ML19332E410
| ML19332E410 | |
| Person / Time | |
|---|---|
| Issue date: | 11/29/1989 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 8912070186 | |
| Download: ML19332E410 (2) | |
Text
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m NOV 2 91989 FC/584
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MEMORANDUM FOR: Carlton Kamerer, Director State, Local, and Indian Tribe Programs-Office of Goverraental l
and Public Affairs FROM:
Robert M. Bernero, Director
' Office of Nuclear Material Safety l
and Safeguards
SUBJECT:
REVIEW OF POLICY ON LICENSING OF CONTRACTORS WHO PERFORM DECOMMISSIONIt!G ACTIVITIES In response to your memorandum dated October 20, 1989, we have reviewed the issue of licensing of contractors who perform decommissioning activities. This included a review of the application for a license made
-to Region V by Diversified Scientific Services, Inc. and of the response from Region V to the applicant (both of which were enclosed in your memorandum).
Thelicense application from Diversified Services was for the purpose of performing. decontamination and decommissioning work (and thus handling of radioactive material) at an NRC licensed facility,. Building 628 of the McClellan' Air Force Base. Region V returned the application to Diversified Services because "The NRC policy is that contractors who L
perform decommissioning activities at NRC licensed facilities do not L
require separate licenses, but rather perform these operations under the current NRC -license for the facility."
o In reply to your request of NMSS views on the licensing policy in this area, NMSS supports the policy stated by Region V.
NRC has endorsed this policy in issuance of the decomissioning rule,(50 FR 5601) in which it in particular in the Supplementary Information to the Proposed Rule is indicated that "the licensee is responsible for completing decomissioning in a manner that protects health and safety." This policy is in the process of being implemented into practice by the issuance of two supporting regulatory guides on standard format and-content of decomissioning plans for nuclear reactors (draft guide, DG-1005, Sept.
1989) and for materials facilities (active guide 3.65, August 1989).
Both of these guides indicate that licensee radiation protection policies must address contractor activities.
Specifically, DG-1005 indicates that
'"The licensee may choose to accomplish some or all decomissioning L
activities and tasks by using contractors.
However, the responsibility p
for health and safety during decommissioning rests with the licensee and L
all license requirements must be complied with."
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. 1 There are a few-licensees authorized to perform decontamination services at temporary job sites. These licenses were intended to allow service e
companies to possess contaminated equipment at unlicensed sites, or to transport or store contaminated materials. The licenses do not:
authorize activities at-licensed customers' facilities.
For example, a licensed service company could operate at a power reactor site under the reactor operating license, but could transport. residual contamination to another-location under the service company license.
Thus, Chem-Nuclear, Inc. has a license which authorizes decontamination at temporary job sites, but a restriction which prohibits activities at a customers' facility except as authorized by the customers' license. We also r
checked with the resident project manager at Three Mile Island Unit 2, regarding decontamination operations, and he informed us that all operations there are performed under the reactor license.
In summary, based on our current practice, we agree with the licensing policy as stated in the Region V response to Diversified Services.
L (Signed) Robert M. Bernero Robert M. Bernero, Director Office of Nuclear Material' Safety L
and Safeguards Distribution: CentMTE11ef S/ b NMSS r/f LLRB r/f LLRB t/f FCardile TJohnson MBell JSurmeier PLohaus i-L RBangart JGreeves JHickey Directors r/f JGlenn CJenkins
-JLepre JFunches EDavis GBidinger PDR YES
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NO C / ACNW YES / F /
NO
/-~/
SUBJECT ABSTRACT:-
REVIEW OF POLICY ON LICENSING 0F CONTRACTORS WHO PERFORM DECOMMISSIONING ACTIVITIES
- SEE PREVIOUS CONCURRENCE OFC :LLRB*
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NAME:RBer ero :
DATE:jj/47/89 1
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