ML23156A074
| ML23156A074 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1984 |
| From: | Dircks W NRC/EDO |
| To: | |
| References | |
| PR-034, 49FR39168 | |
| Download: ML23156A074 (1) | |
Text
ADAMS Template: SECY-067 DOCUMENT DATE: 10/04/1984 TITLE: PR-034 - 49FR39168 - INDUSTRIAL RADIOGRAPHY RADIATION SURVEYS AND LICENSEE'S PERFORMANCE INSPECTION PROGRAM CASE
REFERENCE:
PR-034 49FR39168 KEYWORD: RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete
GLITSCH FIELD SERVICES, INC.
5250 Mayfair Road
- P.O. Box 2908
- Nortti 9anton, Ohio 44~~ , 6/494-9436 December 3 , 1984 Secretary , U. S, Nuclear Regulatory Commission Washing t on , D. C. 20555 Attention: Docketing and Service Branch
- Subject : Comment on proposed rule change , Title 10 CFR 34 Parts 34. 11 (d) and 34 . 43(c)
Reference : Industrial Inspection Industries , Inc.
Dept . of Glitsch Field Services , Inc .
P . O. Box 2908 5250 Mayfair Road North Cant on , Ohio 44720 USNRC Specific License No . 34-14071-0 1 Gentlemen:
Please consider the enclosed as Industrial Inspection Industries , Inc . Dept.
of Glitsch Field Services , Inc. position with regard to the proposed rule changes referenced in subject above.
III, Inc. dept . of Glitsch Field Services, Inc. does not favor the proposed revision to 34 . 43(c) in its cur r ent form for reasons as follows:
- 1. In the opinion of the writer , the proposed revision to record the radiation level at the time the device is placed in a storage area disregards the more critical time period when the device has been secured (guide tube and crank assembly disconnec t ed and safety plug inserted) and t he device is being carried or transported to i t s storage location . It is during this period that the device is in i t s closest proximity to the Radiographer and the greatest exposure could be received.
- 2. In certain forseeable applications shift changes could occur without the exposure device being returned to a designated storage location .
The relieving Radiographer would not have final survey results , recorded at the end of a prior shift ' s operat i ons . This cou l d result in an increase in the number of incidents involving the relieving radiographer incorrectly believing the source to be in its shielded position.
- 3. Recording survey results in the field is of no greater difficulty than recording other required information such as barricade radiation levels as was suggested by the petitioner .
U.I. NUaEAR REGULAT(")~V COMMI SSIOM l)OCKETING & SERVlr r: <:ECTI0N OFFICE OF n -'F r ' ~y OF THE r0 1 . 'vN t ics Polllnn Date Cop!* Rec,,.* I
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. A. 34.43 (c) (Continued)
- 4. Storage area surveys:
- a. In vehicles must be surveyed in accordance with DOT Title 49 regulations when preparing the vehicles for transport and the storage location acts as an outer shipping container, (example - leaving a field job location) to determine the Transport Class and Transport Index. (Contact and one meter)
- b. All storage locations must be surveyed around the perimeter in accordance with Title 10 CFR 20 Part 20.l0S(b) if they are to be designated as Unrestricted Areas.
- 5. Surveys on a device performed in a storage area with a background intensity, caused by other devices in storage or within containment at a nuclear facility would not be representative of that device and might even fail to disclose an empty device.
Industrial Inspection Industries, Inc. dept. of Glitsch Field Services, Inc.
would like to propose that a preferential revision would be to record the radiation level of the device s urve yed immediately after securing the device.
The definition of "Securing the Device" should be:
Disconnecting the guide tube, crank assembly, inserting the safety plug (all as applicable) and locking the device in preparation for storage.
It is felt that by recording the results of the survey proposed above, no additional benefit would be received from requiring the recording of an additional device survey at the storage location in that it would be highly unl ikely and in most instances, impossible for the source to become dislodged after being properly secured and locked in the device.
B. Proposed revision to Title CFR 34 Part 34 .11 (d)
In that the proposed revision has been represented as an attempt to clarify , and not to revise current requirements, Industrial Inspection Industries, Inc. Dept. of Glitsch Field Services, Inc. would like to make the following observation .
The requirement of Part 34.11 (d) ** (as proposed} has been a license condition with this licensee since 19 76 . This requirement has his -
torically proven to be a difficult a nd costly safety practice for a company engaged primarily in field radiography.
The following is a listing of some of the more commonly encountered difficulties:
- 1. Industrial Radiographers are frequently certified in several NDE test methods, and may perform Radiography at infrequent intervals which are difficult to schedule in advance.
- B. Proposed revision to Title CFR 34 Part 34.11 (d) (Continued)
- 2. The Radiation Safety Officer is not always the responsible individual for determining personnel schedules and therefore might not be aware that a certain individual will be assigned to perform radiography on a given night, conceivably missing an individuals first r adiographic operation after a missed audit period.
- 3. On occasions, a safety officer will travel great distances only to find that operations have been secured before his arrival due to a "rain-out" or low work on a given day .
- 4. Radiographers and Assistant Radiographers working as a two (2) man unit are frequently rotated by some companies to enable assistants to gain experience working with several dif fere nt radiographers and thus learn various exposure technique in a shor ter time period .
This practice sometimes results in some individuals being audited on numerous occasions and others being potentially missed .
- 5. In a very competative market, a remote field job expected to last only two (2) months can be bid at a lower cost , however, if the job takes longer than expected, the Radiography Company must absorb the cost of sending a safety auditor to the job location to audit the technicians regardless of their experience or safety record .
Additionally, it should be recognized that an Inspection Company, for its own convenience , will normally select its most experienced, available personnel to send on the most remote, difficult inspection jobs to avoid code , technique, customer -relation , and radiation safety problems.
In the opinion of the writer, the requirements of 34 .1 1 (d) should be revised to allow some flexability based on an individuals experience and safe t y record.
An example of this flexability might be :
Whenever the Lead Radiographer at any field construction site has a minimum of f ive (5) years experience and records of radiation safety audits show no noncompliance in the previous one (1) year period, audit frequency may be reduced at that site to a mimimum of every six (6) months .
The above listed time intervals have been used as examples only ,
however, this type of flexability might greatly reduce the burden on field NOE companies without undue safety hazard.
If you should have any questions regarding these comments or if we may be of any service, please feel free to contact this office.
Phone No. 216-494-9436 Respectfully submitted, Industrial Inspection Industries, Inc.
Dept. of Glitsch Field Services, Inc.
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Alan C. Magno C:: (/
Radiation Safety Director
C-E Power Systems Combustion Engineering, Inc.
