ML20215E225
| ML20215E225 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1986 |
| From: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Bross I BIOMEDICAL METATECHNOLOGY, INC. |
| References | |
| NUDOCS 8610150149 | |
| Download: ML20215E225 (4) | |
Text
PW OCT071986 Dr. Imin D. Bross. President Biomedical Metatechnology. Inc.
109 Maynard Drive Eggertsville. New York 14226
Dear Dr. Bross:
Your letter to the Secretary of the Corsnission siated August 7,1986 was referred to me instead of the General Counsel for reply. Please note that the Freedom of Infomation Act portion of your letter has been addressed in a letter to you from Mr. Donnie Grimsley dated September 4, 1986.
t Pursuant to Section 274b of the Atomic Energy Act of 1954, as amended, the State of Texas entered into an Agreement with the Atomic Energy Comission (now NRC) to regulate byproduct, source and special nuclear materials in quantities less than a critical mass. This agreement i
l became effective on March 1, 1963. Under the Agreement the NRC l
relinquished its health ard safety regulatory authority over these materials and the State of Texas exercises its authority.
Texas and the other agreement States adopt and enforce radiation control regulations which are compatible with those of the NRC. More specifically, those parts of the agreement State regulations which l
address basic radiation standards, definitions and radiation exposure l
limits must be essentially unifom with the corresponding NRC j
regulations.
The radiation exposure " bank" concept in Texas regulations to which you i
refer is derived from NRC's 10 CFR Part 20 and does in fact allow L
certain occupationally exposed individuals to receive greater than 5 rem per year exposure under specified conditions. The same provision is contained in the NRC regulation 10 CFR 20 (copy enclosed).
Specifically, section 20.101(b) (1) & (2) allows a whole body radiation dose up to 3 rem per quarter or 12 rem per year provided that the cumulative dose does not exceed that calculated by the fomula 5(N-18) rems where N equals the worker's age in years at the last birthdate.
The time over which a 25 rem whole body dose might be received is dependent on the rate of exposure and the worker's previous exposure history.
With regard to the documents from Dr. Allen Brodsky that you mentioned, although responses to coments on regulatory proposals are occasionally handled on an individual basis, there is no legal requirement to do so.
In the instance referred to in your letter, a decision was made by NRC g
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Dr. Irwin D. Bross -
management that free distribution of the analysis of coments documents, that neasured at least one inch thick, to each of the seventy-five comenters was not justified. Hornally, responses to coments are placed in the Comission's Public Docunent Room where they nay be exanined and copies may be ~obtained upon paynent of a fee. We very nuch regret that through an unfortunate oversight, which has since been corrected, copies of the analysis of coments documents were not placed in the Comission's public document roon at 1717 H street, N.W.,
Washington, D.C. in a timely manner.
The following docuner.ts were nailed to you at a forner address but were returned to !!RC on August 27, 1986 as undelivera,ble.
Transnittal nenorandun to Comenters on Regulatory Guide 8.18 and NUREG-0267, re medical radiation safety from Allen Brodsky, dated 7/18/86.
NUREG-0267. Rev.1, October 1982 - Princihics and Practices for Keeping Occupational Radiation Exposures at L!edical Institutions As Low As Reasonabiy Achievable. Xerox copy.
!!arked typescript of proposed revision of NUREG-0267, undated draft.
Appendix A, Markup of Decenber 1977 Regulatory Guide 8.18 showing proposed revisions.
Appendix 8-1. List of Coments Received on Regulatory Guide 8.18 and NUREG-0267; Sumary of Staff Responses.
Appendix B-2, Sumary of Staff Responses to Coments on the Guide.
Appendix C Value/Inpact Statenant for Regulatory Guide 8.18 and NUREG-0267.
These documents are being renailed to you under separate cover to the address appearing on your letter of August 7,1986.
Sincerely, NN1) 7. A. Rehm T. A. Rehn Assistant for Operations Office of the Executive Director for Operations
Enclosure:
Distribution:
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20.102(b)
'O'4(c PART 20 o STANDARDS FOR PROTECTION AGAINST RACIATION
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i l cause an dual
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(3) A dose of 0.1 rad due to neutrons 0 R4 Interpreteuens.
o any period o Except as specifically authorised by h calendar quarter from radioactive ma-t (4) A d rad due to particles heavier than protons and with sufft j the Commission in writing. no inter " terial and other sources of radiation a cient energy to reach the lens of the [ pretation of the meaning of the regu. m total occurational dos lations in this part by any officer or 2 the standards specified in the follow-i eye; If it is more convenient to meas-ure the neutron flux, or equivalent. IC employee of the Commiation other Ling table:j than a written interpretation by the l
than to determine the neutron dose in Gemal Counsel win be Mcognised to Renas een Catanoan Quantan rads, as provided in paragraph (c)(3) of this section, one rem of neutron ra
.be binding upon the Commisalon.
e,",,,, g $m$., w,.,,.',*,* "
Q' t
w diation may. for purposes of the regu-S see.
lations in this part, be assumed to be M s,,.,,,,, n r
7%
su ss eamm essy equivalent to 14 million neutrons per 5 24.7 Cosannunications.
