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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A A 79-t 804 h)(apg (
kmMrog'g UNITED STATES g NUCLEAR REGULATORY COMMISSION if
[
g E WASHINGTON, D. C. 20555
/ 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.
O
+
} I s
4 James G. Partlow, Director + .
Div4sion of Inspection Programs 0}
i Office of Inspection and Enforcem tO
Contact:
John D. Buchanan, IE A i
49-29657 M' l h
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