Tel. 203/688-1911 Telex : 99297 1000 Prospect Hill Road Windsor, Connecticut 06095
!!!!a!!!! POWER Eiiilliii SYSTEMS *a4 Nov 26 P1 :sa November 19, 19841JI-F,v *iF ~-
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BRANCH '
Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, o.c. 20555
Subject:
Comments on NRC Proposed Rule for Industrial Radiography Radiation Surveys and Licensee's Performance Inspection Program
Dear Mr. Chilk:
Combustion Engineering (C-E) would like to take this opportunity to provide the following comments on the subject proposal presented in 49 FR 39168, dated October 4, 1984 .
Based on a review of the subject proposal, C-E agrees with the proposed amendments to 10 CFR 34 . 2, "Definitions" and 10 CFR 34.43, "Radiation Surveys". In particular, the Staff should be co1T111ended for their reasonable approach to providing a practical solution for the location of radiation surveys.
C-E, however, feels that the proposed amendment to 10 CFR 34 . 11, "Issuance of Specific Licenses for Use of Sealed Sources in Radiography", which requires an evaluation of each radiographer and radiographer's assistant every three months, is excessive and unnecessary . The current regulations , which provide the opportunity to randomly select and eva l uate a radiographer(s) ~tan interval not to exceed three months, prevent the process from becoming too routine and better preserve the intent of the audit . The requirements for qualifying radiographic personnel, and the annual review of the regulatory requirements with all radiographic personnel, are believed to be sufficient for ensuring that radiographic personnel are properly trained and knowledgeable .
It is agreed that an in-house inspection of radiographic personnel should be conducted to assure that improper work practices are el iminated; however, the intent of an in-house inspection program is to establish an awareness with the radiographic personnel that such an inspection may occur and include them at
~ time. The current inspection of at least one radiographer every three months should be sufficient to ensure that radiographic personnel are following applicable requirements, including operating and emergency procedures . The implementation of this proposed amendment would also impose a significant and unnecessary cost increase on the current in-house inspection program.
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Secretary of the Commission LD-84-066 November 19, 1984 Page 2 Combustion Engineering appreciates the opportunity to comment on the proposed rulemaking. If we can provide any additional information on this subject, please feel free to contact me or Mrs. R. O. Hoogewerff of my staff at (203) 285-5217.
Very truly yours, COMBUSTION ENGINEERING, INC.
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Director Nuclear Licensing AES:las
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{'-4-9/;/G J 9/~~ {.!.};V AirTransport Association ata oF AME;RICA 1709 New York A,.y~11L!~, NW Washington, D C ~ 1** A10 :JQ Phone (202) 626-4000 November 19, 1984 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch
Subject:
Industrial Radiography Surveys and Licensee's Performance Inspection Program - Proposed Rule Gentlemen, The attached letter from member operator, Northwest Orient, is submitted to you in response to your request for comments on the subject. This letter was received after we sent you a letter, dated 11/16/84, which was based on ATA member responses received earlier.
Your consideration of Northwest Orient's comments in addition to our comments of our Nov. 16, 1984 letter is appreciated.
Sincerely, V. w. Ballenger Director Engineering & Maintenance DWL:nam Attachment
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NO R THWEST AIRLINES, INC.
MINNEAPOI.IS-ST. PAUi. INTERNATIONAi. A I RPORT ST. PAUL, MINNESOTA 55111 BEN H . LIGH TF" OOT, J R .
V I C£ PRESIDENT, MAINTENANCE ANO ENG I NEERING November 12, 1984 Air Transport Association of America 1709 New York Avenue, NW Washington, DC 20006 Attention: Mr. D. W. Lotterer
Subject:
Industrial Radiography Radiation Surveys - Proposed Rule
Reference:
Gentlemen:
(.a} ATA Memorandum to Engineering &Maintenance Executives No.84-113 While we don't voice vigorous objection to the proposal for an additional radiation survey at time of storage, we do feel it to be unnecessary--in our operation. We fail to see how the source could shift to an unshielded position with the safety plug installed. We believe the last-use survey assures that the source is properly located in the projector at time of storage. Additionally we see no value in ascertaining source decay data at time of storage. The use of the survey meter throughout the radiographic operation and storage process satisfies instrument operability objectives.
Additionally, we don't see the need for a program to ensure that each indi-vidual radiographer and radiographer's assistant is complying with appli-cable regulatory requirements and operating and emergency procedures. We have a smal l , stable staff of radiographers who are evaluated every three months per the existing regulation (34.ll(d)). Perhaps larger organizations with high turnover of radiographers and radiographers assistants need a program to evaluate their performance, but we don't. We propose that any licensee with a stable staff of six or less r~diographers and assistant radiographers not be required to submit an inspection program as proposed.
Very truly yours,
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- E LD-84-O66 DOt-KE r1t1G & SEwVfC BRANCH
- etary of the Commtsston J
- Nucli:ar Regulatory Co1nr1tsston
~ashington. o.c. 20555 Subj~ct: C01rtl'1ents on NRC Proposed Rufo for Industrial Radiogri:tphy R~d at1o S.ir, *. s and Ltcensee's Pl:!rformanc~ Insp~ction Program
- Combust,0,1 Fngineerrng ~C-E) would l 1ke to take this opportunity to pro, f~14- the:
following comments en tne subj~ct proposal pr~sent~d in 49 FR 3916Bt date~
October~. 1984.
B~sed on a r~vtew of the subject proposalt C-E agrees with th~ proposvct arrie11dmlints ta to '7FR 34.2, "Definitions" and 10 CFR 34.43, '1R11ctiatio 1 1 Surveys. In par-ticulart the Staff sho111d be commended for thei r ri:t son,1bie approach to providing a practical solutton for t~e locatton of r~diation surv~ys.
C-~. llm~~l/er, fee1s tht1t the proposed drn~nlinent. to 10 CFR 34.11 '*tssuwc:e of Spectf1c Licenses for Use o~ Sealed Sources tn Padiog~ phy~ hh1ch reqJ1res d evalud" t., ad1 '"dph dnd rad1ogrt1[) e,.*s as ~tant i:>v~ry hrt>r-!
r" nt 'Hr,t .. The current ri:!gulati0t1S, ~,h1ch provfd ct ~nd evaluate a racttograph~ r(s) at an A ths, preverit the orocess from bt~com1n~ ... oo
- e intent of th~ ~ua t. he uir~m~nts for qud ,,ng radiographic personnel, dnd the annu ~v1ah ~ regulat r.
requ1ren~~ti with dll rad1ograph1c p~rsann~l. u ,~*~ ~ suffic it for ens.trtng th t radfographic persunne1 are propt:!r l.>' ::1 d.i i-;_no ,~.1gl!i.tb1 e.
