ML20236L567
| ML20236L567 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1996 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20236J269 | List: |
| References | |
| FRN-62FR28948, RULE-PR-150, RULE-PR-30, RULE-PR-34, RULE-PR-71 AE07-2-014, AE7-2-14, NUDOCS 9807130075 | |
| Download: ML20236L567 (2) | |
Text
.
Af 0 7 - ?-
l '.'
Jgip9) PbCL RESPONSE SHEET h T0: -
John C. Hoyle, Secretary of the l@,
Commission Morris Costanzi FROM: COMMISSIONER DICUS ON"?n
SUBJECT:
COMSECY-96-006 - EARLY COMMISSION "' EiIN*" !
CONSULTATION ON REVISION TO PART 34, Meadi 18 l RADIOGRAPHY Approved OPTION B Disapproved Abstain i i
Not Participating Request Discussion COMMENTS: Attached SIGNATURE Release Vote / v/ *{
DATE Withhold Vote / / % 5/W Entered on "AS" Yes k No 9807130075 980611 L_'!y "_1
- O'f
f .
Commissioner Dicus' comments follow:
Staff should proceed with finalizing the revisions to Part 34 and it should include the "two-man rule." The "two man rule" was petitioned for by labor.
is supported by industrial trade organizations and by commentors on the proposed rulemaking who favored it by a 4:1 margin. It was developed as part of an rulemaking package to improve the overall safety performance of industrial radiography licensees. Eighteen of the Agreement States have already adopted the rule. Staff argues that the rule is not cost-effective. )
The many assumptions that staff found necessary to make to perform its cost-hADAfit analysis however, render it far less persuasive than it appears to be at first blush. At the March, 1996 NRC-Agreement State workshop in Vancouver, i WA which, among other things. considered the two man rule, an industry representative commented as follows:
"Last March at our joint [American Society of Non-Destructive Testing and the Non-Destructive Testing Management Association) conference the NRC alerted us to the fact that they were considering not going forward with the two person rule for radiography. And at that time they cited concerns about the cost of the rule in the context of their requirements related to reinventing government. And that was news that was very welcome to us. We encouraged the NRC and the Agreement States to be concerned about the cost of all rules.
"And yet ironically, both organizations feel that the benefit of the two-person rule greatly outweighs its cost. That is not normally a position taken by industry."
Weight also should be given to the views of the Agreement States who favor the rule, particularly since they collectively have the largest population of M. radiography licensees and have been in the forefront of developing regulatory initiatives such as the two man rule to improve the overall radiation safety performance of this licensee group.
For these reasons. I conclude that the Part 34 rulemaking should include the two man rule. Proceeding with the two-man rule will contribute to improving l
industrial radiography safety. NRC's adoption of this rule will also result in a greater uniformity in safety standards for industrial radiography.
l I I
l !
I f
L