Text

PRM-035-013 - 61FR04754 - National Registry of Radiation Protection Technologists; Receipt of a Petition for Rulemaking
	ML23151A553
Person / Time
Issue date:	02/08/1996
From:	; NRC/SECY
To:	;
References
	PRM-035-013, 61FR04754
	Download: ML23151A553 (1)
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{{#Wiki_filter:DOCUMENT DATE: TITLE: CASE

REFERENCE:

KEYWORD: ADAMS Template: SECY-067 02/08/1996 PRM-035-013 - 61FR04754 - NATIONAL REGISTRY OF RADIATION PROTECTION TECHNOLOGISTS; RECEIPT OF A PETITION FOR RULEMAKING PRM-035-013 61FR04754 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

NUCLEAR REGULATORY COMMISSION 10 CFR Part 35 [Docket No. PRM-35-13] DOCKETED

USNRC,.'

[7590-01-P] 2002 SEP l 9 AM 9: 12 '* "il,;_ -:;-IE SECRHARY RULE.MAKIHGS AND ADJUDICATIONS STAFF National Registry of Radiation Protectloi:i Technologists; Wlthdrawar of Petition for i Rulemaklng AGENCY: Nuclear Regulatory Commission. ACTION: Withdrawal of petition for rulemaking.

SUMMARY

The Nuclear Regulatory Commission (NRC) is notifying th*e public of the withdrawal of a petition for rulem_aking (PRM-35-13) submitted by the National R~gi~try o.f Radiation Protection Technologists (NRRPT). The petitioner requested that the NRC amend its regulations to accept NRRPT registration in lieu of the requirement for 200 hours of classroom training specified in 1 O CFR 35.900(b)(1 ), and to accept the NRRPT registration as a sub$titute tor 9 of the 12 months experience required in 1 O CFR 35.900(b )(2) as a radiation safety technologist at a medical institution under the supervision of the Radiation Safety Officer (RSO). Since the receipt of the petition, the NRC has revised 1 O CFR Part 35, essentially in its entirety. The final rule was published in the Federal Register on April 24, 2002 (67 FR 20251-20397). On August 7, 2002, the petitioner formally withdrew its petition.

ADDRESSES: Copies of the petition for rulemaking, the public comments received, and NRC's e-mail acknowledging the petitioner's request to withdraw the petition may be examined at the NRG Public Document Room 1 Room 01 F23, 11555 Rockville Pike, Rockville, MD. These documents also may be viewed and downloaded electronically via the rulemaking website. The NRG maintains an Agencywide Document Access and Management System (ADAMS), which provides text and image files of NRC's public documents. These documents I may be accessed through the NRC's Public Electronic Reading Room on the Internet at http://www.nrc.gov/reading-rm/adams.html. If you do not have access to ADAMS or if there are problems in accessing the documents located in ADAMS, contact the NRG Public Document Room (PDR) Reference staff at 1-800-397-4209, 301-415-4737, or by email to pdr@nrc.gov. FOR FURTHER INFORMATION CONTACT: Patricia L. Eng, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, telephone (301) 415-7206, e-mail ple@nrc.gov. SUPPLEMENTARY INFORMATION: On February 8, 1996, (61 FR 4754) the NRG published a notice of receipt of a petition for rulemaking PRM 35-13 in the Federal Register. The petition was submitted by the National Registry of Radiation Protection Technologists. The petition requested that the NRG amend its regulations to accept NRRPT registration in lieu of the requirement for 200 hours of classroom training specified in 1 O CFR 35.900(b)(1 ), and to accept the NRRPT registration as a substitute for 9 of the 12 months experience required in 1 O CFR 35.900(b )(2) as a radiation safety technologist at a medical institution under the supervision of the Radiation Safety Officer. Since the receipt of the petition, the NRG has 2

revised 1 O CFR Part 35, essentially in its entirety. The final rule was published in the Federal Register on April 24, 2002 (67 FR 20251-20397). On August 7, 2002, the petitioner informed the NRC that it wished to withdraw its petition. Based on the petitioner's request, the NRC is withdrawing this petition for rulemaking. Dated at Rockville, Maryland, this \\ '6+/-:f.. day of ¥* , 2002. For the Nuclear Regulatory Commission. ~v,~-~ Annette Vietti-Cook, Secretary of the Commission. 3

DOCKET NO. PRM-035-013 (61FR04754) DATE DOCKETED ll/24j95 02/05/96 03/01/96 03/05/96 03/11/96 03/18/96 03/20/96 03/29/96 04/04/96 04/04/96 04/04/96 04/08/96 04/12/96 04/12/96 04/12/96 04/17/96 In the Matter of NATIONAL REGISTRY OF RADIATION PROTECTION TECHNOLOGISTS; RECEIPT OF A PETITION FOR RULEMAKING DATE OF TITLE OR DOCUMENT DESCRIPTION OF DOCUMENT 11/17 /95 02/02/96 02/27/96 02/27/96 03/06/96 LTR FM JERRY A. RIDGEL, CHAIRMAN, NRRPT, SUBMITTING PETITION FOR RULEMAKING FEDERAL REGISTER NOTICE - RECEIPT OF PET-ITION FOR RULEMAKING COMMENT OF EDWIN M. LEIDHOLDT, JR. '( COMMENT OF PETER G. VERNIG ( COMMENT OF ZHENG SHI (

3)

2)

1) 03/13/96 COMMENT OF WILLIAM K. TUTTLE III (

4) 03/18/96

, COMMENT OF LANCE J. PHILLIPS (

5) 03/22/96 02/27/96 COMMENT OF AMERICAN ASSOCIATION OF PHYSICISTS IN MEDICINE (BHUDATT R. PALIWAL) (

6)

COMMENT OF WILLIAM K. TUTTLE III (SUPPLEMENT TO COMMENT NO. 4) 02/27/96 COMMENT OF EDWIN WRIGHT (

7)

8) 02/28/96 COMMENT OF R.J. HOFFMAN (

04/05/96 04/06/96 04/08/96 04/10/96 COMMENT OF ILLINOIS DEPARTMENT OF NUCLEAR SAFETY (STEVEN C. COLLINS) (

9)

COMMENT OF MARK C. BRUELS (

10)

COMMENT OF OMAHA PUBLIC POWER DISTRICT (T.L. PATTERSON) (

11)

COMMENT OF AMERICAN COLLEGE OF MEDICAL PHYSICS (WALTER GRANT Ill, CHAIRMAN) (

12) 04/15/96

-COMMENT OF TIMOTHY A. MCCALL, SR. (

13)

DOCKET NO. PRM-035-013 (61FR04754) DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 04/22/96 04/15/96 04/22/96 04/16/96 04/23/96 04/21/96 04/24/96 04/23/96 04/24/96 05/09/96 04/22/96 05/06/96 10/06/97 09/30/97 COMMENT OF NEVADA DEPARTMENT OF HUMAN RESOURCES (PAUL W. HARVEY) (

14)

COMMENT OF RAYMOND D. WATERMAN, JR. (

15)

COMMENT OF JANE P. BRAGG (

16)

COMMENT OF AMERICAN COLLEGE OF RADIOLOGY (MELANIE T. YOUNG) (

17)

COMMENT OF KENNETH W. PRICE (

18)

COMMENT OF BOB CARLSON (

19)

LETTER FROM STANLEY R. MARSHALL OF THE NEVADA BUREAU OF HEALTH PROTECTION SERVICES TO SECRETARY, CLARIFYING LITTER OF PAUL W. HARVEY (COMMENT 14)

BOB MILLEA Governor CHARLOTTE CRAWFORD Director D Bureau Administration 1179 Fairview Drive Suite 201 Carson City, NV 89701-5405 (702) 687-6353 Fax (702) 687-5197 Public Health Engineering 1179 Fairview Drive A ite101 rson City, NV 89701-5405 (702) 687-4754 Radiological Health 1179 Fairview Drive Suite 102 Carson City, NV 89701-5405 (702) 687-5394 Fax (702) 687-5751 Environmental Health 1179 Fairview Drive Suite 104 Carson City, NV 89701 -5405 (702) 687-4750 Health Protection Services 620 Belrose Street Suite A Las Vegas, NV 89158 Engineering and Food (702) 486-5068 ological Health ) 486-5280 a (702) 486-5024 Health Protection Services 850 Elm Street Elko, NV 89801 (702) 753-1138/1140 Health Protection Services 475 W. Haskell Street Room 38 Winnemucca, NV 89445 (702) 623-6588 Health Protection Services 87 S. Laverne Street Fallon, NV 89406 (702) 423-2281 Health Protection Services P.O. Box 939 Ely, NV 89301 (702) 289-3325 D Health Protection Services P.O. Box 1227 Tonopah, NV 89049 (702) 482-3997 YVONNE SYLVA Administrator DOCKETED us 1RC VACANT State Health Officer "97 OCT -6 AlO :3 9 STATE OF NEVADA DEPARTMENT OF HUMAN RESOURC~FI,.. ~., )F '"'C:f"'Fl'..- AL,*. HEA S ON Ur l,. I... 1..) *

r I LTH DIVI I RUL~~t1)-f,*.,t'-l*...:"; X ~O BUREAU OF HEALTH PROTECTION SE~OISS1Ct:rc:,.,(; s*~AFF September 30, 1997 John C. Hoyle, Secretary Docketing and Services Branch U.S. Nuclear Regulatoi'y Commission Washington, D.C. 20555-0001

Reference:

Docket No. PRM-35-13

Dear Mr. Hoyle:

. vi ER PM :t_5-/3 (6 I Ff<_ 47~!) This letter is in reference to a letter dated April 15, 1996, signed by Mr. Paul Harvey from this office, in which he stated that a NRRPT registration and associated "hands on" experience has been accepted in lieu of some of the Nevada training and experience requirements for a radiation safety officer employed by a Nevada radioactive material licensee. Mr. Harvey's remarks were in reference to a person who was assigned responsibilities by his employer, a Nevada radioactive material licensee, to perform as radiation safety officer. This person coincidentally held a NRRPT registration at the time of the appointment but his registration was not essential to our review and not otherwise considered by this office to permit him to serve as radiation safety officer on his employer's license. Though I might agree with Mr. Harvey's remark concerning the technical competence of persons holding the NRRPT registration, the remarks in his letter should be considered his personal sentiment only and do not represent an official position of the Nevada State Health Division. Enclosed is a copy of Nevada Administrative Code 459.394 which specifies requirements for radiation safety officers employed by Nevada radioactive material licensees. The regulation does not provide for acceptance of NRRPT registration as a credential for this task. (0)-1~07

U.S. NUCLEAR nEGULATORY COM~liSSION ri:..:..EMAKiNC.S ~d*.D,JUCiCATi0:-!0 STAFi:" OFFIC::: OF TH~ S!:Cr:TAR¥ CF l1 JE CO.; :.. *.,.::,1oi - 10I :1-{q 7 _} _____ _ ,t *:.~ ! C*'\\:~1:- J S;Y ::. 0... ~ -~* l._,,,.,.,, ~ '-J= '/.A.:.:;_-.::... ..,...->-~-'-'-~- _l_&. __ l.-141--/ /<J;~~;,-12~ ----

If you have any questions concerning this issue, please feel free to contact me. Sincerely, Stanley R. Marshall, Supervisor Radiological Health Section Deputy Food and Drug Commissioner Bureau of Health Protection Services Enclosure sm\\adm\\nrcnrrpt. ltr

(f) The signature of the inspector. (Added to NAC by Bd. of Health. eff. 11-1-95) 459.394 Qualifications of radiation safety officer. Except as otherwise provided in NAC 459.3942, a licensee shall require the person fulfilling the responsibilities of the radiation safety officer as provided in NAC 459.3821:

1.

To be certified by one of the following organizations: (a) The American Board of Health Physics, in Comprehensive Health Physics; (b) The American Board of Radiology; (c) The American Board of Nuclear Medicine; (d) The American Board of Science, in Nuclear Medicine; or (e) The Board of Pharmaceutical Specialities, in Nuclear Pharmacy;

2.

To have classroom and laboratory training and experience as follows: (a) At least 200 hours of classroom and laboratory training that included: ( 1) Radiation physics and instrumentation; (2) !li-:!iation prot=ction; (3) Mathematics penaining to the use and measurement of radioactivity; (4) Radiation biology; and (5) Radiopharmaceutical chemistry; and (b) At least 1 year of full-time experience as a radiation safety technologist at a medical institution under the supervision of the person identified as the radiation safety officer on a .:cnse issued by the State of Nevada, the Nuclear Regulatory Commission, or an agreement state that authorizes the medical use of radioactive material; or

3.

To be an authorized user on the license of the licensee. (Added to NAC by 8d. of Health, eff. 11-1-9S) 459.3942 Exemption &om training requirements for radiation safety officer. A person identified as a radiation safety officer by the State of Nevada, the Nuclear Regulatory Commission, or an agreement state on a lia::nse issued before October 1, 1986, need not mmply with the training requirements ofNAC 459.394. (Added to NAC by 8d. of Health, eff. 11-1-9S) 459.3944 Qualifications of authorized user of radiophannaceutical in uptake, dilution, or E:XCl"etion studies. Except as otherwise provided in NAC 459.3962 and 459.3964, a licensee shall require the authorized user of a radiopharmaceutical in uptake, dilution, or excretion studies to be a physician who:

1.

Is certified in one of the following specialties: (a) Nuclear medicine by the American Board of Nuclear Medicine; (b) Diagnostic radiology by the American Board of Radiology; or * (c) Diagnostic radiology or radiology by the American Osteopathic Board of Radiology;

2.

Has received classroom and laboratory training in basic radioisotope techniques applicable to the use of prepared radiopharmaccuticals, and has the following supervised clinical experience: (a) At least 40 hours of classroom and laboratory training that included: ( 1) Radiation physics and instrumentation; ( 2) Radiation proteetion; (3) Mathematics penaining to the use and measurement of radioactivity; ( 4) Radiation biology; and 459-118

From: Mary Lynne Thomas To: WND1.WNP2(ELJ) Date: 10/ 8/ 97 4:46pm

Subject:

Retraction letter from Stan Marshall, State of Nevada -Reply -Reply Perhaps we should docket it as a clarification of a comment. This letter came about from my digging into Nevada's regs and asking embarrassing questions of Mr. Harvey and his management.

