ML20127M839

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Forwards Comments on Final Rules 10CFR30,40 & 70 Re Regional Matls Licensing for Federal Facilities
ML20127M839
Person / Time
Issue date: 02/26/1985
From: Pineles B
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Deegan G
NRC
Shared Package
ML20127M518 List:
References
RULE-PR-30-50FR72, RULE-PR-40-50FR72, RULE-PR-70-50FR72 AB81-2, NUDOCS 8505230369
Download: ML20127M839 (18)


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l DO NOT vee this form as a RECORD of approvals, concurrences, disposeis, -

clearances, said similar act6 ens -

FROM:(Neme, org. symbol. Agency / Post) Room No.-Bids.

Md8-Dil Pttone No.

OCTM DnRIPA GELD MNSR 19 L,1%

sost-to ' OPfl0NAL FORM 41 (Rev. 7-74) e m i sist o . ses.sn tant NnYck*aYt.nl.aos 8505230369 850515 PDR PH 30 PDR

Identical letters sent to: The Honorable Morris K. Udall, Chaiman ,

Subcomittce on Energy and the Environm:nt

DRAFT Comittee on Interior and Insular Affairs

'.. . . United States House of Representatives -

Washington, DC 20515.

cc: ~

The Honorable Manuel 1.ujan

- a nd -

h u--- " - "' ' ._ L. C;;;,, Chairm Subcomittee on Energy Conservation and Power Comittee on Energy and Comerce  !

The Honorable Alan Simpson, Chairman United States House of Representatives Subcomittee .on Nuclear Regulation Washington, DC 20515 Committee o'n Enviroment and Public Works cc: The Honorable Carlos Moorhead.

United States Senate ,

Washington, DC 205.10 .

Dear Mr. Chairman:

The Nuclear Regulatory Commission (NRC) has sent to the Office of the Federal Register for publication the' enclosed revision to the Commission's rules in 10 CFR Parts 30, 40, and 70. op. e odo cm pf:97 i y . p <f. xW.%I This revision additional licensing extends the from authority program forf; nuclear

!, dqu;rter;. to the five naterials licensing by 4RS Reaional o delegating

. Offices._lThis action expands an existing effort by including certain Federal Fgov.ernment j

successful inlicensees the past.FI; in the t r*decentralized r.;; the cear'procram, a; t uth 0which rit; has oroven le;ci itself t; th0; '

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"'0; us ;;r; cf f00t!O 2 ad ' 7 ' 0'! 0 0 O u r 0;- - u r. ' ;a t f e rQ The C; -f::ica d e d erut qhis rule Ywhi; pill take effect on April 1, D 1985.  : - d" m ccre.i S;.mcr:1,p rTh g,c. tion e.xpa.nds a. successfoi d ecentra. liza. tion prgra.m '

IncivJg certa.in fediral Fac:itities, John G. Davis, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated cc: The Honorable Gary Hart be,twer.A -me. PO R.G W lic.eAsce.s. %Is c in +vroj wui e.n, hec.e the. eMrc.cu;.y oF h u.gchy 'S  ;

reguIa., tory p togro.m.

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DRAFT .

MEMORANDUM FOR: John G. Davis, Director ~

Office of Nuclear Material Safety and Safegua'rds FROM: Richard E. Cunningham, Director -

'l Division of Fuel Cycle and Material Safety

SUBJECT:

FEDERAL REGISTER NOTICE AND DELEGATION OF

. AUTHORITY FOR CERTAIN FEDERAL FACILITY NUCLEAR MATERIALS LICENSEES m Fede.rwl 9,cak+cr retic.e. a.de.kscdson ob% city, j _

Enclosed are tgp 250:: it;T,C and a draft cover memorandum to the

' Executive Director for Operations (EDO) which pertain to those ifcensing , l actions scheduled for decentralization on April 1,1985. The Delegation

.of Authority requires your signature before it can be sent to the EDO .

for final signature. While your concurrence is required, the Federal Register notice needs only the signature of the EDO to be published.

.c Richard E. Cunningham, Director Division of Fuel Cycle and

. Material Safety ~

Enclosures:

As stated

, cc: 'Mr. Mausshardt .

Mr. Miller Ms. Heumann ,

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NUCLEAR REGULATORY .

COMMISSION .

