ML20249C267
Jump to navigation
Jump to search
| ML20249C267 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1998 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20249C259 | List: |
| References | |
| SECY-98-077-C, SECY-98-77-C, NUDOCS 9806260278 | |
| Download: ML20249C267 (2) | |
Text
_ _ _ _ _ _ _ _ _ _ - _ _ _
1 RO T A T I O N V O T E RESPONSE SHEEI TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DICUS l
SUBJECT:
SECY-98-077 - PROPOSED RULE: " RESPIRATORY PROTECTION AND CONTROLS TO RESTRICT INTERNAL EXPOSURES,10 CFR PART 20" Approved xx Disapproved Abstain Not Participating Request Discussion COMMENTS:
Approved w/ Comment r[c.
a Ear eu ATURE/ )
C Release Vote /_n_/
77 %
/3
/ 9 7 d' DATE g
' Withhold Vote /
/
Entered on "AS" Yes M No i n '*e8liT4 M "
CORRESPONDENCE PDR L
Commissioner Dicus' comments on SECY-98-077:
- 1. The Federal register Notice should specifically ask for public comment on whether the technical aspects of the rule should be addressed in a regulatory guide to permit a more rapid regulatory response by NRC to technical developments and changes in industry consensus standards (subject to lege! constraints).
- 2. Staff should re-review its conclusions with respect to compatibility categories for this rule, in particular for consistency. First, it does not seem reasonable to require APFs to be category B but allow the definition of APF to be Category C. Secondly, given that the definition and values of APFs are required for compatibility (i.e., must be incorporated in Agreement State rfes) it does not make sense to not require inclusion in Agreement State rules the definitions of Disposable respirator, Fit check, Fit factor and Fit test. Defining these terms in a consistent manner would seem essential to assure consistent application of the rule itself by Agreemant States and their licensees. Notwithstanding staff's use of the recently approved adequacy and compatibility policy and implementing procedure to determine the compatibility categories for this proposed rule, if its use results in internal inconsistencies within a proposed rule as it has in this case, then staff should exercise its discretion and propose compatibility categories that assure internal consistency and provide appropriate justification for departing from the policy and procedure.
i l
l l
i l
i