From: To: Date:

Subject:

DOCKET NUMBER PETITION RULE PRU *35 -13 Bob Carlson <carlson@en.com> TWD2. TWP6(mtl) 5/6/96 10:47am NRRPT RSO Requirements 41 FR 475'!) OOCKE Ir D U RC

96 MAY -9 A10 :58 Michael T. Lesar (301 ) 415-7163 MTL@NRC.GOV OFFIC or ~ LPi:- TAR f DOC KE Tl __ -~t. ICE In reading responses to the proposal from the NRRPT to include them tot fl. list 0f.

qualifications for a Radiation Safety Officer at a medical institution with only three months experience, I feel would be a serious mistake. The fact that a physician can be named as a R.S.O. is bad enough since they have next to no involvement in the day-to-day radiation safety activities at most medical institutions. But to have another group state that only three months exoperience is adequate can not be viewed by this person as remotely adequate. Granted, the N.R.R.P.T. is a growing certification body and has many competant individuals amongst it's memebership, the notion that one could possibly function under a large medical license or a broad scope license with three months experience hardly seems to be in the inerest of safety and quality. Perhaps the NRC could take a cue from INPO and state the number of hours in a week that would count toward expereince. For example, if one were to work an 80 hour week, that may count for two weeks of calander experience. Then one would have to figure out what would be new experience versus repeated experiences. In closing, I am NOT opposed to the addition of the NRRPT tio the list, but since the requirements for being a NRRPT certified technician only specifies a high school level of education, that they be subject to at least two years experience in a medical institution unless they have only worked in medical facilities. Radiological Physics Service, Inc. Full Service Medical Physics Consulting - Nuclear Medicine - Diagnostic Radiology - Radiation Oncology QMP Specialist

US NUC.l f.'~ t.C.JL.;,ORY COMMISS~ DOC" ,,,~ K SEfWICE SECTION 0' **, _*1,~F-THE St::RETARY l, I C )M.,ISSION Postmark Dat. &'J./m /f,tS

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From: DOCKET NIJMSEn.. - ".. PmrJON RULE PRU ( '-1 F~ 4154)- --:1~ Kenneth Price <75301.361@compuserve.com> DOCKETED USNRC To: Date: Mr. Sam Jones <szj@nrc.gov> 4/22/96 2:33pm

Subject:

NRRPT Petition For Rulemaking

Dear Mr. Jones,

96 APR 24 A10 :07 OFFI C~: 0, 'S: 1* ~ETA RY DOCKE T:NG.?.. $Ef\\VICE BRANi.:H I am writing to comment on the Petition For Rulemaking that appeared in the February 8, 1996 Federal Register concerning the NRC's requirements for training and experience of a Radiation Safety Officer at a Medical Licensee. It appears that this proposed rule is relaxing the training and experinece requirements of an RSO at a Medical Licensee buy reducing the 1 year supervised experience requirement to three months. Assuming the 200 hours "classroom and laboratory training and experience requirement" is actually met by NRRPT registration, the reduction to a three month supervised work experinece under a practicing RSO is astonishing. I have been the RSO of a Broad Scope Human Use Licensee for over 5 years and just cannot rationalize how a reactor trained NRRPT could, in the period of three months, gain enough insight and confidence to be an RSO period!

This is especially perplexing when compared to the information provided in draft NUREG-1516, "Management of Radioactive Material Safety Programs at Medical Facilties" concerning NRC expectations of RSOs. Perhaps the RSO requirements could be based on license category (as suggested in NUREG-1516) such that an NRRPT registrant could be RSO at a Limited Specific Licensee with one year's experience under an acting RSO. Perhaps Certified Nuclear Medicine Technologists should be included in this category also, as they generally have college based classroom training and an abundance of experinece in dealing with the hospital environment. The Radiation Safety Officer at a Braod Scope Licensee needs to be, at a minimum, a graduate of an accrediated college or university in a science with extensive experience at a medical institution. In summary, I believe the federal regulations should reflect actual practice and expectations of those filling the RSO position. Kenneth W. Price, MPH, CHP Radiation Safety Officer University of Connecticut Health Center Farmington, Connecticut APR 2 9 1996.. 4\\cknowfedged by eard.............. :.=.::-:::-.,

U.S. NUCLEAR REGULATORY COMMISSIO~ (X)CKETING & SERVICE SECTION OFFICE Of THE SECRETARY Of THE COMMISSION DoCtlnent Statistics POSlmlrkflate _____ _ Copes Received ______ _ .\\dd'1 Coples Reproduced ____ _ ~ OlstrltxJtion _____

April 23, 1996 John Hoyle Secretary AP DOCKETING & SERVICE BRANCH SECY-NRC Via FAX DOCKET NUMBER U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 PETITION RULE PRM ' (Cotr~4,s ~ ~ Attn: Docketing and Services Branch

Dear Sir:

On behalf of over 30,000 physician and physicist members of the American College of Radiology (ACR), we appreciate the opportunity to comment on the petition for rulemaking filed by the National Registry of Radiation Protection Technologists (NRRPT) as described in the February 8, 1996, Federal Register. The ACR opposes the petitioner's request that the NRC amend its regulations by including acceptance of NRRPT registration as fulfilling some of the training requirements for a radiation safety officer. The NRRPT Certificate of Registration is not focused specifically on the medical field but covers a broad range of radiation protection topics. We do not believe that the NRRPT Registration provides adequate assurance that all applicants will have knowledge of real and potential radiation protection problems related to the areas of nuclear medicine, radiation oncology and diagnostic radiology. We believe the present one-year requirement of supervised experience is a reasonable minimal standard and the request to reduce that time period to three months creates significant potential for radiation safety problems for personnel and the public. A mechanism already exists for fully qualified radiation protection technologists to petition the NRC to recognize their training and experience as satisfying the intent of Title 10 CFR 35.900 on a case-by-case basis. Approving this petition would unjustifiably lower the standard set for radiation safety officer duties. Thank you for considering ACR's comments on the NRRPT petition. Sincerely, ~~/I.Jo~ Melanie T. Y~ Assistant Director Government Relations AMERICAN COLLEGE ~ rAPR 2 g* 1996"' Owfedged by card--.. -...,::;::; OF RADIOLOGY 1891 Preston White Drive, Reston, Virginia 22091 (703) 648-8900

U.S. NUCLEAR REGULATORY COMMISSIO~ DOCKETING & SERVICE SECTION OFFICE Of THE SECRETARY OF THE COMMISSION Document Statistics Po~ Date ~a4ci<o ~~,.,_o ~~ Coples Received r ,\\d<fl Copies Reprod~ ~ Special Dislrlbution~ ~-~

From: Jane P. Bragg, M. Phil. 455 Beach 130 Street Belle Barbor NY 11694 April 21, 1996 To: Secretary U.S.Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Chief, Docketing and Servicing DOCKETED USNRC "96 APR 23 P 3 :OS OFFI CE (Jr-./!'R TARY DOC KE f It, 1 SERVIC. BRAN'H DOCKET NUMBER PETITION RULE PRU Branch (~\\l=e...4,s~")

SUBJECT:

Docket No. PRM-35-13; National Registry of Radiation Protection Technologists (NRRPT) Petition

Dear Sir or Madam:

I would urge the NRC to accept registration by the National Registry of Radiation Protection Technologists as fulfilling the required two hundred hours of classroom and laboratory training specified by Part 35 to qualify as a Radiation Safety Officer. I would also urge the acceptance of three months experience in a medical institution as qualifying experience. In order to take the NRRPT exam, one must have a minimum of five years experience in radiation protection. An appropriate bachelor's degree may be substituted for two years experience. Thus every NRRPT registrant has at least three years experience in radiation protection rather than one year. Previous comnentators have raised the issue of therapy. Under medical licenses, the therapy physicist named in the license and is thus, responsible for therapy physics. This is not the function of the radiation safety officer. Part 35 states that the function of the radiation safety officer is to be responsible implementing the radiation safety program. This is precisely what the NRRPT is all about.... radiation protection.... the every day, nitty gritty radiation protection program. I was dismayed that some objections appeared to be based on the possibility that allowing the NRRPT registrant to qualify as an RSO would increase competition for jobs. This is mostly certainly not an acceptable criterion for any evaluation. Thank ~u. f? ~A // ~ P. Bragg, M. Phil.

U.S. NUCLEAR RtGllt.J'I i uAY COMMISSIOt-. OOCKETING & SERVICE SECTION OFFICE Of THE SECRETARY Of THE COMMISSION Document Statistics Postmark Dale <.)>~n, 0e) ~ Co~s Re~ived-4 _____ ,\\dd'I Copies Reproduced -=----- ~ Oistrlb.stion ~ .~<<>~94.'

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BOB MILLER Governor STATE OF NEVADA YVONNE SYLVA Administrator CHARLOTTE CRAWFORD Director DOCKETED US RC DONALD S. KWALICK, M.D., M.P.H. BUREAU CHIEF 687-6353 ENVIRONMENTAL HEALTH 687-4750 ENGINEERING 687-4754

96 APR 22 AlO :1 O DEPARTMENT OF HUMAN cfWJOUB~~ PE 1*A A

er ~--- RY HE LTH DIVISIO?fff Tf ~ ~- :-i:-Rv1cr BUREAU OF HEALTH PROTECTION SEBV-~ES RADIOLOGICAL HEALTH SECTION 620 Belrose Street State Health Officer DRINKING WATER PROGRAM 687-6615 MILK PROGRAM 687-3787 RADIOLOGICAL HEALTH Las Vegas, Nevada 89158 (702) 486-5280 Fax (702) 486-5024 DOCKETNUMSER April 15, 1996 John C. Hoyle, Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Docketing and Services Branch Reference Docket No. PRM-35-13

Dear Mr. Hoyle:

PETITION RULE PRM 3.,5;;.\\o (<o1Fe4754:} This letter is in support of NRRPT Registration as fulfilling some of the training requirements for a radiation safety officer. In Nevada we have accepted NRRPT registered persons, with three or more months "hands on" experience, as radiation safety officers. My personal experience with NRRPT registered persons have shown them to be intelligent and very capable individuals. Sincerely, Pa:a:: H~v'!;?- Radiation Control Specialist Deputy Food and Drug Commissioner Bureau of Health Protection Services PH\\nrc.ltr ~ k wled 'N'R " 9 1996 c no ged bv ean1.................. -...........: (OIJl:?.'LV

U.S. NUCLEAR REu LJLAT V 1$.StO~ DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY Of THE COMMISSION Ooa.ment St.at! Postmlrk Date..=q..~=------ Coples Recei ,\\dd'1 Co

DOCKET NUMSER, S PETITION RULE PRM ~ \\o ecretary (. bf FR.~~- Nuclear Regulatory Commission

i..J"tJ ATTENTION: Chief, Docketing and Service Branch

~ Washington, DC 20555 \\:.:::J

Dear Madam or Gentleman:

DOCKETED US RC '96 APR 1 7 P 3 : 1 0 OFFICE OF SECRr* fARY OOCKEl l"G c'.. S RVICE BRANU1 I am currently a certified South Carolina Paramedic with Oconee Memorial Hospital EMS, Coordinator of Oconee County Rescue Squad, and a member of Oconee County Emergency Preparedness Agency Commission. I am a member of the National Registry of Radiation Protection Technologists (NRRPT) and I have 14 years experience as a Radiation Protection Technician at the Oconee Nuclear Site. I have worked and trained closely with RSO's from local hospitals, county government, and state government. Considering my experiences, as noted above, I SUPPORT the NRRPT's request to amend 10CFR35, Subpart J, Training and Experience Requirements for Radiation Safety Officer. Thank you for your time. ~ e,!JttLJl Timothy A. McCall, Sr. 603 Playground Road Walhalla, SC 29691 4cknowled ed b 'APr 1 t J9.9L_. g v earcf.......................,....,.. "*~

U.S. NUCLEAR REGULATORY CO 1$ IO DOCKETING & SERVICE SECTION OFFICE OF THE SECRETAR OF THE COMMISSION Document Stat! tics Postmark Date _4---4-1=--+-~---- Coples Reaiived_..__ ____ _ .\\d<fl Coples Rep

American College of Medical P&f*~ffl) U~1rlRC 1891 Preston White Drive

Reston, Virginia 22091 (703) 648-8966 * (703) 648-9176 FAX l

p 3 zg

96 APR 2

April 10, 1996 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NUMBER PETITION ~ULE t RM.55-\\o ( ~1FR.,475~ - \\a Attention: Docketing and Services Branch Sir: The American College of Medical Physics is a 14 year old organization with a membership of 400 senior Medical Physicists. The objectives of the College are to enhance the quality of practice of Medical Physics, to engage in professional activities for the benefit of the Medical Physics Community and to promote the continuing competence of the practitioners of Medical Physics. With this background, we believe it is important for us to respond to the petition of the NRRPT for changes in training requirements for Radiation Safety Officers in hospitals. The ACMP opposes this petition because we believe that the training demonstrated by the NRRPT Certificate of Registration does not focus specifically on the medical use of isotopes. Thus, the Certificate of Registration does not assure that all applicants will have knowledge of real and potential radiation protection problems related to the areas of nuclear medicine, diagnostic radiology and radiation oncology. We believe that the present one-year requirement of supervised experience is a reasonable minimal standard in the medical areas and the request to reduce that time period to three months creates a significant potential for radiation safety problems for personnel and the public. We also note that there is already a mechanism in place for fully qualified NRRPT's to petition the NRC to recognize their additional unique training as satisfying 10 CRF 35.900. Therefore, disapproving this petition does not prevent persons with the proper training from assuming the responsibility of the RSO. On the other hand, approval of this petition creates the potential for inadequately trained individuals to assume these responsibilities thereby increasing the risk to the public and working personnel. Executive Committee: Walter H. Grant, Ill, Ph.D., Chairman

Paul A. Feller, Ph.D., Immediate Past Chairman Alan L. Huddleston, Ph.D., Vice-Chairman
Alexander P. Turner, Ph.D., Secretary Roy E. Landers, Jr., Ph.D., Treasurer Board of Chancellors: Bruce H. Curran, M.E.
Yakov M. Pipman, Ph.D.,
Dean W. Broga, Ph.D.

Kenneth N. Vanek, Ph.D.

George D. Oliver, Ph.D.
John L. Horton, Jr., Ph.D.

Alan S. Baker, M.S.

Frederick H. Hager, M.S.
David L. Neblett, M.S.

'Af'R f B 0

L Fl AciulowJedged by card........

i:1:1o Executive arector: aura emmg Jones

U.S. NUCLEAR REC !..ATORY COMMISSIOt-. OOCKETING & SERVICE SECTION OFFICE Of Tl1E Sf.CRET ARY OF THE CO ISSIO Docume~t tatisncs

I thank you for the opportunity to express our opinions on this matter and for your consideration of our comments. Sincerely yours, w~~~-u£ Walter Grant ill, Chairman American College of Medical Physics WG:aal xc: Laura Jones, ACMP Executive Committee

45.5124 ._..._ - ~ Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 Apri 1 8, 1996 LIC-96-0043 Secretary, U. S. Nuclear Regulatory Commission Attn: Docketing and Services Branch Washington, D.C. 20555-0001

References:

1.

Docket No. 50-285 DOCKETED US RC "96 APR 12 P 3 :28 DOCKET NUMBER*-- P:::: - - JI r ~~ &S-l.3 (Co\\FR.'-\\-7~

2.

