ML20249A694
| ML20249A694 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1998 |
| From: | Nellis D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mcknight J NRC |
| Shared Package | |
| ML20013K439 | List: |
| References | |
| FRN-58FR53670, REF-10CFR9.7, RULE-PR-32 AF76-1-001, AF76-1-1, SECY-97-028-C, SECY-97-139-C, SECY-97-28-C, NUDOCS 9806180108 | |
| Download: ML20249A694 (3) | |
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- GY 44 y- 4 UNITED STATES g.6 N #
j s* NUCLEAR REGULATORY COMMISSION 2 WASHINGTON, D.C. 20066 0001
\,,,,,/ June 11, 1998 i
MEMORANDUM FOR: James C. McKnight l' Nuclear Documents System FROM: Donald O. Nellis hM 0' kb Rulemaking and Guidance Branch Division ofIndustrial and l Medical Nuclear Safety, NMSS
SUBJECT:
REGULATORY HISTORY - PROPOSED RULE, " LICENSE APPLICATIONS FOR CERTAIN ITEMS CONTAINING BYPRODUCT MATERIALS," ( MINOR REVISION OF 10 CFR 32.14 TO INCORPORATE GASEOUS TRITIUM LIGHT SOURCES )- RESPONSE TO PRM-32-4 1
i Attached is an index and copies of 26 documents of central relevance to the above proposed
' rule. All documents have been identified in the upper right-hand corner of each document with the designator "AF76-1" In addition, most of the documents enclosed have been marked "PDR" in the upper right-hand corner of the page to indicate that they can be made available to the public. Other documents have been marked "CF only" in the upper right-hand corner to indicate that they cannot be made available to the public. .
A copy of the index has been forwarded to the Rules and Directives Branch, ADM. Should you have any questions, please call me on extension 415-6257.
Attachments:
- 1. Index
- 2. Relevant documents i
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RIN: 3150-AF76-1 Regulatory History for Proposed 10 CFR Part 32 No. Type of Document Fromffo Subject Date l
! 1 Petition PRM-32-4 mb-microtec to Request changes to 10 July 29, Secretary, NRC CFR 32.14 1993 2 Memorandum P.Norry to Eric Review for fast track, Aug 34, Beckjord comments & concur. 1993 3 Fed. Reg. Notice NRC to public Public comment on Oct 18, petition. 1993 4 Letter mb-microtec to Additionalinformation July 24, L. Riani on petition. 1994 5 Letter mb-microtec to Transmits new June 21.
C. Mattsen information. 1995 6 Letter mb-miocrotec to Corrects error in Nov 8, S. Baggett petition. 1995 7 Letter mb-microtec to Comments on Health July 25, F. Costanzi Physics article 1996 8 Letter G. Glen, ORNL to Skin doses from tritium Aug 5, C. Mattsen in watches. 1996 9 Office concurrence D. Morrison to Office Approval of Sept 4, memo Directors Rulemaking Plan 1996 10 Commission memo H. Thompson to intent to implement Feb 7, Commissioners Rulemaking Plan 1997 11 Plan for Rulemaking Same Attachment to # 10 Feb 7, 1997 12 Regulatory Agenda Same Attachment to # 10 Feb 7, Entry 1997 13 Staff Requirements J. Hoyle, Secy to L.J. No objection to RM Mar 7, Memo, SECY-97-028 Callan, EDO Plan 1997 14 Office concurrence ' D. Morrison to Office Approval of Proposed May 13, memo Directors Rule 1997 1
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4 RIN: 3150-A F76-1 Regulatory History for Proposed 10 CFR Part 32 No. Type of Document From/To Subject Date 15 Memorandum B. Shelton, IRM to Comment on rule Re: June 17, C.Trottier, RES OMB clearance 1997 16 Memorandum A. Thadani, RES to Proposed Rule Pkge, June 24, L.J. Callan, EDO 10 CFR Part 32 1997 17 Commission Paper L. Callan to Solicit Commission June 24, Commissioners approval for proposed 1997 rule.
18 Proposed Rule Attachment to # 17 19 Draft Regulatory Attachment to # 17 Analysis 20 Draft Press Release Attachment to # 17 21 Staff Requirements J. Hoyle, Secretary to Commission approval Aug 14, Memorandum L.J. Callan, EDO and recommended 1997 changes.
22 Memorandum C. Trottier to D.L. Request to implement Sept 3, Meyer, ADM publication of PR 1997 23 Congressional D. Rathbun to Transmit public Sept 15, Letters D.Schaefer and R. announcement and 1997 Hall proposed rule FRN 24 Proposed Rule Fed. Register Proposed Rule Sept 19, publication publication 1997 62 FR 49173 25 Notification D.Meyer to Federal Correction to #24 Sept 29, Register 1997 26 Correction to Federal Register Notice of correction Oct 3, proposed rule publication 62 FR 51817 1997 2
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(716)69& 2695 Af76 - 1 July 30.1993 The Secretary US NRC Atta: Chief, Docketing and Service Branch Washington, DC 20555
Dear Sir:
Attached you wuf find my Petition for Rule =Eg I was adsised that my letter of April 28, 1993 to Steve Baggett requestmg an amendment would not accomplish the change requested.
