ML20209E206
| ML20209E206 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1985 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Rosztoczy Z Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-034, AA39-2-34, NUDOCS 8504090038 | |
| Download: ML20209E206 (4) | |
Text
- / %, UNITED STATES 8 7, NUCLEAR REZULATORY COMMISSION ,
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- g****I ] MAR 2 91985 MEMORANDUM FOR: Zoltan Rosztoczy, Chief Research and Standards Coordination Branch Division of Safety Technology, NRR -
FROM: Frank J. Congel, Chief Radiological Assessment Branch, DSI
SUBJECT:
REVIEW 0F RECOMMENDATIONS ON " IMPROVED PERSONNEL 00SIMETRY - 10 CFR 20" Per R. Cleveland's request we have reviewed the recommendations'regarding an ongoing rulemaking sponsored by the Office of Research.* The rulemaking is concerned with a proposed revision to 10 CFR 20 that would require licensees'to use the services of an accredited processor to process all personnel dosimeters (with some exceptions) that are provided to comply with 10 CFR 20. We concur with the Office of Research's recommendation, as described in their draft transmittal memorandum (Enclosure 1), that NRC should proceed with the rulemaking. However, we have some comments on the specific language of the proposed rule (Enclosure 2).
This review was performed by Ed Branagan.
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Frank J. Co gel, Chief Radiological Assessment Branch Division of Systems Integration
Enclosures:
- 1. RES's draft memorandum
- 2. Comments on the proposed rule cc: R. Bernero
- 0. Muller
- 0. Lynch R. Cleveland 1D. Nellis (
- The incoming memorandum was from K. R. Galler to T. P. Speis, dtd March 8, 1985.
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MEMORANDUM FOR: William J. Dircks Executive Director for Operations ,
FROM: Robert B. Minogue Director Office of Nuclear Regulatory Research
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SUBJECT:
CONTROL OF NRC RULEMAKING: RES REVIEW DF DNGUING RES SPONSORED RULEMAKING Based on our review of ongoing RES sponsored rulemaking: " Improved Personnel Dosimetry Processing --- 10 CFR Part 20," RES recomends that the NRC should proceed with this rulemaking. This recomendation, in draft form, has been coordinated with the user offices NMSS, NRR, SP and IE.
The basis for our recommendations is as follows:
- Past studies of dosimetry processor performance indicated a need for comon performance standards.
- Voluntary performance standards have not achieved erlde participation and acceptance from the personnel dosimetry processing industry.
- Recent testing programs conducted against the industry standard ANSI N13.11 indicate marked improvement is possible in the industry.
f - The majority of coments received on the proposed rule which was l published in January 1984, were in favor of the rule.
In addition, interagency cooperation and coordination has been solicited throughout the development of the rule from the Interagency Policy Cessnittee on Personnel Dosimetry. (IPCPD).
The complete RES review package has been sent to OEDO (Attention:'3EDRDER) and to the Directors NMSS. NRR,,SP and IE.
l Robert B. Minogue. Director Office of Nuclear Regulatory Research l
l Enclosure G
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.. W I. ' ' APR 0 51985 Enclosure 2 C0fmENTS ON PROPOSED 10 CFR 20.202 The proposed 5 20.202 " Personnel monitoring" reads as follows:
"(c) After Feburary 1986, all personnel dosimoters, except extremity dosimeters and pocket ionization chambers, that require processing to yield a dose value and that are provided to comply with 5 20.101, with the requirements of paragraph (a) of this section, or with the applicable terms and conditions of any license issued by the Nuclear Regulatory Commission..."
We note that the phrase "all personnel dosimeters ... that are provided to comply with i 20.101 leads to some ambiguities. Section 20.101 is entitled
" Radiation Dose Standards for Individuals in Restricted Areas." Who(the licensee or the NRC) determines whether or not the dosimeter was "provided to comply with 6 20.101," and what is the basis for that determination?
If an individual is not required to wear a dosimeter by the present i 20.202 but as a matter of prudence wears a dosimeter would the proposed regulation require that the dosimeter be processed by an accredited processor? If the answer is "yes" to the last question, then licensees whose employees receive doses less than those required for personnel monitoring and who process their dosimeters inhouse would be unnecessarily affected. The impact on small licensees
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o might be to force them to send their dosimeters to an accredited processor -
even though personnel monitoring is not required by the present 520.202.
We recommend that the wording of the proposed $20.202 be changed such that only dosimeters presently required by $20,202 would be required to be processed by an accreditied processor.
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r g UNITED STATES 8 o . NUCLEAR RECULATORY COMMISSION s I wasHWOTON. D. C. 20655 IRAR 8 1985 MEMORANDUM FOR: Richard E. Cunningham, Director, FC/NMSS k Themis P. Speis, Director, DST /NRR Donald A. Nussbaumer, Assistant Director, SAP /SP James G. Partlow, Director, DDEP/IE FROM: Karl R. Goller, Director, DRPES/RES
SUBJECT:
CONTINUATION OF ONGOING RULEMAKING ACTION SPONSORED BY RES
--10 CFR PART 20: IMPROVED PERSONNEL 00SIMETRY PROCESSING The purpose of this memorandum is to request your concurrence in draft recomendations from the Director, Office of Nuclear Regulatory Research, to the EDO regarding the advisability of continuing in an ongoing rulemaking action.