Federal Register Volume 61, No. 27, dated February 8, 1996 (61 FR 4754)

Subject:

Comments on Proposed Rule Regarding National Registry of Radiation Protection Technologist Registration The Omaha Public Power District (OPPD) has reviewed Reference 2 regarding the proposed rule change to include acceptance of the National Registry of Radiation Protection Technologist (NRRPT) registration as fulfilling some of the training requirements for a Radiation Safety Officer (RSO). Specifically, the rule change requests that the NRC accept NRRPT registration for the current requirement of 200 hours of classroom and laboratory training, as specified in 10 CFR 35.900(b)(l), and for nine months of the current one-year experience requirement specified in 10 CFR 35.900(b)(2). OPPD agrees with the proposed rule change to 10 CFR 35. 900 (b) (1) that would accept NRRPT registration for the current 200-hour cl ass room and 1 aboratory training requirement. OPPD agrees that an applicant which meets the NRRPT registration requirements and successfully passes the comprehensive multiple-choice examination has equivalent training to the current 200 hours of classroom and laboratory training. The subject categories of the NRRPT examination are equivalent to those stated in 10 CFR 35.900(b)(l).

However, OPPD does not agree with the proposed rule change to 10 CFR 35.900(b)(2).

OPPD does not agree that the experience requirements for NRRPT certification equate to nine months of full-time experience as a radiation safety technologist or as a radiation safety specialist at a medical institution, under the supervision of the RSO. OPPD does agree with expanding the definition to allow time as a radiation safety technologist or time as a radiation safety specialist to apply, if under the supervision of the RSO at a medical institution. However, OPPD reconmends that the experience requirement in 10 CFR 35.900(b)(2) remain at one year. "APR 1 8 1996 f\\cknowledged by card.............. ".........,... "* Employment with Equal Opportunity

US NUC~EA~- t :.: L ".,*i-/ \\,OMMISSI0/1. DOCl<ET1NG & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Docvneflt Statis, cs Postmark Date # Copies ReceivYc: _ .\\dd'I Copies Re 'L Special Di tribt. uns:j._c~ ~~W~$:!:lJ

Secretary, U. S. Nuclear Regulatory Corrrnission LIC-96-0043 Page 2 If you should have any questions regarding OPPD's corrrnents on this proposed rule change affecting NRRPT registration, please contact me. Sincerely, f.~p~ T. L. Patterson Division Manager Nuclear Operations TLP/dl l c: Winston & Strawn L. J. Callan, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector Document Control Desk

Samuel Jones USNRC BRUELS AND ASSOCIATES, LIMITED 22 DOYLE DRIVE GREENVILLE, SC 29615 DOCKETED USt RC '96 APR 12 p 1 :46 OFF/Cf 0~ s=-cRETARY DOCKETl~JJ &. SER,1c. BRA CH Office of Nuclear Regulatory Research l OCKET NUMBER. Washington, DC 20555 PETiTIOI\\I RULE_!Rrvi.,3S.-\\3

Dear Mr Jones,

((o\\FtcA-754) @ With respect to the proposal to add a new category of training for Radiation Safety Officer: I am totally opposed to this. There is no adequate training proposed and this is especially critical for hospital radiation safety officers. There may be 3,255 members of NRRPT, but membership in an organization does not automatically confer any education or adequacy of experience. I am especially incensed by the proposal that anyone who works under an RSO for three months should be considered as an individual trained adequately to provide Radiation Safety Officer services. In the 25 years experience that I have had in Radiological Physics including Radiation Safety Officer Experience, I have seen individuals who have worked for over a year that I simply would not allow to serve as a Radiation Safety Officer. In fact, in todays environment of increasing complexity and decreasing staff, allowing such inexperienced and poorly trained individuals to serve as RSOs in hospitals may well contribute to many serious incidents in the future. The recent incidents in Northeastern States involving P32 and Brachytherapy should be adequate arguments against this sort of official approval of poor training. Sincerely, Mark C. Bruels, PhD ABR Certified in Radiological Physics ABMP Certified in Therapeutic Oncologic Physics April 6, 1996

U.S. NUCLEAR REGULATORY COMMISSI0/1. DOCKETiNG & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statisticl Postmark Da~ _ _ _ ____ _ Copies ReC6ived _______ _ ,\\dd'l Copies Reproduced ____ _ Special Distribution ______ _

Jim Edgar Governor Secretary of the Commission April 5, 1996 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Attention: Docketing and Service Branch
96 APR -8 A 9 :27 Thomas W. Ortciger OFFI E cPi;~c-~ TARY OOCKETIIF1 x. -~ RYIC 1--

8RP,l'C:: DOCKET U 18!:R PETITIO ~ RULE PRM O _ ~ (lo\\F~'-\\--1S~ Re: National Registry of Radiation Protection Technologists; Receipt of a Petition for Rulemaking. Docket No. PRM-35-13 Gentlemen: The Illinois Department of Nuclear Safety (Department) hereby submits its comments on the referenced petition for rulemaking. The proposed petition requests changes to I 9 CFR 35. 900(b) that would require acceptance of individuals who are registered by the National Registry of Radiation Protection Technologists (NRRPT) and have three months of full-time experience at a medical institution as a qualified Radiation Safety Officer. The Department currently allows individuals to be qualified to be the Radiation Safety Officer whc meet the following requirements listed in 32 111. Adm. Code 335.9010: a) Be certified by either: @ recyclable I)

2)

3)

4)

American Board of Health Physics in Comprehensive Health Physics; or American Board of Radiology in Radiological Physics, Therapeutic Radiological Physics or Medical Nuclear Physics; or American Board of Nuclear Medicine; or American Board of Science in Nuclear Medicine; or ~APr 1 2 1996"" Acknowledged by card................... :...... -,..,,.~

U.S NUCLt./'\\F. nc-.G

r. TORY COMMISSIOt-.

DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date -+lr--->-+-_..,.,. ____ Coples Received__._ _ _ ____ _ Add"! Copies Reproduced ----=::::--- ~ - Special Distributio *~lioll!;;!lin...-::~-.ii;~-.,,

U.S. Nuclear Regulatory Commission Docket No. PRM-35-13 Page 2 (Item a) continued) b) c)

5)

Board of Pharmaceutical Specialties in Nuclear Pharmacy or Science; or

6)

American Board of Medical Physics in Radiation Oncology Physics; or

7)

Royal College of Physicians and Surgeons of Canad~ in Nuclear Medicine; or Hold a master's degree or doctorate degree in physics, biophysics, radiological sciences, radiological physics or health physics and have 6 months of full-time work experience under the supervision of a Radiation Safety Officer at a medical institution; or Have had 200 hours of classroom and laboratory training as follows: A) Radiation physics and instrumentation; B) Radiation protection; C) Mathematics pertaining to the use and measurement of radioactivity; D) Radiation biology; E) Radiopharmaceutical chemistry; and

2)

One year of full-time experience in radiation safety at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Department, U.S. Nuclear Regulatory Commission, Agreement State or Licensing State license that authorizes the medical use of radioactive material; or d) Be an authorized user for those radioactive material uses that come within the Radiation Safety Officer's responsibilities.

U.S. Nuclear Regulatory Commission Docket No. PRM-35-13 Page 3 The Department agrees the NRRPT training satisfies the 200 hours of classroom and laboratory training (i.e., 10 CFR 35.900(b)(l) and 32 Ill. Adm. Code 335.9010(c)(l)) requirement. However, the Department does not agree that the completion of a three-month training program by a registered NRRPT technologist is an adequate substitute for the one year of full-time training (i.e., 10 CFR 35.900(b)(2) and 32 ID. Adm. Code 335.9010(c)(2)) or the six month full-time training (i.e., 32 Ill. Adm. Code 335.9010(b)) requirement. These registered technologists may be from very diverse backgrounds which may or may not include any medical experience. Some procedures conducted in a medical facility may not be performed during a three-month rotation (e.g., leak testing, some dose calibrator checks, therapeutic procedures, etc.) and additional training would be necessary. In general, the Department disagrees with the acceptance of this proposal as stated. If you have any questions regarding these comments, do not hesitate to call me or Ms. Sandi Kessinger at (217) 785-9947. Sincerely, ~f.~ Division of Radioactive Materials SCC:SMK cc: Jim Lynch, State Agreements Officer

From: To: Date:

Subject:

Dear Mr. Jones DOCKET NUMBER PETITION RULE PRM -oS-l?J <RJHZULU@aol.com> (lolfl~.47..S'-+) l'<:i\\ TWD2.TWP9(szj) ~ 2/28/96 2:14am NRRPT petition DOCKETED US RC '96 APR -4 P 3 : 19 OFFICE 0~ Sc.LEETAl~ Y OOCKE.TING,l Sc.RVICE BRANCrl I find the notion that any person that is an NRRPT (with minimum qualifications to be same) and has had as little as three months experience as a radiation safety technician working under someone named as an RSO (possibly a physician with little radiation safety experience at a small hospital) would qualify them to be a Radiation Safety Officer at a large medical institution to be quite extraordinary. I seriously doubt that such a person has had enough formal education and appropriate work experience to be able to perform all of the duties that are necessary to be an RSO. Two hundred class hours (or fourteen semester hours) beyond high school is not adequate formal education for an RSO nor is three months OJT enough experience. An NRRPT that has a BS degree in a physical or life science and has a years work experience would most likely be prepared to handle the job. The large difference between the two situations NRRPT min. exp. and NRRPT with a BS is substantial and the formal education is an absolute necessity. To suggest that an NRRPT from the nuclear power industry with only high school as formal education and 200 hours radiation safety training and three months work experience in a hospital is fully prepared to be a RSO is just not realistic. I urge the NRC to reject the petition. Sincerely, R. J. Hoffman, M.S. Certified Health Physicist

U.S. NUCLEAfi He.Lav-, I\\.,; \\ i.,JMMISSIQf, DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Da~ ~,Q \\==~:s Coples Received___,I __,---_ __ _ Add'l Copies Reproduced _i-\\.._ ___ _ Special Distribution ~ , ~o ~ J

From: To: Date:

Subject:

Mr. Jones: DOCKET NUMBER PETITION RULE PRM ( <oi ~'i',-S-4~~-~ Edwin Wright <elw1@ix.netcom.com> TWD2. TWP9(szj) 2/27/9611 :27am NRRPT Petition DOCKETED USNRC '96 APR -4 P 3 :19 OFFICE " SECF;E T/,R Y DOCKE I !~IG & :iE.RViCE BRANCH Please accept this e-mail message as an official comment on the NRRPT Proposed changes to 10 CFR 35.900. The regulation, as currently written, adequately addresses the MINIMUM qualifications required for an individual to be named as an RSO. It is my opinion that no changes are necessary. The following points are submitted to support this opinion:

1. The NRRPT exam is a broad based technician exam and does not adequately address medical issues. This does not mean that a technician is incapable of learning what is required and I do not suggest that technicians be banned from becoming RSOs.

2. As an inspector for a state radiation control program, I have inspected approximately 50 (fifty) licensed hospitals. The experience and knowledge level required by an RSO to adequately assure the safety of workers, the public and patients is well above the minimum requirements already listed in the regulations. This is especially true at facilities that provide therapy services in addition to nuclear medicine studies.

In fact, I would seriously consider INCREASING and EXPANDING the current requirements. The current requirements should only apply to facilities licensed for 35.100 and 35.200. Additional training and experience (1 additional year) should be added for facilities performing any type of therapy. Thank you for taking the time to review and consider my comments. Professionally yours, Edwin L. Wright, NRRPT, CHP elw1@ix.netcom.com 11287 SE 56th Avenue Milwaukie, OR 97222-4481 'Al'Jf r2 199s-

U.S. NUCLEAR-REGULATORY COMMISSIOI\\ DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date~~..Q ~ Coples Received--+-__ Add'l Copies Reproduced-*+-::----- S~ al Distribution ~p,.,...,,.~ %~e h 7

From: To: Date:

Subject:

DOCKETED DOCKET NUMBER USNRC PETITION RULE PRM (loWR-1\\-1~

35-\\~ '96 APR -4 P3 :19

<TUTTLE. WILLIAM_K@portland.va.gov> ) TWD2.TWP9(szj) ~~ ~::si:"~.- - c- _. 2/27/96 10:24am OFFICt. '..J, ~E CRE TAR Y NRRPT Petition OOCKETl hG & ~ERVI :E m,1\\NCf: Quick comment-minimum one year for small specific, two years ro*r anything else. These opinions are mine not those of the VA or the Government, or anyone else. W.K.Tuttle 11I,PhD,RSO VA Med.Ctr., Portland, Or tuttle.w@portland.va.gov

U.S. NUCLEAR REG0LA TORY COMMISSIOt-. DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Coples Re Adcfl Co. Document Statistics

DOCKETED American Association of Phys~QttiJn Medicine March 22, 1996 .96 MAR 29 P 3 :08 Fir[,..,. r~ "t:" -A, OF I., ..,I .., _ Lt..... I OOCKE p~r: ? SE~YlCE BRA, ;* Office of the President Bhudatt R. Paliwal, Ph.D. Univ. of WI-Madison, Medical School Dept. of Radiation Therapy 600 Highland Avenue, K4 / B100 Madison, WI 53792-0600 (608) 263-8514, (608) 263-8500 FAX: (608) 263-9167 paliwal@madrad.radiology.wisc.edu Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 DOCKET NUMBER Attention:

Subject:

Reference:

PETITION RULE PAM (Co\\ t=~ '-1<7-&-\\- ~ -~ Docketing and Service Branch American Association of Physicists in Medicine Response to the NRRPT Petition for Rule-Making PRM 13

Dear Sir or Madam:

The American Association of Physicists in Medicine (AAPM) is a professional membership organization of approximately 4,000 medical physicists. The medical physics profession is primarily concerned with the use of physical and mathematical techniques in the diagnosis and treatment of disease. Our training and experience in the medical use of ionizing radiation is very extensive. Over the decades, we have developed guidelines, protocols and procedures for effective and safe use of ionizing radiation for a variety of diagnostic and therapeutic procedures. They also work actively in the routine physical aspects of diagnostic radiology, nuclear medicine radiation safety, diagnostic ultrasound, magnetic resonance imaging and radiation oncology. Members of the AAPM play an important role in promoting the delivery of high quality health care. In their duties in diagnostic radiology, nuclear medicine and radiation oncology involving radioactive materials, members of the AAPM have an intimate and ongoing knowledge of the problems associated with radiation safety and protection in the medical field. The AAPM opposes the NRRPT petition for three reasons: 1 ) The training demonstrated by the NRRPT Certificate of Registration is not focused specifically on the medical field, but covers a broad range of radiation protection topics. Thus, the Certificate of Registration does not assure that all applicants will have the depth and breadth of knowledge of real and potential radiation protection problems unique to the medical field. 2 ) The request to reduce the experience requirements from one year to three months demonstrates a lack of appreciation of the variety of real and potential problems which arise in the field of medical radiation protection. In most cases, a formally-trained individual with one year on-the-job experience would be considered as minimally qualified by the AAPM to serve as an RSO in a medium to large institution. This petition is not applicable to small, one-or two-person medical facilities or practices because such groups will not hire a separate RSO. The physician in-charge or the chief technologist will serve as RSO. Acmowtqed bv eard '8: r 2 1998"' _ n............ 11.. tl<<Htr~r., The Association's Scientific Journal is MEDICAL PHYSICS. Member Society of the American Institute of Physics and the International Organization of Medical Physics.

