ML20199D441

Discusses Review of Colorado Rules, Proposed Revs to Colorado Rules & Regulations Pertaining to Radiation Control, Dtd 970926.No Comment on Proposed Rules

ML20199D441
Person / Time
Issue date:	11/10/1997
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Jacobi J COLORADO, STATE OF
References
NUDOCS 9711200337
Download: ML20199D441 (4)

Text

I y*

Mr. Jake Jacobi, Section Chief Radiation Control Division Department of Public Health and Environment 8100 Lowry Boulevard Denver, CO 80220-6928

Dear Mr. Jacobi:

We have reviewed the proposed Colorado rules,

• Proposed Revisions to thn Colorado Rules and Regulations Portaining to Radiation Control' dated September 26,1997. The rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Part 34. Based on this review, we have no comment on the proposed rules.

- Under our current procedure, a determination that a State rule meets the compatibility criteria associated with the equivalent NRC rule is made only based on a review of the adopted final rule.- However, we have determined that if your proposed rules were adopted without significant change, they would meet the current compatibility criteria. Please note, however, that NRC has adopted a revised 10 CFR Part 34 effective June 27,1997. The aniended regulatory requirements should be addressed by the Agreement States by June 27,2000.

We request that when the proposed rules are adopted and published as final rules, a copy of the 'as published

• rules be sent to us. As requested in our All Agreement Gtates Letter SP 96-

< 027,

• Request to Hiahliaht Changes to Aareement State Reaulations Submitted to NRC for C9mpatibiktv Review"(March 1,1990), please highlight the final changes and send one copy in '

a computer readable format, if possible.

t if you have any questions regarding the comments or any of the NRC rules used in the review,-

please contact me or Mr. Richard Blantnn of my staff at (301) 415-232?., or by Internet at

- RLB@NRC. GOV.

Sincerely, original 8%ned Dy; PAULH.LOHAUS Paul H. Lohaus, Deputy Director Office of State Prograrns 9711200337 971110 PDR STPRQ ESQC0 PDR

~

U U e L 4.- % e w s L.$ d k) la

\\

I k

Distribution:

tC D E la DIR RF (7S261)

DCD (SP08 ) -

,,r.n*

PDR (YES.f___ NO

)

SDroggitis Colorado File,

v-*

DOCUMENT NAME: G:\\RLB\\ COO 9971R.WPI)

• See previous concurrence.

n e.e.va.., oe w. e.com.ni, inee in ie,. noc c /%CSovi.n.cnm.nv.noo.. r cm win n.cuww.ncio..ar no em OFFICE QBP) f Q [c.

O@

l OGC l

OSP D A/f l

/

NAME RLBlantobED PHLdhistlf i FXCameron RLBangartf "'

DATE 10hi/97 '

10/Q/97 11/03/97*

11/Bb /97 OSP FILE CODE: SP-AG-d I.I Il.Ill l.il.llll

1 Mr. Jake Jacebi, Sectivo Chief Radiation Control Division Department of Public Hea4h and Environment 8100 Lowry Boulevard Denver, CO 80220-6928 Dear Mr. Jacobi; I

We have reviewed the proposed Colorado rules, ' Proposed Reviflons to the Colorado Rules end Regulations Perfalning to Radiation Contror dated September 26,1997. The rules were l

reviewed by comparison to the equivalent NRC regulations in 1 CFR Part 35. Based on this review, we have no comment on the proposed rules.

Under our current procedure, a determination that a State rup meets the compatibility criteria associated with the equivalent NRC rule is made only base on a review of the adopted final rule. However, we have determined that if your proposed es were adopted without significant change, they would meet the current compatibility criteria, lease note, however, that NRC has adopted a revloed 10 CFR Part 34 effective June 27,199 The amended regulatory requirements should be addressed by the Agreement St es by June 27,2000.

We request that when the proposed rules are adopted nd published as final rules, a copy of the *as published

• rules be sent to us. As requested i our All Agreement States Letter SP 96 027, *Bagunat to Hiohllaht Changes to Aareement St a Regulationa Submitted to NRC for CQmaallbilttv Review" (March 1,1996), please highli ht the final changes and send one copy in a computer readable format, if possible.

If you have any questions regarding the comments or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415 2322, or by Intemet at RLB@NRC. GOV.

Si erely.

$aul H Lohaus. Deputy Director Office of State Programs

/

//

/

Distribution:

DIR RF (7S261)

/

DCD (SP08 )

SDroggitis j/

PDR (YES,f._, NO

)

Colorado File

>/

DOCUMENT NAME: G:\\RLB\\ COO 9971R.WP

t. co.~.. em or w. noum.aua**m. wc -cW w.meaw.na.o(b' cm en et.em.%ne.n v. a. o OFFICE Qef'y r D lc.

OGC /

OSP:D l

NAME RLBlantel QC 3 PHLcNjV i FXCameron RLBancart DATE 10tM/97' 10/Uf97 10T 77 10/ /97 p

OSP FILE CODE: SP AGs

7....g\\

UNITED STATES p-

)

NUCLEAR REGULATORY COMMISSION wa m norou,o.c.seenseem November 10, 1997 I

Mr. Jake Jacobi, Section Chief Radiation Control Division Department of Public Heahh and Environment 81001.owry Boulevard Denver, CO 80220-6928 Dear Mr. Jacobi.

