ML20205E482
| ML20205E482 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1999 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | GENERAL, MINNESOTA, STATE OF, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF |
| Shared Package | |
| ML20205E487 | List: |
| References | |
| SECY-98-232-C, SP-99-018, SP-99-18, NUDOCS 9904050199 | |
| Download: ML20205E482 (6) | |
Text
D ALL AGREEMENT STATES MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA AND WISCONSIN END PROGRAM MANAGEMENT INFORMATION: SEAMAN NUCLEAR CORPORATION APPLICATION TO DISTRIBUTE GENERALLY LICENSED PORTABLE MO!STURE DENSITY v
Enclosed are an October 5,1998 Commission Paper, SECY-98-232, notifying the Commission of an application from Seaman Nuclear Corporation (Seaman), a December 21,1998 Staff Requirements Memorandum (SRM) in response to the Commission Paper, and the Nuclear Regulatory Commission's (NRC) February 16,1999 response to Seaman.
Seaman applied for a license to distribute portable moisture density gauges to persons generally licensed in accordance with 10 CFR 31.5. The staff reviewed the application, and determined that it met the requirements established in 10 CFR 32.51, however, because approval of the license could set a precedent, the staff notified the Commission of the planned approval of the Seaman application. In response, the Commission issued the December 21, 1998 SRM outlining the Commission's concerns about issuing a general distribution license for portable moisture density gauges. One of the Commission's concerns is that an industry shift to general licensing for this type of device could add about 5000 portable gauges to the generally licensed device population.
]
To address the concerns of the Commission, the staff plans to consult with the Agreement States regarding the Seaman application, and the possible effects resulting from an introduction of a large number of portable devices into the generally licensed device population. To facilitate this, tha stdf will share the information frem the Materials Risk Study with the Agreement States, as soon as it becomes available. The staff also plans to arrange a one day meeting with interested Agreement States, to take place at NRC's Rockville, Maryland Headquarters, to discuss relevant issues pertaining to this matter. We are forwarding the enclosed information to pu at this time to ensure that you are aware of the Commission's decision on the Seaman application.
If you have any questions regarding this correspondence, please contact me or the individual named below.
CONTACT:
RAEANN SHANE INTERNET:
RMS2@ NRC. GOV l
TELEPHONE:
(301) 415-7832 FAX:
(301) 415-5369 OdginalSignedDr.
9904050199 990324 PAULH.LOHAUS PDR STPRG ESGGEN Paul H. Lohaus, Director PDR Office of State Programs 050009
Enclosures:
As stated Distribution:
DIR RF DCD (SP03)( )(NO SDroggitis PDR (YES
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All A/S File"
- See previous concurrence DOCUMENT NAME: G:klHM\\SP99018.WPD To receive e cope of thle document, indicato in the bar: 'C' Copy without attachment /erriosure "E' = Copy w0h attachment /encbsure M AN, opy OFFICE OSP l
NMSS/MSB l NMSS/MSB OSP:D@
NAME JMyers:nb/gd RMShane LCamper PHLohaus' %
DATE 12/29/98* 03/17/99*
03/17/99*
03/18/99*
12/29/98* 03M'99 OSP FILE CODE: SP-AG 4 y5 3e c
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. +
- ALL AGREEMENTSTATESl 4
- MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA AND WIS NSIN PROGRAM MANAGEMENT INFORMATION:i SEAMAN NUC EAR CORPORATION APPLICATION TO DISTRIBUTE GENERALLY LICENSED P RTABLE MOISTURE DENSITY
'(
Enclosed are an October 5,1998 Commissio,l' Paper, SECY 98-232, notifying the Commission of an application from Seaman Nuclear Corporation (Seaman), a cember 21,1998 Staff Requirements >
- g _JIen)prandumjn response to the Commission Paper, and e Nuclear Regulatory Commission's y
-_ NRC) February 16,1999 response to Seaman.