U.S. NUCLEA I - -* -.Jf V I ~I DOCKETING SERVI SECTION OFFICE OF THE St,R

T ARY OF THE COMMISSION Document S PoSlmark Date ~

Copes Reooived_~------- A Coples Reproducc.J _,__~------:~ Speclal Dlstrtwtion~~~..::::.,i~~ @!,\\J

3 } There Is already a mechanism in place for fully qualifi_ed RPT's to petition the NRC to recognize their training and experience as satisfying the intent of 1 o CFR 35.900 on a case-by-case basis. Approving this petition would not serve the health and safety of the nation. Thank you for considering our comments on this petition. Sincerely, /4:?,.A.~v~ Bhudatt R. Paliwal, Ph.D. President, AAPM xc: Charles A. Kelsey, Ph.D., F.A.C.R. Chair, Radiation Protection Committee, AAPM Radiology Department University of New Mexico Albuquerque, NM 87131 505/277-6101 (P} 505/277-0330 (F} ckel@unm.edu (E} Richard S. Lane, Ph.D. Chair, Legislation and Regulation Committee, AAPM University of Texas Medical Branch Department of Radiation Therapy 301 University Boulevard Galveston, Texas 77555-0484 409/772-6383 (P} 409/772-1856 (F) lane@utmbrt.utmb.edu (E)

Monday, March 18, 1996 Secretary, US Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Docketing and Services Branch DOCKETED USHRC '96 HAR 20 P 3 :09 OFFICE CF SERE. Tt~R'f'.: OOCKE 11 ~G

S R\\i ICE BRA~CH

Subject:

Docket No. PRM-35-13; National Registry of Radiation Protection Technologists (NRRPT); Receipt of a Petition for Rulemaking. DOCKET NUMBER To Whom It May Concern: PETITION RULE PRM ( b1 ~ 4-75-:4.)~ ~ u,., @ The purpose of requiring certain qualifications for the position of Radiation Safety Officer is to ensure that this position is filled by competent persons. The requirements were added after certain facilities, for mostly economical reasons, placed less that qualified persons in such positions, leading to poor decisions regarding and weak oversight in the use of licensed radioactive materials. As a Radiation Safety Officer for over ten years and a Certified Health Physicist I have much experience in the area. I have also supervised numerous NRRP technologists. The key word in their title is Technologists. Many are fine people, but only have high school educations and technician type experience. As technologists, they understand well on how to make radiation measurements with portable instruments, survey for loose contamination, etc., but they do not know what, why, which, and where measurements need to be taken. They are not trained to be fluent in the regulations nor or they qualified to manage a program. By allowing this low level certification to be a qualification for the RSO position, you will be prompting management, of the extremely cost conscious medical industry, to hire individuals of much lower qualifications in the interest of lowering cost. These individuals have neither the experience nor education of the current incumbents. I fear that this will lead to a degradation of many fine radiation safety programs. I hope my opinion aids you in making an informed decision. Please contact me if I may be of further help. Lance J. Phillips, CHP MAR-2 *r 1996-Acknowledged by card.......................... -:-:~ Lance J. Phillips, CHP

1921 Rock Street #11
Mountain View, Ca. 94043 * (415)960-1731

12: ;*J-: E;i~ ~ - LATOOYCOM ISSIOh DOC ETI G & SERVICE SECTION OFFICE Of THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date.-:3~\\..... 11i~r3.... k- ___ _,, Copies Received__..___ ____ Add'I Copies Reproduced..;..,+ ______ _ Speclal OislribJtion~,9Nth.~ctta-,

Secretary, US Nuclear Regulatory Commission Washington DC 20555-0001 attn. Docketing and Services Branch DOCKET NUMBER

Dear Sirs,

PETITION RULE PAM ~ ( Cot FR~75i-\\ DOCKETED USNRC.: '96 MAR 18 A9 :30 OFFICE C .. EC RETARY OOCKE rl t* ~ &..,t.RYICE 8 A 'CH I strongly urge the rejection of the petition for rule making (Federal Register, Vol. 61, No. Feb. 8,1996, pp 4754-4756) submitted by the NRRPf. I have been a physicist in Nuclear Medicine for seven years, and a Radiation Safety Officer at a broad scope Medical Center for fourteen years. It is my experience that a mere 3 months supervised experience is not nearly enough to qualify a NRRPf certified person to be a RSO in a medical environment. For a specific license, I would consider one year supervised experience a MINIMUM for a person with an appropriate Bachelors Degree (Health Physics, Physics (some HP related coursework), etc.) For a broad scope program, two years supervised experience would be a minimum. The NRC sets high standards for its' licensees. If you set a minimum requirement, that is exactly what you will get in most institutions. It should be noted that the NRRPf exam does not cover any radiation biology or radiopharmaceutical chemistry, important topics in the medical environment. Finally, I have a colleague who sent for some written material from the NRRPf, and in examining the sample questions, found them to be of poor quality, easy to answer without much depth of knowledge, and in fact one of the answers was JUST PLAIN WRONG! Respectfully submitted, William K Tuttle III (., ~ fr, Totfk 3']ro 5w di,*frJs r'Ycl k lri ClsCJJ't,0/l~ 9'70 35 MAR 2 8' 1ooa, ~wleaged by card...................... f.~-4 *** '#

U.S. NUCLEAR ht:LH.,... AiORY COMMISSIOI\\. DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistial Postmark Data ~~w.,,.,..__ ___ Coples Received._...__ _____ _ Add'l Copies Reproduced _4-...,__ ___ _ Special Distribution ~oOl>Pb, WD:-L, ---:?3?iL,3\\)> S ~ -ZS-

ENTECH DOCKETED USNRC '96 MAR 11 A11 :22 OFFICE o;:- SiCHETARY DOCKE THtG & 3EFOICF. March 6, 1996 B,~,1 NC:- DOCKET NUMBER Secretary PETITION RULE PRM s _ 8 (fc1Fte_4,s+ @ ATT: Docketing and Services Branch U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sir:

Thank you for the opportunity to comment on the proposed petition for NRC rulemaking. My personal point of view is basically against such a change of RSO qualification.

1.

RSO is the management position of a Radiation Safety Program. Its responsibility and liability shall require a high level of training and experience that one usually would acquire either through a college or a university. The current FDA mammography regulation requires that the annual x-ray unit survey must be done by a qualified medical physicist, excluding the QC technologist or others. Even a technologist collecting data for the physicist, is not acceptable. Although, we have seen that some RSO's who were qualified MD's, did not fulfill their RSO duties or even seemed to be less knowledgeable than a radiation safety technologist. The issue here is their awareness. We have noticed that the radiologist professional societies have already started to address this issue. (e.g. RSNA has some course for physicians, specifically for RSO duty.)

2.

The radiation protection technologist is only employed at a large medical institution or a university hospital. For most hospitals and medical institutions, this position is not available in general because they can not afford to create a job that is solely for the radiation safety. The petition did not reflect the common needs. MAR 1 8' 1996~ Acknowledged by card.. _.. _w,,wmu~.,11!c 2504 West Southern Avenue Tempe, Arizona 85282 (602) 437-9081 (800) 451-0591 FAX (602) 437-9082

v S. 1~JCL A~ tit:uULATORY COMMISSIOt-. DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date -=+-<+.......,..,_ ___ Coples Recei Add'! Copies R

3.

If the door is opened to the NRRPT, the door should also be opened to ARRT(N) and CNMT. The number of available jobs for health and medical physicists is already very limited in today's market. The effect of the petition would only degrade the work quality and worsen the health physicist job market. There is no shortage of health and medical physicists. If fact, there is no shortage of even certified health and medical physicist. Why we should downgrade RSO's qualifications to a high school diplomat? In the 10 CFR part 35, section of 35. 900 (b) is written for RSO market conditions in the past. In my view, this section is outdated and should be eliminated. Sincerely, Zheng Shi, Ph.D. /pp

February 27, 1996 . secretary USNRC Washington D.C., 20555 Gentlemen, DEPARTMENT OF VETERANS AFFAIRS MERl,~~ i JJ 1055 <!fer~,treet Denver"'c'6"8 220

95 HAR -5 PS :13 DOCKETED USNRC MAR -5 P 3 :53 DOCKET NUMBER PETITION RULE PAM

_ ~ 0 (~n=~475~ ~ This letter represents my own opinion only and not that of this facility or the Department of Veterans Affairs. It is concerning the petition for rule making of the National Registry of Radiation Protection Technologists [NRRPT]. Currently, under 35.900[a] persons certified by the American Board of Health Physics, American Board of Radiology, American Board of Nuclear Medicine, and Board of Pharmaceutical Specialties are considered qualified to serve as Radiation Safety Officers [RSO] of Medical Institutions without other qualifications. One part of the petition, as I understand it would add the NRRPT to the list of certified personnel qualified. I support that position. I think the NRRPT has become well enough accepted with in the Health Physics Community. The experience required to sit for the exam and passing the exam constitute equivalent assurance of competency with the other certifications. Indeed, weak points in the current regulation are that it allows a person certified by the American Board of Health Physics to serve as a medical RSO without any experience in a medical institutions as well as one listed as an RSO, on any type of license, prior to October of 1986 [35.901]. Another weakness is that a physician, designated as an authorized user under 35.950 with as little as eight hours of instruction in proper handling of radioactive sources could be designed as RSO of a medical Institutions. In the worst case this could be a First Year Resident. While I consider the above to be weaknesses, I do not consider that a person without experience as a medical institution RSO to be automatically unqualified. That requirement, ignores the potential to gain equivalent experience in places that would not qualify as medical institutions. One very qualified Nuclear Regulatory Commission [NRC] Inspector of medical programs had her most recent experience prior to the NRC at a major radiopharmaceutical manufacturer. I do not know her entire background so she may well have had hospital experience also, but it would have been quite some time ago. The second part of the petition would reduce the requirement to serve as a radiation safety technologist under an RSO from 12 months to 3 months. I do not view this as lowering the standards for the reasons already partly discussed above. This requirement ignores the potential of similar experience as mentioned in the case of one of your own personnel. Another example would be my own case. I had experience with a manufacturer of brachytherapy sources, radiopharmaceuticals and providing services to student health services at the University of California, none of which might qualify as medical institutions but all of which were valuable in preparing me to be a medical RSO. MAR 1 8 199f

U.S. NUCLEAR REGULATORY COMMISSIO~ DOCKETING & SERVICE SECTION OFFICE Of THE SECRET ARY Of THE COMMISSION Docoolent Statistics Postmll'kData.s>.L..~=---- Coples Received-1--_____ Coples Reproduced _,~~ ---- Specla Distriootion~S>tO>>' ~I>~ '

Comment on National Registry of Radiation Proptection Technolgist - February 27, 1996 - Page2 Some of the discussion I have seen regarding this proposal, allege that the public health and safety may be at risk if the requirement for direct experience is watered down. I do not feel that is the case. Where therapeutic use of isotopes, teletherapy or brachytherapy are practiced there is a potential for serious consequences, if mistakes are made. However, those practices have training requirements for the authorized users and teletherapy physicist under sections 930, 932, 934, 940, 960, and 961 of part 35. Additionally, if the RSO in such institutions is considered to need special qualifications, that is where I would recommend additional requirements be added to RSO in such programs. I do not feel that is necessary, however. The NRC Inspector I mentioned, if she had not had experience under a medical institution RSO would have been ineligible, by regulation, to serve as a hospital RSO yet, in my opinion would still be very qualified to do so. The NRC hired her, in part to inspect medical programs. I think medical institutions should have the same flexibility. The institution I work for, besides practicing Nuclear Medicine does research using radioisotopes and that portion ofmy position has no regulatory required training or experience. I would suggest that a Regulatory Guide giving profiles of programs and reasonable qualifications would serve the licensed community much better than requirements which always have exceptions and inequalities. Sincerely, Peter G. Vernig Radiation Safety Officer

Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Docketing and Service Branch 448 Foothill Boulevard Oakland, CA 94606 February 27, 1996 DOCKETED USNRC

96 MAR - 1 P 3 :03 OFFICE CF SECRF:TARY DOCKETlNG & ::,::RVICE BHANCH Subj: Comments regarding Petition for rulemaking from the National Registry of Radiation Protection Technologists, Federal Register, February 8, 1996 DOCKET NUMBER PETITION RULE PRM

Dear Sir or Madam:

(~l~CL\\,7~::-1.\\:~ ~0~\\ l-:-1.:) Thank you for the opportunity to comment upon this petition. I request that the petition, as written, be denied. I have two objections to it. First, however, please recognize that technologists registered by the NRRPf will, in general, not become Radiation Safety Officers (RSOs) at small medical facilities; at these facilities, the RSO will almost always be a nuclear medicine physician, a radiologist, or a nuclear medicine technologist, because these facilities cannot justify nor afford full-time RSOs. Thus, we are considering persons registered by the NRRPT as RSOs of medium and large medical facilities. My first major concern is with regard to the proposed three months of full-time experience supervised by an RSO. I do not believe that this is sufficient medical experience for a person to become a competent medical radiation safety officer. Most persons certified by the NRRPT come from the reactor or industrial fields. The medical field is very different. Unlike shipyards and power reactors, where health physics duties tend to be quite specialized, the medical RSO must master all parts of the program. The instrumentation is different - dose calibrators, xenon traps, and liquid scintillation counters. The radionuclides and their chemical forms are different. Even the cultures are different; one must dress differently and interact differently. Additionally, many operations, such as brachytherapies, radiopharmaceutical therapies, annual testing of the dose calibrator, iodinations in research facilities, shipping of research radioactive waste, annual audit of the QM Program, annual management briefing, annual NESHAPS report, etc., may occur so infrequently that none are performed during a particular three month period. Also, in three months, it is unlikely that much experience will be gained in the types of incidents that tend to occur in medical facilities - spills, accidental punctures with radioactive hypodermic needles, accidental administrations to the wrong patient, etc. In 1983, I became the RSO at a medium-size medical facility. I held a doctorate in nuclear engineering, had a year's experience as a full member of the radiation safety committee at a major university, was a former senior reactor operator of a research reactor, and had performed research in nuclear medicine for several years as a graduate research assistant. The NRC required that I work: under the guidance of an experienced RSO for my first year. I found this requirement to be appropriate and discovered, during my first year, that I frequently needed to consult my mentor. In summary, three months medical experience is completely insufficient; a year's experience, in my opinion, would be a minimum acceptable requirement My other main objection to the proposed rule is that it extends an existing weakness of 10 CFR 35.900. The current rule permits 200 hours of training and a year's full-time experience as a technologist supervised by an RSO to qualify a person to be a medical RSO. However, the-position of radiation safety officer at medium and large medical facilities is a professional position. Acknowledged by card....MAB...1.. 8:.1&_

