ML20024C215
| ML20024C215 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1983 |
| From: | Ebersole J, Gage K Advisory Committee on Reactor Safeguards, NUCLEAR INFORMATION & RESOURCE SERVICE |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| FRN-48FR12619, RULE-PR-MISC 48FR12619, NUDOCS 8307120417 | |
| Download: ML20024C215 (6) | |
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d Morable Nunzio J. Palladino' Q
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Washipgton, DC 20555
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' Dear Dr.' Palladino
Subject:
ACRS COMMENTS ON REGIONALIZATION OF NRC STAFF. ACTIVITIES During its 274th, 275th, and 276th meetings, February 10-12, Parch 10-12, and April 14-16, 1983, respectively, the ACRS revie.wed the proposed plan for regionalization of certain NRC operations.
I.n this review, we had the
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henefit of a Subcommittee meeting"on February 8,1983 with menbers of the NRC Staff and the information contained in the Draft Policy Statement on Regionalization, SECY-83-14,,. dated January 12, 1983, and the subsequent memora'ndum from the Secretary of the Commission to the Executive Director for Operations on the same subject, dated Parch 7,1983.
, { _,,During_this long period.of interaction'and introspection, we have been able to reach a conclusion, but have been unable to agree on a recommendation:
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Conclusion:==
If there is one among us who fully supports the present
. program and pace for regionalization, he has not made himself known.
Our concerns are several, but all have to do with the po-
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l tential negative impact on reactor safety.
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We have been (so far) unable to arrive at a. col-Recommendation _:
legial recommendation between two alternatives, to which individual members of the Committee are attached:
Stop or defer regionalization until its impact on safety has been nore thoroughly understood.
proceed with extreme caution and attention to specific safety-related concerns.
We hope to discuss this question at greater length, both with you and with each other and hope that, at a minimum, nothing irrevocable is done in the interim, to leave us with a fait accompli.
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8307120417 830419 Jesse C. Ebersole PDR PR Misc 48FR12619 PDR Acting Chaintan
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1346 Connecticut Avenue NW,4th Roor. Washington, D.C. 20036 (202) 2967552 ew f II a
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.y, May 12, 1983' /0 s
Mr. James Asselstine Commissioner
- Nuclear Regulatory Coned.ssion 1717 H Street, NW Wachington, DC 20555
Dear Jir. Asselstine:
We are writing to share with you some concerns ste"4ng from recent information va have received about the NRC's Regionalization program.
As you know, the Nuclear Information and Resource Service isi a national organization serving citizens concarned about nuclear energy.
The particular matter which has come to our attention reflects a disturbing inattention on the part of some NRC staff to ropar process and procedure.
We direct this information to your attention both
(.:cause you are directly affected and because of your customary concern for main-taining proper process and procedure at the-agency.
_._._. ___. m.
.A portion of an KRC document has come into our possession which identifies a numbar of programs within the Division of Fuel Cvele_and Material Scfedy, KMSS ;
of the NRC which have been decentralized to the regions as of April 1,1983.
16 types of materials licenses and three types
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Spacifically, these include:
To the of cmendtients to existing fuel cycle licenses (see attached document).
linowledge of the public (and the Commission), a number of these type's' of -licensing This dis -
responsibilities were not scheduled to be regionalized until FY 84.
crepancy, while relatively minor in itself, is i=portant in that it indicates that the Co._ ission and public are not being accurately informed of NRC staff activities, and that part of the proposed regionalization plan has already b'een implenented prior to written public co= ment and Co= mission and Advisory Co=mittee As this division of licensing covers the prepan-on Reactor Safegyards approval.
darance of total NRC licensing, the scope of the problem takes on added significance.
In light of the extreme controversy of the regionalization program (see ACRS letter,
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^ enclosed), this hasty implementation seems especially inappropriate.
we have reason to believe that the action of this particular division reflects a greving agency-wide tende'ncy to take actions independent of Co-4 ssion cuidance.,
Your investigation into these =atters will be greatly appreciated.
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ACCELERATED DECENTRALIZATION SCHEDULE' DIVISION OF FUEL CYCLE. AND MATERIAL SAFETY l
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F4,, bl /83 PPSAS CODE PROGRAM CDDE ITEM I
1311-10,25,39 M01100, 200 Academic Medical Institutions 1311-11, 21, 31 M02110c 120 Medical Private Practice 1311-12, 22, 32 M02200 Other Medical Licenses 1311-14, 24, 34.
M02400 Measuring % ystems - Gauges, etc.
1311-17, 27, 37 M03120 Services - Leak Test, Installation 1311-1G, 2G, 3G M03220 Broad - No Distribution 1311-10, 20, 30 M03610 Other.Ho Distrib6 tion 1311-1P, 2P, 3P M03620 Civil Defense 1311-1Q, 2Q, 3Q M03710 Plutonium Neutron So.urces and Unencapsulated 1311-1H, 2W, 3W M22110-150 Plutonium Power Sources 1311-1X, 2X, 3X M22110-150 1311-1Y, 2Y, 3Y M22110-150 J abor Expended on SRM 2
Deplet-ed Uranium for Shielding 1311-1R, 2R, 3R M11200 300 2
Subcritical Assemblies 1311-15, 25, 35 M11300 2-Manufacturing of Products 1311-10, 20, 30 M11200, 3002 Other Source Material 1311-1V, 2Y, 3V M11200. 300 licenses for More Than Critical Amounts of SNM, but less Than Critical Amounts 3
(s To Be Located in Any Room or Area 1111-4
. Uranium Fuel Fabrication Licenses for Decontamination / Termination and 4
M21220,'230 lill-D Cl ose-Out. Surveys Advanced Fuel R&D and Pilot Plant Licenses 4
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l fon Decontamination & Close-Out Surveys 1111-92 9 = Zero; O = Alphabet Letter 1.