i l
square centimeter incident upon the body; or. If there exists sufficient in-Except where otherwise specified in formation to estimate with reasonable this part, au communications and re-(b) A licensee may permit an individ-ports concerning the regulations in <.ual in a restricted area to receive a accuracy the approximate distribution in energy of the neutrons,the incident 2 this part should be addressed to the 2 total occupational dose to the whole number of neutrons per square centi E Executive Director for Operations. body greater than that permitted meter equivalent to one rem may be a U.S. Nuclear Regulatory Commieston, s under paragraph (a) of this section.
estimated from the following table:
}' Washington D.C. 20555. Communica. I provided:(1) During any calendar quarter th tions, reports, and applications may be NguinoN Flux Doas EourvatawTs delivered in person at the Commis-total occupational dose to the whole Washington, D.C.; or at 7920 Norfolk
_ body shall not exceed 3 rems;and sion's offices at 1717 H 8treet NW l
a a.
ig
- 8"*Q
- Avenue. Bethesda. Maryland.
- (2) The dose to the whole body, when added to the accumulated occu.
f *" " " *
- so - ema asws
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pational dose to the whole body, shall i
not exceed 5 (N-18) rems where "N" j
e= 9 gas tusannesonesessess r
i regidressentu ceS approusk equals the indhidual's age in years at his last birthday; and
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(a)The Nuclear Regula (3) The licensee has determined the o oes uo. io*
sto r'a-ammaa= bas subenmed o
o os soo n sea soo taformance couarden semeiramente j indlykual's accumulated occupational dose to the whole body on Form NRC-ei isoio; comlaed h ele put O Omos of so a
i 'yng a 1 t e info Nu mang====t and Budget (OMBl ier f
fg at 2
g appmvalas mquimd by &e hM g that form; and has otherwise complied l
so-so.ioa is Reduction Act of 1000 (44 UAC. 3801 et with the requirements of I 20.102. As j
re. io.
ir
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re seq.) OMB bee approved the used in paragraph (b). " Dose to the 17 re to, u. io' to. -._
to inf m dosconcedon h
whole body" shall be deemed to in-
. to w so..
)
oostainedla this pad centrol clude any dose to the whole body.
t (d) For determining exposures to X sumber 3181N1014, gonada, active blood. forming organs, I
or gamma rays up to 3 Mev, the dose (b)The approvedInferenatica head and trunk. or lens of eye.
j limits specified in il 20.101 to 20.104..: collection requisements osatalandle this i
inclusive, may be assumed to be equiv 2 part appearla $$ EtGE,E15.M105.
Ottlet hnninetton W W ooet alent to the " alt dose". For the pur. " m1086 3D.58.R315.R30R.E411.
pose of this part " air dose" means that l R401. R40R. R43. 2408.R4f.
(a) Each lleensee shall require any individual, prior to first entry of the i
the dose is measured by a properly i E4R and R400, indhidual into the licensee's restricted calibrated appropriate instrument in (c)'thlo part osatalas laformados area during each employment or work 4
air at or near the body surface in the odlocdos.
' - -to la addidea to assignment under such circumstances
, region of highest dosage rate.
&oes aM under se osotrol that the indhidual will receive or is number bdis pungrepb(s) of dde likely to receive in any period of one esc 6ea, laformados a== Mas Han calendar quarter an occupational dose
- _ -_ to and 6e esotrolsembore in excess of 25 percent of the applica-I 5 20.5 l' nits of radioactielty.
.under which they an appmed an as ble standards specified in i 20.101(a)
(al Radioactivity is commonly, and follows:
and i 20.104(a), to diactose in a writ-for purposes of the regulations in this (1)la $$ M101 and M10s. Form
,, ten, signed statement, either: (1) That part shall be, measured in terms of dis.
NRC4 le approved under centrol
- the individual had no prior occupa.
)i integrations per unit time or in curies.
sumber 3181HIDGB-2 tjonal dose during the current ca!sn.
. One curie -3.7 x 10'8 disintegr*tions.
(2)la 5 meet. Form NRC4le a dar quarter, or (2) the nature and K
approved under contro'. aumber Stab I amount of any occupational does
~
h'Non er ni ute (dpm). C o
- which the individual may have re-used submultiples of the curie are the 0000.
ceived during that specifically ident!.
millicurie and the microcurte.
fled Current Calendar quarter from (1) One millicurie (mC1) 8- 0.001 Prustsstet.: Doses. W. AND sources of radiation possessed or con-Comemaamme trolled by other persons. Each Ilcensee curie (Cil '-3.7 x 10' dpa (2) One microcurie (dt) '=0.000001 shall maintain records of such state-curie = 3.7 x 10' dp4*
" I 20.101 Radiation dose standards for in-ments until the Commission author-dividuels in restricted areas.
Ises their disposition.
(a) !n accordance with the provisions (b) Before permitting, pursuant to m go.Wes 40 Fa SM641 3 of I 20.102(a), and except as provided i 20.101(b), any individual in a restrict-in paragraph (b) of this section, no 11'.
ed area to receive an occupational rs.
censee shall possess. use, or transfer 11 distion dose in excess of the standards to go.wes 59 Fa H990.1 censed material in such a manner as to specified in i 20.101(a), each licensee shall:
May 31,199d 20-3
.