ML20154L015
| ML20154L015 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1998 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Hirschler B CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS |
| Shared Package | |
| ML20154L018 | List: |
| References | |
| NUDOCS 9810190116 | |
| Download: ML20154L015 (6) | |
Text
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{ WASHINGTON, D.C. enana -1 l October 6, 1998
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l Mr. Bruce Hirschler I Technical Assistant, SSRCR's Office of Executive Director i Conference of Radiation Control Program Directors, Inc. l 205 Capital Avenue Frankfort, KY 40601 1
Dear Mr. Hirschler:
As requested in your letter of June 18,1998, we have completed the review of Part E -
Radiation Safety Requirements for Industrial Radiographic Operations dated May 1998. That regulation was adopted by the Board of Directors of the Conference of Radiation Control Program Directors, Inc. (CRCPD) on June 12,1998. The proposed regulation was reviewed by comparison to the equivalent regulation,10 CFR Part 34.
As a result of our review, we have two comments that have been identified in the enclosure.
These comments will need to be addressed to meet the compatibility category of the equivalent NRC regulation. The comments were discussed with Mr. David Turberville, Committee Chair, who agreed that the comments could be adopted.
1 Also, we have one comment regarding the Rationale for Revisions to Part E. A revision of the Compatibility Requirements section should be considered because of the new adequacy and compatibility policy statement approved by the Commission by Staff Requirements Memorandum dated June 30,1997. In the section titled, " Compatibility issues" the following information should be inserted in place of the current paragraph:
The various provisions of the 10 CFR Part 34 regulation are assigned different compatibility and health and safety categories. Definitions of each category and the specific category assigned to each provision of 10 CFR Part 34 are set out in U.S. [
Nuclear Regulatory Commission, Office of State Programs Internal Procedure B.7, Compatibility Categories and Health and Safety identification for NRC Regulations and
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Other Program Elements. They reflect the new adequacy and compatibility policy statement approved by the Commission by Staff Requirements Memorandum dated i June 30,1997 (see also 62 FR46517). Agreement States should consult the B.7 procedure to determine the compatibility category assigned to each 10 CFR Part 34 section.
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Bruce Hirschler g.0 61998 Finally, Section E.17.c.li, the SSR equivalent to NRC's 10 CFR Part 34.43(c)(3) is identified as a "D" level of compatibility. Therefore, E.17.c.il presently meets compatibility requirements.
However, a change in Part 34.43(c)(3)'s compatibility status appears to be necessary given the importance of this requirement and need to have consistency in training requirements to reduce trans-boundary impacts. Any proposed changes to this requirement, will be provided to the Agreement States and CRCPD for review and comment.
We requect that when this suggested State regulation is published as a final regulation, a copy of the "as published" regulation be provided to us for review. As requested in our All Agreement States Letter SP-96-027,"Reauest to Hiahliaht Chances to Aareement State Reaulations Submitted to NRC for Comoatibility Review"(March 1,1996), please highlight any i final changes and send one copy in a computer readable format, if possible.
l If you have any questions, please contact me at (301) 415 2326 or Jim Myers of my stati at (301) 415-2328 or JHM@ NRC. GOV. i I
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Paul H. Lohaus, De ty D ector l Office of State Programs
Enclosure:
As stated i
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't COMMENTS ON SUGGEST STATE REGULATION, PART E .
Division NRC Regulat!gn SSB Sublect and Comments B 34.46 E.19 This section is designated Category B which means it should be adopted using estentially identical language due to significant direct trans-bour.fary implications. The SSR section, as written, would require 6 rect supervision only during the times that the Assistant is uring the exposure device or source. The SSR section is not worded broad enough to assure that all aspects of the radiographer assistant's work will be personally and directly supervised by a radiographer. The intent of this requirement is to assure personal supervision any time a radiographer's assistant uses a radiography device, its associated equipment or a sealed source. Therefore, the words " radiographic exposure devices, associated equipment or sources of radiation" should be used in place of the words sources of radiation."
B 34.71(a)(2) E.29.a.ii This section is also designated Category B. The SSR Section does not require both the identity and signature of the radiographer in the utilization log. Therefore, the word "and" should be used in place of "or" in E.29.a.ii.
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- Bruce Hirschler OCT 0 61998 i
l Finally, Section E.17.c.ii, the SSR equivalent to NRC's 10 CFR Part 34.43(c)(3) is identified as l
a "D level of compatibility. Therefore, E.17.c.ii presently meets compatibility requirements.
However, a change in Part 34.43(c)(3)'s compatibility status appears to be necessary given the importance of this requirement and need to have consistency in training requirements to reduce
! trans-boundary impacts. Any proposed changes to this requirement, will be provided to the j Agreement States and CRCPD for review and comment.
We request that when this suggested State regulation is published as a fi .al regulation, a copy of the "as published" regulation be provided to us for review. As req',ested in our All Agreement States Letter SP-96-027,"Reauest to Hiahliaht Chanaes to Aareement State Reaulations Submitted to NRC for Compatibility Review" (March 1,1996), please highlight any final changes and send one copy in a computer readable format, if possible, l if you have any questions, please contact me at (301) 415-2326 or Jim Myers of my staff at (301) 415-2328 or J' IM c @ NRC. GOV.
! Sincerely, Original Signed By:
l PAUL H. LOHAUS l
Paul H. Lohaus, Deputy Director Office of State Programs l
Enclosure:
As stated l
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Distribution:
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If you ha any questions, please contact me or Jim Myers of my staff at (301) 415-2328 or JHMONR . GOV, i ,
Sincerely, Paul H. Lohaus, Deputy Director l; Office of State Programs
Enclosures:
As stated l \
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Distribution:
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DCD (SP03)
- SDroggitis . PDR (YES/)
LBolling TO'Brien EWeeerCQ e CRCPD File DOCUMENT NAME: G:\JHM\PART-E.JHM l
' tr receive a ese r of thle document, Indicate in the bou: "C" = Copy without attachment /s ure *E" = Copy with attachment / enclosure 'N' = No copy !
l OFFICE- OSP r W t OSP:DD l NMS$1MNS l OGC l OSP:D __
l- NAME JHMyers:nb " PHLohaus - DCool \ FXCameron RLBangert L DATE- 08/M /98 08/ /98 08/\ /98 08/ /98 08/ /98 l OSP FILE CODE: SP-C-7
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Bruce Hirschler .
l if you have any questions, please contact me at (301) 415-2326 or Jim Myers of my staff at (
, (301) 415-2328 or JHMONRC. GOV. ;
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i Sincerely,
{
l Paul H. Lohaus, Deputy Director }
Office of State Programs L
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Distribution:
DlR RF (74iWe6) 95 / </0 DCD (SP03)
SDroggitis PDR (YES/)
LBoll;ng TO'Brien l
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- CRCPD File
- . *See previous concurrence DOCUMENT NAME
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. DATE 08/11/98* 08//198 08/ /98 08/16/98 08/ /98 OSP FILE CODE: SP-C-7 i
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