ML20148J976
| ML20148J976 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1988 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Dan Collins, Congel F, Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8803300442 | |
| Download: ML20148J976 (3) | |
Text
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'k UNITED STATES
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March 8, 1988 x,
MEMORANDUM FOR:
Frank J. Congel, Director Division of Radiation Safety and Safeguards, RI Douglas M. Collins, Directee Division of Radiation Sa#*ty end Safeguards, RI?.
John A. Hind Director Division of Radietion Safety and Safeguards, RIII Richard L. Bangart, Director Division o.f Radiatin Safety and Safeguar(;, RIY Ross A. Scavane. Director Division of Radiatim S6/ety and Safeguards, RV FROM:
Dennis M..Crutchfield, Director.
Division of Reactor Pojects - HI, fY, V and.,pecial Projects Office of Nucler-Reactw RegulatDL
SUBJECT:
REGULATORY MSFONZalITIES F0F EYPRODU" MATERIALS IN NON-?OJtn RF).CTCP.S In a memorandum dated June 8, 1987, Reghan IV reonested guidance for determining cases where licegsed Rterial in t. 21-power. reactor facility may becoveredbyaNRCmateisallicens;oranAvescentState}icense,rather than the reactor license. This issue becomes important in uetermining compliance and issuing notices of violation involvins Umiseo material in a reactor facility. All regions were asked to commcnt on'this issue.
A".c r consideration of your coments, we are providing tha following guidance.
The guidance has been coordinated with NMSS, GPA, and OGC, 1.
Generic guidance related to this issue is contained in Inlyection Manual Chapter 2882, Appendices 1 art 2 11y be assux d to neNormally, m a non-power reactor facility will genere possessed by the reactor licensee, unlets then is prior documentati0n approved by NRC, or some other c16ar demonitration that the licensed material is covered under another license, f,0 I
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Consistent with #1 above, NMSS does not normally issue separate licenses which authorize possession of licensed material within an operating reactor facility.
If a reactor facility license is silent with regard to possession of byproduct material, it should be amended. NRC normally exercises exclusive federal jurisdiction within operating reactor facilities.
3.
All byproduct material which is to be inserted into a reactor, or which is removed from the reactor, nust be covered by the reactor license while the naterial is within the facility.
4.
The facility boundaries for a non-power reactor are normally defined by the Safety Evaluation Report or Technical Specifications.
In the absence of identifiable facility boundaries, the Regions should establish a facility boundary with the licensee for compliance purposes, and the boundary should be specified in TS or FSAR.
5.
As indicated in Manual Chapter 2882, Appendix 2, there are exceptions to the above guidelines, and specific cases can be complex. Questionable cases should be referred to Headquarters for resolution along with a proposed course of action.
Questions concerning this guidance or specific cases should be referred to this Division for resolution. We will coordinate with NMSS, GPA, and OGC as appropriate.
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ennis'K.' Crutchf e (br '
Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation i
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Man.h-8, 1988 t 2.
Consistent with #1 above, NMSS does not normally issue separate licenses which authorize possession of licensed material within an operating reactor facility.
If a reactor facility license is silent with regard to possession of byproduct material, it should be amended. NRC normally exercises exclusive federal jurisdiction within operating reactor facilities.
3.
All byproduct material which is to be inserted into a reactor, or which is removed from the reactor, must be covered by the reactor license while the material is within the facility.
4.
The facility boundaries for a non-power reactor are normally defined by the Safety Evaluation Report or Technical Specifications.
In the absence of identifiable facility boundaries, the Regions should establish a facility boundary with the licensee for compliance purposes, and the boundary should be specified in TS or FSAR.
5.
As indicated in Manual Chapter 2882, Appendix 2, there are exceptions to the above guidelines, and specific cases can be complex. Questionable cases should be referred to Headquarters for resolution along with a proposed course of action.
Questions concerning this guidance or specific cases should be referred to this Division for resolution. We will ccordinate with NMSS, GPA, and 0GC as appropriate.
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c Dennis M. Crutchfield, Director Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation DISTRIBUTION:
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