ML20151J032
| ML20151J032 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/1988 |
| From: | Liza Cunningham Office of Nuclear Reactor Regulation |
| To: | Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151J037 | List: |
| References | |
| NUDOCS 8808020170 | |
| Download: ML20151J032 (2) | |
Text
ENCLOSURE 1
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UNITED STATES
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E NUCLEAR REGULATORY COMMISSION r,
W ASHINGTON, D. C. 20666 f
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- j Jul.131988 MEMORANDt>M FOR: Those on Attached List FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protectiot, and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
MINUTES OF THE REACTOR HEALTH PHYSICS COUNTERPART MEETING, MAY 18-19, 1988 i
A copy of the subject minutes is enclosed for your infomation. These minutes have been revised in response to coments received on the draft sent for review on June 14, 1988,
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- M LeMoine J. Cunningham, C tef Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
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Minutes of the Reactor HP Counterpart Meeting C0tiTACT:
John D. Buchanan NRR 492-1097 h
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ENCLOSURE 1 4.
Connents on inclusion of transportation inspections in the Core Inspection Program:
Draft appears generally acceptable.
5, Status of revision of Supplement 5 (Transportation) of HRC Enforcement Policy: This revision should appear in the next published re.Mision of the enforcement policy.
6.
Recent rrJiography accident in Texas which may involve release of source from a Type B package.
7, Change of date for next transportation training course from June to October 1988.
If HMSS will develop the course material, oi,e day on low-level waste will be added to this course, b.
Pennsylvania Inspections at Part 50 Sites W. Pasciak, R-1, described the programs, under a subagreement between NRC and Pennsylvania inspectors. Areas of inspection for Pennsylvania inspectors include completion of transportation packages and compliance with procedures regarding transport and Part 61.
Pennsylvania inspectors cannot look at PCPs, training, and other judgmental aspects of LLW processing, packaging and shipping. The State will look at about 25 percent of shipments and will schedule their inspections when packages are being prepared. The State cannot issue violations. The State inspection report goes to NRC for con-currence before being issued to the licenset. Tr.e State also does an annual inspection to look at records. The State will have 10-12 inspectors who will do inspections about two weeks per year. Regior. I is training and testing these inspectors.
8.
Non-Power Reactor !ssues T. Michaels and A. Adams, NRR/PDSNP, discussed the following issues.
Regulatory Responsibilities for Byproduct Materials in Non-Power a.
Reactors Guidance on this subject is provided in a 3-8-88 memoran m from D. M. Crutchfield, NRR, to Regional Directors of the Divisions of Radiation Safety and Safeguards. This memorandum indicates that generic guidance related to this issue is contained in Inspe
- Licensees who do a
,<e Manual Chapter 2882, Appendices 1 and 2.
the appropriate license conditions should request an amendmen6 Inspectors should identify licensees who do not have standard license conditions.
NRR/PDSNP will sent wording of the standard license condition to the Regions.
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ENCLOSURE 2
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UNITED STATES f
NUCLEAR REGULATORY COMMISSION aI W
w AsHiNo 7 ON, D. C. 20555 jr March 8, 1988 MEMORANDUM FOR:
Frank J. Congel, Director Division of Radiation Safety and Safeguards, RI Douglas M. Collins, Director Division of Radiation Safety and Safeguards, RII John A. Hind, Director Division of Radiation Safety and Safeguards, RIII Richard L. Bangart, Director Division o.f Radiation Safety and Safeguards, RIV Ross A. Scarano, Director Division of Radiation Safety and Safeguards, RV FROM:
Dennis M. Crutchfield, Director Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
REGULATORY RESPONSIBILITIES FOR BYPRODUCT MATERIALS IN NON-POWER REACTORS In a memorandum dated June 8, 1987, Region IV requested guidance for determiningcaseswherelicenstdmaterialinanon-powerreactorfacili[ymay be covered by a NRC material license or an Agreement State license, rather than the reactor license. This issue becomes important in determining compliance and issuinq notices of violation involving licensed material in a reactor facility. All regions were asked to comment on this issue. After consideration of your concents, we are providing the following guidance. The guidance has been coordinated with MSS, GPA, and OGC.
1.
Generic guidance related to this issue is contained in I'ispection Manual Chapter 2882, Appendices 1 and 2.
Normally, material within a non-power reactor facility will generally be assumed to be possessed by the reactor licensee, unless there is prior documentation approved by NRC, or some other clear demonstration that the licensed material is covered under another license.
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l CONTACT:
l T. Michaels NRR/PDSNP Ext. 21102 f?!!!MNA djf)
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ENCLOSURE 2 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 inito 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 fc a non-power reactor are normally defined by the Safety Evaluation Report or Technical 5)ecifications.
In the absence of identifiable facility boundaries, tie Regions should establish a facility boundary with the licensee for compliance purposes, and the boundary should be specified in TS or FSAR.
S.
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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yen'niYK.' Crutchf e, Irgtbr '
DivisionofReactorProjects-III/IV, Y and Special Projects Office of Nuclear Reactor Regulation
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