I * ~grLed that an tn-house tnsp~ction of radiogrd~ )ersonn~l should be co ucted to assure that lnproper work practices are ijlt ~in ated; how0v~r, the intent of an in-house inspection program is to est~blish dn aw~r~n~ss wi:h th~
r,,diographic personnel thdt such an 1nsp,~c ;on 1flay occur dnd inc:Tude t~c>n at
~ tim~. ThP. curr~nt i11spttctian of at leci. t orir~ radio9ri1ph@r j;!'H*!ry tl\litt~
months should be sufficient to ensure that radiographic personn~l are following applir.-\'1<? requit~rnents, tnclud11,g operating dnd ~ri~rgenc.y proced 1Jr~s~ Tile tmpl tati'~ of this proposed amendm~nt would ~lso impose a sig,ificant and unnt ry cost 1ncreJse on th~ curr~nt in-house insp~ction program.
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Secretdry of the Comm1ssion L0-84-066 November 19. 1984 Page 2 Combustion Engi nel!ri n~ appr!!ci dtl."S th!:! oppurtun; ty to comment on the proposed rulf:!mi,king. If we can provtde <1ny additional informatio1, on this subject, please fo~l free to contdct m~ or Mf"S. R. 0. Houg~w~rff of my staff r,t {203) 205-5217.
v~ry truly yourst COMBUSTION ENGINEERING. tNC,.
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BRA_NCH suBJEcT, Guide for the Preparation of Applications for the Use of-Sealed Sources and Devices for Performing Industrial Radiography, Task FC 401-4, October 1984 TO :
U.S. Nuclear Regulatory Commission ATTN: Docketing and Services Branch Washington, D.C. 20555
- 1. Subject document has been reviewed and the following comments are provided:
- a. Page 5, Item 5: Replace "Because of the large area that requires surveillance *** " with "Because of the high intensity of the sources *** " for clarification.
- b. Page 6, Item 7: Nonconcur with not giving at least some credit to the performance of radiography with x-ray devices. The fundamentals of area surveys, radiation protection measures, ALARA, biological effects, etc, are the same for an x-ray or an isotopic device. Such previous training would only need be supplemented with training specific to isotopic radiography devices. The current requirement imposes an unnecessary cost for additional training to achieve the same knowledge. Further, the capabilities of an individual will be evaluated under the self-inspection program.
- c. Page 7, Item 8: Paragraphs 1-7 are currently confusing and appear to be the same thing. Recommend condensing requirements into a single para-graph.
- d. Page 8, Item 8, 7: Comment as noted in paragraph l.b. above.
- e. Page 9, 8.1: Eliminate the last sentence in the last paragraph since it is redundant.
- f. Page 9, 8.2: Clarification should be made as to the intent of "the art of radiography." It is assumed that this refers to the actual evalu-ation of radiographic films.
- g. Page 10, 8.2: Current NRC policy is that the designated radiation protection officer should have training and experience commensurate with the proposed use (i.e., be a radiographer). The requirement to have know-ledge beyond that given in radiograpy courses implies the radiation protection officer must also have training in health physics, etc. The rationale for this requirement deserves further explanation.
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- h. Page 11, Item 9, 1: Clarification should be made as to the intent of "the nature of the areas" surrounding a radiography facility. It is assumed that a description of adjacent areas, identifying unrestricted areas and/or type of use, is being requested.
- i. Page 11, Item 9, 3: Establishment of a 2 mR/hour limit for unrestricted areas does not allow for operational differences nor does it correlate with the requirement of 10CFR20.105 unless continuous operation is assumed. Recommend that this requirement include such factors as workload; occupancy factors, etc, utilized in the NCRP recommendations on shielding to achieve the permissible levels of radiation in unrestricted areas specified in 10CFR20.105.
- j. Page 14, 10.3: The current internal inspection requirement implies that smaller radiographic operations employing only one or two individuals must make provisions for an outside agency to perform the evaluations of radiographers/assistants and to avoid conflict of interest. Further, those qualified radiographers performing such evaluations must be continually involved in radiographic operations to maintain currency and also be subject to the 90 day evaluations. A "Catch-22" is apparent as is the potential conflict of interest. If the intent of the NRC is to enhance radiation safety through independent evaluation of radiographer/assistants, recommend that consideration be given to the NRC providing such services.
- k. Page 15, Exhibit 1: The questions 1 and 2 of the checklist should be revised to include film badges, thermoluminescent dosimeters (TLD's), and pocket dosimeters.
- 1. Page 18, 10.4.3: Comments as noted in paragraph l.j. above.
- m. Page 19, 10.4.4: Change the last sentence of the third paragraph to read "A physical survey should be performed to confirm that the area around the storage facility meets the requirements for an unrestricted area."
- n. Page 21, 10.4.7: The requirement for training using dummy sources should be included in the training section (page 6, Item 8).
- p. Page 25, Exhibit 2, c: Delete the last sentence of the first paragraph and insert "A survey meter should be placed adjacent to the projector so that exposure readings may be observed."
- 2. Any questions regarding these comments should be directed to the under-
~------....d at (512)536-3331.
~4.u~sc Executive Secretary, USAF RaVo'is~tope Committee Office of the Surgeon General 2
Air Transporf =As..,s ociation ata ~~Off ,'AMERICA
.., * , .' L P12 :05 1709 New york ~"'edl'.lbUe~ o5 Washington, DC 2 O 6 Phone (202) 626-4000 Novembe *- lifi.,1 1984,./ ~ 1 1
-~ . CI Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch
Subject:
Industrial Radiography Radiation Surveys and Licensee's Performance Inspection Program - Proposed Rule Gentlemen, On behalf of its member airline operators, the ATA offers the following comments on the subject:
The proposed revision to §34.11 paragraph (d) should not specify that a licensee has to evaluate the performance of each radiographer and each assistant every 3 months. If there is a need to specify a time interval for such evaluation then the time interval should spe-cify a period of reasonable length such as one year, but certainly not less than 6 months.
The author of the proposed rule has not indicated a need to make the existing rule more restrictive but instead indicates that a quarterly performance inspection of radiographers is already required. Several of our members indicated that they now conduct random spot checks every quarter. The proposed rules are different than these spot checks and other programs that are now being administered because they will impose additional administrative and economic burdens on the licensees.
Without a showing that the existing programs are unsafe, it is difficu l t to understand why the proposed rule change to §34.ll(d) is necessary.
Your consideration of our comments is appreciated.
