ML20209B279

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Comments on Amends to 10CFR20 Re Use of Accredited Personnel Dosimetry Processors.Concurs W/Proposed Action
ML20209B279
Person / Time
Issue date: 10/03/1986
From: Fraley R
Advisory Committee on Reactor Safeguards
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20209A892 List:
References
FRN-49FR1205, RULE-PR-20 AA39-2-006, AA39-2-6, NUDOCS 8704280403
Download: ML20209B279 (1)


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UNITED STATES NUCLEAR REGULATORY COMMISSION g

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,a ADVlsORY COMMITTEE ON REACTOR SAFEGUARDS 1

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October 3, 1986 Mr. Victor Stello, Jr.

Executive Director of Operations U. S. Nuclear Regulatory Commission Washington, D. C. 20555

SUBJECT:

ACRS COMMENTS TO AMENDMENTS TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL 00SIMETRY PROCESSORS

Dear Mr. Stello:

During its 317th meeting, September 11-13, 1986, the Advisory Committee on Reactor Safeguards decided not to comment on the Amendments to 10 CFR Part 20, however, it agreed to forward the following comments of an individual member for your consideration.

General It is my opinion that the NRC Staff has carefully analyzed the situa-tion, including a detailed review of the public comments, and that the conclusions reached and accompanying recommendations are sound.

I concur in the action proposed.

Specific In the way of specific comment:

a.

I do not understand the statement (page 5, item 4, Backfit Analy-sis) that " Analysis of 1982 exposure records indicate some 7,000 person-rem were under reported in the 2 rem per year or greater range."

If this is explained elsewhere, I missed it.

b.

On page 18, last two lines, of the " Final Rule," it is stated that licensees may apply for an exemption to this rule in accordance with 10 CFR 20.501.

Perhaps it is obvious that this refers to the existing 10 CFR 20; it is coincidental that Section 10 CFR 20.501 of the proposed revision of 10 CFR 20 covers the application of the

" Final Rule" being discussed here."

Sincerely, r

%. 1-R. F. Fraley, Executive Director cc: ACRS Members g-[

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