U.S. NUCLEAr. RE"'..'..)TORY CbMMISSIOt,.. DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSION Document Statistics Postmark Date ~ -.....i~ ---- Co~es Recei d _ _,_ _____ _ Add'! Copies Ret-'rod, ed __._ _ __ Special Distribution~<<w>h,9fP+~,.,

It requires the ability to interact with and gain the cooperation of radiologists, nuclear medicine specialists, and other physicians; medical facility management; and principal investigators. The ability to communicate verbally and in writing at the RSO level; to analyu technical radiation safety issues from a deeper standpoint than that of a technologist; and to manage a radiation safety program are very different than the skills required to be an effective technologist. A person can be a successful technologist and yet lack the skills and ability to be a successful RSO. Similarly, experience as a scrub nurse does not qualify a person to be a surgeon nor does experience as an airplane mechanic qualify a person to be a pilot. Furthennore, although 10 CFR 35.900 does not explictly require medical experience from those certified by professional boards, the ABSNM, the ABR, and the ABMP all require years of relevant experience in the medical field at the professional level. Thus, even a year's experience is not sufficient if the person is performing only technologist duties. To be appropriate training to become an RSO, the year should be a preceptorship in which the RSO involves the technologist in RSO level duties, such as preparing materials for radiation safety committee meetings, preparing minutes of meetings, participating in radiation safety committee meetings, reviewing research protocols prior to submission to the committee, interacting with management, handling incidents under the tutelage of the RSO, and interacting with regulatory agencies. Additionally, the other certifications cited in 10 CFR 35.900 all require college degrees. The medical physics certifications all require at least master's degrees in appropriate disciplines and the ABHP will require a bachelor's degree for applicants after this year. In contrast, the NRRPT certification does not require even a bachelor's degree. One NRC staffer, commenting on this petition, stated that the "NRC' s role is to establish absolute minimums... " and that "the amount of experience needed should be the employer's decision." Unfortunately, facility management is likely to assume that the NRC knows better than they who is qualified and thus assume that anyone meeting the NRC's criteria is well qualified. I request that the Commission be aware that, once a regulation is promulgated, it tends to replace whatever standards of practice that were formerly followed. The setting of minimum..- requirements, if done carelessly, can weaken, rather than strengthen, safety. In conclusion, I believe that the NRRPf certification should be treated as meeting the 200 hours training requirement. However, I recommend that at least a year's experience in a medical radiation safety program be required. Furthermore, I recommend that this experience, and also the experience listed in 10 CFR 35.900(b)(2), be under an RSO who is intentionally preparing the person to assume th~ duties of a medical RSO. As eYidenc~ of such training, a statement to that effect from the preceptor RSO should be required. Thank you again for the opportunity to comment on this petition. Sincerely yours, pj_-1?! J2ttt/,). Edwin M. Leidholdt, Jr., Ph.D.

NUCLEAR REGULATORY COMMISSION 10 CFR Part 35 DOCKETED [7590 Qlll. '96 FEB -5 A 7 :49 OFFICE C.f SU RE iAHY [Docket No. PRM-35-13] OOCKE rw: ~ERV ICE BRA.. >-1 National Registry of Radiation Protection Technologists; Receipt of a Petition for Rulemaking AGENCY: Nuclear Regulatory Commission. ACTION: Petition for rulemaking; Notice of receipt. DOCKET NUMBER PETITION RULE PRU --..::-..::.L;) ceo, ~ !.\\-, s "\\-J

SUMMARY

The Nuclear Regulatory Commission (NRC) has received and requests public comment on a petftion for rulemaking filed by the National Registry of Radiation Protection Technologists (NRRPT). The petition has been docketed by the Commission and assigned Docket No. PRM-35-13. The petitioner requests that the NRC amend its regulations by including acceptance of NRRPT registration as fulfilling some of the training requirements for a radiation safety officer. The petitioner believes that this amendment would support the objectives of the NRRPT and provide a substantial qualified resource to the medical community throughout the United States. ~ ~s, \\C\\C\\lo DATE: Submit comments by (75 da~s afte, sate ef p~hlicatie~. Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except to those comments received on or before this date. 1

ADDRESSES: For a copy of the petition, write: Rules Review Section, Rules Review and Directives Branch, Division of Freedom of Information and Publications Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Submit conments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Attention: Docketing and Services Branch. Deliver comments to 11555 Rockville Pike, Rockville, Maryland, between 7:45 am and 4:15 pm on Federal workdays. For information on sending comments by electronic format, see "Electronic Access, 11 under the Supplementary Information section of this notice. FOR FURTHER INFORMATION CONTACT: Michael T. Lesar, Office of Administrati-on, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Telephone: 301-415-7163 or Toll Free: 800-368-5642, or e-mail MTL@NRC.GOV. SUPPLEMENTARY INFORMATION: Background Information The NRC's training and experience requirements to be a Radiation Safety Officer (RSO) at a medical institution licensed by the NRC are described in 10 CFR Part 35, Subpart J - Training and Experience Requirements, § 35.900 Radiation Safety Officer. Specifically, an applicant must meet the requirements in§§ 35.900(a), 35.900(b) or 35.900(c). The regulations in§ 35.900(a) provide a list of acceptable certification boards (e.g. American Board of Health Physics in Comprehensive Health Physics; American Board of Radiology) for an individual to be qualified to work as an RSO at a medical institution licensed by the NRC. 2

The NRC regulations in§ 35.900(b) are the subject of this petition and are as follows: "Except as provided in§ 35.901, the licensee shall require an individual fulfilling the responsibilities of the Radiation Safety Officer as provided in§ 35.32 to be an individual who: (b) Has had classroom and laboratory training and experience as follows: (I} 200 hours of classroom and laboratory training that includes: (i) Radiation physics and instrumentation; (ii) Radiation protection; (iii) Mathematics pertaining to the use and measurement of radioactivity; {iv) Radiation biology; and (v) Radiopharmaceutical chemistry; and (2) One year of full time experience as radiation safety technologist at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Conunission or Agreement State license that authorizes the medical use of byproduct material; or.... " The NRC regulations in§ 35.900(c} permit an authorized user (i.e. a physician, dentist, or podiatrist) identified on the licenses's license to serve as the RSO. The Petitioner The petitioner is the National Registry of Radiation Protection Technologists (NRRPT). NRRPT was incorporated in 1976 as a nonprofit 3

organization and has a current membership of 3255. The petitioner states its objective is to encourage and promote the education and training of radiation protection technologists and, in so doing, promote and advance the science of health physics. Receipt of Petition for Rulemaking The NRC received the NRRPT petition for rulemaking on November 24, 1995. The petition is dated November 17, 1995, and was docketed as PRM-35-13 on November 27, 1995. Petitioner's Request The petitioner requests that the NRC amend its regulations in 10 CFR 35.900 specifying training and experience requirements for a radiation safety officer. Specifically, the petitioner requests that the NRC accept NRRPT registration for the current requirement of 200 hours of class-room and laboratory training, as specified in§ 35.900{b)(l), and for nine months of the current one year requirement specified in§ 35.900(b)(2). The petitioner states that the NRRPT Certificate of Registration certifies that its holder has met general requirements and passed a multiple choice comprehensive examination to test competence in fundamental concepts required as a Radiation Protection Technologist. The general requirements an applicant for registration must meet are as follows:

1.

The applicant shall have a high school diploma or equivalent.

2.

The applicants' minimum age at the time of application shall be 21 years. 4

3.

An applicant must have a minimum of five (5} years experience in applied 'radiation protection. Credit, up to a maximum of two (2) years, for 1 formal education, company training programs and military.training programs applicable to the field of radiation protection may be substituted for experience.

4.

An applicant must provide two references recommending the applicant for approval to take the NRRPT Registration Examination. The petitioner states that each successful applicant is also required to pass a broad-based multiple choice examination on radiation protection. The subject categories and the associated knowledge factors used by the petitioner are as follows: Applied Radiation Protection: Surveys and Inspections; Emergency Preparedness; Evaluating Internal and External Exposures and Controls; Prescribed Dosimetry and Radiation Equipment; Contamination Control; Radioactive Material Control and Transportation; Guides and Regulation; and Procedures and Programs (ALARA); Detection and Measurement: Analytical Methods; Instrument Calibration and Maintenance; Personnel Dosimetry; and Equipment Operation; Fundamentals: Sources of Radiation; Biological Effects; Mathematics Chemistry; Physics; and Units and Terminology. The petitioner states that the examination consists of one-hundred fifty "multiple choice" type questions based on these elements. 5

Discussion of the Petition The petitioner states that one of the minimum qualifications for NRRPT registration is 5 years experience as a radiation protection technologist. For some registered members, the requirement of§ 35.900(b){2) either currently or as amended in accordance with this petiti?n, may be included in their historical work experience upon application for registration. For those individuals (who are registered in the NRRPT and have three months experience in a medical institution), the petitioner believes that the requirement of §.35.900(b)(2) would be satisfied and need not be repeated prior to eligibility for Radiation Safety Officer at NRC or Agreement State licensed medical facilities. The petitioner believes that for individuals completing 200 hours of classroom and laboratory training required under the current requirement of § 35.900{b){2), the one year full-time work experience as a radiation safety technologist at a medical institution is appropriate and necessary for hands-on operational experience. The petitioner states that the previous work experience and qualifications for some registered members of the NRRPT may be reviewed and found acceptable for upper level job classifications such as specialist or health physicist positions, depending on the job requirements, job descriptions, and the needs of the employer. The petitioner believes that language should be included in current § 35.900 to allow for work in upper-level positions to minimize a potential conflict between the specific regulatory requirement for job title and the potential availability of upper-level employment for registered members. 6

The petitioner acknowledges that acceptan~e for radiation safety officers at licensed medical facilities is based on NRC's review of an applicant's credentials and experience. The petitioner believes that the applicant's credentials and experience may be mitigated at the time of the NRC's review. However, the petitioner believes that the current§ 35.900 allows that certain opportunities for NRRPT, as well as the job applicant, may be waived due to an overly restrictive job title. In support of the petition, the petitioner has provided a statement of the general requirements necessary for an individual to apply for registration as a radiation protection technologist, a copy of their bylaws, and a copy of the application package. The Petitioner's Proposed Amendment The petitioner recommends the following amendments to 10 CFR Part 35.

1.

In§ 35.900, paragraphs (b) and (c) are redesignated as paragraphs (c) and {d), respectively, and a new paragraph (b) is added to read as follows: § 35.900 Radiation Safety Officer. (b) Is registered by the National Registry of Radiation Protection Technologists and has had three months full-time experience as a radiation safety technologist or radiation safety specialist at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Commission or Agreement State license that authorizes the use of byproduct material; or 7

Electronic Access Comments may be submitted electronically, in either ASCII text or WordPerfect format (version 5.1 or later), by calling the NRC Electronic Bulletin Board (BBS) on FedWorld. The bulletin board may be accessed using a personal computer, a modem, and one of the commonly available communicat1ons software packages, or directly via Internet. Background documents on the petition for rulemaking are also available, as practical, for downloading and viewing on the bulletin board. If using a personal computer and modem, the NRC rulemaking subsystem on FedWorld can be accessed directly by dialing the toll free number {800) 303-9672. Communication software parameters should be set as follows: parity to none, data bits to 8, and stop bits to I (N,8,1). Using ANSI or VT-100 terminal emulation, the NRC rulemaking subsystem can then be accessed by selecting the "Rules Menu" option from the "NRC Main Menu. 11 Users will find the 11FedWorld Online User's Guides" particularly helpful. Many NRC subsystems and data bases also have a "Help/Information Center" option that is tailored to the particular subsystem. The NRC subsystem on FedWorld can also be accessed by a direct dial phone number for the main FedWorld BBS, (703) 321-3339, or by using Telnet via Internet: fedworld.gov. If using {703) 321-3339 to contact FedWorld, the NRC subsystem will be accessed from the main FedWorld menu by selecting the "Regulatory, Government Administration and State Systems," then selecting "Regulatory Information Mall." At that point, a menu will be displayed that has an option "U.S. N~clear Regulatory Commission" that will take you to the 8

NRC Online main menu. The NRC Online area also can be accessed directly by typing "/go nrc 11 at a FedWorld command line. If you access NRC from FedWorld's main menu, you may return to FedWorld by selecting the "Return to. FedWorld 11 option from the NRC Online Main Menu. However, if you access NRC at FedWorld by using NRC's toll-free number, you wi:1 have full access to all NRC systems, but you will not have access to the main FedWorld system. If you contact FedWorld using Telnet, you will see the NRC area and menus, including the Rules Menu. Although you will be able to download documents and leave messages, you will not be able to write comments or upload files (coR111ents). If you contact FedWorld using FTP, all files can be accessed and downloaded but uploads are not allowed; all you will see is a list of files without descriptions {normal Gopher look). An index file listing all files within a subdirectory, with descriptions, is available. There is a IS-minute time limit for FTP access. Although FedWorld also can be accessed through the World Wide Web, like FTP that mode only provides access for downloading files and does not display the NRC Rules Menu. For more information on NRC bulletin boards call Mr. Arthur Davis, Systems Integration and Development Branch, NRC, Washington, DC 20555-0001, telephone (301) *415-5780; e-mail AXD3@nrc.gov. Single copies of this petition for rulemaking may be obtained by written request or telefax ((301) 415-5144) from: Rules Review and Directives Branch, Division of Freedom of Information and Publications Services, Office of Administration, Mail Stop T6-D59, U.S. Nuclear Regulatory Commission, 9

Washington DC 20555-0001. Certain documents related to this petition for rulemaking, including comments received, may be examined at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC. These same documents may also be viewed and downloaded electronically via the Electronic Bulletin Board established by NRC for this petition for rulemaking as indicated above. Dated at Rockville, Maryland, this)'1£day off"'~, 1996. For the Nuclear Regulatory Commission. 10

National Registry of Rad* tection Technologists PO BOX 6974, KENNEWICK, WA 9933 6 Secretary DOCKETED NOV 2 4 1995 DOCKETING& SERVICE B'RANCH ~ SEOY-NRC 509-736-5400 November 17, 1995 Nuclear Regulatory Commission ATTENTION: Chief, Docketing and Service Branch Washington, DC 20555 DOCKET NUMBER PETITION RULE PRM ::OS-\\B (le\\ FR.-..\\-7 5 4)

Dear Madam or Gentleman:

The National Registry of Radiation Protection Technologists (NRRPT) respect-fully request Title 10, Code of Federal Regulations, Part 35 be reviewed and amended in accordance with the following petition. For reference and future correspondence, the NRRPT business office address is as follows: DeeDee Woolhiser, Executive Secretary NRRPT P.O. Box 6974 Kennewick, WA 99336-0602 (509) 736-5400 (509) 736-5454 (FAX) The Executive Secretary will direct communications in regard to this petition to the appropriate Registry committee for review and response. Thank you for your assistance. Sincerely, /)(2iJ/ TY A. Ridgel, Chairman Board of Directors National Registry of Radiation Protection Technologists enclosure

U.S. NUCLEAR REGULATORY COMMISSIOI\\. OOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY Of THE COMMISSION Document Statistics Postmark Date.-.u.+=~l::..l----- Coples Rece,ved_4--_____ _ Add'I Copies Reprodt.iced _______ _ Special Distribution ~ ~ s

NATIONAL REGISTRY OF RADIATION PROTECTION TECHNOLOGISTS Petition for Amendment to Nuclear Regulatory Commission Regulation, Part 35, Subpart J - Training and Experience Requirements, Paragraph 35.900 Radiation Safety Officer REF:.Title 10, Code of Federal Regulations, Part 35 (10 CFR 35)- Medical Use of Byproduct Material; Title 10, Code of Federal Regulations, Part 2 ( 10 CFR 2) - Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders. Current Regulation and Proposed Amendment Paragraph 35.900 states as follows: "Except as provided in 35.901, the licensee shall require an individual fulfilling the responsibilities of the Radiation Safety Of!icer as provided in 35.32-to be an individual who: (a) Is certified by: (1) American Board of Health Physics, in Comprehensive Health Physics; (2) American Board of Radiology; (3) American Board of Nuclear Medicine; (4) American Board of Science in Nuclear Medicine; or (5) Board of Pharmaceutical Specialties in Nuclear Pharmacy; or (b) Has had classroom and laboratory training experience as follows: (1) 200 hours of classroom ~nd laboratory training that includes: (i) Radiation physics and instrumentation; (ii) Radiation protection; (iii) Mathematics pertaining to the use and measurement of radioactivity; (iv) Radiation Biology; and (v) Radiopharmaceutical Chemistry; and (2) One year of full time experience as a radiation safety technologist at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Commission or Agreement State license that authorizes the use of byproduct material; or (c) Be an authorized user identified on the licensee's license.

