ML20137Q705

Comments on Proposed Rule 10CFR35 & Reg Guide 10.8.Assurance of Training Adequacy Must Be Provided.Revs to Other NRC Regulations Allowing Nonaccredited Instruction Might Be Considered Separately

ML20137Q705
Person / Time
Issue date:	03/19/1984
From:	Jupiter C NRC
To:	Cunningham R NRC
Shared Package
ML20136D915	List: ML20136D909 ML20136E266 ML20136E272 ML20136E278 ML20136E295 ML20136E318 ML20136E323 ML20136E492 ML20136E705 ML20136E879 ML20136F099 ML20136F109 ML20136F154 ML20137Q526 ML20137Q531 ML20137Q538 ML20137Q545 ML20137Q557 ML20137Q566 ML20137Q572 ML20137Q579 ML20137Q585 ML20137Q596 ML20137Q605 ML20137Q644 ML20137Q655 ML20137Q660 ML20137Q671 ML20137Q682 ML20137Q688 ML20137Q690 ML20137Q692 ML20137Q695 ML20137Q697 ML20137Q705 ML20137Q710 ML20137Q715 ML20137Q719 ML20137Q721 ML20137Q724 ML20137Q726 ML20137Q734 ML20137Q742 ML20137Q747 ML20137Q760 ML20137Q766 ML20137Q777 ML20137Q783 ML20137Q791 ML20137Q796 ... further results
References
FRN-50FR30616, RTR-REGGD-10.008, RULE-PR-35 AA73-1, NUDOCS 8509230221
Download: ML20137Q705 (2)

Text

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o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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MEMORANDUM FOR: Richard E. Cunningha o re FROM: Clyde Jupiter

SUBJECT:

COMMENTS ON DRAFT 10 CFR PART 5ANDDRAFTREVISIONbT REGULATORY GUIDE 10.8, GUIDE FOR THE PREPARATION OF APPLICATIONS FOR MEDICAL PROGRAMS In response to your request of February 13, 1984, the draft Part 35 and draft Reg. Guide 10.8 have been reviewed. These documents have been greatly improved by the recent work on them and they appear generally to be in good form. Several outstanding questions, including the issue of patient excreta exemptions, the apparent use of conflicting language in the discussion of general licenses and a number of other minor issues were resolved in a staff meeting on March 15.

However,'there is an issue regarding physicians' training which deserves attention. The statement is made in the Part 35 package (Er. closure 1,

p. 61, middle 9) that training of physicians may be received as private tutored instruction, or elsewhere. There is no apparent precedure to assure

'that the tutor'is qualified or that the course of instruction is adequate.

The classroom'and laboratory training requirements given on pp. 134, 137, 139,:141,142,143 and 144 of Enclosure 1 do not provide assurances of training adequacy. There is a risk that the applicant may either unknowingly select an unqualified tutor, select a tutor who will conduct an' inadequate source'of instruction, or the applicant may falsify information regarding tutored. instruction received. In any case, simple reliance on the applicant's statement regarding privately tutored instruction received may lead to the granting of a license to an improperly trained applicant, resulting in possible health risks for patients and staff.

. As a possible fix, the regulation might be revised to require either of

/ the following: (1) that only courses of instruction from NRC-accredited

/ institutions would be acceptable; (2) that physicians pass a qualifying test g administered by NRC; or (3) that any tutored instruction or training be

' '- endorsed or verified by a licensed physician. The latter option would still not provide complete assurance of adequacy of training, but would raise the "s level of confidence that the training was adequate by involving someone other than the applicant in the training verification.

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-The question of assurance of training adequacy applies to other parts of NRC's regulations besides Part 35. For example, 633.15 (Requirements for the issuance of a Type C specific license of broad scope), in Section (b)(1) requires

"(a); a college degree at the bachelor level, or equivalent training and experience ...; (2) at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training and experience in the

-safe handling of. radioactive materials ...",

without'specifying requirements for the adequacy of the training and experience. ~Any consideration to revise Part 35 to provide assurance of the adequacy of training should, for consistency, include similar adjustments in other parts of the Commission's regulations where non-accredited instruction or training is allowed. .Any such general revision of the regulations, "however, might more appropriately be considered separately from the current

. revision of Part 35.

'I hope you will find these comments useful.

Attachment:

As-Stated l

l cc: J. E. Zerbe D. Rathbun

N. McElr'oy V,littcett 7 s i ,

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