ML20141F527

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Recommends That Administrative Determination Be Made to Accept Forms Containing Requisite Info Re SNM Access Authorization Applications W/O Revising Regulation
ML20141F527
Person / Time
Issue date: 06/16/1982
From: Burnett R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Brady R
NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20140E750 List:
References
FRN-50FR39076, RULE-PR-11 AB99-2-16, NUDOCS 8601090410
Download: ML20141F527 (1)


Text

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. M J 6 b2 MEMORAllDUM FOR: Rayinond J. Brady, Director Division of Security Office of Administration FROM: Robert F. Burnett, Director Division of Safeguards Office of Nuclear Material Safety and Safeguards

SUBJECT:

RELIEF FROM DOCUMENTATION REQUIREf1EllTS OF SNM ACCESS AUTil0RIZATION APPLICATIONS By letters dated February 18 and November ll,1901, Babcock & Wilcox, a licensee possessing fonnula quantities of special nuclear material subject to the physical protection requirements of 10 CFR 73.20, 73.45 and 73.46, requested relief from duplication of documentation requirements of 10 CFR 11.15 for personnel possessing current 00E clearances. From several recent discussions between members of our

(- staffs, we understand taat the Division of Security concludes that originals of the forms cited in ll.15(b) & (c) are required. We further understand that the F Division of Security position is based upon the regulatory language and the belief that a change in policy to accept copies of 00E fonns would require a revision to the regulation. We have discussed the phrase contained in the regulation with Bob Fonner of CELD and have been informally advised that in his opinion, the intent of the language was to disallow licensee use of independently designed fon:is which would make processing of applications cu:nbersome. An administrative determination could, in his opinion, therefore be made to accept copies of forms containing the requisite information without revising the regulation. We recommend that this be done, possibly under the provisions of the Paperwork Reduction Act.

If you agree, please have your staff contact Russ Rentschler regarding implemen-tation of the decision. If not, let's set up a meeting to discuss the matter further.

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Robert F. Burnett, Director Division of Safeguards DISTRIBUTION:

Office of Ituclear Material Safety and Safeguards SGFF r/f & s/f CRON0 NMSS 060109041o e51223 PDR PR RRR 11 50FR39076 PDR

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