10 CFR Parts 30, 40 and 70 .

~

Regional Nuclear Materials Licensing for Certain Federal Facilities AGENCY: Nuclear Regulatory Commission.

ACTION:.

Final rule. .

SUMMARY

The NRC is amending its regulations co,ncerning the domestic -

u.sinec. W etys

-licensing of source, byproduct, and special nuclear material (h:J;;7;ci; terovide. -kr Arwers referred to as nuclear materials) to p ;;'.d: "nfo m: tier abrut + "

,Jc.ca.ntro.t*za. tier. of % A3 Rc. Itse.as uy;, p rou-a. i yditi = ....gi c...m at:t i e r 0 + "PC ' :  :: ntr;;i:cc li::n:in;'pr:;rc't. This t chctAtkiTz.a;tioa amendment implements another pfase of a prern*,t planned =grc:  ;;x r: ;g-by extending the program ir :11 R ;ienf to include licensees at certain Federal facilities. D'u b 1 ' = t i : n o f t h e ~ e ~' : nt ' tr ' "c pic =t 00 prc:;::ti c; li nnsies of w. . cnt NRC pi ect ke cau v ;eninti;O Ta EFFECTIVE DATE: April 1,1985. ._

t FOR FURTHER INFORMATION CONTACT: Donald R. Chapell, Deputy Director, .

'N Division of Fuel Cycle and Material Safety, Office of Nuclear Material 5 Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone: (301) 427-4152.

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SUPPLEMENTARY INFORMATION: On May 27,1982 (47 FR 23138), April 14,1983 (48 FR 16030) (effective April 1,1983), and May 9, 1984 (49 FR 19630) the i decentrairz% me .e i Nuclear Regulatory Commission (NRC) published rules Peping the domestic licensing of nuclear materialsete d:centrelize mest parts of its progranC The a

NRC is aga4e_ amending 4tf regulations to include certain Federal f::ility licenskser; thin the ::cpe lits decentralization progradp Thestgevisionsto

- 55 30.F, 40.5, and 70.5 s3$7y. th:t inqui-ic: 00-i ng' f. vC'certain Federal facilities .w:=;o i ranses ceyg mmed Wrs-an%e,

-regu;ctt n:: i010 CFR Parts 30 through 35, 40, and de r license. noom_atron_s, d 70 am epp::::icnf for 1, ...,_, W.enst renewals, and revisions 15: :;nt tcc

+e ec.e *e m 1 ropriate 8egional officg, rather than NRC headquarters offices. .This

""a +a +ha m action now incorporate (hese Federal facility licensees o k provieu5ly iiiuluded under : rlier :m:ndmentff the Regional mater

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(licensing programs. -

LS.f.SJ The only Federal licensees n'ot affected by this action u;pd b:1 the United rhei i unur Ihrts 3c-V wtanhoj '

States Air Force and United States Navyf" ,:g'ncensi-@ submittal sjwill t be sep fo m t.nue te +he be rt":Office.pf wec . rom h)pejear N"C heh Materic@ qurteri c fhese fi ceOcafety licensees have Andt"\ot Sakswtrd 7 . <inc3 ded, i 4hev arc a t.een epp;croecause g := currently in the process of submitting / proposals terrais; for broad license 5with the NRC, which would, if approved, consolidate over one hundred individual licenses into one " rested license.

This action also adds another item to the list of exception to the authority gre delegated to the ; +giens spa . under i censing ge denntraire,Sen pivgr:%. progrus.;Inis -ne< exception, inclu (codifies 3 paragraph"(b) (1) (v) in 5530.6, 40.5, and 70.5, r-e'icctspo actual dang: f,;m'?

t reavicinct kJ MSS a current practiceyhet, it dccuma..t3 e condition that 5:: &aye haan e adt?

+o will rc :in, ; "eedquerter: re pensibi'ity Otte review ef new uses or te,chniques Ec s use ci-radie;ctiv0-e nuclear material .

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These amendments apply to NRC licensees 'and applicants in non-Agreement States, Guam, Puerto Rico, the Virgin Islands,.and the District of Columbia, L g herever werare locMe) w;%1n % kJRe9 ,

and to NRC Federal- licensees and applicants , ,,- -

...............~..,,.........,

t 3 vrivMic3J. . N-e United States Air Force and Navyl. Delegations of authority

, y gexcept to the: Regional Administrators are contained in NRC Manual Chapter 0128. The chEn s.to .5530 6, 40.5, and 70.5 are nonsubstantive amendmen'ts. The revised secio ndicate the type of 1.icensing authority delegated to Regional Admi nistrators.

