ML20204C730
| ML20204C730 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/1978 |
| From: | Sniezek J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Grier B, James Keppler, James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20204C708 | List: |
| References | |
| RTR-REGGD-08.013, RTR-REGGD-8.013 NUDOCS 7811290385 | |
| Download: ML20204C730 (2) | |
Text
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UCi' 7g 1:EMORA"DUM FOR:
Leo c. Hiaainbotham, Assistant Director for fuel Facilit; and Materials Safety inspection, IE FROM:
Robert A. Purple, Assistant Director for Radiological Health Standards. SD
SUBJECT:
it4SPECTION AND ENFORCEMENT EXPERIENCE WITH REGULA10RY GUIDi 8.13, " INSTRUCTIONS CONCERNING PRENATAL RADIATION EXPOSURE' l-i The subject guide was issued for comment in March 1975, and Revision 1 to that guide was issued in November 1975.
There has been very little informa-tion available to the SD staff regarding the response to that guide.
The information that has been received indicates a high degree of acceptance by both licensees and workers.
.l As you know, the matter of effective rule making (amendnunt to 19.12, 10 CFR Part 19) to require instruction of workers regarding the biological risk of prenatal exposure to an embryo or fetus was taken under advisement by the Commission in June 1976.
We are considering a request for Commission resolution of this pending matter either by publication of an effective rule or by withdrawal of the notice of proposed rule making published by AEC January 3,1975.
The central argument in favor of issuing a regulatory requirement is that Regulatory Guide 8.13 may be forgotten in the future and that by making specific reference to the issue in the regulations this would never happen.
The main argument for not specifically identifying prenatal radiation exposure in the regulations is that it really is not nec'essary to clutter up the regulations with this type of detail since there has been widespread adoption of the guidance in Regula-tory Guide 8.13.
We request your assistance in obtaining more information on the effectiveness of Regulatory Guide 8.13.
A We will appreciate any information that you may be able to provide in this regard, including input from the Regional Offices. Of particular interest would be (1) indication of the nature and extent of use of the regulatory t
guide by licensees', (2) any enforcement actions (citations, deficiency letters) taken with regard to the implementation', or lack thereof, of Regulatory Guide 8.13, and (3) your views on the necessity of the proposed rule change to insure compliance with the intent of. Regulatory Guide 8.13.
1 As a separate, but related, matter; we.would also appreciate knowing of any evidence or ailegativia. e.
'scrimination against women that may be attribut-able to the guide,. including a summary of any IE followup.
O P
- 7 81A 103f5 R b rt A. Purple', Assistant Director for Radiological Health Standards Office of Standards Development I # 0#'
SD task no: O
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1 NOV 151978
.1 GOMEF FOR:
E. H. Grier Director, P.egion I J. P. O'Reilly, Director. P.egion II J. G. Keppler, Director, Region III K. V. Seyfrit. Director Region IV l
R. H. Engelken, Director, Region V FP.0M:
J.' H. Snie:ck, Director. FFMSI, HQ
SUBJECT:
INSPECTION AND ENFORCEMEffT EXPERIEtiCE WITH REGULATORY GUIDE 8.13. "It!SPf.CTION C0fiCEF.liIriG PP.ERATN. REDI ATION 1
6 EXPOSURE"
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%.4 The Office of Standards Development has requested that IE provide assistance in obtaining more infonaation from the field on the effective-ness of the subject regulatory guide. The guide was last revised in Nove:nber 1975.
As you may know, a proposed rule (amendnent to Section 19.12 of Part 19) to require instruction to workers regarding the i
biological risk of prenatal exposure to an embryo or fetus was taken i
under advisement by the Commission in June 1976.
~
l Standards is considering requesting the Comission to resolve this utatter i'
either by publication of an effective rule or by withdrawal of the notice of proposed rule naking which was published in January 1975.
The argument in favor of a rule is that licensees cay forget about the guide in the q
future and by making a regulatory requirement they would be required p-to comply.
On the other hand,' an argument' cgainst such rule making is l-that the regulations would be' cluttered with too riach detail such as set l
.forth in the guide. : The outcome may therefore depend on how well licensees
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, have impimented the guide.i.:.Rgf,fR:.9
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D,.;.-. Speci fically,~iri'o.rdei to resolve this' issue core infomation is needed
.regarding 1) an' indication of the nature' and extent of the use of the
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- c7.. regulatory guide, 2) any enfor ccment actions such'as deviations or
'- 3.; deficiencies as: appropriate wlth regard to'iciplementation (or 1ack) o.f
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3.'.' / ' ethe guide?.and 3) your. views on the necessity of a rule to insure
' compliance ~with the intent of the regulatory guide.-:, --
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'd ?.~..M relathd matteri pTe'ase identify instsnces of alle~ ations of g
d!scrirnination (within'the context of theiuide) and indicate whether the allegations were substantiated.--
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CONTACT:
J. R. Metzger 49-28188~
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d Regional Directors NOV 151978 l:
Any com.nents related to the above would be appreciated within two weeks if possible from receipt of this request.
Please subrnit your comments to the contact listed.
1 J. H. Sniezek, Director Division of Fuel Facilities and 4
P.aterials Safety Inspection
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Office of Inspection and Enforcement.
1 bec:
Robert A. Purple. OSD
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