Sincerely, V. W. Ballenger Director Engineering &Maintenance OWL: nam
U.S. NU LEAR R COM/t.lSSIOM DOCKETING P. '
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- GOC ~ TING c'.. Sc:.KVI* ' t'J't:!tJ BRANCH BRANCH U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch
Subject:
10CFR Part 34, Proposed Rule - Vo l. 49, No. 184, Issued October 4, 1984 Secretary:
As a Byproduct Material Li cense holder and a subscriber to Title 10 Code of Federal Regu l ations, Bulletins, and Notices, Reactor Controls, Inc. (RCI) has historically responded positively to concerns expressed informally, or in writing, by official communications from State or Federal agencies regarding the safe execution of industrial radiographic operations or handling of radio-active materials.
RCI has, as with industry as a whole, grown and matured with respect to full recognition of the absolute necessity to conduct industrial radiography in the safest and most secure manner possible.
It is fully understood and accepted that the mere implementation of safety regulations and guidelines to the letter of a Code does not necessarily guar-antee employee or radiographer expertise or freedom from excessive ionizing radiation. Thus, th)e real requirement is that decisions be made based on existing regulations and good sound judgement and practice. The need to revise 10CFR Part 34 is questioned, especial l y with short notice, it appears as if a high degree of urgency exists.
10CFR Part 34.21 currently provides for permissable levels of radiation for exposure and storage devices. The manner in which licensees achieve minimum levels of radiation at storage facilities and equipment is not so important.
It is important that minimum levels be achieved at any cost. This regulation exists, and enforcement should be carri ed out, with penalties to organizations that forsake safety for expediency, or are just simply not informed and con-vinced of the potential personal hazards of improperly stored/shielded radio-active material. Similarly, the requirements exists for each license, to insure that only trained and qualified persons perform radiography. As the proposed rule indicates, the existing required internal inspection plan should provide for detection of variances from acceptable operational practices and procedures. Additionally, these inspections should evaluate ongoing training of radiography personnel.
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U.S. NUCLEAR R"GUt TORY COMMISSfOISI DOCKFTlt-'G I', SE VICE SECTION OFF ~ - fHE S , T'.PY V Tl Postmark Date Copies cc Add'I C ,..,
Speci I Disrr '
U.S. Nuclear Regulatory Commission RCI November 15, 1984 Page 2 Another rule will not necessarily cause those organizations who operate on tight budgets or without highly qualified personnel to take precautions (required or not) to prevent overexposure. Licensees who have traditionally upheld and enforced the regulations and good practice to insure minimal ex-
- posure will simply have to undergo another round of amendments to their Byproduct Material Licenses and be subject to more scrutiny as a result of a few organizations who have not accepted the responsibility to implement existing regulations.
Recommendation: As violations and overexposures occur, determine the root cause. If the overexposures are of a trend type nationally, not unique to a specific type storage or exposure device, then some form of a revision to 10CFR 34 may be in order. If however, the overexposures are unique to a specific storage/exposure device, then the rule would apply to those license holders of that type of equipment, others would be exempt. Unless the problem is truly generic, nationwide, it would appear unnecessary to issue more and more regulations without adequate justification.
REACTOR CONTROLS, INC.
~~~-'
Bob Surratt Q.C. Manager BS:jw
..., . 1 9 P\2 :Q3 STATE OF ILLINOIS DEPARTMENT OF NUCLEAR Si\~~T! -G f'tEc. vi 1035 OUTER PARK DRIVE oocr E *~*RA~C~
SPRINGFIELD 62704 (217) 546-8100 DON ETCHISON TERRY R. LASH D IRECTOR November 14 , 1984 DEPUTY D IRECTOR Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- ATTN: Docketing and Service Branch Sir:
Please accept the following comments regarding a proposed change in 10CFR34 as published in the Federal Register, Vol. 49 , No. 194, dated October 4, 1984.
This agency agrees that 10CFR34.43 should be amended to require a radiation sur-vey of any portable radiography device at any time the device is put into storage.
We agree that such survey should encompass the entire circumference of the radio-graphic exposure device and should include the source guide tube as appropriate.
A record of the time-of-storage survey should be made and maintained.
We do not agree that a quarterly review of the 'WOrk methods of every radiographer and radiographer ' s assistant should become a requirement of 10CFR34.ll(d). Annual refresher training and verification of competency seem adequate to maintain radio-graphers ' skills. In our opinion, a quarterly procedural examination is not a reasonably achievable component of a cost effective internal inspection system.
Maur Ne weg, Manager Office of Radiation Safety MN/mfm
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LAW ENGINEERING ~.-tlNG COMPANY geotechnical, envronmental & const/.u¢ ~ materials consultants 1140 HAMMOND DRIVE, N.E.
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- ATLANTA, GEORGIA30356-0013 (404) 396-8000 *3
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BRANCH Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch Gentlemen:
This is in response to a proposed revision to 10CFR34 as pub-1 ished in the Federal Register, Thursday, October 4, 1984. We received the NRC mailout on November 13, 1984 and hope that our comments can be formally included, despite the Sunday, November 18, 1984 deadline.
There are specific situations where the proposed performance inspection of radiographers and radiographers' assistants would be extremely costly to implement. An example would be where a radiographer or radiographers' assistant, either of whom has not performed radiography for a period of three months, is sent to a remote location (often 200-300 miles) from the office to perform radiography. This situation commonly occurs when radiographers have other duties such as other NDT work.
The proposed amendment would require that another individual accompany the radiographer and radiographers' assistant just to perform an inspection. The cost of this would be exorbitant and, we feel, would provide very little increased assurance of safety of the operation.
Further, based upon the results of our inspections, the amendment to require that operation of each radiographer and radiographers' assistant be inspected every three months will do very little to increase safety.
Sincerely,
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By-product Materials Licensing Coordinator
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- M. Beck K. E. Roberts
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Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 Pl2 :oo Secretary of the Commission U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D.C. 20555
Dear Mr. Chil k:
Subject:
WASHINGTON PUBLIC POWER SUPPLY SYSTEM PROPOSED RULE, 10CFR34 - INDUSTRIAL RADIOGRAPHY RADIATION SURVEY ' S AND LICENSEE'S PERFORMANCE INSPECTION PROGRAM The subject proposed rule, which appeared in the Federal Register (Vol. 49, No. 184, Oct. 4, 1984) has been reviewed by the Washington Public Power Supply System.
We favor adoption of the proposed rule, which would require industrial radiography licensees to perfonn an additional survey of any radiography device at any time the device is put in storage and would change an existing record keeping requirement.
We appreciate the opportunity to review and comnent on proposed NRC rules prior to their adoption.
