ML20210A652
| ML20210A652 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Goller K NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-028, AA39-2-28, NUDOCS 8512100357 | |
| Download: ML20210A652 (1) | |
Text
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December 3, 1985 L
1 MEMORANDUM FOR:
Karl R. Goller, Director Division of Radiological Programs and Earth Sciences Office of Nuclear Regulatory Research FROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
' AMENDMENTS TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL DOSIMETRY PROCESSORS 4
i We have reviewed the subject package that was forwarded by R. E. Alexander on -
November 12, 1985. Our coments are as follows:
1.
In the proposed new paragraph (c) of Section 20.302, the words " extremity dosimeters" should be changed 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 considerable confusion over its meaning.
We have provided this comment to your staff several times before, most recently in the IE/DI concurrence with comment on the continuation of this rulemaking, March 8, 1985.
1 2.
In the new definition of " dosimetry processor" to be added to 10 CFR section 20.3, the words " dose equivalent" should be changed to " dose as defined in this part." The term " dose," not " dose equivalent," is used and defined in Part 20.
3.
Responses to a number of comments involve statements about the inspection program. These responses include the responses to commenters #69, #74,
- 40, #55, #56, and to the commenters giving approval of the requirement for accreditation but opposing the recordkeeping requirement. Although we have no major concerns about these statements, they do indicate a need for additional discussions between, and coordinated actions by, our i
respective staffs.
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James G. Partlow, Director Div4sion of Inspection Programs 0}
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Office of Inspection and Enforcem tO
Contact:
John D. Buchanan, IE A
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