The National Registry of Radiation Protection Technologists respectfully requests that 10 CFR 35.900 be amended to include the following: Acceptance of NRRPT registration for the current requirement for 200 hours of classroom and laboratory training as specified in 35.900(b)(1)(i)(ii)(iii)(iv)(v) AND acceptance of NRRPT registration for nine (9) months of the current one year requirement as specified 35.900(b )(2). In regard to the requirements of 35.900(bX2), one of the minimum qualifications for NRRPT registration is 5 years experience as a radiation protection technologist. For son:i-e registered members, the requirement of 35.900(b)(2) either currently or as amended in accordance with this petition, may be included in their historical work experience upon application for registration. For those individuals, the Registry feels that the requirement of 35.900(b)(2) would be satisfied and need not be repeated prior to eligibility for Radiation Safety Officer at NRC or Agreement State licensed medical facilities. Also in regard to the requirements of35.900(b)(2), one year full time work experience as a radiation safety technologist at a medical institution is specified. For individuals completing 200 hours of classroom and laboratory training required 35.900(b)(l), this level of work activity is appropriate and necessary for hands-on operational experience. For some registered members, their previous work experiences and qualifications may be reviewed and acceptable for upper level job classifications such as specialist or health physicist positions. This would depend on the job requirements, job descriptions and the needs of the employer. In order to minimize a potential conflict between the specific regulatory 'requirement for job title and the potential availability of upper level employment for registered members, the Registry believes that language should be included in the current regulation to allow for work in upper level positions. The Registry acknowledges that acceptance for Radiation Safety Officers at licensed medical facilities is based on Agency review of applicant's credentials and experience. In this regard, the above circumstance may be mitigated at the time of Agency review. However, as currently written, certain opportunities for the institution as well as the job applicant may be waived due simply to a overly restrictive job title. 2

For clarification, suggested language for 10 CFR 35.900, as amended, is provided below. Actual language, 'which includes the intent of this petition, as written by the Commission in accordance with Agency procedures is acceptable. Underlines indicate proposed changes. "Except as provided in 35.901, the licensee shall require an individual fulfilling the responsibilities of the Radiation Safety Officer as provided in 35.32 to be an individual who: (a) Is certified by: (1) American Board of Health Physics in Comprehensive Health Physics; (2) American Board of Radiology; (3) American Board of Nuclear Medicine; (4) American Board of Science in Nuclear Medicine; or (5) Board of Pharmaceutical Specialties in Nuclear Pharmacy; or (b) Is registered by the National Rei:;istry of Radiation Protection Technologists and has had three months full time experience as a radiation safety technologist or radiation safety specialist at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Commission or Agreement State license that authorizes the use of byproduct material; or (£} Has had classroom and laboratory training experience as follows: (1) 200 hours of classroom and laboratory training that includes: (i) Radiation physics and instrumentation; (ii) Radiation protection; (iii) Mathematics pertaining to the use and measurement of radioactivity; (iv) Radiation Biology; and (v) Radiopharmaceutical Chemistry; and (2) One year of full time experience as a radiation safety technologist at a medical institution under the supervision of the individual identified as the Radiation Safety Officer on a Commission or Agreement State license that authorizes the use of byproduct material; or @ Be an authorized user,identified on the licensee's license. 3

INTRODUCTION The National Registry of Radiation Protection Technologists (NRRPT), incorporated in 1976 as a non-profit organization, adheres to objectives as shown in its bylaws contained in Appendix A to this petition. The objective of the Registry is to encourage and promote the education and training of Radiation Protection Technologists and, in so doing, promote and advance the science of Health Physics. The NRRPT Board of Directors manages Registry operations, develops standards and procedures for the registration of Radiation Protection Technologists; institutes examinations leading to registration; and issues written proof of registration to individuals who possess the qualifications for registration. On behalf of the NRRPT membership, it is also the duty of the Board to promote recognition of the Registry and the qualifications of its registrants within the health physics community and to provide support for the career interest of its registered members. These interests include career growth and empl?yment opportunity, educational and professional development and credential recognition as a technicg,l resource. The NRRPT Board of Directors feel that the amendment to Part 35, as represented above and substantiated in the following, would support the objectives of the Registry and would provide a substantial qualified resource to the medical community throughout the United States. For reference, current Registry membership stands at 3255. Registry Application and Administration The NRRPT Certificate of Registration certifies that its holder has met the general requirements and passed a multiple choice comprehensive examination to test competence in fundamental concepts required as a Radiation Protection Technologist. 4

The general requirements necessary upon application for registration are as follows: The applicant shall have a high school diploma or equivalent. The applicant's minimum age at the time of application shall be 21 years. An applicant must have a minimum of five (5) years experience in applied radiation protection. Credit, up to a maximum of two (2) years, for formal education, company training programs and military training programs applicable to the field of radiation protection may be substituted for experience. An applicant must provide two references recommending the applicant for approval to take the NRRPT Registration Examination. NRRPT Application Package, contained in Appendix B to this petition, details the requirements for registration and application process. Applications are forwarded directly to the Executive Secretary by the candidate. All applications are reviewed for approval by a member( s) of the NRRPT Board of Directors or Examination Panel. A major part of the application review is the investigation of field experience and the ability to perform radiation protection work. This includes examination of the applicants work history and institutional or in-plant training programs completed. The 3 7 current members of NRRPT Board of Directors and Examination Panel are appointed from the active membership of the Registry. A conscious effort is made to select Board and Panel members with a view toward maintaining diversity with respect to areas of health physics expertise and geographical distribution. Areas of technical specialization represented on the NRRPT Board and Panel include:

nuclear medicine applications
university research applications instrumentation and calibration
power reactors
environmental assessment 5
regulatory compliance
operational health physics
emergency preparedness
weapons ~nd special nuclear materials handling
decontamination and decommissioning
internal and external dosimetry
waste management and transportation and
training.

The employers sponsoring Board and Panel members span the entire nuclear industry, including:

Major Medical Centers
Universities
Public and Private Utilities
DOE National Laboratories
Government Regulatory Agencies
Contracting and Consulting Firms As evidenced in the preceding, the petitioner believes that this diversity of backgrounds and experience parallels the broad range of individuals presently occupationally involved as radiation protection technologist and is conducive to maintaining a contemporary technical direction and overview to the registration process.

Activities associated with the registration process are set forth in procedures which are incorporated in the NRRPT Operations Manual. The Operations Manual details the duties and responsibilities of the Board and Panel and associated Registry Committees. The standardized registration process provides necessary methodology to meet the needs and expectations of the membership and the industry which it serves. Registration Examination Each successful applicant is required to pass a broad based multiple choice examination on radiation protection. The examination is routinely given two times each year at various locations throughout the United States based on proximity of incumbent or former Board or Panel members to proctor the exam. The examination is administered under the direction of the proctor and in 6

accordance with the EXAMINATION PROCTOR INSTRUCTIONS contained in the NRRPT Operations Manual. Distribution and grading of the examination is currently provided by the University of Missouri - Columbia In accordance with Registry Bylaws, examination materials, including test questions and individual exam composition, are prepared by the Examination Panel under the direction of the Examination Panel Chairman. Procedures detailing exam preparation are detailed in the NRRPT Operations Manual. The Chairman and members of the Examination Panel shall be Registered Radiation Protection Technologist and are appointed by the Registry Board. In order to develop a "performance based" qualification standard, the NRRPT examinationjs constructed in a logical, incremental approach, starting with the role delineation which describes the various tasks associated with employment as a radiation protection technologist. The task analysis results in a listing of fundamental knowledge factors required to perform the tasks. From this delineation, a blueprint for the design of th~ examination was developed. Each exam is built around this blueprint from a large bank of "multiple choice" questions which have been prepared to test various aspects of the individual knowledge factors. Knowledge elements in the task analysis are defined in three categories:

System knowledge: This includes the types of knowledge that one needs for the operation of various components that form specific systems. (For example:

the knowledge of a scintillation detection system's general components or the knowledge of reactor or radiography system fundamentals.),

Academic knowledge: This category specifies the academic or classroom knowledge needed to perform a task as well as to understand why it is being performed. (For example: the knowledge of interactions of radiation with matter and the knowledge of internal deposition pathways.)
Administrative knowledge: This category includes regulations and standards.

(For example: the knowledge of Nuclear Regulatory Commission (NRC) and Environmental Protection Agency (EPA) requirements relevant to radiation protection and national and international consensus standards on dosimetry and related health physics practices.) 7

For convenience, the application of knowledge factors to role delineation was organized by the Registry in three subject oriented categories: Applied Radiation Protection, Detection and Measurements, and Fundamentals. The subject categories along with their associated knowledge factors used by the Registry are as follows: Applied Radiation Protection Surveys and Inspections Emergency Preparedness Evaluating Internal and External Exposures and Controls Prescribed Dosimetry and Radiation Equipment Contamination Control Radioactive Material Control and Transportation Guides and Regulation Procedures and Programs (ALARA) Detection and Measurements Analytical Methods Instrument Calibration and Mainten*ance Personnel Dosimetry' Equipment Operation Fundamentals Sources of Radiation Biological Effects Mathematics Chemistry Physics Units and Terminology The NRRPT examination consists of one-hundred fifty "multiple choice" type questions based on these elements. The scope and balance of questions are carefully matched to the range and difficulty of typical tasks performed by a radiation protection technologist. Given the diversity of nuclear applications and the range of employment for the technologist, a wide scope subject matter is a virtual necessity on the NRRPT examination. 8

Test questions are developed by the Examination Panel from Question Development Resources detailed in the Operations Manual. Each question is required to include a specific reference citation and is submitted for peer review by three members of the Examination Panel. This review includes format and clarity, technical content and difficulty. Question construction is performed in accordance with the NRRPT guidelines. The comprehensive national examinations plays the dominant role in the; registration process. Although registration does not constitute license nor does it guarantee adequacy of an individual's performance, registration does test competency in fundamentals and operational topics including those required for suitable management ofNRC licensed medical use of byproduct materials. For reference as an indicator, historically to date, 54% of all persons participating in the Registry examination were successful. The applicant's work experience and the passing of the Registry examination directly support this petition. A successful candidate for registration should have, as a minimum, a hands on working knowledge of the principles and practices of* radiation protection. Furthermore, either through self study or educational

programs, the successful candidate for registration has demonstrated, by
u examination, their ability for understanding and application of those subjects addressed in 35.900(b)(l).

Academic Credit Recommendation The National Registry of Radiation Protection Technologists has been independently evaluated for academic content. The American Council on Education (ACE) performed an in-depth review of the registration process and examination in 1988, under the auspices of it's Program On Non-collegiate Sponsored Instruction (PONSI). This academic review lead to a recommendation of 30 semester hours distributed as follows: In the lower division baccalaureate/asso*ciate degree categliry, 6 semester hours in Introduction to Radiological Science; in the upper division baccalaureate category, 8 semester hours in Radiation Detection and Measurements; 8 semester hours in Radiation Protection and Control; and 8 semester hours in Applied Health Physics Internship. 9

NOTE: For those students who already possess a baccalaureate degree, the upper level baccalaureate credit recommendations can be considered graduate level recommendations. In 1994 PONSI performed a 5 year reevaluation of the Registry to document continuing application of the ACE educational recommendation. The 1994 evaluation reaffmned the Registry status and provided further definitions of the educational outcomes of the Registry. The ACE credit recommendation is indicative of a registered member's specific and general academic knowledge of the radiation protection profession and the applicable training requirements specified in 35.900(b )(l ). The credit recommendation is national and can be used by any college or university that is willing to accept the ACE recommendation. The actual amount of credits accepted depends upon the school's normal policies for transfer credits. 10

Appendix A Bylaws

BYLAWS ARTICLE I - NAME

1.

The name of the organization shall be the National Registry of Radiation Protection Technologists, which hereinafter shall be designated the Registry.

2.

An elected Board of Directors will administer the Registry program, and will hereinafter be designated the Board. ARTICLE II - OBJECTIVES

1.

The objectives of the Board shall be to develop standards and procedures for the registration of Radiation Protection Technologists; to institute examinations leading to registraion; and to issue written proof of registration to individuals who possess the required qualifications for registration.

2.

The objective of the Registry is to encourage and promote the education and training of Radiation Protection Technologists and, by so doing, promote and advance the science of Health Physics. ARTICLE ill - BOARD OF DIRECTORS ;ryIBMBERSHIP

1.

The membership of the Board shall be at least five (5), and no more than twelve (12).

2.

Members of the Board shall themselves be active, registered Radiation Protection Technologists.

3.

Members of the Board shall act as individuals and not as representatives of any organization.

4.

The term of office of each Board member shall be five (5) years, beginning on January 1 following election to the Board. The terms of office of Board members shall be staggered so that no more than three (3) terms expire on the Board each year.

5.