Very truly yours,
- ft G. C. Sorensen, Manager Regulatory Programs GCS/kd Acknowledged by carcf. ) /. ~ / °.+ ~~
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JEROME J. McGRATH
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- Street N W Wash,noton. D C 20036 I.,, - l JERRY T. VERKLER Se,ior v,ce President 1660 L Street. ~ W washington, o c 20035
' 4 DV 19 A11 :09 JOHN H. CHEATHAM, Ill Vic* President. General Counsel and Secretary 1660 L Street ~ W Washington D.C 20036 t..F I * .,
'.ice:: Tl.!G ,~ s J.B. HIPPLE November 16, 1984 3R NCH Treasurer PO. Box 252' Houston, Te,as 77252 EXECi.TIVE COMMITTEE PETER J, KING, JR.
Chairman of the Boa d PO Bo, 1087 Secretary Colorado Springs, Colorado B0944 U.S. Nuclear Regulatory Commission ROBERT C. THOMAS Vee Chairman Attn: Docketing and Service Branch P.O. Box 2511 1717 H Street, N.W. Houston, Texas 77001 Washington, D.C. 20555 I. DAVID BUFKIN PO. Box 252' Houston Te,as 77252 Re: Industrial Radiography Radiation Surveys and DAN DIEHSTBIER 2223 Dodge St,eet Licensee's Performance Inspection Program - Omalla, N~rasl<a 68102 Proposed Rule RICHARD S. MORRIS PO Box 1492 El Paso. Texas 79978
Dear Sir:
In response to the Notice, subject as above, which appeared in the Federal Register of Thursday, October 4, 1984, the Interstate Natural Gas Association of America {INGAA) wishes to provide the following comments.
INGAA is a non-profit national trade association representing virtually all of the major interstate natural gas transmission companies operating in the United States. INGAA's members operate over 200,000 miles of pipelines and related facilities, and account for over 90 percent of all natural gas transported and sold in interstate commerce. INGAA's members perform and contract for radiographic services during pipeline construction and maintenance and are, therefore, vitally interested in any regulatory activity which may affect those
- services or their construction programs.
INGAA concurs with the Nuclear Regulatory Commission's proposal to revise the "storage area" definition in 10 CFR Part 34 (§34.2) and the time-of-storage survey and recording procedures (§34.43). We believe the potential safety benefits of these changes far outweigh any minor increase in cost which may occur.
Although we also concur with the need for periodic inspections of radiographers and radiographers' assistants, we foresee implementation problems for the pipe-line industry. The nature of pipeline construction and maintenance operations may require radiographic teams to operate over a very large geographic area and outside normal working hours and days. This situation may create a signifi-cant problem for inspecting each radiographic worker "during an actual radio-graphic operation at intervals not to exceed three months11 (§34.ll(d)(l)) and "the next time the individual participates in a radiographic operation" (S34.ll(d)(2))
if he has not participated in a radiographic operation for more than three months lcdg dbycard .* //(.~/{t_
INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA 1660 L STREET, NORTHWEST, WASHINGTON, O.C. 20036-5611. TELEPHONE 202/293-!1770 f
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Add'I C Spec, ..i o*.,rb ,1,l
since the last inspection. These requirements could create scheduling problems for the inspector and the radiographic workers and could cause work delays, particularly during emergency repair work. We believe some flexibility in the inspection schedule is needed which could be provided by establishing a calendar quarter requirement in lieu of a three month requirement. Therefore, we recom-mend §34.ll(d)(l) and (2) be revised to read as follows (deletions bracketed and additions underlined):
§34.ll(d) 11 (1) Include observation of and recording of the performance of each radiographer and radiographer's assistant during an actual radiographic operation.Cat intervals not to exceed three months]
once each calendar quarter;
"(2) Provide that, if a radiographer and radiographer's assistant has not participated in a radiographic operation for more than
[three months] two consecutive calendar quarters since the last inspection, that individual's performance must be observed and recorded the next time the individual participates in a radiographic operation; and" INGAA believes the changes recommended above will provide the flexibility needed for inspecting radiographic operations which occur at remote and widely separated work sites and for observing workers who may not have been required to participate in a radiographic operation for some time. We think the two consecutive quarter nonperformance period is a more realistic and reasonable alternative.
We appreciate being given the opportunity to comment on this proposed rulemaking.
Sincerely,
- ~~or1:.k__
Vice Presid~~tstruction and Operations TLK/jda
MQITTON THIOKOL. INC.
Huntsville Division 84-10116 I
) '
U. S. Nuclear Regulatory Commission ...i.
1717 H Street, N. W.
Washington, D. C. 20555 Attention: Docketing and Service Branch
Subject:
Proposed Rules, 10CFR Part 34, Industrial Radiography Radiation Surveys and Licensee's Performance Inspection Program Gentlemen:
The Huntsville Division of Morton Thiokol currently conducts radio-graphic operations under License 01-00856-02, Amendment 27. This daily operation is conducted in two large bays that are locked after working hours. Once these doors are locked, the bays comply with your definition of 11 storage area 11
- Under the provisions of the new rule stated in Paragraph 34. 43(d),
the control cables and source tube must be disconnected, safety plugs installed and a survey conducted. It is believed that this rule imposes an unwarranted burden on a daily operation where the source is not actually moved to storage .
The proposed change in Paragraph 34. 11 i~onsidered unnecessary.
Evaluating the performance of a radiographer and radiographer's assistant 11 at intervals not to exceed 3 months" is too frequent. In our operation, first level supervision is present approximately 80%
of the time. The existing regulation is considered adequate.
Very truly yours,
¥9-. /1/.,.,,,,,,,,,,-
E. J. Magnusson, Chief Nondestructive Testing Section Testing Department EJM:rw Huntsville, Alabama 35807-750 1 (205) 882-8000
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PROPO~fD RULE _ --I, ~
DUKE POWER GOMPANY P.O. BOX 33180 C"'1-9 /:'£. ..59I t:,B)
CHARLOTTE, N,G, 28242 HAL B. TUCKER TELEPHONE VICE PRESIDENT (704) 373-4:"131 NUCLHAR PRODUCTION November 5, 1984 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Docketing and Service Branch
Subject:
Proposed Rule 10 CFR Part 34 Industrial Radiography Radiation Surveys and Licensee's Performance Inspection Program
Dear Sir:
The NRC requested in a Federal Register Notice dated October 4, 1984 (Vol. 49, No. 194 FR 39169 - 39171), comments on the subject proposed rule 10 CFR Part 34. In response, Duke Power Company offers the following for consideration.
10 CFR 34.11 Observation and recording of the performance of each radiographer and radiographers' assistant on a quarterly basis does not seem appropriate for radiography done under close scrutiny and controlled conditions, where these observations are now done every six months as required by the license. However, for remote field operations, unannounced observations and recording every six months, as well as spot checks, would appear to be appropriate for ensuring compliance with the regulations.
