ML20209B196
| ML20209B196 | |
| Person / Time | |
|---|---|
| Issue date: | 02/17/1987 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Breaux J SENATE, ENVIRONMENT & PUBLIC WORKS |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-005, AA39-2-5, NUDOCS 8704280388 | |
| Download: ML20209B196 (1) | |
Text
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"4 UNITED STATES 7,
NUCLEAR REGULATORY COMMISSION d
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J February 17, 1987 The Honorable John Breaux, Chainnan Subcommittee on Nuclear Regulation Comittee on Environment and Public Works United States Senate Washington, D.C.
20510
Dear Mr. Chairman:
Enclosed for the information of the Subcomittee is a copy of a final rule amending 10 CFR Part 20 that will be published in the Federal Register.
The Nuclear Regulatory Commission is amending its regulations with respect to those licensees who are required by the NRC to provide radiation monitoring to workers. This amendment will require such licensees to have dosimeters processed by personnel dosimetry processors accredited under the National Volentary Laboratory Accreditation Program operated by the National Bureau of Standards.
The amendment will result in greater uniformity and accuracy in personnel dosimetry processing and recording for all affected licensees and is expected to improve the accuracy of dosimetry that is performed voluntarily.
The Commission is issuing the final rule with an effective date 1 year after publication in the Federal Register.
Sincerely, d
-M f Car rector l
Office of Congressional Affairs l
Enclosure:
As stated cc: Sen. Alan Simpson v
0LLA-lf IDENTICAL LETTER SENT T0:
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Rep. Sharp /cc: Rep. Moorhead - #
Rep. Udall/cc: Rep. Lujan 8704280388 870422 PDR PR 20 49FR1205 PDR l
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P A A 39-A N
,f Federal Register / Vcl. 52. No. 30 / Friday. F2bruary 13. 1987 / ' Rules cnd Reguhti:ns 4801 l
DfUCLEAR REGULATORY accurately and consistently and conduct a study to compare and 1
COtetitSS40N interpreted correctly to ensure the evaluate dosimetry processors against accuracy and integrity of worker dose '
the four existing standards.* Most 10 CFR Part 20 records, to ensure that the NRC dosimetry processors did not fare well regulatory dose limits of 10 CFR 20.101 against any of the standards. Re study improved Personnel Doelmstry are not exceeded. and to ensure that recommended cdoption of the draft Processing dosimetry is provided in accordance standard being developed by the Health Asasscv: Nuclear R'8"!at with 10 CFR 20.202(a). It is imperative.
Physics Society Standards Committee t
l Commission.
therefore, that the personnel dosimetry (HPSSC). (This standard was pub!!shed processing industry conform to as a draft in 1978.)
AcTson: Final rule.
perfonnance standards that will ensure in 1976, at the urging of the suasesaav:The Nuclear Regulatory accuracy and uniformity of results.
Conference of Radiation Control Commission (NRC)is amending its Dos /metryProcessorPerformance Program Directors (CRCPD) regulations to require alllicensees to Studies (representing the States). the NRC, the h:ve personnel dosimetry devices that Bureau of Radiological Health, and the cre utilized to comply with NRC Energy Research and Development regulations processed by processors that pro indust a been a at h:ve been accredited by the National for many Iears.The commercial Agency jointly conducted a public ssing business has always been meeting to discuss personnel dosimetry Voluntary Laboratory Accreditation fighly competitive, with competent andproblems. As a result of the Program (NVLAP)of theNational recommendations made at this meeting.
Bureau of Standards (NBS).This actica conscientious processors com ng the NRC contracted with the University w:s initiated because performance g7,,ce t
rf s work in a cf Michigan to conduct two rounds sysluations of personnel dosimetry (1977-1979) of roficiency testing of processors indicated that a eignificant technically sound manner. Customers of P
percentage of such processors were not cornmercial processors, however, have dosimetry processors against the draft '
performing with a reasonable degree of often lacked expertise in dosimetry HPSSC standard. Fifty-nine personnel accuracy. These amendments will result processing and often contracted their dosimetr> processors voluntarily in greater uniformity and accuracy in processing needs to the lowest bidder, participated in these tests. Results of the personnel dosimetry.
so that the more qualified processors tests showed that the standard should may have had to reduce the quality of be modified. (It was modified in June arracTiva OATE: February 12,1968.
their services in order to remain 1981 and was published as ANSI N13.11 Pen runTHen peronenATson CoseTACT:
competitive.
