ML19057A563
| ML19057A563 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 10/30/2003 |
| From: | Mccann G NRC/RGN-III |
| To: | Jensen C Battelle Memorial Institute |
| References | |
| Download: ML19057A563 (4) | |
Text
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PERSON(S):
LICENSEE:
LICENSE No:
DOCKET No:
CALLER:
DATE:
SUBJECT:
TELEPHONE CONVERSATION RECORD Craig E. Jensen, CHP Radiation Safety Officer (RSO)
Battelle Memorial Institute (BMI)
West Jefferson, OH
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George M. Mccann, Senior Radiation Specialist \\P..O I ri0 \\) ~
Decommissioning Branch October 30, 2003 NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING REVISION TO DECOMMISSIONING PLAN (MC 312674)
REFERENCES:
- 1.
- 2.
- 3.
October 17, 2003 letter from licensee, transmitting revised Decommissioning Plan Licensee Attachment 1, "Response to NRC review comments dated September 25, 2003, SNM-7" Decommissioning Plan, DD-93-19, Revision 5, October 16, 2003 On the above date, Region Ill staff contacted the licensee's RSO to discuss staff findings regarding the licensee's October 17, 2003 license response. The NRC staff indicated that the response was close to satisfying NRC concerns regarding the licensee's over-sight of the West Jefferson decommissioning project. However, the NRC staff believes there are still some weaknesses which need to be addressed before the NRC will endorse the DP amendment request.
The areas which the licensee was requested to respond to are listed below. The NRC staff comments may be preceded by an excerpt from the licensee's submittal for reference. The reviewer's comments and request for additional information are bolded.
A.
from DP page 1 and 2, 1st bullet Oversee daily decommissioning activities, audits and assessments of closure contractor programs, and stop work authority over closure contractor activities that constitute a substantial safety hazard or involve an unacceptable potential for such hazard. These activities are discussed in the BCLDP Oversight Plan, included as Attachment 1.
From DP page 30, section 2.2.2" Decommissioning Operations" The BMI RSO performs additional oversight activities. The BMI RSO has the responsibility and authority to order the cessation or modification of any activities believed to constitute a substantial safety hazard or involve an unacceptable potential for such hazard. The BMI RSO also provides oversight to BCLDP in matters concerning license conditions and the quarterly review of segments of the radiation protection program. The BMI RSO and Site RSO will communicate frequently and maintain such records as are deemed necessary to conduct their operations. The BCO RSO position is filled by an employee of Battelle and may not be filled by a contractor. Qualifications for the BMI RSO are:
from page 44, section 3.3 Radiation Protection Program The BMI RSO is appointed by the Battelle CEO and reports to the CEO through Battelle's Vice President for ESH&Q; the BMI RSO has direct access to the CEO when deemed appropriate. The BMI RSO is responsible for periodically assessing compliance with RPP requirements by performing oversight and assessment of BCLDP operations. The BMI RSO may stop any operations involving licensed activities that are unsafe or non-compliant with NRC requirements. The Vice President of ESH&Q and the ODO Program Manager will consult the BMI RSO in the assignment of managerial positions in the RPP.
The BMI RSO is responsible for periodically assessing compliance with RPP requirements by performing oversight and assessment of BCLDP operations.
NRC COMMENT: The NRC staff requests the licensee to clarify the statements identified in the above two portions of the licensee's DP. The use of the qualifier in the first two sections, i.e., substantial. Needs to be explained." The licensee must have stop work authority for any activity determined to not be in compliance with NRC regulations or license condition.
B.
From DP page 2, Note: Since the Oversight Plan is a living document, it is requested that it not be incorporated by reference to the DP, but rather it will be change managed through the HP-AP-36.0 process.
NRC COMMENT: The NRC staff does not agree with this request. The NRC needs this document to have minimum confidence that BMI will have sufficient oversight of the program after the Closure Contractor takes over the day-to-day decommissioning operations. The staff also believes the licensee has ample 50.59 authority. The licensee will either need to retract this request or provide additional information to support the request.
C.
From page 15, Section 2.1.3.4 Decommissioning Operations The Area or Building Characterization Report includes radiological and chemical survey data, prior to decontamination. It will be prepared for each
building or area to be decontaminated. Upon completion of the final status survey, each area or building, ifleludiflg aFeas F1et deeefl'lfl'lissieAed, will have a Final Status Report produced that documents residual radioactivity levels. Each area will also require an independent verification survey to confirm that release criteria have been met. Building JN-1 will be characterized to the extent necessary to provide quantification of radiological hazards and radioactive waste management information, but will not require a Final Status Report since it will be deconstructed and managed as radiologically contaminated materials NRC COMMENT: Clarify this deletion from the DP. The licensee is required to comply with NUREG 5849. The NUREG calls for surveys of adjoining unaffected areas.
D.
from page 25, section 2.2.2 Decommissioning Operations The BMI RSO performs additional oversight activities. The BMI RSO has the responsibility and authority to order the cessation or modification of any activities believed to constitute a substantial safety hazard or involve an unacceptable potential for such hazard. The BMI RSO also provides oversight to BCLDP in matters concerning license conditions and the quarterly review of segments of the radiation protection program. The BMI RSO and Site RSO will communicate frequently and maintain such records as are deemed necessary to conduct their operations. The RSO position is filled by an employee of Battelle and may not be filled by a contractor. Qualifications for the BMI RSOare:
from Battelle Columbus Laboratories Decommissioning Proiect {BCLDP)
Oversight Plan, section II. Oversight Organization The BMI Chief Executive Officer (CEO), who has primary responsibility for NRC license SNM-7, has assigned two positions with responsibility for the oversight of the West Jefferson D&D efforts. These positions consist of the BMI Radiation Safety Officer (RSO) and the BCLDP Project Manager. Since the BCLDP oversight is the primary assignment for each of these positions, it is expected that there will be a daily BMI presence on the BCLDP site. The BMI RSO has been assigned the responsibility for overseeing the day-to-day implementation and compliance with the Decommissioning Plan (DP) and the Radiation Protection Program (RPP) plan. The BCLDP Project Manager has been assigned the responsibility for overseeing the line management, technical approach, schedule timeliness, and quality of the decommissioning effort, all of which must meet license requirements. These two functions work closely together to provide a comprehensive and independent review of the activities conducted by the Closure Contractor.
NRC COMMENT: The NRC staff requests a specific commitment, that is, there will be a daily onsite presence of BMI oversight personnel, i.e., the BCO RSO and Project Manager or qualified designee (e.g., BMI HP Rad Tech). Also, there will be weekly
walk-downs by RSO and Project Manager or qualified or BMI designee. That the RSO and Project Manager will receive and review the weekly decommissioning work plans prior to work being conducted.
E.
from Battelle Columbus Laboratories Decommissioning Project (BCLDP)
Oversight Plan, section II. Oversight Organization, Ill. Oversight Activities, Table 2. Oversight Assessments Frequencies NRC COMMENT. Since the project is schedule to only last another two years, and since the NRC believes this to be a unique initiative, the NRC staff believes annual frequencies in all the independent assessment categories to be too long. The licensee was requested to consider and provide bac to the NRC frequencies which will assess the Closure Contractor's performance early on, e.g., 3-6 months after assuming management of the decommissioning work and 6 months thereafter. Not all the categories have to be reduced. The licensee will need to look at those areas with the greatest potential for impacts on the worker, environment and public.