[ RadSafe ] Docket No. PRM­34­7; NRC­2016­0182, Individual Monitoring Devices for Industrial Radiographic Personnel

[KARAM, PHILIP]

I guess that one would naively hope that if a dosimeter passes NVLAP testing and is accredited that it would be good enough for NRC. If that's not enough for the NRC then that would seem to beg the question as to exactly what standards they're using to find a dosimeter acceptable - if objective, performance-based testing is not sufficient then we're into subjective standards, and I'm not sure that this is a good way to make such decisions.

Andy

P. Andrew Karam, PhD, CHP
NYPD Counterterrorism Division
(718) 615-7055 (desk)
(646) 879-5268 (mobile)

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu [mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Sander Perle
Sent: Wednesday, November 23, 2016 10:50 AM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: [ RadSafe ] Docket No. PRM347; NRC20160182, Individual Monitoring Devices for Industrial Radiographic Personnel

Dear Radsafe members. As  you may recall, the NRC for some reason determined
in late 2014 when a facility submitted their license renewal, they were no
longer permitted to use advanced technology to meet the requirements in 10
CFR Part 34. In the meantime a Petition for Rulemaking, has been submitted
from Dr. Arny Bereson of the Nondestructive Testing Management Association
(NDTMA) and Mr. Walt Cofer of the American Society for Nondestructive
Testing (ASNT). The petitioners request that the NRC amend its regulations
to authorize use of improved individual monitoring devices for industrial
radiographic personnel. The PRM was docketed by the NRC on August 12, 2016,
and has been assigned Docket No. PRM­34­7. The NRC is examining the issues
raised in PRM­34­7 to determine whether they should be considered in
rule-making with comments due January 23, 2017.


Here is the NRC link where the publication in the Federal Register as well
as other information can be found, including the capability to submit a
5,000 character response online:
https://www.regulations.gov/document?D=NRC-2016-0182-0002



The NRC has not demonstrated any inclination to recognize advanced dosimeter
technology. I have personally submitted a detailed response supporting
approval of the Petitioner¹s request that demonstrates that as advances in
technology evolve, that the NRC promulgate ³living regulations² to meet the
needs of the radiation worker and management and not restrict utilization of
these advancements that provide for significant benefits, especially when
they are NVLAP approved.



While this petition currently pertains only to 10 CFR Part 34, the NRC has
asked whether or not the petition should refer to Parts 36 and 39 as well
(the answer is YES)! It is also not a leap where the NRC in the future could
determine that other current exiting as well as proposed advanced
technologies are not recommended or approved to meet monitoring requirements
in 10 CFR 20. 



Your support will be most appreciated, as well as all of your colleagues and
organizations!



Regards and Happy Thanksgiving to all of you, your families, friends and
colleagues!



Sandy

Retired/Consultant


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