Dear Powernet 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