(
Seaman applied for a license to distribute portable mois re density gauges to persons generally -
licensed in accordance with 10 CFR 31.5. The staff rev wed the applicatiorgand determined that it y
met the requirements established in 10 CFR 32.51, t ever, because aporoval of the license could set a precedent, the staff notified the Commission of e planned approval of the Seaman application. Ir. response, the Commission issued cember 21,1998 Sb" m@ema* $RlW x
't-W"m. outlining the Commission's concem bout issuing ajicense Of ?.M;;$for portable
'y moisture density gauges. One of the Commission' ncerns is that an industry shift to general licensing for this type of device could add about portable gauges to the generally licensed device population, k
gg gg4 To address the concerns of the Commission, th staff plans to consult with the Agreement States regarding the Seaman application, and the pos ble effects resulting from an introduction of a large number of portable devices into the generally li nsed device population. To facilitate this, the staff will share me information from the Materials R' k Study with the Agreement States, as soon as it l
' becomes available. The staff also plans to a ange a one day meeting with interested Agreement i
States, to take place at NRC's Rockville,-
eadquarters, to discuss relevant issues pertaining to this matter. We are forwarding the encio
' formation to you at this time to ensure that you are aware of the Commission's decision on th eaman application.
A w dtu.A For more information about the issues de cribed above, please contact Ms. Raeann Shane at 301-415 7832 or RMS2@NRC. GOV.
If you have any questions regarding thi correspondence, please contact me or the individual named below.
. CONTACT:
JIM MYERS TELEPHONE:
(301) 415-2328 FAX:'
(301)415-3502 INTERNET:
JHM@NRC. GOV Paul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
- As stated j
Distribution.
DIR RF DCD (SP03)
SDronnitis PDR (YES / )(NO,J RMShane. NMSS A/S File DOCUMENT NAME: G VHM\\SP980XX
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03/17/99 03/ /99 L/ dV V /99 03/ /99 OSP FILE CODE: SP-AG-4
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For information about the issue described above, pleas contact Mr. John Lubinski at 301-415-7868 or JWL@NRC. GOV.
If you have any questions regarding this corresponde e, please contact me or the individual named below.
CONTACT:
JIM MYERS TELEPHONE:
(301) 415-2328 FAX:
(301) 415-3502 INTERNET:
JHM@NRC.G V b
Paul H. Lohaus, Deputy Director Office of State Programs
Enclosures:
As stated '
l l
Distribution.
DIR RF DCD (SP03)
SDroggitis PDR(YES / )(NO
)
JLubinski, NMSS A/S File DOCUMENT NAME: G:UHM\\SP980XX T* Mwo a cop r of this document, Indicate in the box: "C" = Cm M ittachment/ enclosure "E' = Co >y with attachment / enclosure "N" = No copy
~ l OFFICE OSPnM l OSP:@[jj /
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lNAME JMyers:nb [f PHLohauW %Dsl ' DCool RLBangart lDATE 12/S'98 12Pt98 l
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565-4001
+
March 24, 1999 ALL AGREEMENT STATES MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA AND WISCONSIN PROGRAM MANAGEMENTINFORMATION: SEAMAN NUCLEAR CORPORATION APPLICATION TO DISTRIBUTE GENERALLY LICENSED PORTABLE MOISTURE DENSITY GAUGES (SP-99018)
Enclosed are an October 5,1998 Commission Paper, SECY-98-232, notifying the Commission of an application from Seaman Nuclear Corporation (Seaman), a December 21,1998 Staff Requirements Memorandum (SRM) in response to the Commission Paper, and the Nuclear Regulatory Commission's (NRC) February 16,1999 response to Seaman.
Seaman applied for a license to distribute portable moisture density gauges to persons generally licensed in accordance with 10 CFR 31.5. The staff reviewed the application and determined that it met the requirements established in 10 CFR 32.51, however, because approval of the license could set a precedent, the staff notified the Commission of the planned approval of the Seaman application, in response, the Commission issued the December 21, 1998 SRM outlining the Commission's concerns about issuing a general distribution license for portable moisture density gauges. One of the Commission's concerns is that an industry shift to generallicensing for this type of device could add about 5000 portable gauges to the generally licensed device population.
