ML20052A769
Text
,. -
f
?
-l
,-Q
~
,V."
4 4
FCRL:JMB N 17 IW D '
/
(71562) t Department of the Navy ATIN: Mr. Gene W. Hendrix>
Naval Facilities Engineering Coranand
,i.,
200 Stovall Street-i u-Alexandria,..Virg M a 22332,.#,ff
~
x.y q-,
u.e..4 ; <
Gentlemen:
' O
. in. :.
4 j
/!
i - V;;i, -
^
u',"? '
1 m.
\\
.n This concerns your April 21, 1976 letter requesting interpartation and l amend:nent of your License 45-16359-03.
'.., C;,
1 7
3,y i
i Your proposal provides for a separate letter of agreement with each
-i service or federal agency to comply with NAVFAC administrative controls l
specified by your License 45-16359-03. However, each federal agency.
(but not military service), is considered a separate " person" as set forth in Section 30.4(k) of 10 CFR Part 30, and therefore, would, pursuant to Section 30.3 of 10 CFR Part 30, require a separate license issued in the name of each such federal agency authorizing it to possess and usa the byproduct material in the radioisotope power generators.
Therefore, each federal agency desiring to possess and use radioactive material in radioisotope power generators should m h application on l
Form AEC-313 for a specific license to use the byproduct material involved.
It will be necessary that we receive additional clarifying information concerning your proposal to cover the use of radioactive material in radioisotope power generators by other military services by your License 45-16359-03. The conditions of. possession and use of radioactive l
material'by each and every military service must be clearly established.
~
Please describe the role of each military service in the possession and use of radioisotope power generators. If all military services are to possess and use the radioactive material pursuant to statements and representations previously made by the Navy as the basis for License 45 16359-03, then the other military services should formally submit evidence of agreements with the Navy to this effect, and copies of individual service regulations,' instructions, etc. implementing these agreements, statements and representations throughout each of the services.
.- i,
^
. jlh$'}.,
+
- M,%j ;
~
4 ef
..J.* ; %.~,Q(
~
fp : V, -
careca e
.. +..J. : *
- 820A2M T
9
)
y l >rns A1.C.}14 (Rev. 9 53) ALCM 0240 -
W u. a.oovsamasant ens = Tine orrecas to,4.one.see s.'",
y 9
k'
)h T
t Departnent of the Navy If the military services other than the Navy are to be subordinate to the Navy 'in their programs of use of radioisotope power generators, this should be cicarly established. Such a subordinate role for the military services other than the Navy is not c1carly indicated by your letter of April 21, 1976' For example, you state that "The custodian and users designated by the other service or agency will be trained by the Navy".
This i= plies that other survices will appoint " custodians" and " users".
However, you also state "All administrative controls of the NAVFAC Radiological Safety Guide will be applied". Your Guide states in Item II.B. that "An authorized user is a person who has been approved by NAVF'.C...". - The latter statement implies that the Navy will make the sola de, termination as to which persons will act as " users",~.whereas the f.
~'
, 4 initial quote, above, implies that other services will determine who' will act as " users"' with the Navy participating only in the training of each such " user".
If the other services will not be subject to control ~ ~
~
by the Navy, in so far as assuring compliance with the terms and condi-tions of the Navy's license is concerned, then these other services should apply for and obtain their own licenses.
Racaipt of the above requested information will help us in the further consideration of the amendment of your license to authorize use of radioisotope power generators by all services.
Sincerely, Jack M. Bell Radioisotopes Licensing Branch Division of Fuel Cycle and Material Safety 1
l I
l j
1 a'
l N
.x
-r o,->c e,-
J, l ELD E
- > = =
- __..J f
r=*
_. /. /76...- 9th/76 Rev. 9 53) AECM 0240 W u. s. novenmusar ramtma orricas ser4.sa see