ML20211N154
| ML20211N154 | |
| Person / Time | |
|---|---|
| Issue date: | 07/29/1999 |
| From: | Woodruff R NRC |
| To: | Salomon S NRC |
| Shared Package | |
| ML20211N144 | List: |
| References | |
| NUDOCS 9909100085 | |
| Download: ML20211N154 (12) | |
Text
[ Stephen Salomon -~REVlEVfdF 56UiH CAROLINA R5DULATIONS '
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From: Richard Woodruff To: Stephen Salomon Date: Thu, Jul 29,199911:00 AM
Subject:
REVIEW OF SOUTH CAROLINA REGULATIONS Good morning!
During the SC IMPEP, the team determined that SC had revised their RAM regulations in 1996 and again in 1998, but these revisions were not provided to NRC for review and comment, and hence the SC revisions have not been processed under SA-201 procedures.
Following the IMPEP, I contucted a review of the regs that were revised, and drafted the attached letter.
The letter was modified to reflect the facts.
Request that tne reg review be coordinated and processed in accordance with the SA-201 procedure, and notification be made to the State. Their were no comments developed during the reg review, SC typically adopts regs needed for compatibility essentially as published by NRC CC: Brenda Usilton GRAol WP I
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TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS l STATE: SOUTH CAROLINA l NRC REG: LICENSING AND RADIATION SAFETY REQUIREMENTS FOR 1RRADIATORS (58 FR 7715), EFFECTIVE 07/01/93 STATE REG: RADIOACTIVE MATERIALS REGULATIONS 61-63, TITLE A, PART XI
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DATE REVIEWED: JULY 27,1999 NRC CAT REGULATION STATE COMMENTS REG REG 36.1 C Purpose and Scope 11.1 Essential objectives l (para (b) and (c) met 36.2 C Definitions Irradiator 11.2.3 Essentially identical 36.13 D/H&S Specific Licenses for 11.3 Essentially identical Irradiators 36.21 B Performance Criteria for 11.7 Essentially identical l sealed sources I
36.23 D/H&S Access Control 11.8 Essentially identical 36.25 D/H&S Shielding 11.9 Essentially identical 36.27 D/H&S Fire Protection 11.10 Essentially identical 36.29 D/H&S Radiation Monitors 11.11 Essentially identical 36.31 D/H&S Control of source 11.12 Essentially identical movement 36.33 D/H&S Irradiator pools 11.13 Essentially identical 36.37 D/H&S Power failures 11.15 Essentially identical 36.39 D/H&S Design requirements 11.16 Essentially identical 36.41 D/H&S Construction monitoring 11.17 Essentially identical
& acceptance testing 36 51 D/H&S Training _
11.18 Essentially identical 36.53 D/H&S Operating & Emergency 11.19 Essentially identical procedures 36.57 D/H&S Radiation Surveys 11.21 Essentially identical
South Carolina Regulations Page 2 of 2 36.59 D/H&S Detection of leaking 11.22 Essentially identical sources I 36.61 D/H&S Inspection & 11.23 Essentially identical maintenance 36.63 D/H&S Pool water purity 11.24 Essentially identical 36.65 D/H&S Attendance during 11.25 Essentially identical operation 36.67 D/H&S Entering and leaving the 11.26 Essentially identical irradiation room 36.69 D/H&S !rradiation of explosive or 11.27 Essentially identical inflammable materials 36.83 C Reports 11.29 Essentially identical I
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oA TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CA ROLINA RADIOACYlVE MATERIALS REGULATIONS 61-63, TITLE A NRC REG: DECOMMISSIONING RECORDKEEPING AND LICENSE TERMINATION: DOCUMENTATION ADDITIONS p p)7 5 I99 3 -l (58 FR 39628), EFFECTIVE OCTOBER 25,1996 l TIMELINESS IN DECOMMISSIONING OF MATERIAL LICENSES l
(59 FR 36026), EFFECTIVE AUGUST 15,199f[ {g 75 /99 4-J STATE REG: FINANCIAL ASSURANCES AND RECORDKEEPING FOR DECOMMISSIONING (RHA 1.15 and 2.11) l DATE REVIEWED: JULY 27,1999 NRC REG CAT REGULATION STATE COMMENTS REG 30.35 (a), D/H&S Financial assurance 1.15.1 Thru Essentially identical (b),(d),(g) and recordkeeping for 1.15.11 decommissioning 30.36(c), D/H&S Expiration and Termin- 2.11.3 thru Essentially identical l (d),(e),(g), ation oflicenses and 2.11.6 l (h),(j), (k) decommissioning of sites and separate buildings or outdoor areas l
