ML20198Q235

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Discusses Review of Part Q Licensing & Radiation Safety Requirements for Irradiators,Per 970807 Request. Offers No Comments Re Regulation.Regulation Meets Compatibility,Health & Safety Categories
ML20198Q235
Person / Time
Issue date: 01/09/1998
From: Lohaus P
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Hirschler
CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS
Shared Package
ML20198Q240 List:
References
NUDOCS 9801220378
Download: ML20198Q235 (6)


Text

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.p k UNITED STATES g s NUCLEAR REGULATORY COMMISSION  !

WAsHlWGToN O.C. St346-0001 ,

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. January 9,1998 0

Mr. Bruce Hirschler Technical Assistant, SSRCR's Office of the Executive Director.

Conference of Radiation Control Program Directors, Inc.

205 Capital Avenue Frankfo t, KY 40601 *

Dear Mr. Hirschler:

As requested in your letter of August 7,1997, we have completed the review of Part Q -

Licensing and Radiation Safety Requirements for Irradiators. Thai regulation was adopted by the Board of Directors of the Conference of Radiation Control Program Directors, Inc. (CRCPD)

[on July 28,1997. The proposed regulation was reviewed by comparison to the equivalent regulation,10 CFR Part 36.

As a result of our review, we have no comments about the regulation, and if published in final, without 7 3gnificant change, the regulation would meet the compatibility and health and safety categorieta established in OSP Internal Procedure B.7.

- We request tha' ~vhen this Suggested State Regulation !s published as a final regulation, a copy of the 'as published" regulation be provided to us 'or review. As requested in our All Agreement States Letter SP-96-027, "Recuest to Highlicht Chances to Aareement State Regulations 2 Submitted to NRC for Comostibility Review" (March 1,1996), please highlight any final char ges and send one copy in a computer readable fon.lat, if possible.

We do have one comment in the Rationale for Revisions to Part Q. The Compatibility Requirements section needs revision because of the new adequacy and compatibility policy statement approved by the Commission by Staff Requirements Memorandum dated June 30, 1997 (Enclosure 1 describes the new compatibility categories). The first sentence of the second paragraph should be deleted. - In its place, we suggest the following:

The various provisions of the 10 CFR Part 36 regulation are assigned different compatibility and health and safety categories. Definitions of ecch category and the specific category assigned to each pmvision of 10 CFR Part 36 are set out in U.S.

No: lear Regulatory Commission, Office of State Programs internal Procedure B.7, p Compatibility Categories and Health and Safety identification for NRC Regulations and

< .Other Program Elements. They reflect the new adequacy and conapat:bility policy statement approved by the Commission by Ctaff Requirements Memorandum dated June 30,1997 (see also 62 FR 46517). j ,

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Mr. Bruce Hirschler - - If you have any questions, please contact me or Dr. Stephen N. Salomon of my staff at (301)415 2322.

Sincerely,

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( (({ , k 'd'st is 1 - g s, Paul H. Lohaus, Deputy Directdr Office of State Programs

Enclosure:

- As stated r

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'9 Comontibility Cateoorv and H&S Identification fcr NRC Raoulations Key to categories:- A= Basic radiation protection standard or related definitions, signs, labels or terms necessary for a - ,

common understanding of radiation protection principles. The State program element should be 4 essentially identical to that of NRC.

B= Program element with significant direct  ;

transboundary implications. The State program element should be essentially identical to that of NRC.

C= Program element, the essential objectives of which should be adopted by the State to avoid conflicts, duplications or gaps. The manner in which the essential objectives are addressed may be different thar that used by NRC.

D= Not required for purposes of compatibility, NRC= Not required for purposes of compatibility. These are NRC program element areas of regulation that cannot be relinquished to Agreement States pursuant to the AEA or provisions of Title 10 of the Code of Federal Regulations. The State should not adopt these program elements.

H&S = Program elements identified as H&S are not ,

required for purposes of compatibility; however, they do have particular Matth and safety significance. The State should adopt the essential 4

objectives of such program elements in order to maintain an adequate program.

ENCLOSURE 1 -

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Mr. Bruce Hirschler ~8 E If you liave any questions, please contact me or Dr. Stephen N. Salomon of my staff at -

(301)415-2322.

Sincerely, Ofghs! 3hnod By RICHOD L BANO. ART Paul H. Lohaus, Deputy Director Office of State Programs

Enclosure:

As stated DiakittuliQQ:

DlR RF (7S189) e DCD (SP03)

SDroggitis y PDR(YES2C_ NO )

JMyers -

- LBolling

.TO'Brien CRCPD File-Part 36 File *See previous concurrence

. DOCUMENT NAME: G:\SNS\PARTQ.SNS

. T' rese4ve a oop > of this clocument, Ind6cato in the bos: 'C" dich amthout attachment /endoeure "E" a Coco with attachment /erdostS "N= m No copy '

OFFICE OSP [E O% OGC OSP( l 41 l NAME- SNSalomon:nb/gd PHLolaus- FXCameron RLBangart V

< DATE 12/23/97* 12/dj97 190668* 12/M97 iOSR FILE CODE;tSR C-7 SP-P ... _ . . . . . . . . . .

i L,,, 7, o-I Mr. Bruce Hirschler q i

if you have any questions, please contact me or Dr. Stephen N. Salom of my staff et l

- (301) 415-2322.-

Sincerely, l 4 o 1

i Paul H. Lohaus, puty Director l Office of State Pr rams

Enclosure:

As stated -

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Distribution-DIR RF (7S189) DCD (SP03)

SDroggitis PDR (YESJ._ NO )

JMyers LBolling TO'Brien CRCPD File Part 36 File *See previous concurrence DOCUMENT NAME: G:\SNS\PARTQ.S A /

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NAME- SNSalomon:nb/gd PHl/onaus FXCameron RLBangart " V DATE 12/23/97* / 12/df97 12/--#7' 12/M97 OSP FILE CODE: SP-C-7 SP-P-7 7

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EXECUTIVE TASK MANAGEMENT ~~~---- .. -~~~--

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m DATE- 08/11/97 - MAIL CTRL. - 1997

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e TASK STARTED - 08/11/97 TASK DUE - 10/07/97 TASK COMPLETED - / /

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TASK DESCRIPTION - REVIEW AND COMMENT ON PART Q- LICENSING AND RADIATION

~~~~---- ...-~~.

SAFETY REQUIREMENTS FOR IRRADIATORS REQUESTING OFF. - CRCPD REQUESTER - HIRSCHLER WITS - 0 FYP - N

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