In 1923.) The results also showed that a Donald O. Nellis. Division of Regulatory Some problens became apparent significant percentage of the processors Applications. Office of Nuclear shortly after the Atomic Energy Act of were not performing to the degree of Regulatory Research. U.S. Nuclear 1954 authorized the commercial accuracy acceptable to the NRC. which Regulatory Comraission. Washington, application of nuclear technology when indicated. In turn, that records and DC 20555. Telephone: (301) 443-7989.
the first intercomparison of film badge reports of worker whole body and skin inquiries regarding the accreditation interpretations was conducted by NBS dose could be considerably different program for personnel dosimeters at the in 1955 under an Atomic Enerev from the actual dose received. It became Niuonal19ureau of Standards should be Commission (AEC) contract. ln 1963, the apparent to the NRC that the
~~
addressed to Robert L Gladhill.
AEC published a notice in the Federal performance and competency of N:tional Voluntary Laboratory Register (28 FR 9411) outlining the need dosimetry processors had to be Accreditation Program (NVLAP).
for a Film Dosimetry Calibration evaluated on a periodic basis and that National Bureau of Standards.
Laboratory and provided some interim rulemaking was needed to ensure this Administration A-631.Gaithersburg, film dosimetry performance criteria, periodic evaluation.
htD 20809, telephone: (301) 921-343L Subsequently, several studies attempted sumpt.anssarrany arconnavices:
to evaluate processor performance, but hunaden Effort i*Back " "d n method of comparing actual Cooperation and coordination with 8
performance with the interim other interested organizations were Personnel dosimeters are devices performance criteria was ever initiated in 1977 with the formation of worn by workers to monitor their established. Consequently, the AEC the Interagency Policy Committee on exposure to radiation. NRC licensees requested in 1967 that Battelle Personnel Dosimetry, which included cre required to provide such monitoring Northwest Laboratory, now called the Department of Defense, the devices to certain individuals as Pacific Northwest Laboratory, conduct a Department of Energy, the specified in 10 CFR 20.20::(a) and other study to determine a basis for film Environmental Protection Agency, the cpplicable provisions of to CFR Chapter dosimeter performance criteria.'
NBS, the Occupational Safety and.
L Although the study revealed that Health Admimstration of the l
Among the types of monitoring about 85% of the participating Department of Labor, the Center for i
equipment in use are dosimeters such as processors had excessive bias and Devices and Radiological Health of the l
film badges, track. etch. type dosimetera.
variance, and although the study defined Food and Drug Administration of the tkrmoluminescent dosimeters (IUrs).
certain performance criteria, no definite Department of Health and Human and direct and indirect reading pocket standard was promulgated at that time.
Services, the CRCPD. and the NRC.
ionization chambers. All of these, with During the next few years, four separate Cooperation and coordmation with the thz exception of the pocket ionization standards were developed, and the NRC dosimetry processing industry were also chambers, require processing la order to in 1978 contracted with Battelle to dstermine the radiation dose by observing a particular radiation induced
,a m.g,m % g 8 M Ud eu!Me Estah=at and Pmannel Domkneenst BNWL.215s(ten) Bensus effe:t in the dosimeter.%ese emanon of rum cosimeter ruf-Critada? Northmet t.aboratones. ExMand. w = *arw l
donimeters must be processed BNWL-442(1ssF)exhland Washmgut.sesSt.
es352.
s 4602 Federal Register / Vcl. 52, No. 30 / Friday, February 13, 1987 / Rules and Regulations enhanced in 1977 with the formation of minimum elements of a generic quality processors. In accordance with NVLAP the Industry Overview Committee on assurance program that should be procedures and authority (15 CFR Part Personnel Dosimetry to monitor the established as part of the dosimetry 7), the DOC published NRC's request (46 progress and development of the processing performance criteria. The FR 9689) for development of such a evaluation program and to ensure that major technical questions raised were Laboratory Accreditation Program (LAP) any regulatory action taken would be those concerning the selection of dose on January 29,1981 and requested public appropriate and effective.
conversion factors within the standard.
comment. NRC sent a copy of the DOC Advance Notice ofProposed Several of the commenting dosimetry Federal Register Notice and a RulemaAing processors also requested a third round description of the NVLAP to all known of performance testing to allow dosimetry processors and interested On hfarch 28,1980, the NRC took the processors to be tested against the persons on Februarv 6,1981. All19 initial step in the rulemaking process revised HPSSC standard before any letters of comment received were with the publication in the Federal rulemaking on dosimetery processin8 unanimous in their approval of the Register of an Advance Notice of became effective.
