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

[Sander Perle]

AMEN!!!!

Regards,

Sandy
Sent from my iPhone

> On Nov 23, 2016, at 13:20, KARAM, PHILIP <PHILIP.KARAM at nypd.org> wrote:
> 
> 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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