ML20046C663

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Responds to Re Implementation of Revised 10CFR20
ML20046C663
Person / Time
Site: 07000008
Issue date: 07/20/1993
From: Pierson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Fess G
Battelle Memorial Institute, COLUMBUS LABORATORIES
References
NUDOCS 9308110325
Download: ML20046C663 (1)


Text

JUL 2 01933 Docket 70-8 License SNM-7 Mr. Gregory H. Fess 1

NRC Licensing Coordinator Battelle Memorial Laboratories 505 King Avenue Columbus, Ohio 43201

Dear Mr. Fess:

SUBJECT:

IMPLEMENTATION OF REVISED 10 CFR PART 20 By letter dated June 1,1993, we were informed of your decision to implement effective June 1,1993, the requirements of the revised 10 CFR Part 20 for the Battelle Columbus Laboratories Dccommissioning Project (BCLDP). While implementation of the regulations prior to January 1,1994, is allowed by 10 i

CFR 20.1008, the rationale of implementing the revised provisions for only a sector of your licensed activities is questioned. We understand that there is a dedicated staff assigned to the BCLDP and that the staff would not be subject to both current and revised Part 20 requirements.

In addition, you-indicate that the revised Part 20 requirements are more consistent with the Department of Energy's radiation protection requirements with which you must also comply.

Notwithstanding these considerations, we believe that implementation would be simplified if the revised Part 20 requirements were applied to all of your licensed activities at the same time.

However, if adequate justification is provided, an exemption may be granted. To resolve this issue in a timely manner, please submit, within 45 days of the date of this letter, justification for implementing the revised Part 20 provisions for the BCLDP and not the remainder of SNM-7 licensed activities Sincerely, Original signed by '

Robert Pierson, Chief Licensing Branch Division of fuel Cycle Safety and Safeguards, NMSS DISTRIBUTION:

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