NVLAP alternative. Consequently the National Voluntary Laboratory NVLAP dosimetry LAP was started in 204 3)
P is s e
19 der Int ge cy ement results of the proficiency testing against yA uediadonProgram(NVIAP) erna ive B
the !!PSSC standard and the need for rulemaking to improve dosimetry During the comment period for the contracted by the NBS. Proficiency processing. It presented four ANPRhi, a fifth alternative for the testing and NVLAP accreditation of alternatives for the operation of a operation of a proficiency testing proficiency testing laboratory that laboratory that would utilize the NVLAP processors began in January 1984.
would conduct performance testing of the NBS was identified by the AdditionalPerformance Testing against the !!PSSC standard. The Interagency Policy Committee. NES, in Since the ori inallIPSSC standard ANPRh! specified that any proficiency accordance with NVLAP procedures 8
testing laboratory established would be specified in 15 CFR Part 7, would was s n h b s aff sp ns ed monitored for techmcal competency by contract the services of a proficiency
, p 9t est, t the NBS and that licensees would be testing laboratory to admimster a third round of performance testing required to use dosimetry services that proficiency testing of dosimetry against ANSI N13.11, which was satisfied criteria established by NRC processors against a performance completed in 1983.8 Seventy personnel and administered by the proficiency standard specified by the NRC (in this dosimetry processors voluntarily testing laboratory. The four alternatives case ANSI N13.11),
participated in this rosni The standard for proficiency testing laboratory The process of accreditation provides a total on eight radiation operations as described in the ANPRhi according to NVLAP procedures would categories involving h'gh energy and were:
require three separate actions:(1) low-energy ph/ons, beta particles,
- 1. Processors and licensees would Completion of a NVLAP questionnaire neutrons, and rr.htures of these. The establish one or more laboratories to and other application materials that procedure was for a processor to send administer proficiency testing against involve documentation of responsible 15 dosimeters for each test category in the llPSSC standard.
personnel, equipment, facilities and which it wished to be tested to the
- 2. The proficiency testing laboratory quality control procedures:(2) testing laboratory. These dosimeters would be a Federal Government facility successful performar:ce in dosimetry were then irradiated with doses known managed and operated by the NRC.
proficiency testing in accordance with only to the testing laboratory and
- 3. The NRC wou!d contract ne ANSI N13.11. " Criteria for Testing returned to the processor. NBS had the services of a proficiency ter%
Personnel Dosimetry Performance"; and responsibility of verifying the accuracy laboratory.
(3) onsite inspection by NVLAP of the irradiations performed by the
- 4. Another Federal agency assessors of the processor's routine testing laboratory. The processor then exprienced in laboratory testing would dosimetry service with respect to determined the dose for each dosimeter operate the proficiency testing processing protocols and associated and reported the results back to the laboratory.
minimum quality assurance criteria testing laboratory for evaluation against Analy, sis of Comment Lettcrs specified in NVLAP general and specific the standard. The testing laboratory criteria and supplied to the processor evaluated the processor's performance Forty-six comment letters were upon application for the program, in accordance with the performance received in response to the ANPRht.
NVLAP would thus offer a system of criterion specified in ANSI N13.11. Of Twenty-one did not state a preference third. party accreditation by a Federal the category tests attempted, an average for which alternative should be used in Covernment agency, namely, the of 25% failed.This compares to failure establishing a proficiency testing Department of Commerce (DOC) rates of 52% for the first test and 38% for laboratory and three felt no proficiency operating through the NBS. In addition, the second, as measured against the testing program was necessary. Of the the pass-fail criterion for accreditation final standard.
remaining 22,20 expressed a preference ensures that the mean of the reported Although the identity and individual for laboratories controlled by the doses will be within 50% of the actual results of the dosimeter test data were Federal government (alternatives 2,3, or dose at the 95% confidence level, and confidential to the proficiency testing 4). Commenters also inquired and that at least 90% of the individual laboratory, the contractor reported that commented on control of the testing reported doses will be within 195% of the categories failed in this third round laboratory. on procedures to be used in the actual dose at the 95% confidence of testing were evenly distributed among the regulatory program, and on various level.
