ML20211A604
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UNITED STATES Y
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o,j NUCLEAR REGULATORY COMMISSION s
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MAY 2 71986 MEMORANDUM FOR: James H. Joyner, Chief l
Nuclear Materials Safety and Safeguards Branch, Region I Kenneth P. Barr, Chief Nuclear Materials Safety and Safeguards Branch, Region II William.L. Axelson, Chief Nuclear Materials Safety and Safeguards Branch, Region III Ramon E. Hall, Chief Radiological Protection and Safeguards Branch, Region IV James Montgomery, Chief Nuclear Materials Safety and Safeguards Branch, Region V FROM:
Robert E. Alexander, Chief Radiation Risk Assessment and Management Branch, RES
SUBJECT:
FINAL AMENDMENT TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL DOSIMETRY PROCESSORS Please review the enclosed final rule package and provide your comments and office concurrence.
The following is a summary of this request.
1.
Titie:
Final Amendment to 10 CFR Part 20 - Improved Personnel Dosimetry Processing.
2.
RES Task Number:
OP 506-1 3.
RES Task Leader:
Donald 0. Nellis, 427-4588 Y
4.
Requested Action:
Provide concurrence for your office.
5.
Requested Completion Date: JUN 12 B86
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Background:
NRC regulations require licensees to provide personnel dosimetry under 10 CFR 20.202(a) and 10 CFR 34.33(a). Although some of the dosimeters provided require processing to obtain dose readings, NRC regulations do not require performance standards for personnel dosimetry processing. Problems concerning the accuracy of dosimetry processing were recognized as far back as 1955 when the AEC Contracted with NBS to perform an intercomparison of film badge readings.
In spite of this and several subsequent studies, a suitable performance standard for dosimetry processing did not become available until 1976.
Between 1977-79 the NRC sponsored two rounds of personnel dosimetry testing at the University of Michigan against the 1976 HPSSC draft standard. As a result of these tests, the NRC concluded that rulemaking was needed to require periodic evaluation of dosimetry processors, and on March 28, 1980, issued an Advance Notice of Proposed Rulemaking (45 FR 20493). Of the 4 alternatives proposed in the ANFRM, the majority of comment letters favored the use of a Federal Government controlled Proficiency Testing Laboratory to conduct the periodic evaluations.
A third round of proficiency testing against the revised HPSSC standard (which was subsequently published as ANSI N13.11), was completed in 1982.
On January 10, 1983 the NRC published a Notice of Proposed Rulemaking (49 FR 1205) that would require NRC licensees to use the services of personnel dosimetry processors that had been accredited under the National Voluntary Laboratory Accreditation Program of the National Bureau of Standards.
As a result of the public comments the final rule has been changed to delete the requirement for a licensee to maintain a record of the accreditation certificate of its processor.
In other respects the final rule is unchanged except for those changes made to clarify the intent and characterization of the rule.
Robert E. Alexander, Chief Radiation Risk Assessment and Management Branch, RES
Enclosures:
(List Attached)
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i Comission Paper with
Enclosures:
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Federal Register Notice' B.
Regulatory Analysis i
C..
Analysis of Comments D.
Final Regulatory Flexibility Analysis
- E.
Backfit Analysis
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Congressional Letter G.
Public Announcement i
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