10 CFR 34.43 Most industrial radiographers actually make the proposed required survey as a routine matter. We do not object to the requirement to record this survey data on the utilization log. However, we feel that the requirement to survey after the last exposure should be left intact; i.e., recorded on the utilization log. Elimination of the recording requirement would provide temptation for personnel error and hence subject the radiographer and others to potential hazard while carrying the source from its last use to the storage location.
Your consideration of this matter is greatly appreciated.
If there are any questions or problems concerning this subject, please advise.
Very truly yours, Hal B. Tucker JWD:slb A~knowledzod by card . *. nltJ/.l!I~
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U. S. NUCLEAR REGULATORY COMMISSION, DOCKETING & SERVICE BRANCH OFFICE OF THE SE RETAR Y OF I It: COi I !.~ ... I J ~
I
Secretary of the Commission November 5, 1984 Page Two bee: K. s. Canady N. A. Rutherford J. s. Warren R. L. Gill R. o. Sharpe P. F. Guill L. Lewis R. T. Bond C. L. Hartzell T. L. McConnell Group File: GS-811.02
UNIVERSAL TECHNICAL TESTING LABORATORIES, INC.
Post Office Box 372, Collingdale, Pa. 19023 Phone (215) 586-3070 Woodlawn & North, Collingdale, Pa. Folcroft East Business Park, Sharon Hill, Pa.
November 5, 1984 Secretary U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Docketing and Service Branch Re: PROPOSED RULE MAKI NG 11 PERFORMANCE INSPECT I ON OF RADIOGRAPHERS AND RADIOGRAPHER'S ASSISTANTS 11 Gentlemen:
Once again the commission is ignoring the most obvious solution b the problem of safety in industrial radiography, and that is the use of the two-man crew. Instead, the commission insists on increasing the various layers of management checks and counter-checks without any reasonable affect on safety.
Now the commission wants each technician to be audited four times a year and as currently interpreted by Region I inspection personnel, this should be under field conditions.
With a work force of 11 radiographers, the company would have to dedicate over one month of a manager's time to these audits without any reasonable affect on safety.
We protest this additional burden.
Sincerely,
~ ~STING LABS, INC.
Michael C. Modes Executive Vice-President MCM:emm
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) fJrU.,tD RULE l DEPARTMENT OF THE AIR FORCE (-"17'-H-~- ~9//,8)
HEADQUARTERS UNITED STATES AIR FORCE BOLLING AFB, D .C. 20332 REPLY TO AFMsc?GPA ATTN OF: BROOKS AFB TEXAS 78235 suBJECT, Industrial Radiograµ,y Radiation surveys and Licensee's Performancfi! Inspect...
ion Program (Reference 49FR194)
TO:
US Nuclear Regulatory Corrmission ATTN: Docketing and Services Branch Washington D.C. 20555
- 1. The proposed rule change to radiographic operations (49FR194) has been reviewed and the following corrments are provided:
- a. Additional clarification is needed in defining who will be responsible for evaluating radiographer/radiographer assistant performance and the reauired qualifications of that individual. A potential conflict of interest is created, particularly if the individual reviewer is also reauired to perfonn radiograµ,ic operations. The proposed rule should define acceptable options.
- b. In conjunction with the proposed rvle, recorrmend that 10CFR34.22 also be amended to provide a specific reouirement to lock exposure devices or containers for transportation purposes. As currently written, an exposure device could be transported in a "secured" position if under the direct surveillance of a radiograµ,er or radiograµ,er ' s assistant.
- 2. Any questions regarding the above co1M1ents should be directed to the undersign~d at (512)536-3331.
~ ~/
- J ,,,-
LANCE? BOLLINGER, *capt, USAF: isc Secretary, USAF Radioisotope Committee Office of the surgeon General Acknowledge
U.S.
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DOCKETED .._. e.__
USN C ..!.J0 NUCLEAR REGULATORY COMMISSION
~ OCT -1 P4 :09 10 CFR Part 34 ff1c:.* OF s* CR t* .
Industrial Radiography Radiation Surveys D,;r 1~,:rr*1'.i i su, i ~
and Licensee's Performance Inspection Program i PAl,C*
AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission is proposing to amend its regulations that apply to industrial radiography. The proposed rule would require industrial radiography licensees to perform an additional survey of any radiography device at any time the device is put into stor-age, and would change an existing recordkeeping requirement. Currently, each licensee must record the required survey of the device made after the last exposure before storage. The proposed rule deletes this record-keeping requirement and substitutes *a requirement that a record of the new storage survey be maintained. The proposed rule would also require that each license application describe the program the licensee will use to evaluate the performance of each radiographer and radiographer's ass ist-ant at intervals not exceeding 3 months to ensure that they are following the Commission 1 s regulatory requirements and the l icensee's operating and emergency procedures when performing radiography. This action is intended to provide additional assurance that radiographic operations are conducted safely.
DATE: Submit comments by November 18, 1984.
Comments received after this date will be con-sidered if it is practical to do so, but assurance of consideration can-not be given except as to comments received on or before this date.
ADDRESSES: Send comments to: Secretary, U.S. Nuclear Regulatory Commis-sion, Washington, DC 20555, ATTN: Docketing and Service Branch. Hand deliver comments to: Room 1121 , 1717 H Street NW., Washington, DC, 1
[7590-01]
between 8:15 a.m. and 5:00 p.m . Examine comments received and the regu-latory analysis at: NRC Public Document Room, 1717 H Street NW.,
Washington, DC. Obtain regulatory analysis (single copy) from: Donald 0.
Nellis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301)427-4588.
FOR FURTHER INFORMATION CONTACT : Donald 0 . Nellis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone _(301)427-4588.
SUPPLEMENTARY INFORMATION: The Nuclear Regulatory Commission is consider-ing three amendments to its regu l ations pertaining to industrial radio-graphy. One amendment would require licensees to perform an additional radiation survey of the radiographic exposure device at the time of stor-age, delete an existing requirement to record the radiation survey made of the device immediate ly after the last exposure prior to storage, and add a requirement to make and mainta i n a record of the storage survey.
This amendment to§ 34.43 wou ld provide a method of ensuring that the sealed source is in the proper position within the device when the dev i ce is stored. The second amendment would revise§ 34.ll(d) to spec i fy that each license application must describe a program by which the licensee will evaluate the performance of each radiographer and radiographer's assistant at intervals not exceeding 3 months. This *amendment would clarify the requirements for the description of the in-house inspection program that the applicant must provide in the license application . The third amendment provides a definition of sto rage area" in§ 34.2,
Definitions". This definition is provided so that it is clear at what locat ions the storage survey is to be made. Interested persons are invited to comment on any or all of the proposed amendments.