Since these ar ]or, procedural amendments rel'ating to agency organizationeE and managemi ntgno ice, opportunity for comment and a delay of effective tun dera

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date are not quired by the Administrative Procedure Act f5 U.S.C. 553 .

ENVIRONMENTALIMPACT-CATEGORICALEXCLUSION The NRC has determined that this final rule is the type of action described in. categorical exclusion 10 CFR 51.22[(c)[(3)[(i). Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this final rule. -

PAPERWORK REDUCTION ACT STATEMENT This final rule does not contain a new or amended information collection requirement subject to-the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 pF' et' seq.). . Existing r.equirements were approved by the Office of Management / .

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-and Budget approval numbers 3150-0017 for Part 30, 3150-0020 for Part 4t), par-bs and 3150-0009 for Part 70. 31-35 crgprewls LIST OF SUBJECTS IN 10 CFR PARTS 30, 40, AND 70 .

Part '30 - Byproduct material, Government contracts, Intergovernmental relations, Isotopes, Nuclear materials, Penalty, Radiation protection, arregim and rcemrdkGesing re@uirements.

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. 3., .

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- '4-Part 40.- Government . contracts, Hazardous materials-transportation, Nuclear materials, Penalty, Reporting and recordkeeping requirements, Source material, l' and Uranium. . t Part 70 - Hazardous materials-transportation, Nuclear materials, Packaging 1

and containers, Penalty, Radiation protection, Reporting and~ recordkeeping v.

requirements, Scientific equipment,. Security measures, Special nuclear material.

- Urider the Atomic Energy Act of 1954, as amended, the Energy Reorganization A'ct of 1974,- as amended, and 5.U.S.C. 552, the fc11owing amendment's to 10

.CFR Parts 30, 40, and 70 are published as a document subject to codification.

The authority citation for this document is:

' ( b. > i. , o_., and s -

Sec. 161 Pub. L.83-703, 68 Stat. 948, as amended (42 U.S.C.

Authority:

. 2201); Sec. -201, Pub. L. 93-41[, 88 Stat.1242, as amended (42 U.S.C. 5841).

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PART 30-RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL

'1. In 530.6, paragraphs (b) (2)'(i), (ii)', (iii), (iv), and- (v) are amended -

by changing the phrase, "With the exception of Federal facilities, the regional licensing program involves tEIollowing Region I (etc.) non-Agreement States' to read "With the exception of the United States Air Force and Navy, the

. , in ske Of.cn 3 regional licensing program involves all .ethd Federal facilities t];Cs n .tM 'J-itM St:tdl., and non-Federal licensees in Te Region's non-Agreemen i

. St;te.." Also the introductory textu of paragraph (b) and paragraph (b) (1)

. are. revised to read as follows: . .

/

530.6 Communications.

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(b) The Commission has delegated to the five Regional Administrators  !

licensing authority for selected parts of its decentralized

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. . licensing program for nuclear materials as described in ,

paragraph (b)(1) of this section. Any communication, report, or application covered under this licensing program must be submitted as specified in paragraph (b)(2) of this section.

(1) The delegated licensing program includes authority to issue, renew, amend , carcel , codi fy, suspend , or revoke

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licenses for nuclear materials issued pursuant to 10 CFR -

. Parts 30 through 35, 40, and 70 to all persons except the United States Air Force and Navy for academic, medical, add industrial,pses, with the following exceptions:

(i) Activities in the fuel cycle and special nuclear material in quantities sufficient to constitute a critical mass in any room or area. This exception does not apply to license modifications relating to termination of special nuclear material licenses that authorize possession of larger quantities when the case is referred for action from NRC's headquarters ,

to the Regional Adninistrators.

(ii) Health and safety design review of sealed sources and devices, and approval, for licensing purposes, of sealed sources and devices.

(iii) Processing of source material for extraction of metallic .

compounds (including Zirconium, Hafnium, Tantalum, Titanium, Niobium, etc.) .