Some of these licenses are being handled presently by Regions I and III, 2.
The license actions although they have not been specifically delegated.
were forwarded to the two Regions on a case-by-case basis.
On 4/01/83, all of these licenses will be delegated officially to all Regions.
. This is only a portion of the work done under this PPSAS Code (entitled 3.
Complete Licensing Cases for Critical Mass Materials Licensees).
The remainder wi)1 be delegated to the Regions on 4/02/84.
Only the above portions of the PPSAS Codes will be delegated to all five 4.
Regions in April 1983.
The remaining functions will be delegated at a later time.
The first 12 items were delegated to Regions I and III on 5/13/82.
(. NOTE:
-Licenses 2for District of Columbia agencies are included in t ese an h
d subsequent delegations.
Unti.1 further' notice, federal facility licenses will be handled by Headquarters.
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ACCELERATED DECGTRALIIATION SCHEDULE DIVISION OF FUEL CYCLE AND MATERIAL SAFETY
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PPSAS CODE PROGRAM CODE ITEM Teletherapy 1311-13, 23, 33 M02300 Distribution - Radiopharmaceuticals 1311-15, 25, 35 M02500 Medica,gging Well Lu 1311-16, 26, 36
' M03110 Broad - Authorizes Distribution 1311-18, 28, 28 M03211 Other - Authorizes Distribution 1311-19, 29, 39 M03212 Distribution to General Licensees Other Than In Vitro 1311-1A,12A, 3A M03213 Distribution to General Licensees of In Vitro. Kits 1311-1B, 2B, 3B M03213 Nuclear Laundries 1311-1F, 2F, 3F M03218 Corcnercial Low-Level Waste Receipt and/or Prckaging 1311-11, 21, 31 M03232 Radiography - Fixed Facility 1311-1J, 2J, 3J M03310 Radiography - Temporary Job Sites 1311-1K, 2K, 3K M03320 1311-1L, 2L, 3L M03400 Power Source Irradiators - Internal Beam 1311-1M, 2M, 3M M03510 Irradiators - Other 1311-1H, 2N, 3N M03520 e'. J P1 tv..'.;m-Powered Cardiac Pacemakers 1311-1Z, 2Z, 3Z, M22160,161 Ccmp1'ete Licensing Cases for Critical 1111-4)
Mass Materials Licensees Complete. Licensing Cases for Interim 2
Spent Fuel Storage Facilities 1111-5 Perform Interim Spent Fuel Storage Minor 1111-52 Reviews Complete Licensing Cases for Storage of 5
1111-6 Reactor Low-Level Wasta Perform Storage of Reactor Low-Level 1111-61 Waste Major Reviews Perform Storage of Reactor Low-level 1111-62 Waste Minor Reviews b
Licenses for more than critical amounts of SNM, but less than critical 1.
amounts to' be located in any room or area - delegated to Regions on 4/01/83.
2.
PPSAS' Code 1111-51 (Major Reviews) will not be delegated to the Regions.
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(Continued)
ITEM' PPSAS CODE _
PROGRAM CODE
. Complete Licensing Cases for Uranium Fuel 1111-8 R&D and Pilot Plants Perform Uranium Fuel R&D and Pilot 1111-81 Plants Major Reviews Perform Uranium Fuel R&D and Pilot
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Plan 6 Minor Reviews 1111-82 Complett Licensing Cases for Advanced 1111-9
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Fuel R&D and Pilot Plants Perform Advanced Fuel R&D and Pilot 1111-91 Plants Major Reviews Perform Advanced Fuel R&D and Pilot 3
Plants Minor Reviews 1111-9g Conduct Pre-and Post-Licensing Activities 1111-C Complete Licensing Cases for Radiological lill-E Contingency Planning-
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e A portion of this PPSAS Code (licenses for decontamination and c1'ose-out 3.
'sdryeys).was del'egated to the Regions on 4/01/83.
A portion of this PPSAS Code will be retained at Headquarters to cover p
licensing activities, including technical assistance to the Regions, not 4.
being decen"ralized as of 4/02/84.
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ACCELERATED DECENTRALIZATION SCHEDULE b.
DIVISION OF FUEL CYCLE AND MATERI AL SAFETY 10/01/S4 PPSAS CODE PROGP M CODE ITEli Comple1Rt Licensing Cases for Uranium Fuel Fabrication Facilities 1111-1 Perform Uranium Fuel Fabrication 1111-11
, Facility Maior Reviews Perform Uranium Fuel Fabrication
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Facility Minor Reviews 1111-12 Comp 1ste Licensing Cases for Fresh Fuel Storage Only at Reactor Sites 1111-3
'Ferform Fresh Fuel Storage Only Major i
1111-31 0.tv ews Perform Fresh Fuel Storage Only Minor Reviews
.W 1111-32 Processing for Extraction of Oiher Elements
- 1311-1T, 2T, 3T (lirconium, Halfnium or Rare Earths)
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