Radiation Survey and Record The Commission received a petition for rulemaking, assigned Docket No. PRM-34-3, from the Chicago Bridge and Iron Company. The Commission requested comments on the petition in the Federa l Register on November 23, 1982 (47 FR 52722). As discussed below, this proposed rule would in
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effect grant the petition. The petitioner suggested an amendment of 10 CFR 34.43(c) that would require that each licensee survey a radio-graphic exposure device when it is placed in storage. This survey would be made using a radiation survey instrument at a point on the surface of the device specified by the licensee in its operating procedures. This last survey would occur at or near the place of storage, and would pro-vide a record showing that the radiographic exposure device had been stored with the sealed source in a safe location within the device.
Under the c4rrent regulations, § 34.43(b) requires that, after each radiographic exposure, the radiographer ,perform a radiation survey of the radiographic device to ensure that the sealed source has been returned to its shielded position. Paragraph (c) of§ 34.43 requires that the radiographer record the results of the survey following the last radio-graphic exposure made before locking the device and ending direct surveil-lance of the operation. This survey is made where the device is last used before storage. The licensee must keep a record of the survey for 2 years.
The petitioner contends that because no check of the sealed source position is required, the current regulation does not ensure safe storage of the sealed source in the radiographic device, yields equivocal records, and is inconvenient. More specifically, the petitioner contends that the device may be subject to rough handling when being moved under field conditions from the area of use to the area of storage. If the source were dislodged during the movement to the storage area, the radiographer might store the device with the sealed source outside of its proper location within* the device. The petitioner contends that, by requiring that the radiographer make the final survey at the time of storage and at a point on the device specified by the licensee in its operating procedures, the recorded exposure rate would provide unequivocal assurance that the source was properly located within the device, and would also provide a check on the decay of the sealed source and the constancy of the survey instrument.
The petitioner also contends that it is easier to record the survey data at the location of storage than at the location ~fuse because of weather and work conditions that are encountered in field radiography.
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The Commission received one telephone and three written comments on the petition. Three commenters concurred completely with the petition.
One* commenter said that the survey should be made at the sealed source outlet port with the safety plug installed. One commenter said that licensees shou l d not be required to submit modified procedures for review unt il it was time for them to re new t heir licenses.
The petitioner's suggested amendment would eliminate the requirement that the last- use survey be recorded, and put in its place a requirement that a time-of-storage survey be made and recorded. Although the Commis-
- sion is aware of only one overexposure that was caused by failure of the locking mechanism (NUREG/BR-0024, p. 153, case 46 1 ) followed by moving the radiographic device, several incidents have been observed where radio-graphic devices were stored with the source in an unshielded position caused by failure to lock the mechanism. The probability of occurrence and the consequences of this type of event seem to be of sufficient magni-tude to justify the time-of-storage survey requirement suggested by the petitioner. In addition it is considered to be a good safety practice to survey at the time of storage, and many radiographers include this survey in their routine procedures. Therefore, the Commission agrees that it is desirable to require that the time- of-storage survey be made and recorded. However, this would not relieve licensees from requiring that radiographers make a survey immediately after the last exposure and before tra nsport to the place of storage, although no record of the last use survey would be required.
The Commission also agrees that the measurement of the exposure rate at a point on the surface of a device, during the storage survey, would provide additional assurance that the sealed source was properly stored within the device as well as data on source decay and instrument opera-bility useful to both the licensee and NRC inspectors. However, storage survey procedures should also be consistent with the survey procedure required after each exposure. Therefore, the proposed amendment would require that the time-of-storage survey be made around the entire circum-ference of the radiographic exposure device, consistent with existing 1Copies of NUREG/BR-0024 may be obtained from the GPO Sales Program, Division of Technical Information and Document Control, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301)492-7333.
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survey procedures (10 CFR 34.43(b)), and that the surv ey include a measurement of the radiation exposure rate at the source outlet port with the safety plug installed, as recommended by one commenter.
A record of the time-of-storage survey result would provide assur-ance to the Commission that the radiographer had surveyed the device after the last exposure. The Commission agrees that it may be more convenient to record the results of a survey taken at the location of storage than one taken in the field, and that this storage survey record may be more impo~tant to safety.
Since the time-of-storage survey and record procedure are similar to the currently required last-use survey and record procedure, l icensees would not be required to submit modified procedures for review. If the Commission implements the proposed rule, a copy will be sent t o each licensee. A cover letter will inform the licensee that the new survey and record method should be used and that a license amendment need not be requested.
Performance Inspection of Radiographers and Radiographers' Ass istants In order to receive a specific license for radiography, t he appli-cant presently must have an in-house inspection program to ens ure that radiographers and radiographers' assistants are following NRC regulatory requirements and the licensee's operating and emergency proced ures. The in-house inspection must be conducted by the licensee every 3 months.
This requirement was intended to be explicit in§ 34.ll(d) of the Commission's rules.
The Commission intends that the applicant describe in the license application the program that will be used to inspect the work methods of each radiographer and radiographer's assistant during an actual radio-graphic operation to ensure that each individual is following applicable regulatory requirements and operating and emergency procedures. Each inspection would be conducted by having an individual who knows the applicable requirements and procedures observe each worker dur ing an actual radiographic exposure to ensure that each worker is fol lowing the requirements and procedures. The proposed rule clarifies this require-ment. Some license applicants and licensees believe that a sy stem of 5
[7590-01]
spot checks of some radiographers and radiographers ' assistants is suffi-cient to meet the requirement of existing regulation. The Commission does not agree that a system of spot checks is adeq uate to provide assur-ance that radiographers are working safely. The Commission is proposing that the regulation be revised to specify that a de scription of the inspec-tion program be included in license applications an d that the inspection program provide for the inspection of the work methods of each radiographer and radiographer's assistant actively engaged in radiography, at intervals not to exceed 3 months. If a radiographer has not participated in a radiographic operation for more than three months, the rule provides that individual's performance will be observed and record ed the next time he or she participates in a radiographic operation.
ENVIRONMENTAL IMPACT: CATEGORICAL EXCLUSION The NRC has determined that this proposed regulation is the type of action described in categorical exclusion 10 CFR 51.22(c)(3)(i) and (i ii) .
Therefore, neither an environmental *impact statement nor an environmen tal assessment has been prepared for this proposed regulation.
PAPERWORK REDUCTION ACT STATEMENT This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act (44 U.S.C. 3051 et seq.).
This rule has been submitted to the Office of Management and Budget fo r review and approval of the paperwork requirements as part of the 1983 renewal for 10 CFR Part 34. Approval of the paperwork requirement was granted 08/10/83, 0MB No. 3150-0007.
REGULATORY ANALYSIS The Commission has prepared a regulatory analysis on this proposed regulation. This analysis examines the costs and benefits of the alternatives considered. The analysis is available for inspection in the Public Document Room, 1717 H Street NW., Washington, DC. Single 6
[7590-01]
copies of the analysis may be obtained from Donald 0. Nellis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301)427-4588.