Steve has held up work in that direction, I have sent a check for the amendment process. If there ,
is an additional fee required, please let me know.
I Sincerely, N
Vice F.Av.t mb-microtec (USA) Inc.
cc: StevenBaggett Medical, Academic and Commercial Use Branch, NMSS l
US NRC Washington, DC 20555 ..
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Nortn Tonawanca. New York 14120-9174 (716) 694 2695 July 29.1993 The Secretarv US Nuclear Regulatory Commission Ref. License a 31-23712-ole Attn: Chief. Docketirg and Service Branch Washington. DC 20555
Dear Sir:
PE iiiION FOR RULEMAKING In accordance with 10 CFR 2.802. we petition the Commission to amend its regulat on. The purpose of the requested eer.cr.dir.cr.t is to put watches with gaseous tritium light sources (GTLS) on the same regulatory basis as watches with lummous intium paint regarding the requirements for their distribution exempt from the requirements of 10 CFR 30.19.
At present, watches with GTLS's can be distnbuted with an activity up to 200 mci T, but only, when each watch model is individuaDy approved by the Commission for its exempt distribution, a requirement in contrast to those for watches with tritium paint. The Comnussion exerts a further {
control over GTLS watches as it requires a disclosure on the pertinent properties of GTLS's used in watches. An approval of satisfactory disclosure may be in the form of a registration of the l '
G1LS in general as is e.g. the case of the products by our company (NR-446-S-102-S).
It is our experience that watch mam6e*~m do not want to become involved with the present licensmg procedures conceming GTLS watches. In that sense, the present regulations are indeed counterproductive, withholding a better and safer watch inununation from the consumer.
Further present regulations do not take account of the progress GTLS tachaalagy has pehieved over the past 15 years. Today, an an:Gog watch can be welliHumia*A with 14 GTLS of a total activity of 25 mci T, the same activity prJf admitted for tritium paint watches. Moreover, -
today's pmdwAw. techniques pennit GTLS manufacture of sman, ef5cient sources with perfect '
seals. Only the minute amounts of tritium diffusing through the glass walls can escape.
In support of the petition, we submit additional iEormation.
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The enclosure 1, details the proposed amendment in the regulation to achieve the stated goal Two fvdanclosures irview the existing regulations conceming tu@~ with tritium, and assess the b
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- l. Petition for Rufemaking per 10 CFR 2.802 e.
It is the goal of the proposed amendment to put timepieces with gaseous tritium hght sources (OTLS) on the same regulatory basis as those with tritium paint in regard to their distnbution exempt from the requirements of 10 CFR 32.14 starting with (d). Other changes are not necessary to keep the regulation consistent with the amendment.
(d) The Commission determines that:
(1) The method of contamment or binding of the byproduct materialin the product is such that the radioactive material will not be released or be removed from the product under the most severe conditions which are likely to be encountered in normal use anii handling.
Tritium in luminous paint will be considered to be properly bound to dials. hands pointers and bezels if there is no visible flaking or chipping and the totalloss of tritium does not exceed 5 percent of the total tritium when prototype dials. hands, pointers. and bezels are '
subjected to the tests (i), (ii), and (iiii) below in the order specified.
Tritium is also considered to be property bound ifit is contained in gaseous form in a scaled vial of mineral glass if the vials do not get damaged or become dislodged and the loss of tritium does not exceed 5 nCi when prototype dials, hands. pointers and bezels are subjected to the test (i), (iii), and (iiii) below in the order specified.
(i) Attachment of dials and bezels to a vibrating fixture at a rate of not less than 26 cycles _
per second and a vibration acceleration of not less than 2G for a period of not less than one hour.
(ii) Attachment of the hub ends of the hands or pointers to a clamp and bending of hands or pointers over a 1-inch diameter cylinder, or (iii) Attachment of the hub ends of the hands and pointers to a clamp on a sibrating fixture and vibration at a rate of not less than 16 cycles per secono ano a sibration acceleration of not less than 2G for a period of not less than one hour.
(iiii) Total immersion of the dials, hands, pointers and bezels used in the tests described in subdivision (i), (ii), or (iii) of this subparagraph in 100 nulliliters of water at room ter.greure for a period of 24 consecutive hours and analysis of the test water for its radioactive materials content by liquid scintillation counting or other equally sensitive method.
(2) The product has been subjected to and nieets the requirements of the prototype tests.
I Prototype tests for automobile lock illummators are prescribed by S 32.40. Schedule A.
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