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l Distribution of products containing radioactive

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(iv) ,

material to persons exempt pursuant .to 10 CFR 32.11 through 32.26. .;

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(v) New uses or techniques y use 7 ad;vadM of b preduct, source) pa;ognuclear material .

PART 40-DOMESTIC LICENSING 0F' SOURCE MATERIAL

2. -in 540.5, paragraphs (b) .(2) (1), (ii), (iii), (iv), and (v) a're amended by changing the phrase, "With the exception of Federal facilities, the regional.

licensing program involves [the following Region I (etc.) non-Agreement States')

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to read "With the exception of the United States Air Force and Navy, the tin tW EWC@

regional licensing program invojves all MFederal p facilities t"N^tghoS n 4he-tfrrtrea stateCand non-Federal licensees in6Ie Region's non-Agreemeh tates"3 Also, the introductory text of paragraph (h) and paragraph ,(b) (1)

-are revised to read as follows:

540.5 Communications.

(b) The Commission has delegated to the five Regional Administrators licensing authority for selected parts of its decentralized licensing program for nuclear materials as described in paragraph (b)(1) of this section. Any communication, report, or application covered under this licensing program must be submitted as specified in paragraph (b)(2) of this sectio'n.

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(1) The delegated licensing program includes authority to issue, renew, amend, cancel, modify, suspend, or revoke licenses for nuclear materials issued pursuant to 10 CFR

. Parts 30 'through 35, 40, and 70 to all person except the

United States Air Force and Navy for academic, medical, and industrial uses, with the following exceptions

-(i) Activities in the fuel cycle and special nuclear material in quantities sufficient to constitute a critical mass in any room or area. This exception-

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does not apply to license modifications relating to termination of special nuclear material licenses thateauthorize possession of larger quantities when the case is referred for action from NRC's headquarters to the Regional Administrators.

(ii) Health and safety design review of sealed sources and devices, and approval, for licensing purposes, of sealed sources and devices.

(iii) Processing of source naterial for extraction of ,

i metallic compounds (including Zirconium, Hafnium, Tantalum, Titanium, Niobium, etc.).

(iv) Distribution of products containing rad'ioactive material to persons exempt pursuant to 10 CFR 32.11 through 32.26.

65.) (pyproduct, scurcef orspecit/

(v) New uses or techniques use of.ea446u u .ve v0 nuclear material.

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PART 70 - DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL

3. In 570.5, paragraphs (b) (2) (1), (ii), (iii), (iv), and (v) are amended by changing the phrase, "With the exception of Federal facilities, the regional .

-licensing program involves e following hn I (etc.) non-Agreement States")

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to read "With the exception of the United States Air Force and Navy, the gs<Re.g,io k s regional licensing program involves all ottre9-Federal facilities threyned.U Jhc hited Statek and non-Fed.eral. licensees infth Region's non-Agreemen@

C Also, the introductory text of paragraph (b) and paragraph (b) (1) are revised to read as follows:

570.5 Communications.

(b) The Commission has ' delegated to the five Regional Administrators licensing authority for selected parts of its rsgional licensing program for nuclear materials as described in paragraph (b)(1) of this section. Any communication, report, or application covered under this licensing program must be submitted as specified in paragraph (b)(2) of this section.

(1) The delega.ted licensing program includes authority to issue, renew, amend, cancel, modify, suspend, or revoke licenses for nuclear materials issued pursuant to 10 CFR Parts 30 through .

35, 40 and-70 to all persons @except the United States Air Force and Nav for academic, medical, and 1.ndustrial uses, with the following exceptions:

n. .

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(i) Activities in the fuel cycle and special nuclear material in quantities sufficient to constitute a critical mass in any room or area. This exception

- does' not apply to license modifications relating to termination of special nuclear material licenses that authorize possession of larger quantities when the case is referred; for action from NRC's headquarters to the Regional A.dministrators.

(ii) Health and safety design review of sealed sources and devices, and approval, for licensing purposes, of sealed sources and devices.

(iii) Processing of source material for ~ extraction of

.e-metallic compounds (including Zirconium, Hafnium, Tantalum, Titanium, Niobium, etc.).

(i v)' Distribution of products containing radioactive material to persons exempt pursuant to 10 CFR 32.11 through 35.26.