To address the concerns of the Commission, the staff plans to consult with the Agreement States regarding the Seaman application, and the possible effects resulting from an introduction of a large number of portable devices into the generally licensed device population. To facilitate
. this, the staff will share the information from the Materials Risk Study with the Agreement States, as soon as it becomes available. The staff also plans to arrange a one day meeting with interested Agreement States, to take place at NRC's Rockville, Maryland Headquarters, to
- discuss relevant issues pertaining to this matter. We are forwarding the enclosed information to you at this time to ensure that you are aware of the Commission's decision on the Seaman application, if you have any questions regarding this correspondence, please contact me or the individual named below.
CONTACT:
RAEANN SHANE INTERNET:
RMS2@NRC. GOV TELEPHONE:
(301) 415-7832 FAX:
(301) 415-5369 l
[M Paul H. Lohaus, Director Office of State Programs
Enclosures:
As stated 1
a.
n s
., 4 l
- October 5,1998 SECY-98-232 FOR:
The Commissioners FROM:
L. Joseph Callan /s/
Executive Director for Operations
SUBJECT:
SEAMAN NUCLEAR'S APPLICATION FOR A LICENSE TO DISTRIBUTE PORTABLE MOISTURE DENSITY GAUGES TO GENERAL LICENSEES PURPOSE:
=The staff wishes'to alert the' Commission to its intent to issue a license that may estabiish a significant precedent. Specifically, Seaman Nuclear Corporation has requested a license to distribute portable moisture density gauges to persons generally licensed in accordance with 10 CFR 31.5. Seaman Nuclear anticipates sales of its device to approximate 500 units ann';-N.
However, approval of the application could set a precedent, assuming an industry shift to gene ;.
licensing for this type of device, that may add up to 5000 portable gauges, containing cesium-137 and americium-241/ beryllium, to the generally licensed device population. Effectively, this would add a significant number of devices to the registration program established in response to SECY-97-273, " Improving NRC's Control Over, and Licensees' A7 countability For, Generally and '
Specifically Licensed Devices," date April 13,1998, since the quantities of cesium-137 and americium-241/ beryllium meet the levels specified for registration.
BACKGROUND:
. Portable moisture density gauges are designed for use in industries, such as construction and civil engineering, to measure moisture content and density of soils, asphalt, and concrete. They are typically used by engineers and technicians at field ' construction sites. There are approximately.-
5000 gauges of this type currentry in use in the United States. For over 30 years their use has been authorized only under specific licenses issued by the U.S. Nuclear Regulatory Commission (NRC) or an Agreement State. Issuance of such licenses has beer a matter of operational practice, as opposed to regulatory restrictions disallowing use of these devices under a generallicense.
F CONTACT: John'Lubinski,'NMSS/IMNS ~
'301-415-7868 4
s ENCLOSURE 1 Mo 33 p' g,.
i l'
The Commissioners '
t 2
I A typical gauge cor tains~ two sealed sources - a 1.'48-gigabecquerel (40-millicurie) americium-241/ beryllium source used for backscatter measurement, and a 0.37-gigabecquerel (10-millicurie) cesium-137 source used for direct transmission measurementi For most designs, the backscatter source and its accompanying detector remain in the device during use. Also, for most designs, the direct transmission source is inserted, via a source rod, beneath the surface to be. measured, through a punched access hole.
Since portable moisture density gauges are usS.d.under specific licenses issued by NRC or an Agreement State, the users are required to comply with 10 CFR Parts 19 and 20, or Agreement State equivalents. This. requires, in part, that the licensees implement a radiation safety program, l
that licensees secure the devices from unauthorized removal or access, and that users be trained in the proper use of the gauges and the applicable regulations. NRC and Agreement States ensure the gauges are used safely and in accordance with the appropriate regulations, through inspections that are performed on a periodic basis (usually a 5-year frequency).
There are currently three major distributors of portable moisture density gauges in the United SMtes. Seaman Nuclear is an NRC licensee. The other two -Troxler Electronic Laboratories, Inc.,
and Boart Longyear Company (CPN Products) - are both located in Agreement States.
DISCUSSION:
Seaman Nuclear's application requests a license to distribute portable moisture density gauges to general licenseesc NRC and Agreement States have issued licenses authorizing distribution of other types of portable gauges to general licensees, including static-elimination devices, gas chromatographs, and movable density gauges that contain cesium-137.
