ML20207P168

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Responds to Re Planned Changes to Dept of Nuclear Safety Radiation Protection Rules.Changes Proposed in Response to Category I Comments Contained in Author to Seiple Satisfactorily Address Concerns
ML20207P168
Person / Time
Issue date: 04/23/1986
From: Nussbaumer D
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Salus B
ILLINOIS, STATE OF
Shared Package
ML20207P159 List:
References
NUDOCS 8701150145
Download: ML20207P168 (3)


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[ lis. Betsy Salus

! Staff Legal Counsel Department of !!uclear Safety

1035 Outer Park Drive Springtield, Illinois 62704

Dear Hs. Salus:

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Thank you for your letter of April 10, 1986 to Joel Lubenau concerning the planned changes to the Department's radiation protection rules. We also appreciated the opportunity to neet you on April 14, 1986 to discuss our coments on the planned changes.

We believe that the changes proposed in response to our Category I coments contained in ny March 5,1986 letter to Mr. Seiple satisfactorily address those concerns.  ;

I Ue also reviewed with ycu the changes proposed in response to our other I coments and to those submitted by other comentors. We found these to be acceptable with the following exceptions:

o The proposed change to Section 330.400(b)(4) should not include the IRC as a possible transferee of radioactive l materic1. He consider the need to delete !!RC to be Category I coment, o In Section 330.40(c)(4) and, we understand, elsewhere in the regulations, the phrase "these regulations" is to be replaced by "this Part." To ensure that no misunderstanding occurs, when "this Part" is used in lieu of "these regulations" in the context of exemptions from the regulatica, it shculd be acconpanied by an explanation that it means codes 310, 320, 330, 340, 350, 351, 370, 400 and 601 or equivalent language.

Since this can affect the interstate distribution of certain radioactive materials to persons exempt from regulation we must identify this as4 a Category I comment.

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o You may wish to modify your response to the Anershan coment concerning A3 and A., values for certain sources of An and Pu.

A limited exemption'for these sources exists in Illinois' present proposed regulations at 341.40c)2) which corresponds to the flRC exemption provided in 10 CFR 71.10(b)(2).

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Ms. Setsy Salus I' IDMS seems to have made excellent progress in their draf ting the revision to the regulations and the staff should be commended. We will look forw rd to continulag to working with the State on the proposed Section 274b agreement.

Sincerely, sa aginal Si&D#d UI p.ausabeumer Donald A. Ilussbatmer Assistant Director for State Agreements Program Dffice of State Programs Distribution:

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