ML20203C254
| ML20203C254 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1999 |
| From: | Camper L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mcburney R TEXAS, STATE OF |
| References | |
| NUDOCS 9902110307 | |
| Download: ML20203C254 (5) | |
Text
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pomog It UNITED STATES p
y Ig NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20555-0001 February 5, 1999 g
Ruth E. McBurney, CHP, Director Division of Licensing, Registration, and Standards Bureau of Radiation Control Texas Department of Health
Dear Ms. McBurney:
This responds tc your letter dated September 2,1998, to Mr. Steven Baggett, requesting that he provide the U.S. Nuclear Regulatory Commission (NRC) policy on combining licensed operations within one license.
J Your specific questions and our answers to your questions follow:
1.
Has the NRC adopted a policy by which specific licensees of broad scope are authorized to conduct the activities specified in 10 CFR 33.17(a)(1)-(4) even though the quoted part prohibits the activities to be conducted under the auspices of 10 CFR Part 337 No. Specific licenses of broad scope exclude the uses described in 10 CFR 33.17(a)(1)-(4) without separate line item authorizations pursuant to other parts (and requirements) of the NRC's regulations. Briefly,10 CFR 33.17 states that persons licensed under this part shall not conduct certain nctivities "unless specifically authorized (emphasis added) pursuant to other parts..." Note that the quoted section does not prohibit these activities, but rather requires specific line item authorization. Regional license reviewers have specifically authorized medical teletherapy, for example, as a license condition on medical broad scope licenses. On the other hand, in the case of industrial radiography or large irradiators, the license conditions that must be included on broad scope licenses would make these licenses large and difficult for the licensees and reviewers to use and therefore these uses have not typically been added to broad scope licenses. However, the regulations do not prohibit an applicant from engaging in these activities if the applicant is qualified in these categories and has been specifically authorized to do so by other parts of Title 10 of the Code of Federal Regulations.
D 2.
Has the NRC adopted a policy by which specific licenses of limited scope are authorized to conduct disparate licensed operations under the auspices of one license document?
]\\./O I
Guidance for Multi-Site Licensees, Policy and Guidance Directive, PG-1-23, indicates in Item 3.1.B, that "... licensed material uses currently licensed separately should continue to be Ucensed separately..." However, this policy was adopted mainly for administrative y
reasons as _ indicated in the response to question 1, e.g., to prevent long cumbersome license documents which are difficult to read and locate specific requirements, and
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might be confusing to understand. However, if an applicant (or licensae seeking an amendment) met the requirements for teletherapy and nuclear medicine, a reviewer could combine both uses on one linense.
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R. McBurney ' Q We trust this responded to your questions regarding thiS issue. If you have any further
'r questions pleaSe contact Anthony Kirkwood of my staff at (301) 415-6140 or INTERNET:
ASK@ NRC. GOV.
Sincerely, (orig. signed by)
Larry W. Camper, Chief Materiels Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards DISTRIBUTION: IMNS r/l PDR YES
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R. McBurney -
We trust this responded to your questions regarding this issue. If you have any further questions please contact Anthony Kirkwood of my staff at (301) 415-6140 or INTERNET:
- ASK@ NRC. GOV.
i Sincerely, La W.
am Mat rials afety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards i
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R. McBurney We trust this responded to your questions regarding this issue. If you have any further questions please contact rne at (301) 415-6140 or INTERNET: ASK@NRC. GOV.
Sincerely, l.
Original Signed By:
Anthony S. Kirkwood Anthony S. Kirkwood Materials Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards DISTRIBUTION:
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4 R. McBurney I k
We trust this responded to your questions regarding this issue, if you have any further questions please Contact Anthony Kirkwood of my staff at (301) 415-6140 or INTERNET:
ASK@NRC. GOV.
Sincerely Larry W. Camper, Chief Materials Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards
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