ML20199D357
| ML20199D357 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1997 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Paris R OREGON, STATE OF |
| Shared Package | |
| ML20199D361 | List: |
| References | |
| NUDOCS 9711200318 | |
| Download: ML20199D357 (5) | |
Text
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Mr. Ray D.' Paris, M: nager Radiation Protection Services Ori gon State Health Division gy 3 3 g Department of Human Resources P.O. Box 14450 Portlana, OR 97214-0450
Dear Mr. Paris:
Given the significance of the revised 10 CFR Part 20 rule to both NRC and Agreement State programs, NRC undertook a review of all Agreement State final Part 20 equivalent rules for compatibility *.vith 10 CFR Part 20. The review was conducted as a two step process. The first step involved a review by Oak Ridge National Laboratory (ORNL), under contract with NRC, to identify any differences or inconsistencies between 10 CFR Part 20 and each Agreement State equivalent rule. A copy of the two volume ORNL report, dated August 24,1995 documenting its staff review of the Oregon final Part 20 equivalent rule is enclosed for your information and use (Enclosure 1). NRC staff first evaluated the ORNL report to determine if any potentially s'gnificant health and safety issues were identified that required immediate attention. If ti,ere were none, NRC staff then conducted, as resources permitted, a detailed review of the differences and inconsistencies identified by ORNL for compatibility and adequacy issues that should be brought to your attention for routine action.
The NRC review focused on those provisions of the rules that should be adopted in accordance with the new adequacy and compatibility policy statement approved by the Commission by Staff Requirements Memorandem dated June 30,1997 (Enclosure 2 describes the new compatibility categories). The NRC review concluded that the Oregon 10 CFR Part 20 equivalent rule meets the compatibility and health and safety categories of the new policy.
If you have any 4.estions regarding these comments, the compatibility criteria, the NRC regulations used in the review, or the Oak Ridge report, please contact me at (301) 415-2326 or Ms. Cs.rdelia Maupin of my staff at (301) 415-2312 or INTERNET: CHM @NRC. GOV.
Sincerely, g$nalSigned By; PAULH.LOHAUC 9711200318 971113 PDR STPRG Eso0R Paul H. Lohaes, Deputy Director PDR Office of State Programs l
Enclosures:
As stated Distribution:
DlR RF (7S240) 1DCD (SP08)-Copies of Enclosure 1 to be SDroggitis
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filed in Central Fi'es and PDR only CHackney, RIV PDR (YES)
KSchneider.
BUsi1 ton MOregon File SSalomon Part 20 File (w/o Enclosure 1).
JKyers
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DOCUMENT NAME: G:\\ CHM \\PART20\\ OREGON.LTR
- See Previous Concurrence.
T1 receive a Looy of then stocument, indecate in the box: "C" = Copy without attachment / enclosure T = Copy w'th attachment / enclosure 'N" a No co OFFICE OSP l
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NAME CHMaupin:nb PHLohaus FXCameron RLBanga F "
DATE 10/17/97
- 10/17/97
- 11/03/97
- 11//3/97 A
OSP FILE CODE: SP-AG-23, SP-P-1 r.= c
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Mr. Ray D. Parb i'inally, implementation procedures for the n 3w policy statem nt provide guidance that ir:dicates Agreement State rules that are not c'Jrrently consistent with he new compatibility category designations should conform with the new policy not later t an 3 years after the policy's effective date.
If you have any questions regarding these comments, th compatibility criteria, the NRC F
regulations used in the review, or the Oak Ridge report, lease contact me at (301) 415-2326 or Ms. Cardelia Maupin of my staff at (301) 415-2312 or l TERNET: CHM @NRC. GOV.