Organizations sponsoring persons for election to the Board shall place in nomination the names of one (1) or more persons for each vacancy. Election to the Board shall be by majority vote of the total membership of the Board from the nominations submitted, except as provided in Article III, Item 9.

6.

When a member of the Board is unable to complete a term of office for any reason. the Board may, by majority vote of the remaining members, elect a replacement for the remainder of the term from candidates nominated within the past two (2) years or from among the existing membership of the Panel of Examiners. Upon completion of this term, this person will be eligible to serve a full term at the discretion of the Board.

7.

A Board member may be removed from the Board for unethical conduct, or other just cause, by a three-quarters (3/4) vote of the total membership of the Board.

8.

A member shall not be re-elected to the Board within a period of three (3) years following the conclusion of a full term of office. A.1

9.

The Chairman of the Examination Panel shall be selected annually from the membership of the Panel and shall have full voting rights as a Board member. ARTICLE N - OFFICERS OF 1BE BOARD

1.

The officers shall consist of a Chairman, a Vice-Chairman, and a Secretary-Treasurer chosen from membership of the Board by a majority vote of the Board.

2.

The Chairman shall preside over the meetings of the Board. The Chairman shall appoint necessary ad hoc committees (and administrative positions) with the approval of the Board. Such appointments shall be for one year. The Chairman shall administer the business affairs of the Board, delegating duties to other members as appropriate. The Chairman shall keep an accurate list of the membership of the Registry and the registration actions taken.

3.

The presiding office shall have no vote except in the case of a tie, under which circumstance, the presiding officer shall cast a deciding vote.

4.

5.

The Vice-Chairman shall perform the duties delegated by the Chairman, and, in the absence of the Chairman, shall assume the duties of the Chairman. A. The Secretary-Treasurer shall keep a record of all meetings of the Board, and shall receive and be custodian of all monies due the Registry. The Secretary-Treasurer shall submit to the board the accounts for audit at the last Board meeting prior to the end of the term and shall transfer to the elected successor, with audit committee approval, all funds and properties of the office at the next Board meeting. B. The term of office of the Secretary-Treasuer may be extended up to 3 months, at the discretion of the Board, to assure a smooth transition with the incoming Secretary-Treasurer.

6.

The terms of office for all officers of the Board shall be one (1) year starting on January 1, following election.

7.

The Secretary-Treasurer of the Board, and such other persons as may be designated by the Board may be bonded in any amount determined by the Board and by a bonding company approved by the Board. Expense of bonding shall be borne by the Registry. ARTICLE Y -MEETINGS OF THE BOARD

1.

There shall be at least one (1) meeting of the Board each year.

2.

Additional meetings may be called by the Chairman, or by request of a majority of the Board.

3.

In order to conduct the business of the Board, a quorum of two-thirds (2/3) of the voting membership must be present at all meetings except as provided in Article V, Item 4.

4.

A member of the Panel may sit on the Board as a proxy for an absent Board member, if the following conditions are met A. A two-thirds (2/3) membership is not present. A.2

B. The Board members of the quorum shall constitute a majority. C. Verbal agreement for the proxy is received by the Chairman from the absent member prior to the start of the meeting. D. The absent member follows up with a written agreement to the Chairman within fourteen (14) days. Actions of the Board will not be ratified until such written agreement is received.

5.

When, in the opinion of the Chairman, essential Board action is required prior to the next scheduled Board meeting, approval may be a two-thirds (2/3) majority vote by telephone. The Chairman shall obtain ratification of this telephone vote by written correspondence. This action shall be entered in the minutes of the next Board meeting. ARTICLE YI -FINANCIAL

1.

All funds shall be paid into the office of the Secretary-Treasurer, where they shall be entered in the records of the Registry and deposited in a bank approved by the Board.

2.

All monies due the Registry shall be billed and collected by the Chairman or by the Secretary-Treasurer.

3.

The Chairman and the Secretary-Treasurer may expend funds from the treasury in accordance with the wishes of the Board.

4.

The Secretary-Treasurer shall keep proper accounts of all financial transactions of the Board and shall submit an annual report.

5.

The Chairman of the Board is authorized to approve expenditures of funds to provide travel, hotel, and other reasonable expenses to persons necessary in conducting the business of the Registry.

6.

The application fee for registration shall be established by,a majority vote of the Board. The application fee is not returnable after any portion of the examination procedure has commenced.

7.

All monies received by Registry shall be used exclusively for the purposes of the Registry, or such other purposes as are within the meaning of Section 501(c)(6) of the Internal Revenue Code of 1954 (or the corresponding provisions of any future United States Internal Revenue Law). ARTICLE VII - EXAMINATION PROCEDURES

1.

Applicants seeking registration shall apply to the Board on the designated form, approved by the Board.

2.

To achieve registration, applicants shall be required to pass an examination approved by the Board.

3.

An Examination Panel and a Chairman of the Examination Panel shall be selected by the Board. Each member of the Examination Panel shall be an active, registered Radiation Protection Technologist A.3

4.

Members of the Examination Panel will serve for a term of four (4) years, with approximately one-fourth (1/4) of the membership initiated each year.

5.

The Examination Panel shall prepare material for the examination and shall submit such material to the Board for approval.

6.
An examination shall be held at least once (1) per year at a location, or locations, and a time determined by the Board.

ARTICLE VIII -MEMBERSHIP

1.

Applicants fulfilling the requirements of Article VII, Item 2 shall be deemed members of the NRRPf and identified as Registered Radiation Protection Technologists. A. The Registry may establish requirements for continuation of Active Membership, as appropriate to the furtherance of the Article II Objectives, by majority vote of the Board. B. Members who elect not to sustain the requirements established in accordance with Article VIII, Item lA, shall be deemed Inactive Members.

2.

Members who have made sustained and substantial contribution(s) to the Registry may be appointed to Emeritus Membership by majority vote of the Board.

3.

By majority vote of the Board, non-registered membership categories may be established in accordance with the Article II Objectives. Also, non-registered membership involvement in the activities of the Registry shall be determined by majority vote of the Board.

4.

Following investigation of the facts by the Board and upon unanimous approval of the members of the Board, registration may be withdrawn for actions considered to be in violation of the Code of Ethics. Any person for whom such action is contemplated shall have the right of appearance before the Board. ARTICLE 1X -DISSOLUTION

1.

Upon dissolution of the Registry, the Board of Directors shall, after paying or making provisions for payment of all liabilities of the Registry, dispose of all the assets of the Registry exclusively for the purposes of the Registry in such manner or to such organization or organizations organized and operated exclusively for charitable, education!, religious, or scientific purposes as shall, at the time, qualify as an exempt organization or organizations under Section 50l(c)(6) of the Internal Revenue Code of 1954 (or the corresponding provision of any future United States Internal Revenue Law). Any such assets not so disposed of shall be disposed of by the Court of Common Pleas of Hamilton County, Tennessee, where the principal office of the Registry is located, exclusively for such purposes or to such organization or organizations as said court shall determine are organized and operated exclusively for su*ch purposes. ARTICLE X -POLffiCAL

1.

The Registry will not, as a substantial part of its activities, attempt to influence legislation or participate to any extent in a political campaign for or against any candidate for public office. A.4

ARTICLE XI - CONFLICTS OF INTERESTS

1.

A member of the NRRPT Board of Directors, Panel of Examiners, employees or their representative(s) shall not become involved with causes, organizations, or activities that conflict with the best interest of the Registry, or otherwise compromise in any manner the integrity of the NRRPT. A person involved in such activities may be censured, as deemed appropriate, with two-third's (213) vote of the Board of Directors. ARTICLE XII -AMENDMENTS

1.

These Bylaws may be changed by a three-quarters (3/4) vote of the Board. In witness whereof we have hereunto subscribed our names on this 17th day of November, 1995: Jerry A. Ridgel, Chairman Michael J. Boyle, Vice-Chairman Norm Sunderland, Secretary-Treasurer A.5

AppendixB Application Package

National Registry of Radiation Protection Technologists P O BOX 6974, KENNEWICK, WA 99336 509-736-5400

Dear NRRPT Applicant,

Enclosed are the following: Application for Registration Examination Location Preference Examination Preparation Guide The Location Preference form should be completed and returned with your application. Please note that the exam locations are tentative and may change. All forms should be returned to the Executive Secretary by the person completing them. The applicant is responsible for ensuring that all forms are submitted. After all forms and the examination fee have been receive4 a member of the Board of Directors or Panel of Examiners will review them to verify that the applicant meets the examination prerequisites. An applicant who is accepted will be subsequently notified. Applicants not approved will be notified as soon as possible and the exam fee refunded in full After an applicant has been approved to sit for the examination, the exam fee is not refundable. If an approved candidate does not take the examination within two years of approval, a new application and exam fee will be required. The examination will be administered on tlie 1st Saturday in May and November at loca-tions throughout the* country. All applications and fees must be mailed no later than March 15th for the May exam, and September 15th for the November exam. The examination fee is ONE HUNDRED AND TWENTY-FIVE DOLLARS ($125.00, U.S.); the re-examination fee is FIFfY DOLLARS ($50.00). The exam questions are based on U.S.A. guidelines and regulations. Successful examinees will be registered by the NRRPT and will receive a certificate of Registration. A plaque will also be available at a cost ofFORTY-1WO DOLLARS ($42.00). Due to the diverse radiation protection subjects covered in the examination, extensive pre-paration is urged. The amount of preparation needed will vary with the education, training and experience of the Candidate. ~-~ Jerry A. Ridgel, Chairman Board of Directors B.I

Registration Procedures Preface The Certificate of Registration certifies that its holder has met the general requirements and passed a multiple choice examination to test competence in fundamental concepts required as a Radiation Protection Technologist. It should be recognized that the Certificate of Registration issued by the Board of Directors is not a license, and therefore does not confer a legal qualification to practice Health Physics. A Registered Radiation Protection Technologist shall be of good moral character and shall have met the requirements listed herein. 'I. Requirements for Registration A. Education The applicant shall have a high school diploma or equivalent. B. Age C. Minimum age at time of application shall be 21 years. Experience An applicant must have a minimum of five (5) years of applicable experience. Training may be substituted for experience. The applicant may be required to submit to the Board information about the training program and proof of completion. This information should include curriculum, typical examinations, and passing requirements for radiation protection related subjects. Experience credit allowed for formal education, company training programs and applicable military training is accumulative up to a maximum of two (2) years. An applicant may not claim work experience while in formal classroom study. Training Program Four Years - BS Radiation Protection Technology Two Years -AS Radiation Protection Technology One Year-Radiation Protection Technology Military and other training/educational activities are evaluated on a case-by-case basis Experience Credit 2 years 1 year 1/2 year 8.2

D. Examination Upon review of the application package and approval by the Board, the applicant will be given permission to take the National written examination. The National exami-nation will consist of a broad based multiple choice examination of radiation protection: (1) Fundamentals, (2) Measurements, (3) Applied concepts. II. Application Applications may be submitted individually or as a group by a company or facility. Group submittals must provide completed individual application forms; however, only one copy of the company or facility training program needs to be enclosed if experience credit is desired for individual applicants within the group. Applications will not be processed until all three sections of the application pack21ge are received by the Executive Secretary. A completed package consists of the applicants portion (employment history, education, training), the Confidential Professional Reference Form, and Immediate Supervisor Reference Form. The reference forms may be forwarded directly to the Executive Secretary separate from the application, but simply having your references sealed in separate envelopes and mailed along with the application is preferable. Please be aware that all NRRPT applications contain double sided forms, a 5 page applica-tion portion (extra page 3's for work history may be attached) and 2 pages each for the Professional and Supervisor reference forms. III. Operational Knowledge A major part of the Board's applicant "screening" will be the ii:ivestigation of field competence and ability to perform radiation protection work. The screening includes examination of the applicant's work history, and institutional or in-plant training programs completed. To facilitate this review the application shall include detailed information regarding the following: companies worked for, positions held and responsibilities while in these positions including a description of bow the work is applicable to applied HP information regarding training programs completed; if possible, include course outlines, typical examinations and passing requirements names of supervisors and knowledgeable persons who, the Board may interview to further establish competence and integrity of the applicant B.3

IV. Examinations A. National Examinations National examinations shall be administered and controlled by an Examination Panel appointed by the Board. The exams shall be proctored by a member of the Board of Directors, a member of the Panel of Examiners, or persons appointed by the Chairman of the Panel of Examiners. The examination will be offered at least twice a year, on the first Saturday of May and November. The locations will be determined by the Board. An approved application will be valid for a period of two (2) years. For example, a person applying for the November 1995 exam will have the opportunity to take the Nov. '95, May '96, Nov. '96, May 97 or Nov. 97 examinations on the initial application. Please note however, that deferral past the Nov. '96 exam would not allow the applicant to take a re-examination without a new application (see IV.B below). B. Re-Examination A candidate who fails the first examination may be admitted for a second examination after one year by payment of a reduced re-examination fee, and by notifying the NRRPT Executive Secretary in writing of their intentions and exam site preference. If a candidate does not appear for re-examination within two yean, if the original application has expired, or if a candidate wants to take the exam a third time, thP.y must submit a new application with the full test fee.

c.

Grading and Passing Requirements The grading and passing requirements will be determined by the Board. The Board's actions on any applicant's examination will be final. Answers to commonly asked questions dealing with actual examination handling will be available from the exam proctor on the day of the examination. Code of Ethics In achieving registration, the Registered Radiation Protection Technologist recognizes and assumes responsibilities due the profession of radiation protection. The Registered Technologist, while active in the field of radiation protection, has a commitment to maintain technical competence. This shall be accomplished by remaining acquainted with scientific, technical, and regulatory developments in their field. In order to uphold the integrity of the profession of radiation protection implied in,.this Registry, their relations with others, including supervision, colleagues, governmental agencies, and the general public shall be based upon and reflect the highest standards of professional ethics and conduct. Registration may be revoked for action considered by the Board to be in violation of this .. Code of Ethics". Any person for whom such action is contemplated shall have the right of appearance before the Board.

8.4

(Rev. 10/95) Office Use Only National Registry of Radiation Protection Technologists . P.O. Box 6974, Kennewick, WA 99336 (509) 736-5400 Application for Registration Instructions: D!J1!. or print neatlv, in black ink Date:--~'----'-'--- SSN: ________ _ 411onthN ear you Intend to take exam: May November D 199 __ Check One: __, Initial Application Reapplication Exam Retake Pd by: Ck#: Amt: ID#: Name:-----...:...------:-------------.Date of Birth:....