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35.406(a) H&S Brachytherapy sources 4.13.4 Essential Objectives ok I inventory f4 35.406(c) H&S (same) 4.13.4.3 Essential Objectives ok 35.610(a) H&S Safety instruction 4.14.4.1.1 Essential Objectives ok l (1) l 35.615(d) H&S Safety precautions 414.94 Essential Objectives ok (3) and and (e) 4.14.9.8 1
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g i TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS 1
STATE: SOUTH CAROLINA l ADIOACTIVE MATERIALS REGULATIONS 61-63, TITLE A
( l NRC REG: PREPARATION, TRANSFER FOR COMMERCIAL DISTRIBUTION, AND USE OF l BYPRODUCT MATERIAL FOR MEDICAL USE. (59 FR 61767 & 59 FR 65243) I EFFECTIVE AUGUST 15,1994 j ,7 STATE REG:
9 NRC CAT REGULATION STATE COMMENTS REG REG 35.2 Definitions C Authorized User 4.2.5 Essential objectives ok C Medical Use 4.2.13 Essential objectives ok l C Written directive 4.2.29 Essential objectives ok 35.11(a) [C] License required 4.3 Essential objectives ok
& (c) 35.?2(a) H&S Quality management 4.16.1.2 & Essential objectives ok (2) and program 4.16.2.1.1 (b)('. )(i) 35.53(a), H&S Measurement of dosages 4.8.4.1 & Essential objectives ok (b) of unsealed byproduct 4.8.4.2 material for medical use.
35.100 H&S Use of unsealed 4.9.1 Essential objectives ok byproduct material for uptake, dilution, and excretion studies 35.200 H&S Use of unsealed 4.10.1 Essential Objectives ok byproduct material for imaging and localization studies 35.300 H&S Use of unsealed 4.11.1 Essential Objectives ok byproduct material for therapeutic administration l 35.404 C Release of patients or 4.13.5 Essential Objectives ok human research subjects treated with temporary implants f
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. TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CAROLINA RADIOACTIVE MATERIALS REGULATION 61-63, TITLE A NRC REG: FREQUENCY OF MEDICAL EXAMINATIONS FOR USE OF RESPIRATORY PROTECTION EQUIPMENT (60 FR 7900), EFFECTIVE MARCH 13,1995 8f-YTS l%%
STATE REG: STANDARDS FOR PROTECTION AGAINST RADIATION (PART 3)
NRC CAT REGULATION STATE COMMENTS REG REG 20.1703 H&S Use ofindividual 3.19.3.3.1.5 Identical respiratory protection equipment l
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l TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CAROLINA RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A NRC REG: PERFORMANCE REQUIREMENTS FOR RADIOGRAPHY EQUIPMENT PART 34 {60 FR 28323), EFFECTIVE JUNE 30,1995 {p73 Nkb STATE REG: SPECIAL REQUIREMENTS FOR INDUSTRIAL RADIOGRAPHY OPERATIONS, PART V f NRC CAT REGULATION STATE COMMENTS REG REG 34.20(a) B Performance 5.6 Essentially identical (2) requirements for l
radiography equipment 34.20(f) B 5.6 Essentially identical j l
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1 N I TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CAROLINA RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A REGULATION: RADIATION PROTECTION REQUIREMENTS: AMENDED DEFINITIONS AND CRITERIA (60 FR 36038), EFFECTIVE AUGUST 14,1995. j Q Cf p [
i STATE REGULATION: PART VI- NOTICES, INSTRUCTIONS, AND REPORTS TO l WORKERS; INSPECTIONS PART lil- STANDARDS FOR PROTECTION AGAINST ,
RADIATION l NRC CAT REGULATION STATE REG COMMENTS l REG '
19.12 C Instruction to workers RHA 6.3 Essential objectives ok 20.1003 Definitions: Essentially identical i A Member of the public 3.2.43 (needs to be revised A Occupational dose 3.2.48 as per 62 FR 4120, A Public dose 3.2.52 that later became i effective 5/29/97) 20.2104 Determination of prior 3.37 Essential objectives ;
C* occupational dose ok 20.2205 C Reports to individuals of 3.48 Essential objectives exceeding dose limits ok C*= This normally is a "D", but should be a "C" if the State chooses to adopt the " planned special exposure" provisions.
TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CAROLINA RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A NRC REG: CLARIFICATION OF DECOMMISSIONING FUNDING REQUIREMENTS:
ADDED DEFINITIONS AND CRITERIA (PARTS 30,40,70,& 72)
(6 FR 38235), EFFECTIVE OCTOBER 20,1995 RAE jcq{f STATE REG: RHA 1.15 FINANCIAL ASSURANCES AND RECORDKEEPING FOR DECOMMISSIONING RHA 2.11 EXPIRATION AND TERMINATION OF LICENSES AND DECOMMISSIONING OF SITS AND SEPARATE BUILDINGS OR OUTDOOR AREAS h
NRC CAT REGULATION STATE COMMENTS REG REG 30.35(b) D Financial assurance and 1.15.4.2 Essential objectives ok (2) H&S recordkeeping for decommissioning 30.35(e) D Expiration and termination 1.15.9 Essential objectives ok 4 H&S of licenses and decommissioning of sites l and separate buildings or l outdoor areas 1 30.36(h) D (same) 2.11.7 Essential objectives ok (2)(i) H&S 30.36(j) D (same) 2.11.9 Essential objectives ok j (1) H&S 30.36 (j) D (same) 2.11.9 Essential objectives ok (2)(i)8. H&S
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I 30.36(k) D (same) 2.11.10 Essential objectives ok H&S
- l 30.35 is Category D, with H&S for paragraphs (a),(b), and (d) only 30.36 is Category D, with H&S for paragraphs (c),(d),(e),(g),(h),(j), and (k) j i
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TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS STATE: SOUTH CAROLINA l RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A '
NRC REG: MEDICAL ADMINISTRATION OF RADIATION AND RADIOACTIVE MATERIALS: PARTS 20 AND 35 (60 FR 48623), EFFECTIVE -
OVEMBER 24,1995 2 P.T5 [ aI STATE REG: PART IV, USE OF RADIONUCLIDES IN THE HEALTH PROFESSIONS 4
NRC CAT REGULATION STATE COMMENTS REG REG i l
35.2 C DEFINITIONS: 4.2.15 Essential objectives ok l Misadministration r \
35.33(a) C Notifications, reports, and 4.7.9.1 Essential objectives ok (2),(3), records of l
(4), misadministrations 35.33(b) C (same) 4.7.9.2 Essential objectives ok 35.33.(c) C (same) 4 7.9.3 Essential objectives ok Note: For misadministrations, reg should adopt the quantitative values to meet the essential objectives.
l For definitions, the statement of considerations replaces the word " patient" with the word
" individual" for clarification.
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TABLE FOR COMPARISON OF STATE REGULATIONS WITH NRC REGULATIONS
. S TATE: SOUTH CAROLINA RADIOACTIVE MATERIAL REGULATIONS 61-63, TITLE A NRC REG: TERMINATION OR TRANSFER OF LICENSED ACTIVITIES:
RECORDKEEPING REQUIREMENTS (61 FR 24669), EFFECTIVE MAY 16, 1996
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STATE REG: HA 1.15 FINANCIAL ASSURANCES AND RECORDKEEPING FOR DECO MMISS lONIN G
RHA 2.11 EXPIRATION AND TERMINATION OF LICENSES AND DECOMMISSIONING OF SITES AND SEPARATE BUILDINGS OR OUTDOOR AREAS PART Vil LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE REVIEW DATE: JULY 26,1999 NRC REG CAT REGULATION STATE COMMENTS REG 20.2108(b) D Records of Waste Disposal 30.35(g) H&S Financial assurance and 1.15.11 Essential objectives ok .
40.36(f) recordkeeping for decommissioning 30.36(k)(4) H&S Expiration and 2.11.10.4 Essential objectives ok 40.42(k)(4) termination oflicenses and decommissioning of sites and separate buildings or outdoor areas 30.51(d), H&S Records 2.11.9 Essential objectives ok (e), (f) 40.61(d), Material balance, (e) and (f) inventory and records 70.51(b)(7) requirement 61.30(a)(3) H&S Transfer of license 7.15.3 Essential objectives ok 61.30(c)(3) Termination oflicense 7.16.3.4