Si cerely, aul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
As stated l
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l Distribution:
DIR RF (7S240)
/
DCD (SP0Q-Copies of Enclosure 1 to be
/
filed in Central Files and PDR only SDroggitis j
CHackney, RIV j
PDR (YES)
KSchneider
/
Part 20 File (w/o Enclosu/
Oregon File -
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/
DOCUMENT NAME: G:\\ CHM \\PART20\\ OREGON.LTR
- See previous concurrence, n r.c.ev. e con of tw oocument. inmeate in vi. no a c con weout enactwn.nvenemur. r = Cop we anacnmenyenclosur. T 1 No copy j
OFFICE
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NAME CHidjQ5in:nb PHkfh'a;6 FXCameron RLBangart DATE 10/( [/97 10/1
/97 11/03/97*
11/ /97 f
OSP FILE CODE: SP-AG-23, SP-P-1
f Mr. Ray D. Pcris Finally, implementation procedures for the hew policy statement provide gu' ance that Indicates Agrerement State rules that are not currently consistent with the new com tibility category designations should conform with the new policy not lator than 3 years a er the policy's effective date.
If you have any questions regarding these comments, the compatibili criteria, the NRC regulations used in the review, or the Oak Ridge report, please cont ct me at (301) 415-2326 or Ms. Cardelia Maupin of my staff at (301) 415-2312 or INTERNET:
HM@NRC GOV, Sincerely, Paul H. L haus, Deputy Director Office of tate P:7 grams
Enclosures:
As stated t
Distribution:
DIR RF (7S240)
DCD (SP0 S-Copies of Enclosure 1 to be SDroggit;s filed in Central Files and PDR only CHackney, RIV PDR (YES)
KSchneider Ore [,on File Part 20 File (w/o Enclosure 1)
DOCUMENT NAME: G:\\ CHM \\PART20\\O 13 receive a copy of th6s document, Indicate in the bo :: *C *pEGON.LTR Copy without a.
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, re E a Copy wth attachmenvenctosure Y a No copy OFFICE qj Ml
@@( I OGCl L, / OSP:D l
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M NAME CHldjMn:nb PHkfhin)~
FXCameron RLBangart DATE
-10/i./97 10/l' /97 10/ /97 10/ /97 OSP FILE CODE: SP-AG-23, SP-P-1
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NUCLEAR REQULATORY COMMISSION
'4AsHINfaf oN, D.C. 200eHm01 November 13, 1997 Mr. Ray D. Paris, Manager Radiation Protection Services Oregon State Health Division Department of Human Resources P.O. Box 14450 Portland, OR 97214-0450
Dear Mr. Paris:
Given the significance of the revised 10 CFR Part 20 rule to both NRC and Agreement State programs, NRC undertook a review of all Agreement State final Part 20 equivalent rules for compatibility with 10 CFR Part 20. The review was conducted as a two step process. The first step involved a review by Oak Ridge National Laboratory (ORNL), under contract with NRC, to identify any differences or inconsistencies between 10 CFR Part 20 and each Agreement State equivalent rule. A copy of the two volume ORNL report, dated August 24,1995 documenting its staff review of the Oregon final Part 20 equivalent rule is enclosed for your information and use (Enclosure 1). NRC staff first evaluated the ORNL report to determine if any potentially significant health and safety issues were identified that required immediate attention. If there were none, NRC staff then conducted, as resources permitted, a detailed review of the differences and inconsistencies identified by ORNL for compatibility and adequacy issues that should be brought to your attention for routine action.
The NRC review focused on those provisions of the rules that should be adopted in accordance with the new adequacy and compatibility policy statement approved by the Commission by Staff Requirements Memorandum dated June 30,1997 (Enclosure 2 describes the new compatibility categories). The NRC review concluded that the Oregon 10 CFR Part 20 equivalent rule meets the compatibility and health and safety categodes of the new policy.
If you have any questions regarding these comments, the compatibility criteria, the NRC regulations used h the review, or the Oak Ridge report, please contact me at (301) 415-2326 or Ms. Cardelia Maupin of my staff at (301) 415-2312 or INTERNET: CHM 7,hRC. GOV.
S
- erely,
@ au/}, I vW I
TH. Lohaus, puty Director Office of State Programs Enclosur63:
As stated l
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l Comoatibility Cater.orv and H&S Identification for 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 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. Tha manner in which the essential objectives are addressed need not be the same as NRC provided the essential objectives are met.
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 relinquishe i to Agreement States pursuant to the AEA or provisions of TPle 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 health and safety significance. The State should adopt the essential
. objectives of such program elements in order to maintain an adequate program ENCLOSURE 2
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