The design of the Seaman Nuclear gauge is typical of portable moisture density gauges, with one important exception. The major difference is that the direct transmission source remains within the
_ gauge during use and is rotated to an open (unshielded) position to obtain a measurement. An optional detector probe may be attached to the device and lowered into a punched hole in the surface for a transmission measurement.
The staff has completed its evaluation of Seaman Nuclear's application and has determined that the requirements established in 10 CFR 32.51 have been met, including a robust metal label securely affixed to the device. Specifically, Seaman Nuclear has demonstrated that even under heavy use conditions, the doses to individuals under normal handling and storage operations would not likely exceed 3 mSv (300 mrem). This dose estimate is based on dosimetry reports from
- persons using similar devices under specific licenses. The acceptance criteria specified in
-10 CFR 32.51(a)(2)(ii) is that under ordinary conditions of handling, storage, and use, it should be unlikely that any person will receive, in one year, a dose in excess of 5 mSv (500 mrem). Seaman has also demonstrated that under accident conditions, it is unlikely that any person would receive an extemal radiation dose in excess of 150 mSv (15 rem). This analysis demonstrates compliance with the accident criteria specified in 10 CFR 32.51(a)(2)(iii). Based on the design of the device (e.g., source remains in device, the handle operates the source shutter mechanism, use of tamper-resistant hardware), it is extremely unlikely that even after loss or theft of the device an individual would receive a dose of 3 mSv (300 mrem).
n 7
. The Commissioners.
3
,a.
= Data in the Nuclear Materials Events Database indicates that the probability of loss or theft of these
. types of devices is generally higher than the probability of loss for other specific or general licensed devices. LTherefore, to address any concems about generallicensees maintaining accountability of the devices, Seaman Nuclear has committed to implementing a program to periodically (at least
. annually) contact its customers to verify that they can still account for their devices. The program would include having users respond to Seaman Nuclear by sending copies of the most recent leak
. test certificate. Seaman Nuclear.would notify NRC about persons who do not respond or cannot account for their devices. In addition, the device has a metallabe_l, riveted to the base of the device, that bears the radiation symbol, the words " Caution - Radioactive Material," and other information conceming use and licensing of the device. Iflost or stolen, this durable labeling will inform persons
'*at handle the device that it contains radioactive material.
The staff notes that,' as part of its response to SECY-97-273, dated April 13,1998, NRC will
. Implement a registration program for certain devices, and the portable moisture density gauges, if 1
. used by general licensees, would be subject to the registration program. However, Seaman l
Nuclear's program would sente as an accountability program in the interim.
The staff notes that the possession and use of these devices under a general license, with either Seaman Nuclear or NRC implementing an accountability program, would reduce the regulatory burden on both NRC and licensees while improving accountability of the devices. Currently, specific licensees are subject to pre-approval of their specific licenses, initial and periodic onsite inspections, and application and annual fees. Under the general license, there would be no pre-approval of licenses nor routine onsite inspections. The annual accountability program (implemented by either Seaman Nuclear or NRC) would provide more frequent contact than the 5 year on-site inspections at lower costs to both NRC and licensees. The accountability program would provide an annual co. iparison of general licensees' inventories against an independent inventory (maintained by Seunan Nuclear or NRC). Initially, the general licensees would not be subject to application or annual fees. However, as directed in SECY-97-273, dated April 13,1998, the issue of fees for
" registration will be considered as part of the rulemaking effort. The staff expects registration fees
. to be less than current fees for the same category of specific licensees.
The staff has completed its review of Seaman Nuclear's application and plans to issue a distribution license to Seaman Nuclear no earlier than 10 days after the date of this paper. In addition, prior to issuing the license, NRC will discuss the reasons for issuing the license with the States of North Carolina and California, the States where Troxler Electronic Laboratories, Inc., and Boart Longyear Company, respectively, are located. This paper informs the Commission of the staff's actions.
COORDINATION:
The Office of the General Counsel has reviewed this paper and has no legal objection.
