ML20211N827
| ML20211N827 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-014, AA39-2-14, NUDOCS 8607080371 | |
| Download: ML20211N827 (6) | |
Text
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! g NUCLEAR REGULATORY COMMISSION ITASHINGTON, D. C. 20656 O ': j
'JUN 3 01986 MEMORANDUM FOR: RobertB.Minogue, Director /
Office of Nuclear Regulatory Research FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
FINAL AMENDMENT TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL 00SIMETRY PROCESSORS K. Goller's memorandum of May 27, 1986 provided for our review and office concurrence the final amendment to 10 CFR 20 requiring the use of accredited personnel dosimetry processors. We have reviewed this amendment and our coments are included in the enclosure. NRR has supported this rulemaking, and I concur in this package subject to appropriate consideration of the enclosed coments.
These coments-have been conveyed to your staff informally. ._
a #c J. } Lf4 2 Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: K. G011er i
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JJN 3 01986 If6MORANDUM FOR: Robert B. Minogue, Director Office of Nuclear Regulatory Research FROM: Harold R. Denton, Director ,
Office of Nuclear Reactor Regulation
SUBJECT:
FINAL AMENDMENT TO 10 CFR PART 20 TO REQUIRE THE USE 0F ACCREDITED PERSONNEL DOSIMETRY PROCESSORS K. Goller's memorandum of May 27, 1986 provided for our review and office concurrence the final amendment to 10 CFR 20 requiring'.the use of accredited personnel dosimetry processors. We have reviewed this amendment and our conments ,
are included in the enclosure. NRR has supported this rulemaking, and I concur in this package subject to appropriate consideration of the enclosed comments.
These comments have been conveyed to your staff informally.
Y Original $igned by H.R.Denten Harold R. Denton.. Director Office of Nuclear Reactor Regulation
Enclosure:
As stated ..
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cc: K. Goller 3
DSR0:SPEB DSR0:SPEB DSR0:DSR0 RCleveland:jf TKing KKniel 06/23/86* 06/23/86* 06/23/86* <
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NAME :HThompson :FMiraglia :RBernero :BSheron :TSpeis :RV limer :HDe n
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DATE :06/24 /86 :06/24/86 :06/ /86 :06/24/86* :06/24/86* :06h49/86 :06/IP/86
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'I ENCLOSURE NRR C0tWENTS ON MAY 27, 1986 FINAL RULE PACKAGE - USE OF r-e
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ACCREDITED PERSONNEL DOSIMETRY PROCESSORS
- 1. The Commission paper is categorized as covering "a minor policy question."
The problems with' accuracy in measurements of doses incurred by workers in licensed facilities are widespread, substantial, and sensitive. The long time interval since early recogr.ition of these problems to the present without effective remedy does not reflect the importance of this action.
Theactionproposedinthisrufe1,slongoverdue,andamoreaccurate characterization of the impoftance and urgency of this action should be stated in the Commission Paper.
- 2. The definition of tolerance level (page 10 of Enclosure A) and related discussions do not clearly indicate the confidence level which could apply to a dosimetry result from an ac dited processor. The degree of unre-3 liability of such results whfch still would be regarded as acceptable should be stated.
- 3. Discussion of benefits from imposition of this rule as including possible reduction in litigation (page 16 of Enclosure A and elsewhere) appears inappropriate. Such reduction is highly speculative, is arguable as to whether it should be considered a benefit, and seems irrelevant to the purpose of the rulemaking.
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- 4. The proposed Paragraph 20.3(a)(20) defining " dosimetry processor" may be unnecessary (page 22 of Enclosure A). If proposed Paragraph 20.202(c)(1) and Paragraph 20.202(c)(2) were reworded to refer to "an individual or an organization" instead of " dosimetry processor," this latter term would not be used and Paragraph 20.3(a)(20) would not be needed. If the term
" dosimetry processor" is retained and its definition is included in the rulemaking, then the term should be used and defined in a manner consis-tent with the term " personnel monitoring equipment," which is the subject of Paragraph 20.202 and is already defined in Paragraph 20.202(b)(1).
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- 5. Proposed Paragraph 20.202(c)(1) requires adherence to 15 CFR Part 7 (page L
23 of Enclosure A). Some explanation of 15 CFR Part 7 and perhaps even a copy of the text should be included in this package. 15 CFR 7 does not ,'
{ reference ANSI Standard N 13.11, and an explanation of how its provisions are required to be followed needs to be provided.
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- 6. Proposed Paragraph 20.202(c)(1) and Paragraph 20.202(c)(2) shoahl not use
" dosimetry processor" in the first section and " processor" in the second part; the terminology should be consistent.
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- 7. The response to Comment C on page 14 of Enclosure C does not resolve the i
concern that licensees could be in noncompliance with NRC regulations if a
& processor should suddenly lose accreditation. The response should be expanded to commit NRC to notify licensees of any loss of accreditation i of a dosimetry processor.
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- 8. The response to Comment D on page 15 of Enclosure C should acknowledge that the rule may well have some adverse impact on voluntary dosimetry.
In addition, it should be made clear that this change applies to all activities for which an NRC license is required.
- 9. The response to Comment 13 on page 24 of Enclosure C appears 'to overlook the fact that Paragraph 20.202(c) has always required licensees to use appropriate personnel monitoring equipment (emphasis added). The Regulatory Guide approach has been used in such situations to clarify what the Commission expects to be done to ensure that appropriate equipment and procedures are used to achieve an adequately reliable performance by the licensee. In this case NRR agrees the issue is sufficiently important that it be explicitly addressed in the rule and that the Regulatory Guide approach not be used. Some revision to the Staff response may be appropriate.
- 10. The response to Comment 9 on page 32 of Enclosure C includes discussion of an analogue detector and algorithm that does not appear germane to the comment and rest of the response. Deletion of this sentence is suggested.
However, some minor revision of the Background discussion on pages 2 and 3 of Enclosure A could resolve the commenter's concern by noting that the rule-only addresses accuracy of assessment of exposure to the dosimeter and that further evaluation by the licensee of the personnel monitoring result is always needed to arrive at the final assessment of an individual's 4
exposure.
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- 11. The discussion of dose savings on page 4 of Enclosure E is highly speculative. It is unlikely that the postulated dose prevention would occur, and some revision appears warranted. Also, the discussion relating to radiation litigation appears inappropriate, and its deletion is suggested.
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