4br (v) New uses or techniques . use .of-tmj i vo d ivc of bypro dv d/ S^9 Cf $cQ nuclear material. * *

  • Dated at Bethesda, MD this day of , 1985.

FOR THE NUCLEAR REGULATORY COMMISSION.

William J. Dircks, Execut.ive Director for Operations

~

, DRAFT MEMORANDUM FOR: William J. Dircks Executive Director for Operations  :.

FROM: John G. Davis, Director Office of Nuclear Material Safety and Safeguards SUBJECTi FEDERAL REGISTER NOTICE AND DELEGATION OF AUTHORITY FOR CERTAIN FE'JERAL FACILITY NUCLEAR MATERIALS LICENSEES Enclosed for your signature are the final rule amendment (to be published in the Federal Register) and the Delegation of Authority pertaining to those licensing actions scheduled for decentralization on April 1,1985.

.Also included are the Daily Staff Notes and the Delegation of Authority for EDO Publication Approval.

. e John G. Davis, Director Office of Nuclear Material Safety and Safeguards

Enclosures:

As stated ,

cc: -Rules and Records DEDROGR Chief Counsel, Regional Operations and Enforcement, Division, ELD Division Directors, NMSS e

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DRAFT DELEGATION OF AUTHORITY FOR E00 PUBLICATION APPROVAL

' Approved for Publication In a final rule published March 19, 1983 (47 FR 11816), the Commission delegated t~o 'the EDO (10 CFR 1.40(c) and (d)) the authority to develop and promulgate rules as defined in the APA (5 U.S.C. '551(4)) subjec.t to the limitations in NRC Manual Chapter 0.103, Organization and Functions, Office of the Executive Director for Operations, paragraphs 0213, 038, a nd 0310.

The. enclosed final rule entitled, " Regional Nuclear Materials Licensing for Certain Federal Facilities," amends 10 C'FR Parts 30, 40, and 70 to include certain Federal facility licensees in the decentralized materials licensing program. .

This final rule does not constitute a significant question of policy, nor does it amend regulations contained in 10 CFR Parts 0, 2, 7, 8, 9 Subpart C, ,

or 110. I, therefore, find that this final rule is within the scope of my .

rulemaking authority and am proceeding to issue it.

Date William J. Dircks Executive Director for Operations 4

9

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. DRAFT DAILY STAFF NOTES DIVISION OF FUEL CYCLE AllD MATERIAL SAFETY OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Final Rule to be Signed by EDO .

On , -1985, the Executive Director fer Operations approved a final rule which rev'ised 10 CFR Parts 30, 40, and 70. This revision informs t' he public of an action that broadens the scope of the nuclear materials licensing L~ 011ted'

. program in all Regions to include licensees at Federal facilitiesb Mr Ferce sd kykw .

~ ihhlB Ih is action implements another phase of a process planned several years ago to decentralize most of the nuclear materials licensing program.

This constitutes notice to the Commission that, in accordance with the rulemaking authority delegat,,ep to the EDO, the EDO has received the final rule .

and proposes to forward it on , 1985 to the Office of the Secretary for FR publication, unless otherwise directed by the Commission.

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DRAFT -

MEMORANDUM FOR: Regional Administrators FROM:

William J. Dircks

. Executive Director for Operations

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Jdhn' G. Davis, Director Office of Nuclear Material Safety and Safeguards

SUBJECT:

DELEGATION AND ASSIGNMENT TO ALL REGIONS OF CERTAIN NATERIALS LICENSIt'G ACTIONS

1. Pursuant to NRC Manual Chapter 0128, " Organization and Functions -

Regional Offices," the Regional Administrators of all regions are .

hereby assigned and authorized (hereafter referred to as authorized) to perfom certain licensing actions as described herein, effective April 1,1985. .This authorization supersedes the ones issued to '

Regions I and III effective May 27, 1982 and to all RegionsYApril 1, 1983 (published April 14,1983) and April 2,1984. foK)

2. Under the Atomic Energy-Att of 1954, as arended, and the Energy Reorganization Act of 1974, as amended, the Office of Nuclear Material Safety and Safeguards (NMSS) is responsible for the principal licensing, regulation, and safeguarding of facilities and materials specified in the Atomic Energy Act of 1954 associated with the processing, transport, and handling of source, byproduct, and special nuclear materials (here-after referred to as nuclear materials). Consequently, NMSS will remain responsible for determining overall licensing and regulatory policy for actions which the regions have beep authorized to perform pursuant to

- this memorandum. To enable NMSS to execute this responsibility properly, NMSS will maintain oversight of these licensing actions. This oversight shall include, but not be limited to, ongoing review of decementation,-

periodic assessments of activities being conducted by the regions, and '

- ongoing coordination and consultation between NMSS and the regions regarding authorized licensing actions. Tne HMSS Director retains the authority to take actions determined necessary in all matters hereby authorized to be perfomed by the regions.

