ML20246H014
| ML20246H014 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1998 |
| From: | Hackney C NRC |
| To: | Bangart R, Belke W, Ross R NRC |
| Shared Package | |
| ML20246G975 | List: |
| References | |
| NUDOCS 9803250196 | |
| Download: ML20246H014 (5) | |
Text
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Charles Hackney F?
To:
RLB2, RAS 1,WLB l-Date:
'2/18/98 2:04pm Subjects Louisiana Letter I
' Region IV. comments on DRAFT LETTER'for Mr. Spell. At the end of paragraph 2.
.After " applying for a specific license". Add, This happens automatically by-l-
virtue of 10 CFR 150.20 (a) once the notification requirements to the State are met Page-2, first paragraph,.line nine, likely.. change by to be.
Mr. Scarano, Mr. Brown (legal council) and myself are in agreement. That is all that,we have as:far as comments.
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9803250196 980316 F
PDR STPRC ESOLA PDR a_-______-________-____________
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ROUTING AND TRANSMITTAL SLIP 1
L DATE: FEBRUARY 6, 1997 PARALLEL CONCURRENCE REQUESTED
$ [rd INITIALS DAll
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N. E 2/
/98 PE".5C;;0TT, RTY-8 2/
/98 E.b JE.2/elm NWW 5-Mope.htm LETTER T0:
WILLIAN H. SPELL, ADMINISTRATOR RADIATION PROTECTION DIVISION LOUISIANA DEPARTNENT OF ENVIR0 MENTAL QUALITY l
FRON:
RICHARD L. BANGART, DIRECTOR OFFICE OF STATE PROGRANS
SUBJECT:
INSPECTION AGREENENT BETWEEN NRC Am LOUISIANA YOUR COMENTS/ CONCURRENCE ARE REOUESTED BY COB FEBRUARY 13. 1998.
OSP CONTACT:
RICHARD L. BANGART (415-3340) i PLEASE CALL KATHALEEN KERR (415-3340) FOR PICK UP.
l 1
2 l
i William H. Spell i L
l f-Nevertheless, the inconsistency in Part 150 does not prohibit Louisiana from providing waivers to the three-day requirement. The scope of functions delegated to the State stem from the rule j
in $150.20 and the inspection Agreement itself. As such, NRC may delegate the waiver function to the Agreement State either by changing the rule in $150.20 or by amending the Agreement in some form. As previously discussed with you, a "subagreement" to the existing 2741 inspection Agreement is proposed That "subagreement" would delegate to the State of Louisiana the authority to approve offshore work by Louisiana licensees under the reciprocity provisions of 10 CFR Part 150 with less than 3 full days notice. The "subagreement" could likely by signed by the NRC Region IV Administrator and an appropriate State of Louisiana high l
level official. Because of the policy issues related to the "subagreement," the Commission should be informed before it is signed. We plan to jointly develop the draft language for the.
"subagreement" with you before it is transmitted to the Commission.
The need remains to inform Louisiana licensees of the NRC and State of Louisiana regulatory 1
jurisdictions and responsibilities in offshore waters, of the need for Louisiana licensees to file requests to work under the reciprocity provisions of 10 CFR Part 150 when conducting operations in offshore waters, and of the need for Louisiana licensees to use radiography equipment that satisfies 10 CFR 34.20 requirements when working under reciprocity in areas I
where NRC has jurisdiction. NRC requests that the letter that was jointly drafted by NRC and l
Louisiana staff, titled " Performing Licensed Activities in Areas of NRC Jurisdiction, including l
Non-Agreement States, Federal Facilities, and Off-Shore Waters," be mailed to Louisiana industrial radiography licensees.
Finally, we recommend promptly scheduling a meeting to discuss the items identified in the enclosed draft agenda. Mr. Charles Hackney, NRC Region IV State Liaison Officer, will contact you to schedule a date for the requested meeting.
