ML21237A451
| ML21237A451 | |
| Person / Time | |
|---|---|
| Issue date: | 08/25/2021 |
| From: | Gregory Trussell NRC/NMSS/DREFS/MRPB |
| To: | |
| Trussell, Gregory | |
| Shared Package | |
| ML21218A156 | List: |
| References | |
| NRC-2008-0173; NRC-2017-0022, PRM-34-6 | |
| Download: ML21237A451 (17) | |
Text
The public meeting on Industrial Radiographic Operations at Temporary Radiography Job Sites (Two-Person Rule) will begin shortly.
This is a Microsoft Teams meeting.
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NOTE: All attendees are muted in the meeting.
The chat is open for technical support questions.
We will answer questions later in the meeting.
Meeting Logistics
- Information meeting with a Q&A session
- Meeting is being transcribed.
- Slides are available to download from the Agencywide Documents Access and Management System (ADAMS) Accession No. ML21237A451.
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Industrial Radiographic Operations at Temporary Radiography Jobsites (Two-Person Rule)
Public Meeting August 26, 2021 1:00 pm - 3:00 pm (Eastern Time) 3
Purpose of Public Meeting To provide an overview of the two-person rule and allow public input on the implementation and solicit feedback on additional guidance.
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Agenda
- Opening Remarks
- Background
- Two-Person Rule
- Questions and Answers
- Closing Remarks 5
Opening Remarks 6
Background
In 2001, during an Integrated Materials Performance Evaluation Program review, the NRC identified that implementation of the two-person rule was not compatible with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 34.41(a). The NRC did further engage with the Office of Agreement States (OAS) and other states.
On November 3, 2005, the OAS submitted a petition for rulemaking (PRM) requesting the NRC to amend its regulations in 10 CFR 34.41(a), 34.43(a), and 34.51 related to industrial radiographic operations:
(1) related to radiation safety training (2) responsibilities of the second individual (3) visual surveillance requirements 7
Background (contd)
The NRC reviewed the petition and determined that the issues and concerns raised in the petition merited further NRC consideration and inclusion in a future rulemaking (73 FR 27771; May 14, 2008).
The NRC issued a notification of interpretation on the two-person rule to respond to the petition (86 FR 29173; June 2021).
Background (contd)
- The interpretation of the regulation was immediately effective upon issuance
- The regulatory requirements did not change
- The NRC will publish a notice in the Federal Register containing an evaluation of the significant comments received during the post-promulgation comment period and any revisions to the interpretation
Agreement State Compatible Compatibility category designation for 10 CFR 34.41(a) from B to C.
- Agreement States may either adopt the NRCs position or may continue to require direct observation of radiographic operations by the second individual.
- Agreement States may also adopt other more restrictive requirements.
Two-Person Rule 10 CFR 34.41(a)
"The additional qualified individual shall observe the operation and be capable of providing immediate assistance to prevent unauthorized entry" are met if the second qualified individual is in sufficiently close proximity to the operation and sufficiently aware of the ongoing activities to be able to provide assistance or take charge when necessary and to prevent unauthorized entry. The second individual may perform other tasks nearby so long as they are cognizant of the site-specific circumstances when radiographic operations are in progress.
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Comments on Notice
- Does not improve clarity or help radiation safety: actual observation is necessary.
- Video observation is rare; radio is more likely.
- Use of the words sufficient and sufficiently are ambiguous.
- Compatibility change might or might not cause consistency problems for Agreement States.
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NRC Takeaways From Comments
- Address safety issue
- Clarify some of the comments
- Provide guidance on applicable approach and provide better examples
Questions and Answers Instructions
- For those using Teams in the application or browser:
- Use the raise hand feature and a presenter will permit you to unmute. You will need to unmute when notified.
- For those calling in:
- Press *5 to raise your and a presenter will permit you to unmute. Press *6 to unmute when notified.
- In the chat:
- Questions can be asked in the chat at the appropriate time. Please indicate All Panelists when asking a question.
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Path Forward
- The NRC staff will review comments and input from this public meeting to formulate the closure to the petition and rulemaking.
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Closing Remarks 16
E-mail: Gregory.Trussell@nrc.gov 17