The draft recomendations are included as Enclosure C in the enclosed Office Review Package. I concur in the recomendations and would like to dispatch the transmittal memorandum (Enclosure G) to the RES Director for his signature within two weeks. Since your office is identified as a user office of the subject rulemaking I would like your concurrence in the recomendations before I do this. For your convenience, provision is made below to indicate the position you are taking regarding these recomendations, and for your signature.
The Office Review Package contains several other documents that provide useful infonnation relating to this rulemaking action. Any coments that you would like to provide on these documents would be welcome at this time, c-Karl R. Goller, Director Division of Radiation Programs and Earth Sciences, RES
Enclosure:
Office Review Package B Concur without comments.
O Concur with coments provided. / \
O Major coments provided which must be resolved before I will concur.
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/ Signature Ri(hard E. Cunningham, Director i Division of Funi rycin and b Title Material Safety
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- g UNITE] STATES 8 % NUCLEAR RECULATORY COMMISSION
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e' MAR 8 1985 i Jf' MEMORANDUM FOR: Richard E. Cunningham, Director, FC/NMSS Themis P. Speis, Director, DST /NRR j __
Donald A. Nussbaumer, Assistant Director, SAP /SP 4 ,,
James G. Partlow, Director, DDEP/IE V i /,
' FROMf Karl R. Goller, Director, DRPES/RES o
SUBJECT:
CONTINUATION OF ONGOING RULEMAKING ACTION SPONSORED BY RES
--10 OFR g PART 20: IMPROVED PERSONNEL 00SIMETRY PROCESSING The purpose of this memorandum is to request your concurrence in draft ,
recommendations from the Director, Office of Nuclear Regulatory Research, to the ED0 regarding the advisability of continuing in an ongoing rulemaking action. .
<t The draft recomendations are included as Enclosure C in the enclosed Office Review Package. I concur in the recomendations and would like to dispatch the transmittal memorandum (Enclosure G) to the RES Director for his signature within two weeks. Since your office is identified as a user office of the subject rulemaking I would like your concurrence in the recomendations before I do this. For your convenience, provision is made below to indicate the -
position you are taking regarding these recomendations, and for your signature.
The Office Review Package contains several other documents that provide useful infonnation relating to this rulemaking action. Any coments that you would like to provide on these documents would be welcome at this time.
d o Karl R. Goller, Director Division of Radiation Programs 6). and Earth Sciences, RES
Enclosure:
g l Office Review Package l
i Concur without coments.
D Concur with coments prowfded. ,
O Major coments provided which must be resolved before I v01 concur.
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.a f Dub VA*A MEMORANDUM FOR: Richard E. Cunningham, Director FC/NMSS Themis P. Speis, Director, DST /NRR l Donald A. Nussbaumer, As.(1stant Director, SAP /SP l James G. Partlow, Director, DDEP/IE {
i FROM: Karl R. Goller, Director DRPES/RES
SUBJECT:
CONTINUATION OF ONGOING RULEPAKING ACTION SPONSORED BY RES
--10 CFR PART 20: IMPROVED PERSONNEL DOSIMETRY PROCESSING The purpose of this memorandum is to request your concurrence in draft recomendations from the Director, Office of Nuclear Regulatory Research, to the ED0 regarding the advisability of continuing in an ongoing rulemaking action.
The draft recomendations are included as Enclosure C in the enclosed Office'I Review Package. I concur in the recommendations and would like to dispatch the transmittal memorandum (Enclosure G) to the RES Director for his signature within two weeks. Since your office is identified as a user office of the subject rulemaking I would like your concurrence in the recomendations befo,re I do this. For your convenience, provision is made below to indicate the position you are taking regarding these recomendations, and for your signature.
The Office Review Package contains several'other documents that provide useful information relating to this rulemaking action. Any coments that you would like to provide on these documents would be welcome at this time.
Karl R. Goller, Director i Division of Radiation Programs and Earth Sciences, RES
Enclosure:
Office Review Package O Concur without coments. -f '
G Concur with coments provided. JSee attached)
N O I O Major comments provided which must be resolved before I will concur.
3 /5 Signature Jamer.p. Partlow Title Director, Division of Inspection Programs Office of Inspection and Enforcerant
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O Date: March 14, 1985 IE/DI Connent ca Sngoing Rulemaking Action Sponsored by RES - 3D CFR Part 20:
Improved Personnel Dosimetry Processing V
The following comment was previously provided orally to M. Federline/RES.
i In the proposed new paragraph (c) of section 20.202, the words " extremity dosimeters" should be cnanged to " dosimeters for the hands and forearms, feet and ankles."
The term " extremity" is not defined in 10 CFR Part 20 and there has been
,,e considerable confusion over its meaning.
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Contact:
John Buchanan /IE
, . 49-29657
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