1 If you have questions, please contact me at (301) 415-3340 or James Myers of my staff at (301)415-2328.
Sincerely, Richard L. Bangart, Director Office of State Programs i
Enclosure:
l As stated 1
l Distnbution DIR. RF (7S259)
DCD (SP08) i SDroggitis PDR (YES/)
l HNewsome Louisiana File T7 eseelve a esp ' of Wits clocument, indlcato in the box: "C"
- Copy without eb r._f DOCUMENT NAME: G:UHM\\LOUISIAN.WPD Q
-?e T" e Copy with 800Chment/enCiosure "N" = No copy OFFICE OSP l
40dC" l RIV l
lMNS:D l
OSP:D
[_
NAME JHMyers:gd PHLohaus PFXCameron EMerschoff DCool RLBangart DATE 10/29/97*
10/30/97*
02//g /98 02/ /98 02/ /98 02/ /98 i
01/08/98*
01/08/98*
t, l
9e pyg (gg OSP FILE CODE: SP-AG-12 L
l l
Willi;m H. Spell -
?
Nevertheless, the inconsistency in Part 150 does not prohibit Louisiana fr m providing waivers to the three-day requirement. The scope of functions delegated to the S te stem from the rule in $150.20 and the inspection Agreement itself. As such, NRC may del gate the waiver i
function to the Agreement State either by changing the rule in $150.20 r by amending the Agreement in some form. As previously discussed with you, a "suba eement" to the existing 2741 inspection Agreement is proposed. That "subagreement" would elegate to the State of J
Louisiana the authority to approve offshore work by Louisiana licen es under the reciprocity provisions of 10 CFR Part 150 with less than 3 full days notice. Th "subagreement" could likely by signed by the NRC Region IV Administrator and an appr riate State of Louisiana high level official. Because of the policy issues related to the "subagr ment," the Commission should be informed before it is signed. We plan to jointly develo the draft language for the "subagreement" with you before it is transmitted to the Commis ion.
The need remains to inform Louisiana licensees of the NRC d State of Louisiana regulatory jurisdictions and responsibilities in offshore waters, of the ne d for Louisiana licensees to file requests to work under the reciprocity provisions of 10 CF art 150 when conducting operations in offshore waters, and of the need for Louisian licensees to use radiography equipment that satisfies 10 CFR 34.20 requirements whe working under reciprocity in areas where NRC has jurisdiction. NRC requests that the lette that was jointly drafted by NRC and Louisiana staff, titled " Performing Licensed Activities in reas of NRC Jurisdiction, including Non-Agreement States, Federal Facilities, and Off-Sho e Waters," be mailed to Louisiana industrial radiography licensees.
Finally, we recommend promptly scheduling a meeti g to discus.: the items identified in the enclosed draft agenda. Mr. Charles Hackney, NR Region IV State Liaison Officer, will contact you to schedule a date for the requested meeting.
If you have questions, please contact me at (301 415-3340 or James Myers of my staff at (301)415-2328.
Sincerely, Richard L. Bangart, Director Office of State Programs
Enclosure:
As stated Distribution:
DIR. RF (7S259)
DCD (SP08)
SDroggitis PDR (YES/)
HNewsome Louisiana File DOCU'JENT NAME: G:\\JHM\\LOUISIAN PD Tt receive a cop r of this document. Indicate in the box: "C" e opy without attachment / enclosure T s Copy wrth attachment / enclosure "N" s No co y I
OFFICE OSP l
OSP:%D l
OGC l
RIV l
lMNS:D OSP:D NAME JHMyers:gd PHLohap6s
,1 FXCameron EMerschoff DCool RLBangart DATE 10/29/97*
10/30/97W 11/
/97 11/
/97 11/ /97 01/ /98 DATE 01rf/98 Qi/ d /98' 01/
/98 01/
/98 01/
/98 01/
s <*
William H. Spell 2
$150.20 and the inspection Agreement itself. As such, NRC may delegate the waiver f ction to the Agreement State either by changing the rule in $150.20 or by amending the Ag
- ment, if both NRC and the State determine that this is the desirable course of action, they ay jointly amend the $274i Agreement to indicate that this function has been delegated to t State.
If you have questions, please contact me at (301) 415-3340 or James Myers my staff at (301)415-2328.
Distribution:
DIR. RF (7S259)
DCD (SP08)
SDroggitis PDR (YES/)
FXC:meron i
HNewsome EMerschoff, RIV Lcuisiana File DOCUMENT NA
- G:UHMtLOUISIAN PDA l
w r.c.h,.. co,, or inw wn.ne. inae.w in in. noc c c
,l/4.ti.cnm.nv ncio.ur. r cop, witn.it.cnm.nie.nao.or. w wo copy OFFICE
NAME
- lMyers:gdQF' PHLotiaus I RLBangart i
DATE
/
106%, 9'7 106D/97 10/ /97 i
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