ML20149F673
| ML20149F673 | |
| Person / Time | |
|---|---|
| Issue date: | 08/08/1994 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Fry R NORTH CAROLINA, STATE OF |
| References | |
| NUDOCS 9408110064 | |
| Download: ML20149F673 (3) | |
Text
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6AUG B - 1594
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l Mr. Richard M. Fry, Deputy Director Division of Radiation Protection Department of Environment, Health and Natural Resources P.O. Box 27687 Raleigh NC 27611-7687
Dear Mr. Fry:
We have reviewed the draft revisions to the North Carolina regulations dated June 27, 1994 (RADMAT.101). The draft rules were reviewed in comparison to the ,
equivalent NRC regulations in 10 CFR Parts 20, 30, 34 and 35. '
As a result of the review, we have several comments, as enclosed. Please note that some of the recommended changes may be necessary to ensure the compatibility of the regulations.
If you have any questions regarding the comments or any of the rules reviewed, please contact me or Mr. Richard Blanton of my staff at (301) 504-2322.
Sincerely,
/
5 Paul H. ha s, Deputy Director Office o State Programs
Enclosures:
As stated Distribution:
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COMMENTS ON DRAFT RULES i
North Carolina July 1994 Amendments Definition Comment Airborne radioactivity area We recommend that you delete the underlined text: "
... in which airborne radioactive materials composed wholly or partly of licensed radioactive material.
exist in concentrations: ...
ALARA To ensure compatibility, add the underlined phrase ".., taking into account the state of technology, the economics of improvements in relation to the state of technoloav. the economics of improvements in relation benefits . . ."
Extremities The definition text is the same as the definition for " External dose."
i Individual monitoring devices It is noted that there is a similar !
definition for " Personnel monitoring j equipment."
Scaled source To ensure the effectiveness of the emergency planning rule, delete the definition in 59 .0104 and use the one in the industrial radiography section (6f l
.0502.) l Permanent radiographic To ensure compatibility, after the word i
installation " vault" add the words: " ... designed or intended for radiography and ..."
Diagnostic procedures manual To ensure compatibility, add the underlined text: " ... approved by the authorized user and the radiation safety officer, and includes the radiopharmaceutical dosaae. and route of administration."
Radiation safety officer To clarify the requirements for medical materials licenses, we recommend adding the words: " ... and in the case of medical materials licenses, is the individual named on the license."
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Reaul ations Comment 9.0323(3)(a) The proposed changes are not compatible with the 66 .0506(b)(1) current NRC rules. They are compatible with an NRC proposed rulemaking, but we recommend that the adoption of your changes be delayed until the NRC rules are final.
55 .0504(a) In the last line - before the word "in," we suggest adding the word " manually," to clarify the intent of the rule.
SS .0510(a)(2) To ensure compatibility, after "... of this Chapter,"
add the following: "the license under which the person will conduct radiography,".
sf .0510(g)(2) For readability, between " Officer" and " include" insert the word "shall."
sf .0513(11) For readability, insert the word "that" just befcre the word "shall".
SS .0512(a) We suggest using the term " exchange" rather than
" replace" for film badges and TLDs.
ss .0515(b) To ensure compatibility, do not delete the requirement to survey the entire circumference of the radiographic exposure device and source guide tube.
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