We have reviewed the proposed Colorado rules,' Proposed Revisions to the Colorado Rules i

and Regulations Perfalning to Radiation Control' dated September 26,1997. The rules were reviewed by comparinon to the equivalent NRC regulations in 10 CFR Part 34. Based on this review, we have no comment on the proposed rules.

Under our current procedure, a determination that a State rule meets the compatibility criteria associated with the equivalent NRC rule is made only based on a review of the adopted final i

rule. However, we have determined that if your proposed rules were adopted without significant change, they would meet the current compatibility enteria. Please note, however, that NRC has adopted a revised 10 CFR Part 34 effective June 27,1997. The amended regulatory requirements should be addressed by the Agreement States by June 27,2000.

We request that when the proposed rules are adopted and published as final rules, a copy of the *as published" rules be sent to us. As requested in our All Agreement States Letter SP 96-027,'Recuasi to Hiahlicht Chanoes to Aareement State Regulations Submitted to NRC for Comoatibility Review" (March 1,1996), please highlight the final changes and send one copy in a computer readable format, if possible.

If you have any questions regarding the comments or any of the NRC rules used in the review, j

please contact me or Mr. Richard Blanton of my staff at (301) 415-2322, or by Internet at RLB@NRC. GOV,

erely, aulH.Loha ep t Office of State Programs u.

~ ' ' ~ - '

^

pkt pbp&t EXECUTIVE TASK MANAGEMENT SYSTEM

<<< PRINT SCREEN UPDATE FORM >>>

TASK,# - 7S261 DATE-10/02/97 MAIL CTRL. - 1997 I^85.SIARJ{g-10/02/97 TASK DUE - 10/31/97 TASK COMPLETED -

/

/

TASK DESCRIPTION - PROPOSED REVISIONS TO PARTS 3 AND 5 TO THE COLORADO RULES AND REGULATIONS PERTAINING TO RADIATION CONTROL REQUESTING OFF.

CO REQUESTER.- QUILLIN WITS -

0 FYP - N PROG.-

PERSON -

STAFF LEAD -

PROG. AREA -

PROJECT STAT.US -

ATTENTION ANY COMMENTS OR QUESTIONS TO JAKE JACOBI

...-~~.....

PLANNED ACC.

-N COLORADO DUE DATE:

10/31/97 LEVEL CODE -

1

\\b-l

.______._ _ _4... _ _ _ _

A STATE OF COLOFADO Roy Norner, Goverras l'An bhwaydet,Isecuthe threms l

tk'dstated to prutatug and 6mprudtg the heshh and endrunment ed the pnple of Cokcadu l;

4100 Cherry Csed ik. $.

I alxamory and stadiatson Services (NvWon -

Denver. Crokwado 802461$30 - 8100 t owry filed.

nuses 001) 692 2000.

Denver Co 80270 6928 -

located in Glendale, Cokaado 00U 692 30'a0 M[

g httpJtwnw.tdphenateto us d

September-26, 1997 I-

--e 1

C3 cn 5N i

Mr.-Richard Bangart u

Director, Office of State-Programs O

United States Nuclear Regulatory Commission Washington, D.C.

20555-0001

Dear-Mr..Bangart,

Attached are the proposed revisions to Parts 3 and 5 to the Colorado Rules and Regulatione Pertaining to Radiation Control.

Also attached is a-. table which indicates differences in language between the Colorado Radiation Regulations and the NRC Regulations.

Please direct any questions or comments'to Jake-Jacobi by October 31, 1997.

He can be reached at (303)692-3036.

cerely,-

Robert M. Quillin, Director Laboratory and Radiation services Division CP Attachments::as stated j

cf: C..-Hackney-i l {,,,,, U V a

4 8 e i Proposed Revisions to the ~ Colorado Rules and Regulations Pertaining to Radiation Control September 26,1997 NRC Rule Colorado Rule Proposed Revisions to Colorado Rule unmuuuuuuuuuu usuuuuuuuuuumu 34.11 Ril 3.10.5 l'se of Scaled Sources in Industrial Radiocranby in addition to the requirements set forth in Ril 3.9, a specific license for use of scaled sources in industrial radiogr.phy will be issued if: 34.ll(a) 1.10.$.1 the applicant will have an adequate program for training radiographers and r;. dias i n :::iMants-and submits to the f department a schedule or description of such prog #am u hich specines the;' 3.10.5.1.1 initial training, 1.10.5.1.2 periodic training, 1.10.5.1.3 on-the job training, 1.10.5.1.4 means to be used by the licensee to determine the radiographer's knowledge and understanding of and ability to comply with department regulations and licensing requirements, and the operating and emergency procedures of the applicant, and 1.10,5.1.6 mean: :c bc.. u-d 1 y :he !icemcc :, de,cr;nine :he radiograihds

c. :'; Lauc.!cdge and. ndcr"- Fag rf;nd aH!i:y :c es ;.i'y - i:h

he ara r./ing ;;nd en.crgency r.;.acd-rc af4hc r.r.r.F.an

.'