______ __._ __

(Last, First, Middle Initial) Mailing Address:. ______ _.._ ____________________..--__________ _ (City) (State) (Zip) NOTE: The NRRPT may need to contact you during the review of your appliC3tion. Plellse provide a phone number at which you can be reached, if necessary, during the next 60 to 90 days. Home Phone:.__ ___,.__ __________ _ Business Phone: '---~----------- Definition of a Radiation Protection Technologist (R.P.T.) A Radiation Protection Technologist is a person engaged in providing radiation protection to the radiation worker, the general public, and the environment from the effects of ionizing radiation. The Radiation Protection Technologist has a basic understanding of the natural laws of ionizing radiation, the mechanisms of radiation damage, methods of detection, and hazards assessment. The Radiation Protection Technologists' tasks are accomplished by providing supervisory, administrative, and/or physical controls, utilizing sound health physics principles in compliance with local and statutory requirements and accepted industry practices. The Radiation Protection Technologist mitigates hazards associated with radioactive materlals and Ionizing radiation producing devices, always adhering to the "as low as reasonably achievable" philosophy. 8.5

(Rev. I 0/95) Page 2 of9 Employment History The applicant must have a minimum of S years of experience in direct Health Physics wotk. Applicable education and training may be substituted for up to 2 years of work experience as determined by the application reviewer in accordance with the Experience Credit Guide. List all applicable work experience beginning with your current or most recent employer. Since your employment history is a critical element of determining your eligibility for registration, it is important that the employment history is as complete and as factual as possible. Since it is the responsibility of the application reviewers to determine the experience level of the applicant, applicants ~re advised to list all applicable work experience, including that experience which may be in_ excess of the minimum requirement of 5 years. Insuring that the history contains a detailed description of your duties and responsibilities will help the reviewer in accurately assessing your eligibility for Registration and avoid unnecessary delays in processing the application package. Photocopies of page 3 of this application may be used if additional sheets are needed to outline your employment history. If additional copies of page 3*are used, please label 4'ach page with an alpha character, such as 3A, 3B, etc., to assist in keeping th~ package in reverse chronological order for the convenience of the application reviewers. Substituting a resume in lien of completing the Employment History section of the application package is unJJcceptable; However, a resume may be attached to the completed application package for additional clarification of your employment history. Failure to fully complete the employment history section* mav result in delaying the evaluation of vour application package. Are.you currently engaged in radiation protection a substantial portion of the time? Yes __ No -- HNo, explain:*------------------------------------- Bt!llin with CJl"ent or most rt!Cent on>>, over. Employer & Address Position Title Startin2 Date Ending Date (MM/DD/YY). (MM/DD/YY) Percent of time in Applied HP:

1o Employer Phone (

) Detailed.Description of Work: Reviewer 'raDy. I Reviewer J: I Reviewer :2: B.6

(Rev. I 0/95) Employer & Address EmDlover Phone ( ) Description of Work: Emolover & Address Employer Phone ( ) Description of Work: Page3_of9 Employment History (continued) Position Title Starting Date (MM/DD/YY) Percent of time in Applied HP: Rel'iewer Tallv I Reviewer: 1: Position Title Starting Date (MM/DD/YY) Percent of time in Applied HP: o;. Reviewer Tally Reviewer 1: Endin2 Date (MM/DD/YY) Reviewer 2:, Endln2 Date (MM/DD/YY) Reviewer 2: -

B.7

(Rev. 10/95) ,Page4 of9 Education and Training List educational and training activities in, or related to, radiation protection. Related areu may include, but are not limited to, biology, chemistry, nuclear medicine, nuclear engineering, physics, industrial hygiene, or environmental technologies. Additional sheets may be used to list these activities as necessary. Documenting educational and training activities is particularly important in determining the applicant's eligibility to receive experiential credit for these activities in the event that the applicant has not fully attained five years of experience as an R.P.T. Providing transcripts (student copies are acceptable) of college level credit earned will aid the application reviewer in assessing the applicability and amount of -credit that may -be substituted-for a:perience. Failure- -to provide mmscFipts or other suitable documentation, such as copies of diplomas and/or certificates, will not in itself disqualify the applicant from receiving experience credit; However, the absence of appropriate documentation may delay the completion of the application review process. aince the minimum mandatory educational requirement for registration is completion of high school *or equivalent, all applicants are required to complete the section labeled "High School or Equivalent."

- Hin School or Eq'i1ivalent Name of High School Attended or School Location Year Graduated or Certlflcatine: Onranization (City, State)

Certificate Obtained . Co"-- -Universities, and Trade *schooll. Name of Dates Attended Major Area Hours Earned Name of Degree Institution (Year to Year) of Study Quarter Semester Earned $hon Courses, Military, Corporate, and.Other Training* {40 clock hours m.lnimum duration for each course). Soonsorin2 Ore:anizatioo Dates Attended Len!!th (Contact Hours) ) Course Title and Detailed Course

Description:

8.8

(Rev. 10/95) Page5 of9

. Short Conr:sea, ~~

Cotpq)_'&t~ an,d Other Tra~g ,-, (! .*. (40.clock'houn*minimum duratfon*for'each"c4nin.e).. Sponsorine OrEanization Dates Attended Lemrth (Contact Hours) Course Title and Detailed Course

Description:

Sponsorin2 Oraanization Dates Attended Lemrth (Contact Hours) Course Title and Detailed Course

Description:

f I authorize and grant permission to the National Registry of Radiation Protection Technologists, hereinafter referred to as the "Registry" or "NRRPT," and any other person(s) acting on behalf of the Registry, to conduct or cause to be made such investigations and inquiries as may be required for the sole purpose of determining my eligibility for Regl.rtration. I authorize all schools and administrators, former employers, current employers, governmeqtal and military authorities, NRC and state licensees, and personal references to release any information pertaining to my eligibility for Registration with the NRRPT; and I specifically and knowingly forever release such Individuals and organizations, Including the NRRPT and any Individual acting on behalf of the Registry, from any and all liability to me or others as a result of acquiring or releasing such information. I may withdraw my consent for this investigatory action at any time upon written request to the Executive Secretary of the Registry. Upon receipt of such notification, all investigation and inquiry will cease as soon as practicaL Withdrawal of consent all be synonymous with retraction of this Application for Registration. My signature below Indicates that I have read, understood, and consented to the above statements and that I have made true, correct, and complete answers and statements on this Application for Registration in the knowledge that it will be relied upon In considering my eligibility for Registration with the NRRPT, and I understand that any omission, false answer, false statement, or othenvise inaccurate information provided by me may affect my eligibility for Registration with the NRRPT now and in the future. Furthermore, a photocopy of this authorization shall be deemed as an original and shall be accepted as such by any person or organization. Full Name of Applicant (Typed or Printed) Applicant's Social Security Number Applicant's Signature Application Checklist: Application form complete? D Confidential Reference Form complete? D Transcripts enclosed (if necessary)? D Personal Reference Form complete? D Date Payment enclo!!ed? D 8.9

(Rev. I 0/95) Page 6 of 9 National Registry of Radiation Protection Technologists P.O. Box 6974, Kennewick, WA 99336 (509) 736-5400 Immediate Supervisor Reference Form All information provided on this form will be held in strict confidence. If additional space is required, use additional sheets. The completed form should be returned by the Immediate Supervisor to the NRRPT at the address shown at the top of thu form. National Registry of Radiation Protection Technologists Program The Certificate of Registration issued by the Board of Directo~ certifles that an individual has met certain requirements and has ssed a multiple choice examination designed to test competence in fundamental concepts required of a Radiation Protection echnologlst It should be recognized that the Certificate of Registration is not a license and therefore does not confer a legal qualification to practice Health Physics. Several requirements must be met before the applicant can be approved to take the registration examination. The candidate must be at least 21 years old *and have a high school diploma or equivalent The applicant must have a minimum of S years of experience In, or directly related to, Radiation Protection Technology. Up to 2 years of experience may be granted by the application reviewer for appropriate educational or training activities. Finally, the applicant must be of.good moral character. In order to assist the Board of Directors in accurately assessing the applicant's qualification for Registration, the applicant Is required to obtain personal references from their immediate supervisor and at least one other person qualified to evaluate the applicant's professional abilities. Your assistance in providing this reference~ appreciated by the Board. To be completed by applicant: .pplicant's Name: ________________ SSN: _______ Phone: ______ _ (Last, Fint, Ml) Address: --------------------------------------- To be completed by the applicant's Immediate Supenrisor:

1. Do you feel the applicant bas been under yo~r supervision long enough for you to properly evaluate their capabilities and broad-based knowledge of applied radiation protection? Yes __ No __

If "No," sign below and return this form to the applicant for their previous supervisor to complete. If "Yes," proceed to page two. Printed Name: ______________ _

Title:

Signature: _______________ _ Phone: ------------ 8.10

(Rev. 10/95) Page 7 of9

2. a. How long has the applicant been under your supervision?

___ year(s)

b. What portion of the applicant's time is spent in applied radiation protection?

c. Briefly describe the applicant's work history with your firm. ----------,--------

3. What are the specific duties and responsibilities of the applicant regarding:

a. Practical protection of people? ___ - ______________________ _

b., Supervision? _________________________________ _

c. Other? (specify) _______________

0 _______________

- To what extent are the applicant's recommendations reviewed before they are put into effect? _____ _

5. Is the applicant capable of properly responding to and assessing potential major radiation hazard problems independently? Please explain ____________________________ _

6. a. How, and by whom, are the applicant's decisions used? __________________ _

b. Wbat radiation protection problems must the applicant solve in their job? ____ ~-------

What are the applicant's responsibilities in case* of emergencies? ______________ _ - 7. Do you have any reservations about recommending the applicant for registration? Yes __ _ No --- (if Yes, please explain) ______________________________ _

8. Are you an: Active NRRPT member? Yes __ No Evaluator's Name: --------------

Title:

Phone: ------------------ Active CHP? Yes Business Address: No Signature: ______________________ _ Date: ----------- B. I l

(Rev. I 0/95) Page 8 of9 National Registry of Radiation Protection Technologists P.O. Box 6974, Kennewick, WA 99336 (509) 736-5400 Confidential Professional Reference Form All Information provided on this form will be held in strict confidence. If additional space is required, use additional sheets. The completed form should be returned by the person completing the Professional Reference section to the NRRPT at the address shown at-the top of this form. The Professional Reference should be either ao activ.e member: of.the NRRPT or a Certified Health Physicist. National Registry of Radiation Protection Technologists Program he Certificate of Registration issued by the Board of Directors certifies that an individual has met certain requirements and has passed a multiple choice examination designed to test competence ln fundamental concepts required of a Radiation Protection Technologist It should be recognized that the Certificate of Registration is not a license and therefore does not confer a legal qualiflcatioi;i to practice Health Physics. Several requirements must be met before the applicant can be approved to take the registration examination. The candidate must be at least 21 years old and have a high school diploma or equivalent The applicant must have a minimum of 5 years of experience lo, or directly related to, Radiation Protection Technology. Up to 2 years of experience may be granted by the application reviewer for appropriate educational or training activities. Finally, the applicant must be of good moral character. In order to Msist the Board of Directors In accurately assessing the applicant's qualification for Registration, the applicant Is required to obtain personal references from their immediate supervisor and at least one other person qualified to evaluate the applicant's professional abilities. Your assistance in providing this referen~ is appreciated by the Board. 41lo be completed by applicant: Applicant's Name: ________________ SSN: _______ Pbone: ______ _ (Lut, First: Ml) Address: ________________________________ _ To be completed by Professional

Reference:

Note: If, for any ~n, you feel you cannot accurately assess the applicant in the areas addressed on this form, return the form to the applicant.

1. How long have you known the applicant professionally?

___ year(s)

2. What has been the nature of your association?~-----------------------

8.12

(Rev. I 0/95) Page 9 of9

3. Briefly describe your impression of how well the applicant applies training and operadonal concepts to practical situations. -------------------------------------

a. How, and by whom, are the applicant's decisions used? __________________ _

b. What health physics problems must the applicant solve in their job _____________ _

c. What are the applicant's responsibilities in case of emergencies _______________ _

e d. What are the applicant's routine daily responsibilities __________________ _

4. What is your evaluation of the manner in which the applicant performs their assigned responsibilities? __ _

I

5. How well does the applicant perform independently, without supervision? Please explain. ______ _

6. What is your estimation of the applicant's:

a. Honesty? ___________________________________ _

b. Occupational ethics?

Do you have any reservations about recommending the applicant for registration? Yes __ _ No --- (if Yes, please explain)---------------------------------

8. Please add any other comments that may be helpful in evaluating the applicant's competence

9. Areyouan: ActiveNRRPTmember? Yes __ No Evaluator's Name: --------------

Title:

Phone: ------------------- Active CHP? Yes Business Address: No Signature: ______________________ _ Date: ----------- 8.13

.J Examination Location Preference Form Applicant's Name ____________________ _ Listed below are the tentative locations for the 1995 examin-ation. Please select the location you pref er, and one alternate. Every attempt will be made to assign you to your first choice. Browns Ferry, AL Grand Gulf, MS Nuclear One, AR Brunswick, NC Tempe,AZ McGuire,NC Diablo Canyon, CA Shearon Harris, NC Livermore, CA Omaha,NE San Clemente, CA Salem, NJ Grand Junction, CO Los Alamos, NM Rocky Flats, CO Las Vegas,NV Crystal River, FL Indian Point 3, NY Orlando, FL Nine Mile Point, NY St. Lucie, FL Ginna, NY Turkey Point, FL Columbus, OH Duane Arnold, IA Davis Besse, OH Idaho Falls, ID Fernald, OH Byron, IL Perry, OH Clinton, IL Limerick, PA Wolf Creek, KS Three Mile Island, PA Paducah, KY Savannah River, SC Waterford 3, LA Seneca, SC I Boston, MA Oak Ridge, TN Maine Yankee, ME S. Texas Project, TX Calvert Cliffs, MD Texas A&M, TX DC Cook, Ml Salt Lake City, UT Monticello, MN Surry, VA Prairie Island, MN Vermont Yankee, VT Fulton, MO Richland, WA Please Note: If you must change your selection after submission, pleas~ contact the Executive Secretary as soon as possible. We will make every attempt to assign you to your preferred location. B.14 I}}

ML23151A553

Contents

Text

REFERENCE:

SUMMARY

Reference:

Dear Mr. Hoyle:

Subject:

Subject:

Subject:

Dear Mr. Jones,

Dear Sir:

SUBJECT:

Dear Sir or Madam:

Dear Mr. Hoyle:

Dear Madam or Gentleman:

References:

Subject:

Dear Mr Jones,

Subject:

Subject:

Subject:

Subject:

Reference:

Dear Sir or Madam:

Subject:

Dear Sirs,

Dear Sir:

Dear Sir or Madam:

SUMMARY

Dear Madam or Gentleman:

Dear NRRPT Applicant,

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Dear Mr. Hoyle:

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Dear Mr. Jones,

Dear Sir:

SUBJECT:

Dear Sir or Madam:

Dear Mr. Hoyle:

Dear Madam or Gentleman:

References:

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Dear Mr Jones,

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Subject:

Subject:

Subject:

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Dear Sir or Madam:

Subject:

Dear Sirs,

Dear Sir:

Dear Sir or Madam:

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Dear Madam or Gentleman:

Dear NRRPT Applicant,

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