ML20024C215

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Package of Two Comments on NRC Policy Statement on Regionalization.Opposes Rule
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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April 19,1983 we

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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,

Further,

^ 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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4/02/B4 -

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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