L. Jcseph Callan Executive Director for Operation
+
December 21,1998 -
MEMORANDUM TO:
' William D. Travers Executive Director for Operations FROM:
John C. Hoyle, Secretary '/s/
SUBJECT:
STAFF REQUIREMENTS - SECY-98-232 -' SEAMAN NUCLEAR'S
' APPLICATION FOR A LICENSE TO DISTRIBUTE PORTABLE MOISTURE DENSITY GAUGES TO GENERAL LICENSEES
. The Commission disapproves the staff's plans to issue a license to Seaman Nuclear for distribution
' of certain portable moisture density gauges to generally licensed persons at this time. The staff should consult with the Agreement States, specifically, the States of California..id North Carolina, regarding the Seaman appli::ation. In addition, the staff should consider the results of the Materials Risk Study and what effect the staff's recommendations from the Risk Study, due to the Commission in December 1998, have on the proposed license for Seaman Nuclear. As part of the.
Agreement States consultation, the staff should share the relevant findings of the Risk Study and its preliminary recommendations with the Agreement States. The staff should then provide the Commission an assessment of the States' comments, its findings, and a recommendation on 1whether to proceed with issuing a distribution license to Seaman Nuclear. If the staff resubmits the
- proposal to generally-license these devices, it should discuss: 1) the enforceability of the Seaman Nuclear voluntary commitment to annually " contact" the users to maintain accountability, 2) whether NRC would have a regulatory basis for imposing a similar requirement'on future distribution
- licensees, and 3) whether the Agreement States would be willing to impose such a requirement.
' The proposal should also provide the Commission with an estimate of the resource impact of adding
'approximately 5000 generally-licensed devices to the " pool" subject to the proposed registration program and whether the program's timeline as described in SECY-98-199 would be negatively impacted.
The Commission _ notes that 10 CFR 32.51(a)(2)(iii) does not specify consideration of the consequences of losses and subsequent accidents of such devices. Therefore, as part of its Materials Risk Study, the staff should provide the Commission with a review of this aspect together with recommendations as to whether this section of the regulation should be amended to address this issue.
' To facilitate NRC consultations with Agreement States for future issues, a screening memod should be established for program office managers to use in determining whether individual issues should be referred to the Office of State Programs for possible coordination with Agreement States.
cc' '
Chairman Jackson-Commissioner Dicus -
Commissioner Diaz; Commissioner McGaffigan Commissioner Merrifield'
.OGC 3
OPA.
- Office Directors, Regions [ACRS, ACNW, ASLBP (via E-Mail)
POR
~'
DCS ENCLOSURE 2
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February 16, 1999 Mr. Scott C. Seaman, Preside' t n
Seaman Nuclear Corporation 7315 South First Street -
- Oak Creek, Wisconsin ' 53154 '
Dear Mr. Seaman:
I am responding to your December 24,1998, letter, which notified the U.S. Nuclear Regulatori; Commission (NRC) of Seaman Nuclear Corporation's concems over the December 21,1998, Staff Requyements Memorandum (SRM)- SECY-98-232. Seaman Nuclearis concerned that NRC plans to provide copies of the SRM and the related Commission Paper to all Agreement States and plans to consult with the States of Califomia and North Carolina, the home States of Seaman Nuclears competitors in the moisture density gauge industry.
Your letter indicates that Seaman Nuclear is concerned that providing a copy of the SRM and Commission Paper, and. discussing Seaman Nucleafs application for authorization to distribute portable moisture density gauges to general licensees, would provide early notification or warning of Seaman Nucleafs technical and marketing efforts, or might provide a wake-up call to competitors. As you know, the Seaman Nuclear application does not contain any information labeled as proprietary information; therefore, a copy of the application is currently available to the public through the NRC Public Document Room. To request the withholding of any persons:
privacy, proprietary, or safeguards information, you must specifically identify the portions of your correspondence that you seek to have withheld and provide in detail the bases for your claim of withholding, by providing the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information. Specifically, you requested the following:
1.
That'the SRM not be transmitted to the Agreement States. Instead, a " generalized" version of the SRM that does not reference Seaman Nuclear or portable moisture density gauges be distributed to the Agreement States.