large and small commercial and in-other problems that could result from a In December 1980, the NRC asked the processor failing to satisfy the DOC to establish, in coordination with
, p%, pw go p,,,,,,,,, 7,,,m,,,
established criteria. Several discussed NRC staff, an accreditation program Per ormel postmetry services nn.1 Report or Test the importance of defining and requiring under NVLAP for personnel dosimetry s 3." NtirdC/CR 2s91. February 1963.
~
Federal Rsglster / Vol. 52. Nr. 30 / Frid:y F;bru:ry 13, 1987 / Rules and Regulations 4605 house processors. In light of the results have their primary dosimeters processed other applicable regulations) may a'pply from the three pilot tests, the NRC by a commercial processor, and to for a license amendment to delete this.
concluded that improvement on the part terminate dosimetry services not requirement from the license before the cf most dosimetry processors was required by 10 CFR 20.202(a). Other effective date of the rule. Nothing in this needed and the regulations should be commenters stated that a differential fee regulation precludes a licensee from emended not only to provide for structure is needed to provide relief to providing voluntary dosimetry services periodic evaluation but also to include small processors, that the onsite whether such dosimetry utilizes checks of a processor's quality assessment should be waived for small accredited processing or not.The rssurance program to improve the processors as a means of reducing costs. Commission. however, encourages the qu:lity of personnel dosimetry and that the proposed i 20.202(c)(2) use of accredited processing for processing.
should be clarified by issuance of a voluntary dosimetry in order to provide Regulatory Guide to assist licensees to the desired accuracy and reliability for II* Proposed Rule determine in which radiation categories all dose records. After the effective date in view of the comments received in they should be accredited.
of the rule, dosimetry required by response to the ANPRM and the in regard to the suggestion that onsite license conditions (which may reference uninimous approval of the NVLAP assessment be waived for small commitments made inlicense citernative, the NRC published on processors, accreditation in the testing applications) must be provided by an knuary 10,1984, a Notice of Proposed program under appropriate categories, accredited dosimetry processor.
Rulemaking (NPRM)(49 FR 1205) that as emphasized in the proposed new with respect to clarifications that would require NRC licensees to use the i 20.202(c)(2), does not in itself ensure would enable licensees to determine services of dosimetry processors that that the processor applies the same care which radiation categories apply to their h:ve been accredited by the NVLAP of and attention to routine dosimetry operations,it should be pointed out that NBS. Five alternatives were considered processing as it does to test dosimeters.
it has always been the responsibility of in drafting the NPRM. and an analysis of The onsite visits conducted by NVLAP the licensee to provide appropriate and sich of these is included in the assessors are not only a part of the properly calibrated personnel Regulatory Analysis, which is available mechanism for detecting sources of monitoring devices.The rule to require for inspection and copying for a fee at variability under the control of the NVLAP accreditation does not alter this tha NRC Public Document Room located processor, they also serve to check on responsibility. In view of the comments st 171711 Street NW., WashingSn. DC.
the quality assurance program of the received, however, the NRC plans to processor as it applies to routine issue supplementary information to help III. Summary of Public Comments dosimetry and ensure that equivalent licensees to determine appropriate The NRC received 96 comment letters care is given both to routine dosimetry testing categories for their specific on the proposed rule, some of which processing and to test dosimetry operations wire duplicates. leaving a net of 93 processing. It is for these reasons that litters, many of which contained more the onsite visits cannot be waived for minimum fees charged by NVLAP can thrn one comment.
the small or in. house processors.
seriousIy affect sma11 dosimetry All of the public comments have been Turning to the major comment from pr cessors. NRC has no authority to considered. and the staff responses to medical and hospitallicensees. It is not thrse comments are set forth in the the intent of the NRC to discourage Analysis of Comments document which.
voluntary dosimetry or redundant -
BS s t eh acc ion es These processors should be aware that is available for review and copying for a dosimetry that is provided in addition to grants may be available from the Small fem at the NRC Public Document Room the required dosimetry.The subject Business Administration to assist small located at 1717 H Street NW.,
regulation will not require the services businesses in paying these fees. Also.