' Proposed Colorado Regulation is different than the equivalent NRC Regulation - ~ -. - -. -..

6 c. NRC Rule Colorado Mule Proposed Retiolons io Colorado Mule m 14.20 Ril 5.:i Perfonnance Requirements for Radiogranhle rauinment Equipment used in industrial radiographic' operations must me:t the following minimum criteria. 5.5.1 Each radiographic exposure d:vice and all associated equipment must meet the r quirements specified in American National Standard N432 1980 ' Radiological Safety for the Design and Construction of Apparatus for Gamma Radiography",(published as NDS llandbook 136, issued January 1981).' ENGINEERING ANALYSIS MAY llE SUllMITTED HY AN APPLICANT OR LICENSEE TO IsEMONSTRATE Tile APPLICABILITY OF PREVIOUSLY PERFORMED TESTING ON SIMILAR INDIVIDUAL RADN)GRAPilY EQUIPMENT COMPONENTS. UPON + REVIEW, Tile DFPARTMENT MAY FIND Tills AN ACCEPTAHLE ALTF.RNATIVE TO ACTUAL TESTING OF Tile I COMPONI"4T PURSUANT TO Tile REFERENCl:D - STANDAP 'M r ' cce:in:a ;..py :i ac ecfce, aced ;;;;;d h :.;" '-J; fcc i:VL'c mi ;; ion d i;; ;;- -----l t"; ; ' u.;a at it lLJk n C;.,,, ! D';, -,43M Cherry C;,,', D he f a,.:F. Pd"'n; M, lh: Heer; OenverrCc'cc ic. C;r ir;J ;ai e of S; ;;f ;,;;;;J r 'c-ial c.Me d ev ideJ a;,

.ieni.,i,;;;,f.v... ic!LJ' m Ci,, l Dh,>.c r.

h fc"; bg raaP,ir.i; ;JJ.. - Dir;;;ar, !!aji r.c, Cc,,,, l Dh. *.., l ICD-DO-Sl, Cc'- re,'. D,i-c.1;; er

cf ll,;.'e,43M Ch;rr,, C;;;', Dr.;e

a i, DeT.i. CGr#0NM#M i 34.20(f) 5.5.6 NOTWITilSTANDING Ri! 5.5.1,5.5.4 AND 5.5.5 EQUIPMENT USI.D IN INDUSTRI AL RADIOGRAPillC Ol'ERATIONS NEED NOT COMPLY WITil SECTION R.9.2(C) OF Tile ENDURANCE l'EST IN AMERICAN NATIONAL STANDARDS INSTITUTE N4321980,IF Tile PROTOTYPE 1:QUIPMENT ll AS IIEEN TESTED USING A TORQUE VALUE REPRESENTATIVE OF Tile TORQUE TilAT AN INDIVIDUAL USING Tile MADIOGRAPilY EQUIPMENT CAN REALISTICALLY EXERT ON Tile LEVER OR CHANKSil AFT OF Tile DRIVE M ECll ANISM. 34.25 Ril 5,10 Leak Testing. Repair. Taggine. Opening. Modification. and Renlacetnent af Scaled Souregs 5.10.6 A SEALED SOURCE WillCll IS NOT FASTENED TO OR CONTAINED IN A RADIOGRAPillC EXPOSURE DEVICE silALLllAVF. PERMANENTLY A1TACllED TO IT A DURAllLE TAG AT LEAST ONC(1)INCil SQUARE IIEARING Tile PRESCRlRED RADI ATION CAUTION SYMilOL IN CONVENTIONAL COLORS, MAGENTA OR l'URPLE ON A YELLOW llACKGROUND, AND AT LEAST Tile INSTRUCTIONS: DANGER RADIOACTIVE M ATERIAL. DO i NOT ll ANDLE-NOTIFY civil AUTilORITIES IF FOUND. i ' Proposed Colorado Regulation is difTerent than the equivalent NRC Regulation .~.

BACKGROUND MATERIAL ) FOR CSP FILES l I 4 AGREEMENT STATE REGULATIONS REVIEW RECORD l 1 t Colorado Proposed Revisions of September 26,1997 i I October 1997 I I I I i l i i I

- 3 Rule Package: Colorado September 1997 Industrial Radiography amendments Category and CFR citation Rule subiect State citation C u.nn + s All regulations are " unchanged" except: 10 CFR Part 34 LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY REOUWEMENTS FOR RADIOGRAPHIC OPERATMNIS C 34.11(a), (b) Issuance of specific licenses for use of sealed IRH 3.10.5.11

equivalent to 34.11 pe" to 6/27/97 sources in Industrial Radiography B 34.20(a), (f)

Performance requirements for radiography [RH 5.51.

equivalent to 34.20 prior to 6/27/97 equipment

-2 34.25(e) Leak Testing, Repair, Tagging, Opening, [5.10.6]

equivalent to 34.25 prior to 6/27/97 Modification, and Replacement of Sealed l

Sources t i m. mi U h 2 4 m... .}}