ML19262C211
| ML19262C211 | |
| Person / Time | |
|---|---|
| Site: | 07000984 |
| Issue date: | 12/13/1979 |
| From: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Olesen D Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| References | |
| NUDOCS 8002080204 | |
| Download: ML19262C211 (4) | |
Text
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M, NUCLEAR REGULATORY COMMISSION
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DEC 131979 FCUP:RLS70-984 Battelle Pacific Northwest Laboratorias ATTN:
Dr. Douglas E. Olesen, Director P. O. Box 999 Richland, Washington 99352 Gentlemen:
Draft questions and comments on your application for renewal of Special Nuclear Material License No. SNM-942 were discussed with Battelle staff, primarily Messrs. Selby, Martin and Richey, during the site visit of Messrs.
A. L. Soong and R. L. Stevenson of my stuff, on November 26, 1979. As promised during those discussions, we are sending you a written set of the questions in final form (enclosed).
To maintain our schedule for the review of your application, it is desirable that we receive your responses by January 7,1980.
Sincerely, Abh*f f
W. T. Crow, Sectit Leader Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety
Enclosure:
Q0estions and Comments on License Renewal Application, Battelle Northwes t, Docket 70-984 cc:
J. M. Selby, BPNL 8002 80 76Y 0
Questions and Comme.nts on License Renewal Application, Battelle Northwest
( Application Dated May 1,1979, and Supnlemented July 2,1979)
Docket 70-984 (Concerning Section 1.0, Criteria and Administrative Procedures) 1.
Pace 1.2 It should be confirmed that Battelle Northwest will notify the Chief, Uranium Fuel Licensing Branch, of any changes in applicable DOE-RL manual chapters that affect the limits for radiation protection.
2.
Paces 1.3-1 and 1.3 It is not clear what organizational commitments are being made.
Thus, we could not construct a consistent chart for the organization using the information in the letter of July 2,1979, and -
the figures on pages 2.4-1, 2.4-2, 2.4-3 and 2.4-8.
Further clariff-cation should be provided in the form of an appropriate organization chart for Section 1, and enough additional textual details in Section 1 to clu 'fy the distinction between " Criticality Safety" and " Nuclear Safety" and between the " Criticality Safety Specialist" and the " Senior Specialist, Criticality Safety."
Furthermor'., tn= Appendix A biograph-ical sketches should include sketches representative of the two positions.
3.
Pace 1.3 a.
Please identify what positions have the authority to shutdown operations deemed a threat to the health and safety of employees or to the public, and describe the procedures for authorization of renewed operation after such action is taken.
b.
The third listed responsibility should include audits of operations, state the required audit frequency and identify the class of position responsible.
4 Pace 1.3 a.
The minimum educational requirements for the Senior Engineer, Nuclear Safety, should be a part of the required qualifications, b.
What is the meaning of " responsible for directing independent audits"?
5.
Pace 1.3-5, caracraoh (6) -
a.
What are the required qualifications for a Criticality Safety Repre-sentati ve ?
b.
To whom in the organization does the Criticality Safety Representative normally report?
6.
Page 1.3 a.
(Penultimate paragraph on page)
Monthly audits are made by a member of the facility operating staff. This implies a possible conflict of interest arrangenent and, in the absence of information, raises the question of the auditor's competence. What are the requirements for audits by qualified criticality safety staff?
2 b.
(Last paragraph on page) Who conducts the audits described, what are th,e required qualifications and at what minimum frequency are audits made?
c.
The wording was revised in the July 2,1979, application to state that criticality safety specifications will be available in all process and storage areas. The former wording required that the applicable specifications be posted. Please explain and justify the revision.
7.
Pace 1.3 The reference to paragraph 71.12 in 10 CFR 71 should include confirmation that the quality assurance program has been reviewed and approved by the U.S. Nuclear Regulatory Commission, as required in the introductory paragraph for paragraph 71.12.
8.
Paragraph 20.l(c) of 10 CFR Part 20 states in part that licensees should make every reasonable effort to maintain radiation exposures as far below the limit specified in that regulation as reasonably achievable ( ALARA).
In order to permit us to evaluate your commitment to the ALARA principle, please provide an analysis of quarterly average occupational exposures (internal and external) covering at least the last two years of operations for each working area in each building in which licensed materials are or may be handled, stored or processed.
The analysis should identify the sources and locations where most exposures occurred as related to job categories and work activities. The analysis of internal exposures should consider the air sampling data as well as the bioassay data (including in vivo lung counting data).
The analysis should conclude with a description of any actions (taken or planned) to reduce employee exposures.
9.
The application for license renewal should be augmented with a plan for the future decontamination of the places of use and sites (owned by Battelle) authorized by the license so that they can be released for unrestricted use. This plan should identify and discuss the factors that were considered in the design of the plan in sufficient detail to enable an independent review. The plan should include an estimate of the costs involved and the financial arrangements that have been or will be made to ensure that adequate funds will be available to cover these costs at the time of decommissioning.
Response to the foregoing request will require a plan and financial commitment applicable to the Battelle Northwest-owned facilities.
3 (Concerning Section 2, Licensing Application Descriptive Supplement)
(Note reference to Section 2 in Question 1) 10.
Pace 2.3 Please provide the schedule for improving the exhaust system in Building 3720.
11.
Page 2.5 Please state the frequency and method for checking the representativeness of the permanently mounted air sampling stations.
- 12. Please provide a summary of the offsite radiological effects, based on analyses of postulated accidents, for fires or explosions in the facilities where licensed materials are handled, stored or processed.