ML19260E057
| ML19260E057 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo, 07000267, 07000785 |
| Issue date: | 01/02/1980 |
| From: | Pierro M NEW YORK, STATE UNIV. OF, BUFFALO, NY |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-79-19, NUDOCS 8002130227 | |
| Download: ML19260E057 (4) | |
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- o; r w crn,. n: n.4T u v 301.6.1 January 2, 1980 Mr. Boyce H. Grier Director United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
Re: Response to Bulletin No. 79-19 This letter is in response to IE Bulletin No. 79-19.
Please accept our apologies for not submitting this response in a more timely manner.
The SUNY at Buffalo's Radiation Protection Department (RPD) processes and disposes of radioactive wastes generated from three sources: The SUNY at Buffalo Campus Laboratories (covered under broad License # 1049 issued by the New York State Department of Health); The SUNY at Buffalo Nuclear Science and Technology Facility (covered under New York State Department of Health License # 1051 and NRC License R-77, SNM-273, and SNM-723); and those Hospital Laboratories affliated with SUNY at Buffalo's School of Medicine (covered under New York State Department of Health License # 1049-2 and NRC License 31-00786-02).
Because the RPD is responsible for the processing of wastes from these sources, I have submitted two responses to this bulletin, one covering the Nuclear Science and Technology Facility's activities, the other covering Campus and affliated Hospital activities.
You may wish to refer to the response submitted by Dr.
Steinback for further information on activities covered under NRC License 31-00786-02.
Very truly yours, Ch
($ Q Mark A. Pierro Manager Radiation Protection Department MAP:kt
Enclosures:
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Page 2 In response to IE Bulletin No. 79-19 dated August 10, 1979, the following information is submitted covering activities under New York State Department of Health License # 1049, 1049-2, and NRC License 31-00786-02:
Item 1 - The RPD maintains a current copy of DOT Regulations (subscription service provided by DAT-0-Line, Inc.) in its office.
NRC Regulations (same subscription service) are maintained at the Nuclear Science and Technology Facility.
Item 2 - A current set of licenses and burial site criteria are maintained on file in the RPD office for each of the three waste burial sites.
Item 3 - The Radiation Safety Officer through the RPD staff members are responsible for the safe transfer, packaging and transport of low-level radioactive material.
The RPD has designated in writting those responsibilities.
Item 4 - Detailed instructions and operating procedures for transfer, packaging, and transport of low-level radioactive waste were generated in August /1978.
Copies of these procedures are maintained in the RPD office and are, there-fore, available to all members of the Department.
Revisions of these procedures to reflect modified site disposal criteria are currently in progress.
Further information on handling of radioactive wastes are contained in our Radiation Protection Manual, Volume I.
Item 5 - Informal training in the DOT and NRC Regulations have been provided to RPD personnel involved in the transfer, packaging, and transport of radioactive materials, whenever the need for such training arose (i.e.,
changes in the regulations, new burial site requirements).
Records of future training dates, attendees and subject matter will be maintained.
Item 6 - The RPD provides a set of instructions on each wasce container that is issued to Users.
These instructions are revised as necessary to meet changes in burial ground requirements and other regulations.
In addition, training sessions are held at the affliated Hospital locations and will soon start on Campus, including coverage of radioactive waste regulations and procedures.
Periodic training is provided to RPD personnel involved in processing the waste as described in item 5 above.
Item 7 - The RPD Operating Committee will establish an audit of all transfer, packaging, and transport activities of radioactive material to provide assurance that regulatory requirements are being followed Item 8 - Audits of radioactive waste activities are performed as follows:
1.
All containers received from the affliated Hospital labs checked and approved for disposal as described in Dr. Steinback's response to this bulletin referenced earlier in this report.
2.
All SUNY at Buffalo Campus radioactive waste containers are checked and approved for pickup to the Waste Processing Area by RPD staff membe rs.
Records are maintained of all approved pickups.
Page 3 Item 9 - 1.
The SUNY at Buffalo RPD made six low-level radioactive waste shipments in 1978 and the first six months of 1979.
The volume of waste shipped was 6,765 cubic feet, including the waste from the Nuclear Science and Technology Facility.
2.
The quantity of low-level waste shipped was 6.559 curries, including the waste from the Nuclear Sciente and Technology Facility.
The major isotopes were Carbon-14, Tritium, Iodine-125, and Phosphorus-32.
3.
The low-level radioactive liquid waste that was generated was solidified using vermiculite.
Page 4 Activities Under NRC Licenses R-77, SNM-273, SNM-723:
Item 1 - A current set of NRC Regulations is maintained at the Nuclear Science and Technology Facility (subscription service provided by Date-0-Line, Inc.).
A current set of DOT Regulations (same subscription service) is maintained by the RPD in its offices.
Item 2 - A current set of burial site Licenses and Reguirements are maintained on file in the RPD's offices.
Item 3 - At SUNY at Buffalo, the RPD is responsible for the safe transfer, packaging, and transport of all radioactive material.
Ites 4 - Instructions and operating procedures in the transfer, packaging, and transport of radioactive material are provided in our Radiation Protection Manual, Volume II.
In addition, detailed instructions are provided on each of the radioactive waste containers issued by the RPD.
Item 5 - Training in the DOT and NRC Regulatory requirements to all personnel involved in the transfer, packaging, and transport of radioactive material is provided in the annual Reactor Requalification Program.
The transfer, packaging and transport of radioactive vastes is provided by the RPD.
Item 6 - All low-level radioactive waste generated at the Nuclear Science and Technology Facility is processed for shipment to a burial facility by the RPD in accordance with established procedures.
Item 7 - The Nuclear Science and Technology Facility Operating Cansittee will establish an audit of all transfer, packaging, and transport activities of radioactive material to provide assurance that regulatory requirements are being followed.
Item 8 - As in iten 6, the RPD is responsible for the transfer, packaging, and transport of radioactive wastes from the Nuclear Science and Technology Facility.
Audits of these activities are performed by the RPD.
Item 9 - The Nuclear Science and Technology Facility does not ship directly to a burial facility.
Waste from the Nuclear Science and Techrology Facility is included in the shipments made by the RPD.
The volume of waste from the Nuclear Science and Technology Facility from 1978 and the first six months of 1979 was 82.5 cubic feet.
2.
The quantity of low-level radioactive waste shipped was 0.007 curies.
The major isotopes were Silver-110m, Cobalt-60, Iron-59.
3.
No liquid waste was generated that needed solidification.