Public comment on the analysis is requested. Comments may be sub-mitted to the NRC as indicated under the ADDRESSES heading.
REGULATORY FLEXIBILITY CERTIFICATION As required _by the Regulatory Flexibility Act of 1980, 5 U.S.C.
605(b), the Commission certifies that th~s rule, if adopted, will not have a significant economic impact on a substantial number of small entities. The NRC has currently issued 369 licenses for the performance of industrial radiography that would be affected by this proposed rule.
Although a substantial number of these licensees would be considered small entities, the proposed requirements are not expected to have a significant economic impact on these licensees.
The proposed radiation survey and record amendment requires an addi-tional survey upon storage of the radiographic device, which is considered a minimal regulatory burden. The amendment substitutes a storage survey record requirement for the *currently required last use survey record, which imposes no additional regulatory burden. The quarterly performance inspection of each radiographer and radiographer's assistant is already required of license applicants. The proposed rule c}arifies what informa-tion must be submitted with a license application.
The additional time-of-storage survey is estimated to cost about
$150.00 per radiographer per year. This is based on each radiographer working 250 days each year, at two locations each day, an estimate that it takes about 0.01 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to complete a storage survey, and that the hourly wage for the average radiographer, plus overhead, is $30.00. Each survey can be estimated to cost approximately 30 cents. The benefit of this additional survey requirement is significantly increased assurance that radiographic sources are safety stored in the shielded position.
Since the quarterly performance inspection ?f radiographers is already required by license condition, there will be no new or additional burden on NRC licensees. The total cost of the quarterly performance inspection 7
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program, whether required by license condition or regulation, is about
$120 per worker each year, assuming each inspection takes one-half hour of worker time and one-half hour of inspector time.
The NRC does not believe these costs constitute a significant eco-nomic impact on small entities. However, the Commission is seeking com-ments and suggested modifications, especially from small entities, because of the widely differing conditions under which many licensees operate.
Any small entity subject to this regulation which determines that, because of its size, it is likely to bear a disproportionate adverse economic impact should notify the Commi~sion of this in a comment that indicates the following:
(a) The licensee's size in terms of annual income or revenue and number of employees; (b) How the proposed regulation would result in a significant economic burden upon the licensee as compared to that on a large licensee; (c) How the proposed regulations could be modified to take into account the licensee's differing needs or capabilities; and (d) Whether the assumptions that a radiographer works an average of two locations a day and that a radiation survey takes about 0.01 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to complete accurately reflect the licensees' actual work experience.
LIST OF SUBJECTS IN 10 CFR PART 34 Packaging and containers, Penalty, Radiation protection, Radiography, Reporting and recordkeeping requirements, Scientific equipment, Security measures.
For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Part 34.
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PART 34 - LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS
- 1. The authority citation for Part 34 is revised to read as follows:
AUTHORITY: Secs. 81, 161, 182, 183, 68 Stat. 935, 948, 953, 954, as amended (42 U.S.C. 2111, 2201, 2232, 2233); sec. 201, 88 Stat. 1242, as amended (42 U.S.C. 5841).
Section 34.32 al~o issued under sec. 206, 88 Stat. 1246 (42 U.S.C.
5846).
For the purposes of sec. 223, 68 St~t. 958, as amended (42 U.S.C.
2273); §§ 34.22, 34.23, 34.24, 34.25(a), (b) and (d), 34.28, 34.29, 34.31(a) and (b), 34.32, 34.33(a), (c) and (d), 34.41, 34.42, 34.43(a),
(b) and (c) and 34.44 are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); and§§ 34.ll(d), 34.25(c) and (d), 34.26, 34.27, 34.28(b), 34.29(c), 34.31(c), 34.33(b) and (e) and 34.43(d) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(0)).
- 2. Remove the authority citations following§§ 34.2, 34.11, 34.22, 34.28, 34.29, 34.31, 34.32, 34.33, 34.43, 34.44, 34.51, and Appendix A.
- 3. In§ 34.2, paragraphs (g) and (h) are redesignated as paragraphs (h) and (i), and a new paragraph (g) i~ added to read as follows:
§ 34.2 Definitions 11 (g) Storage area means any location, facility, or special vehicle 11 at or in which a radiographic exposure device or storage container is secured, when not in use, by lock or physical barrier so as to prevent accidental exposure, tampering with or unauthorized removal of the device.
- 4. In§ 34.11, paragraph (d) is revised to read as follows:
§ 34.11 Issuance of specific licenses for use of sealed sources in radiography.
(d) The applicant has established and submits a description of an in-house inspection program adequate to ensure that t -h~ Commission's 9
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regu l atory requirements and the applicant's operating and emergency proce-dures are fo l lowed by radiographers and radiographers' assistants. The inspection program must:
(1) Include observation of and recording of the performance of each radiographer and radiographer's assistant during an actual radiographic operation at intervals not to exceed three months; (2) Provide that, if a radiographer or a radiographer's assistant has not participated Jn a radiographic operati on for more than three months since the l ast i~spection, that indiv i dua l 's performance must be observed and recorded the next time the individua l participates in a radiographic operation; and (3) Include retention of inspection records for two years on performance of radiographers or radiographers' assistants.
- 5. Section 34.43 is revised to read as follows:
§ 34 . 43 Rad i ation surveys.
(a) The licensee shall ensure that at l east one ca l ibrated and operable radiation survey instrument is availabl e at the location of radiographic operations whenever radiographic operations are being per-formed, and at the storage area as defined in§ 34.2(g) whenever a radio-graphic exposure device is being placed in storage.
(b) The licensee shall ensure that a survey with a calibrated and operable radiation survey instrument is made after each exposure to deter-mine that the sealed source has been returned to its shielded position .
The entire circumference of the radiographic exposure device must be surveyed . If the radiographic exposure device has a source guide tube, the survey must include the guide tube.
(c) The licensee shall ensure that a survey with a calibrated and operable rad i ation survey instrument is made at the time a radiographic exposure device is placed in a storage area to determine that the sealed source i s in i ts shielded position . The entire circumference of the radio-graphic exposure device must be surveyed. In addition, for devices having a source outlet port, a measurement of the radiation exposure rate at this outlet port, with the sa fety plug installed, must be taken.
[7590-01]
(d) The licensee shall ensure that a record of the survey required in paragraph (c), includ ing the measurement of the radiation exposure rate at the source outlet port, with the safety plug installed, is made and is maintained for two years. (J-o-Dated at Bethesda, Maryland, this').. 7 day of ~ , 1984.
For the Nuclear Regulatory Commission .
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Executive Director for Operations.
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