ML20212J859
| ML20212J859 | |
| Person / Time | |
|---|---|
| Issue date: | 10/28/1986 |
| From: | Lubenau J NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Salus B ILLINOIS, STATE OF |
| Shared Package | |
| ML20210H056 | List:
|
| References | |
| FOIA-87-47 NUDOCS 8703090156 | |
| Download: ML20212J859 (3) | |
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l Ref: SA/J0L l 001 C 6 BU Ms. Betsy Salus Staff Legal Counsel Department of Nuclear Safety 1035 Outer Park Drive Springfield, Illinois 62704
Dear Ms. Salus:
The NRC staff's recent review of the Septenber 8,1986 draft prcposal for a Section 274b Agreement uncovered some typographical errors and resulted in a few other minor editorial suggestions for the regulations.
Since the regulations were adopted September 25, 1986, we elected to separate these editorial coments from our other coments on the dref+
proposal which we provided to Dr. Lash on September 29, 1986. We have received the corrected copies of Part 310, Illustration A for Part 3a0 and Appendix B to Part 351. We will make appropriate distribution of '
these documents.
. The editorial coments are enclosed (enclosure 1). Also enclosed, is a copy of an NRC file meno concerning 2 omissions fron the IDNS regulations which NRC staff had not identified earlier (enclosure 2).
As noted in the meno, IDNS staff have agreed to implenent adninistrative arrangements that will satisfactorily address these omissions until the regulations are revised appropriately and wc have received Paul Eastvold's October 3,1986 letter confiming this.
Sincerely,
,,..1 signedDTI 3.,O.Lubenaa l 8703090156 870226 Joel 0. Luknau PDR FOIA Senior Project Manager RADERB7-47 PDR State Agreements Program Office of State Programs
Enclosures:
As stated j cc: P. Eastvold, IDNS, w/encls.
! Distribution:
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Dir R/F J01.ubenau Illinois file (fc) w/ enc 1 p 1
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NIC FORM MS 00-40) NRCM ONO OFFICIAL RECORD COPY -
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Enclosure 1
, Comments on~ Illinois Reoulations
~ 310.10 - typo 1st line: " applies" rather than " apply."
310.20 - There is a typo in definition of " rem," " dose" instead of "does"(topof^page).
330.30(c) - does not contain exemptions for glassware, glass enamel etc.
as~describedin10CFR40.13(c)(2)(iii)&(iv). (See 2nd enclosure.)
, '330.220(h)(4) - need to close quotation marks after " General License " ,
5th line.
330.260(c)(2)(B)(ii) - There seems to be no Illinois regulation equivalent to 10 CFR 30.34(g). Thus, Illinois broad licensees and ;
nuclearfor eluates pharmacies Mo-99. (See are2nd notenclosure required. by) regulation to test generator 330.260(d)(1)(E) - recommend consistency in teminology - e.g. ,
radiogra '
plurals)phers' assistants' (note placement of apostrophe and "s" for 330.270(e)(1)(B) - allows possession of devices.containing up to 100,330-C1, while 10 CFR 33 only allows up to 100,000 curies.
- ' 330.280(d) - typo: delete "r" from " manufacturer."
[ 330.280(e)(2) - refers applicant to the reporting requirements in 10 CFR 32.56 - instead should require reporting to Illinois.
330.280(h)(5) - typo, 3rd line: "stori "
Also, line 6 should read, "Thedirectionsthatthisitemmust..g. .
330.400(c) - typo, 7th line: " transferred " .
330. App. B - certain isotopes exempt quantities are allowed to be up to 1330 uCi while 10 CFR 30.71 limit is 1000 uCi.
330 App. C Group III - typo: inf),2ndline,spellingof" material."
330. App. D - certain isotope limits exceed those specified in 10 CFR 330.100. (Same problem as in App. B).
Section 340:- Either definitions for terms such as " stability" and -
" chelating agent" should be provided in Section 340, or reference shculd be made to Section 601 and definitions included there.
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' 6-340.1030(a)(1) - correct address; there is of Office of. Standards Development at NRC any more; it is now Office of Regulatory Research.
340.2020(e)(1) - typo: next to last line, " Dosimetry Testing."
350.1010 - Typo: 7th line, " containers."
350.2010(d) - only requires annual audits of each radiographer rather than every 3 months as specified in 34.11(d) (effective 7/16/86).
351.4010(d) - We strongly suggest that IL consider deleting the exceptions for H-3, C-14 and S-35 in this section. As written this would allow a field flood licensee, who may use multi-curie quantities-of H-3 or multi-millicurie quantities of C-14 and S-35 to unknowingly walk'away from a contaminated site. Il should note that this'section was not included ir the proposed Part 39.
370.30(a)(2) - typo, 5th line: " quantities."
370.30(b)(1) - number missing in text, 3rd line: "10microcuries."
General Note on Part 601: - Performance Objectives and Technical Requirements are referred to generically throughout the Part, the sections containing these elements should be specifically labelled
" Performance Objectives" and " Technical Requirements."
Section 601.110 c & d. The phrace, "... including equipment, facilities and procedures" ... should be in parentheses to avoid ambiguity.
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.J 0CT 3W Ref: SA/J01.
MCHXA4WM FCr,: -1111ents File Fmi:
Jozl 0. Lubenau '
See.ior Project Nr49cr St6to Agreements Prograr.
Office of State Prograes
SUBJECT:
ILLit!0!5 PROGRAM C90:!TMIKTS During the weeks of September ?? 4 79, 1986 1 spoke with Paul Eastvold, IDNS concerr.ing certain minor problems ideatified during the RRC staff review ef the September 1986 redrafted progras descriptier.. Thase warr.
resolved as follows:
- 1. The IONS regulations (which were adopted September 25, 1996) dc rot eer.tain lar.guage equivalent to 10 CFR 30.34(g). This requirenest is needed to assure a regulatery requirecert exists for poly breakthru tests for nuclear pharwscies trd i
' broad medica) licensees. 1111pois will add this requirenest to their regulations at the aest revisice. In the interin, ID!!S will use a standard condittor, equivalent to 10 CFR 30.34(c) for its broad medical and nuclear phamacy licenses.
When the Agreement becemes effective. IDMS will review these licenses to detemine the need for the condition, i
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- 2. ID'ts reculatioes inadvertently ceitted s's examptien for source i
I material equivalent to 10 CFR 40.13(c)(?)(iii) 8 (iv). This will be added le the next revision. In the interin, IDNS steff will be instructed not to cite persons possessing the subject source material .fer possession cf material without a license.
Joel C. Lubenau Senior Project N eager i State Agreempts Progr:n Office of State Program cc- P. Ea'.tve 01strfbut1on:ld, !N:5 SA R/F Dir R/F Illinois file RLickus. RIII WLubenau SA JOLabenau/bh
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