USDOE Privatization/licensing

["Conklin, Al" <awc0303@hub.doh.wa.gov>]

I have a question for anyone in the NRC, Agreement State Program, USDOE, 
or their prime contractors. Actually, any opinions would be appreciated. 
I'm with the Washington State Division of Radiation Protection. We are an 
Agreement State and have been delegated 40 CFR 61 subpart H and 40 CFR 70 
(Air Operating Permit Program).

USDOE is doing more and more privatization at Hanford, which I have no 
overall problem with. It should save money. But we are exploring 
relatively new territory here on licensing. There are three scenarios:
1. DOE brings in a new "Prime" contractor, which, in turn brings several 
"partners", who may or may not be considered "prime". They are all doing 
work on USDOE land, with USDOE owned waste.
2. DOE is contracting with private companies to come and do work on DOE 
land, with DOE material, but in a facility owned by the private company. 
These companies are definitely not  prime contractors.
3. DOE is also considering bringing in private companies, and leasing the 
land to them to do DOE work, and possibly non-DOE work as well.
We already license the site under state Radioactive Air Emissions 
regulations and 40 CFR 61, subpart H  and are working on the Air 
Operating Permit under 40 CFR 70. We also license some of the X-ray 
equipment brought in by private companies doing short term work, but not 
the other activities I've described. Any opinions on NRC or Agreement 
State  licensing or under the two CFRs would be appreciated.
If you would like to send them directly to me, my internet address is:    
    awc0303@hub.doh.wa.gov