen-sing visits by NMSS staff, which should be carried out together with inspection staff so that the agency has a coordinated approach to program review and interpretations of the new licensing requirements. Also, since the license application would be easier to complete before an applicant had given much thought to planning and imple-mentation of his radiation safety program, we can expect that some applicants may not be fully aware of the scope of the radiation safety requirements that must precede the use of Byproduct Material . Thus, a follow-up program of post-licensing consul-tations and visits, preferably within a few months of the issuance of new licenses, may be needed to ensure that licensees have indeed established the radiation safety programs necessary to fuli operation.
Some substantive suggestions for improvement of radiation safety requirements of the revised regulation are as follows:
- 1. Paragraph 35.31(a)(1) - Add the words, "...a member of the nursing staff," after
" Radiation Safety Officer". Including a member of the nursing staff on the Radiation Safety Committee would be a good practice for enturing nursing staff j participation, cooperation and trust. It would also be consistent with the ie statement in the staff paper that a representative of the nursing staff would d' be included. The Safety Committee at the hospital where I worked in 1971-75 3
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V included a supervisory nurse, who was a very active member of the Committee.
- 2. Paragraph (c)(2), page 49 - End the sentence with the words, "...and used to interpret readings." A correction chart will not improve accuracy of readings &y if it is not used.
3.
Pageshould P-32 50, 35.53(a) and (b) also be assayed - I believe before that high-energy use for therapy. The high energybeta emitters brems- such strahlung should be easy to measure on any dose calibrator in the activity '
ranges likely to be used. A competent Radiation Safety Officer should be able to devise a calibration of at least sufficient accuracy to determine that the dosage is in the proper range.
- 4. Page 60, Section 35.304(a) - Add "(5) Employee protection, including private duty attendants." Employee protection should be emphasized as a primary aim ?,
of radiation safety instruction. Employees are the most likely persons to be d exposed, other than the patients to whom radiopharmaceuticals or radiation administered. pE
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- 5. Page 62, Section 35.405 - Again, an item, "(a)(3) Employee protection," should be added. -
- 6. Page 63, Section 35.604 - Add the following words to the first paragraph:
..., and estimated maximum exposures to employees, visitors and other patients
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- l1 not under radiotherapy treatment."
- 7. Page 65, Section 35.621(b) - Insert words to the first sentence so that it reads, "Each radiation monitor must be routinely provided electrical power independent of the teletherapy machine circuitry, and capable of providing W cu hv ci, isible I xMw notice..."l FIJ
- 8. Page 66 - The licensee should be allowed to correct his calibration after an intercomparison, if he understands the reasons for error. It would be better to state positively that after the licensee finds a 2 percent change, he should have his dosimetry system checked and cleaned or serviced, if necessary, and he should re-check or re-calibrate his system either in a constant field at his laboratory, or by another NBS or AAPM accredited laboratory. gM
- 9. Page 68, last paragraph - Perhaps the newer NCRP and ICRU reports should also i be referenced, although the Physics in Medicine and Biology reference should ,. . I still be quite adequate for Teletherapy unit purposes.&& Q #6y. l'M p p d (,7 l 1 J' l
- 10. Page 74, sixth line - Perhaps certification by the American Board of Radiology in Radiological Physics, Nuclear Medicine Physics or Therapeutic Radiological Physics should also be listed as providing sufficient competence for the posi-tion of Radiation Safety Officer. dw The remaining comments written on the document are mainly editorial in nature. I think that Jim Henry's comments on compatibility with other regulations should also; )
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'O he taken iato acco#at iaci dins the rossihiiities thet other re9eietieas wo id aeed corresponding cha.nges. Jim has sent h!s substantive and editorial comments to Bill Walker separately.
$$bkJfM Allen Brodsky Occupational Radiation Protection Branch Office of Nuclear Regulatory Research O
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