Washington, DC.
of an accredited personnel dosimetry licensees who believe that they should Forty commenters approved of the processor for such voluntary or be exempted from the requirements of proposed rule outright. 20 commenters redundant dosimeters.It should be this rule may apply for an exemption in i
epproved cf the rule but identified noted that there are also other methods accordance with to CFR 20.501.
suggested changes or additions, and 6 of dose assessmer.i such as surve s.
A number of NRC licensees have commenters approved of that part of the time and motion studies, or use o expressed concern that. should their rule requiring accreditation of pocket ionization chambers that do not personnel dosimetry processor lose processors but were opposed to require processing, all of which are accreditation, they could be in non.
requiring the licensee to retain NVLAP outside the scope of this rule.
compliance with the new regulation. The c2 rtification records. (This requirement 1.icensees who do not make a his been deleted from the final rule.)
determination as to which personnel NRC believes, however, that few, gf any.
l Nineteen commenters were opposed to require personnel monitoring to comply dosimetry processors willlose their I
the proposed rule. primarily because of with to CFR 20.202(a) will be required to accreditation and that accreditation loss the cost. and another eight commenters use an accredited personnel dosimetry would be a relatively lengthy process.
provided miscellaneous comments on processor for all dosimeters that need NVLAP accreditation is given for a two-the rule.
processing. Also, licensees who use year period: a processor would have A repeated comment in opposition to dosimeters to determine whether ample warning during the retesting and the rule from raedical and hospital dosimetry Is routinely required under 10 renewal process that accreditation licensees appe ars to be the result of a CFR 20.202(a) or other relevant NRC cnteria were not being met. it would be misunderstanding.These commenters regulations will be required to use the prudent for licensees to negotiate with stated that the imposition of the services of an accredited processor for their processors agreements which Eccreditation requirement would force those test dosimeters. Those licensees require current information regarding them, on the basis of cost. to terminate that have made a commitment in their the reaccreditation process.
their in house monitonng services, license application to provide personnel The NVLAP testing and accreditation which now provide supplementary or dosimetry to personnel for whom it is program has been in operation for more redundant dosimeters to personnel that not required (under 10 CFR 20.202(a) or than two years, and on the basis of this
l 4004
. Federal Register / Vol 52, No. 30 / Friday FIbruary 13, 1987 / Ruhs and Reguiltions e
operating experience it has been found Counndosion. Mall Stop NIA07, (20)"Desimetry processor" means an that a minimum of about six =anths is Washington, DC E655 Telephone (301) individual or an organization that required for processors to receive 443-7909, processes and evaluates personnel accredita tion. Since some processors monitoring m4ma.t in order to fail the first round of testing, an Ws Analysia determine the radiation dose delivered adMonal thm months inay be necessary. On this basis, the As required by to CFR 50.100 (50 FR to the eqdpent.
Conunissimi has demnnmd that ar 38097), the Commission has p P 'd a
- 3. In i 20.202, a new paragraph (c)is added to reed as follows-effective date of one year after backfit analysis for the finalr k 'lhe nin ami n as etennM M on
$ 20.202 Persannet numertas, publication of this rule in effectzve form would W membk this analysis, that backfitting to comply with the requirements of this rmal rule is (c) All personr.el dosimeters (except EnvironmentalImpact: Categorical justified. A copy of the backfit analysis for direct and indirect reading pocket Exclusion is available for inspection and copying ionization cha.nbers and those He NRC has determined that this at the NRC Public Document Room dosimeters used to measure the dose to final rule is the of actiondescribed located at 1717 H Street NW.'
hands and forearms, feet and ankles) in categorical usion 10 CFR Washington, DC. Single copies may be that require processing to determine the 51.22(c)(3).Therefore, neither an obtained from Donald O. Nellis, Office radiation dese and that are utilized by environmental impact statement nor an of Nuclear Regulatory Research, U.S.
licensees to comply with paragraph (a) environmental assessment has been Nuclear Regulat Commission, Mail of this section, with other applicable prepared for this final rule.