3. All Regional Administrators are authorized to issue, renew,' amend, -

cancel, modify, suspend, or revoke, under .the provisions set out by this delegation, licenses for nuclear materials, issued pursuant to.10 CFR Parts 30 through 35, 40, and 70 to all -peMecc4except the United States Air Force and Navypn non-Aoreement States, Guam, Puerto Rico

- Virgin Islands and the District of Columbia for Facademic, medical, and industrial uses, with the following exceptions: l i

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Fcderal fad liti Q f Cur we (1.W.ev 5tutei g 4-M&'& , _

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Regio'nal Administrators .

A.. Activities in the fuel cycle and special nuclear material in quantities sufficient to constitute a critical mass in any room or area. This exception does not apply to license modifications relating to tennination of special nuclear material licenses that authorize possession of .

larger quantities when the case is referred for action from the Nuclear Regulatory Commission's Headquarters to

.the Regional Administrators. .

B. Health and safety design review of' sealed sources and devices, and approval, for lice.nsing purposes, of sealed sources and devices.

C. Processing of source material for extraction of metallic compounds (including Zirconium, Hafnium, Tantalum, .

Titanium, Niobium,etc.).

.D. Distribution of products containing radioactive material to persons exempt pursuant to 10 CFR Parts 32.11 through 32.26.

(F ( bypro h.cks .Sovice, o r s ocGedy E. New uses or techniques e(}o * *"-

  • nuclea r material .

use of rad

4. All Regional Administrators are authorized to issue, with the concurrence of the NMSSAirector, notices of the denial or the pro-posed denial of applications for materials licenses and amendments or renewals thereof, pursuant to 10 CFR Part 2, within the parameters delineated in paragraph 3 above.
5. Actions initiated by Regional Admin.istrators to suspend, modify, or revoke licenses must have the concurrence of the NMSS Director.
6. All Regional Administrators are authorized to respond to all Freedom of Information Act inquiries as well as inquiries from Congress, the media and others about licen, sing actions the Regions have the authority to perform.
7. Actions pertaining to the disposal of nuclear material by burial must have the concurrence of the NMSS Director. .
8. All matters which arise that reasonably could oe expected to have -

policy implications relating to delegated licensingIfactions shall.

a licensing be referred to the.NMSS Director _for resolution.

and/or regulation matter arises which has not been specifically authorized pursuant to this memorandum, it remains the responsi-bility of NMSS until a specific authorization is made to the regions.

9. Disagreements which arise between NMSS and regional staffs on whether or not an issue constitutes an item which remains the responsibility

Regional Administrators . .

of NMSS, or on the way in which a delegated item (s) has been handled will be referred to the NMSS Director who will consult with the Regional Administrator prior to issuing a final resolution.

10. Disagreemen'ts between potential or existing licensees relative to decisions made by the Regional Administrators pertaining to license

, actions should be made known immediately to the NMSS Director. If resolution cannot be achieved at the regional level, the applicant /

licensee shall be informed in writing by the Regional Administrator, with a copy to the NMSS Director, that it may seek resolution of the matter with the NMSS Director.

11. Delegated licensing actions are to be perfonned in accordance with policy guidance and standard review plans issued by the NMSS Director.
12. NMSS will provide a copy of this delegation, related revisions, and other related documents to-bet 6?the Deputy Executive Director for -

Regional Operations and Generic Requirements and the Director and Chief Counsel, Regional Operations Enforcer.ent Division, Office of the Executive Legal Director. All documents submitted under this paragraph will be marked with Delegation and Assignment number

[ ].

.c William J. Dircks Executive Director for Operations John G. Davis, Director Office of Nuclear Material Safety and Safeguards l .