ML20140C255

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Requests Comments Re Final Amend to 10CFR34 Concerning time-of-storage Survey & Quarterly Safety Performance Insps. Comments Should Be Submitted by 860312
ML20140C255
Person / Time
Issue date: 02/19/1986
From: Ryan Alexander
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Cunningham R, Olmstead W, Partlow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8603250296
Download: ML20140C255 (3)


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i E 19 ass MEMORANDUM FOR: William J. Olmstead, Director Regulatons Division, ELD Richard E. Cunningham, Director Division of Fuel Cycle & Material Safety, NMSS James G. Partlow, Director Division of Quality Assurance, Safeguards and Inspection Programs, IE G. Wayne Kerr, Director Office of State Programs, SP Joseph M. Felton, Director Division of Rules and Records, ADM FROM:

Robert E. Alexander, Chief Radiation Risk Assessment and Management Branch

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Division of Radiation Programs and Earth Sciences, RES

SUBJECT:

FINAL AMENDMENT TO 10 CFR 34, TIME-0F. STORAGE SURVEY AND QUARTERLY SAFETY PERFORMANCE INSPECTIONS

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Please review the enclosed ECO package and provide your coments. The following is a summary of this, request.

1.

Title:

Final Amendments to 10 CFR Part 34-Industrial Radiography Radiation Surveys and Internal Inspection System 2.

RES Task Number: OP 302-1 3.

RES Task Leader: Alan K. Roecklein, extension 74358 l

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Cognizant Individuals: John Hickey, NMSS; Jack Metzger, IE; I

Edgar Ashley, SP; John Klucsik, ELD; Mike Lesar, ADM i

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Fequested Action:

Provide corrents for your office 6.

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DATE:

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Background:

An NRC notice of proposed rulemaking ( FR39168) was published in the Federal Register on October 4, 1984. The proposed rule would require that radiography licensees: perform a time-of-storage survey for radiography devices, including a measurement of the exposure rate at the source outlet port; change a record keeping requirement from the last-use survey to the proposed time-of-storage survey, and provide a definition of storage area. The changes regarding the time of storage survey were in response to a petition for rulemaking from the Chicago Bridge and Iron Co.

In addition the notice of proposed rulemaking would codify present licensing practice by amending the regulation regarding licensee's internal inspection programs. The existing rule requires that licensees have in-house inspection programs which include the performance of internal inspections at intervals not to exceed three months.

Licensing and Inspection / Enforcement offices have interpreted this rule to mean that the licensee describe his inspection program in license applications and conduct safety performance inspections of all radiographers and radiographers' assistants at intervals not to exceed three months.

The proposed rule would provide clarifying language so as to codify this existing licensing practice.

As a result of the analysis of public comments and further staff discussions the final rule is unchanged with the exception that a measurement of the exposure rate at the source outlet port is deleted. A requirement for this measurement is now considered to be unnecessary.

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Robert E. Alexander, Chief Radiation Risk Assessment and Management Branch Division of Radiation Programs and Earth Sciences, RES

Enclosure:

Memo from Minogue to Stello with Enclosure A Feder'al Register Notice Enclosure B Regulatory Analysis Enclosure C Public Comments and Staff Response Enclosure D Draft Congressional Letter Enclosure E Daily Staff Note 0FC: DRPF

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