2.
. That the Commission Paper not be transmitted to the Agreement Stater.
3.
That NRC not consult with the States of Califomia nor North Carolina while Seaman Nucleafs application is being reviewed. Seaman Nuclear believes this would provide further unfair advantage to its competitors.
' 4.
If these cannot be' granted, Seaman Nuclear requests a delay in action for 90 days, the
. approximate time for Seaman Nuclear to test approval prospects with an Agreement State.
i
~
We have tinoroughly considered your request. However, while we understand Seaman Nuclears concerns, we have concluded that it is important to implement the actions specified in the SRM for the reasons cited below.
i
- J, e
ENCLOSURE 3 4
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. As it is our policy to ' operate in an open. environment, the SRM and the Commission paper are already publicly available on the internet,.since the information was not identified as being
- proprietary when provided to the NRC. Under the Atomic Energy Act, NRC is required to ensure consistent and adequate protection of public health and safety in regulating the possession and use of byproduct materials. Because NRC has divested its authority for regulation of byproduct materials in the Agreement States, including portable moisture density gauges, it is necessary to facilitate nationally consistent regulation of these gauges by consulting with the Agreement States.
This is necessary because the use of portable gauges containing high-energy gamma sources of the level of activity requested under a general license and a vendor's implementation of an accountability program are new concepts.
NRC does not plan to delay implementation of the actions specified in the SRM. Specifically, NRC will provide a letter, including copies of the SRM and associated Commission Paper, to all Agreement States, shortly. As stated above, this action is necessary to ensure that NRC and
' Agreement States share information in a timely manner. In addition, as specified in your letter, Seaman Nuclear plans to test approval prospects with an Agreement State. While providing this information to the Agreement States does not prohibit the Agreement States from issuing such a license, it would ensure that they are aware of NRC's planned actions. In addition, it would ensure that the Agrer ment States are aware of the benefits from Seaman NucI*ar's voluntary commitment to annually contact users.
If you have any questions about this letter, you may contact Larry Camper of my staff at (301) 415-7231.
Sincerely,
/s/
Carl J. Paperiello, Director Office of Nuclear Material Gafety and Safeguards I
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DUE:-01/11/99 EDO CONTROL: G19980757' DOC DT: 12/24/98
. FINAL REPLY:
' )
. Scott C. Seaman
'Su m n Nuclear Corporation TOsi John Hoyle, SECY.
FOR' SIGNATURE-OF :.
- GRN CRC NO: 98-1161-Paperiello, NMSS-DESC -
ROUTING:
REQUEST THE:NRC NOT' PROVIDE: COPIES OF THE STAFF Travers' j
REQUIREMENTS MEMORANDUM AND POLICY POSITION PAPER Knapp TO ALL: AGREEMENT STATES-Miraglia Norry Blahai BU'erta DATE: 12/29/98 d engart, A
~ ASSIGNED TO:
CONTACT:
NMSS.
Paperiello
'SPECIAL-INSTRUCTIONS-OR REMARKS:
Add'EDO.and Commission.on for concurrence.
Chairman and Commission to review response
-prior to dispatch.
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. OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET t
PAEER NUMBER:
CRC-98-1161 LOGGING DATE: Dec 28 98 ACTION OFFICE:
EDO AUTHOR:
SCOTT SEAMAN AFFILIATION:
ADDRESSEE:
JOHN HOYLE, SECRETARY, NRC LETTER DATE:
Dec 24 98 FILE CODE: OM-6 SRM
SUBJECT:
SEAMAN NUC REQS THE NRC NOT PROVIDE COPIES OF THE I
1 STAFF REQUIREMENTS MEMORANDUM AND POLICY POSITION l
PAPER TO ALL AGREEMENT STATES ACTION:
Direct Reply I
DISTRIBUTION:
CHAIRMAN, COMRS, OGC l
i SPECIAL HANDLING:
j CONSTITUENT-
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NOTES:
COMMISSION CORRESPONDENCE DATE DUE:
Jan 13 99 SIGNATURE:
DATE SIGNEI::
AFFILIATION:
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EDO --G19980757