Stop NIr007 Waa ington, DC 20555, provisions of 10 CFR Chapter 1, or with P:- - m L Reduction Act Stateneent conditions specified in a licensee's and This final rule does not contain any Ust of Subjects in 10 CFR Part 20
{ Q pro g
,9 new or amended information collection Byproduct material. Licensed (1) Holding current personnel requirements subject to the Paperwork dosimetry accreditation from the
--t', ~' ' 'Nu~8-- matenals. Nuclear Reduction Act of 1980 (44 U.S.C. 3501 et po, ', p,nts a'nd reactors. Occupational National Voluntary Laboratory 5
g seq ). Existing requirements were safety and health Packaging and Accreditation Program (NVLAP) of the approved by the Office of Management containers. Penalty, Radiation National Bureau of Standards, and and Budget approval number 3150-0014.
protection. Reporting and recordkeeping (2) Approved in this accreditation Regulatory Analysis requirements, Special nuclear material, process for the type of radiation or The Commission has prepared a Source material, and Waste treatment radiations included in the NVLAP regulatory analysis on this final rule' and disposal.
program that most closely approximate For reasons set out in the preamble the type of radiation or radialons for nbenefi$;o the a$t and under the authority of the Atomic which the individual wearing the i
consi by the Commission.De analysis is Energy Act of1954, as amended, the dosimeter is monitored.
available for inspection and copying at Energy Reorgamzation Act of1974, as Dated at Washington, DC this 9th day of the NRC Public Document Room.1717 H amended, ar:d 5 U.S.C. 553, the NRC is February.1987.
Street NW., Washington, DC. Single adopting the following amendments to For the Nuclear Regulatory Commiission.
copies of the analysis may be obtained 10 CFR Part 20.
Samuel J. Chilk, from Donald O. Nellis. Office of Nuclear Secretaryofthe Cornmission.
Regulatory Research, U.S. Nuclear PART 20-STANDARDS FOR
[FR Doc. 87-3139 Filed 2-72-47; 8:45 am)
Regulstory Commission, Mail Stop NL-PROTECTION AGAINST RADIATION
. o,,-
007. Washington. DC 20555. Telephone-(301) 443-7989
- 1. The authority citation for Part 20 is re sed to read as hws:
Regulatory Fladhahey Analysis DEPARTMENT OF TRANSPORTATION The NRC has prepared a final
,,g
,1 1 3 m. m.
Federal Avletion Administration a
8 regulatory flexibility analysis on the amended (42 U.S.C. 2073. 20s3. 2095. 2111.
impact of this rule on small entities as 2133. 2134. 2xn); secs. 201, as amended. 202, 14 CFR Part 39 required by Section 604 of the 20s, se Stat.12e2. as amended.1244.12es (42 Regulatory Flexibility Act.%e analysis USC 5841, setz. 5846).
(Docket Ms.36-CE-45-AD; Asadt.3D-5563) indicates that although the final rule For the purposes of ecc. 223 es Stat. osa, se Airworthiness Directives; Beech could have an economic impact of $7,000 amended 142 UAC. 2273): il m101. n102, initially, and from 33,000 to $s.400 2atea(s) (b) and (f). miosis) and (bl.
Models 1900 and 1900C Airplanea annually on each persormel dosimetry 20.106(bk m10 sial 20.201,20.202(el. 20.205 Aomocy: Federal Aviation processor, of which about to are small 20.2w. m301,20.303,20.304 and 20.30s are' Administration (FAA). DOT.
entities. the selected alternative is the issued under sec.1sth, as Stat. sea, as least costly alternative that providee amended (42 USC 2201(b)); and lim 102.
ACTIOes: Final rule.
adequate dosimetry processing for m1M20$20w suesuany:His amendment adopts a eec e o licensees and workers. A copy of the amended (42 U.S.C 220tto)).
new Airworthiness Directive (AD), -
final regulatory flexibility analysis is applicable to Beech Models 1900 and available for inspection and copying at
- 2. In $ 203, a new definition E added 1900C airplanes equipped with optional -
the NRC Public Document Room.1717 H as paragraph (s)(20) to read as follows:
chip detect" armunciators.De AD -
Street NW., Washington.DC. Single
. requires that the Pilots Operating copies may be obtained from Donald O.
IaoJ Dennmons.
Handbook and FAA Approved Airplane Nellis, Office of Nuclear Regtdatory (a) As used in this part:
. Flight Manual (POH/AFM) be revised to Research, U.S. Nuclea: Regulatory
' remove language which cordd allow n