ML20211G976
| ML20211G976 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1986 |
| 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 AA39-2-011, AA39-2-11, NUDOCS 8606200389 | |
| Download: ML20211G976 (3) | |
Text
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- 'o,, UNITED STATES 8 g NUCLEAR REGULATORY COMMISSION //
. WASHINGTON, D. C. 20555 t ;;
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June 16,1986 MEMORANDUM FOR: Karl R. Goller, Director Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research FROM: James G. Partlow, Director '
Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
CONCURRENCE IN FINAL AMENDMENT TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL AS DOSIMETRY PROCESSORS As requested in your memorandum dated May 27, 1986, we have reviewed the final rule package for the subject amendment to 10 CFR Part 20.
We concur in the final rule. A few coments on the rule package are enclosed.
- w. ._
James G. Partlow, Director Divijion of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Comments
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Contact:
John Buchanan 49-29657 i
June 16, 1986 I
i 6- MEMORANDUM FOR: Karl R. Goller, Director d
Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research FROM: James G. Partlow, Director Division of Inspection Programs l Office of Inspection and Enforcement '
SUBJECT:
CONCURRENCE IN FINAL AMENDMENT TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL AS DOSIMETRY PROCESSORS As requested in your memorandum dated May 27, 1986, we have reviewed the final rule package for the subject amendment to 10 CFR Part 20.
We concur in the final rule. A few comments on the rule package are enclosed.
ORIGINAL SIGNED BY:
W4E3 & PARTLDW James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement i
Enclosure:
Comments
Contact:
John Buchanan 49-29657 Distribution:
DCS ORPB reading DI reading "
J. Buchanan, IE L. J. Cunningham, IE P. F. McKee, IE L. I. Cobb. IE R. L. Spessard, IE J. G. Partlow IE R. H. Vollmer, IE J. M. Taylor, IE J. E. Wigginton, IE D. O. Nellis, RES
- For previous concurrences A see attached ORC j 0FC :*IE:DI:0RPB :*lE:DI:0RPB :*lE:DI:0RPB :*IE:DI: .
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NAME :JBuchanan:cb:LJCunningham:PFMcKee :RLS ssard: :JGPartlow : :
DATE :06/10/86 :06/10/86 :06/11/86 : /13/86 :06/$/86 : :
e COPt1ENTS ON FINAL RULE PACKAGE AMENDMENT TO 10CFR20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL D0SIMETRY PROCESSORS Memorandum to V. Stello, page 2: This memorandum states that less than 0.5 person-years / year of NRC staff time will be needed to oversee the
/ a program that is operated by another government agency. We realize that h some coordination / liaison effort is needed (less than 0.1 staff-year?).
Enclosure B, : age 4, " Alternative 2": Although we recognize the uncertainties in estimating a lypothetical inspection and enforcement effort involving hypothetical requirements, the 8 staff-year per year estimate appears high. We understand that NVLAP assessors now spend about 2 days at each processor every 2 years.
Allowing another 2 days for travel and report and assuming 100 processors, the estimate would be closer to 1 staff-year per year for inspection.
Enclosure B, page 7, line 8: See preceding comment regarding the 8 person-year value.
Enclosure C page 26, response to comenter #70: There is no direct response to the comment that this rule will set a precedent for requiring accreditation fees for extremity monitoring and bioassay. The rule will set a precedent.
Whether or not that precedent will be followed is another matter.
Enclosure E, page 4, conclusion: It is not clear that adoption of this rule i would prevent this estimated " additional exposure."
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