ML19318C838
| ML19318C838 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 06/10/1980 |
| From: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sly D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8007020337 | |
| Download: ML19318C838 (3) | |
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NUCt. EAR REGULATORY COMMiss:ON e
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,g MEMORANDUM FOR:
Douglas Sly Division of FFMSI, IE FROM:
W. T. Crow, Section Leader Uranium Process Licensing Section i
Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
SUBJECT:
LICENSE RENEWAL APPLICATION LYNCHBURG RESEARCH CENTER (SNM-778, DOCKET 70-824)
A copy of the draft of the proposed license' was submitted to J. B. Kahle, Region II, Office of Inspection and Enforcement, for his review and comment.
A nurber of comments were received. Most coments were resolved by the addition of conditions to the proposed license, one requires further action en the part of the LRC, and the remainder, we feel, requires no action, as explained in this memorandum.
All coments are covered in proposed license conditions (see attached) except the following:
the first coment requires further action by the LRC.
1.
Page A-43 (A.9.5.9.1)
Coment: There appears to be a conflict with Section 9.3.4 on outside storage.
Response: Section 9.3.4 is related to above ground outside storage of dry waste. Outside " underground storage" of dry wastes was not included in the section 9.3.4 on waste storage as it should have been.
In fact, the licensee did not even discuss the outside underground storage in the demonstration section. The licensee agreed to incorporate the outside underground storage in Section 9.3.4 and in the demonstration section of the renewal application.
Section A.9.5.9 provides only the nuclear criticality safety criteria for outside underground storage. Other outside storage is limited to 0.5 gm
- fissile uranium per container.
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Page A-7 (A.5.2.2)
Connent: The requirement that the section manager shall have demonstrated knowledge in the application of radiation and nuclear safety associated with their projects is not inspectable.
Response: We believe the minimum qualifications specified are adequate.
3.
Page A-9 (A.6)
Connent: The requirement for RWP's is not adequate.
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Response: The requirement for RWP's is expanded on page A-12 (A.6.5).
4.
Page A-11 (A.6.4.1)
Connent: The Director receives only a quarte'ly report of the monthly r
nuclear criticality safety and radiation safety audits.
If corrective action is required, the Director or personnel responsible far corrective action should be notified innediately.
Response: ' The monthly audits are conducted in accordance with a-written plan and documented. The distribution of the documented audits is left to the LRC.
If corrective action is required, it is taken as early as possible by the responsible supervisor. The quarterly report to the Director is for his infonnation on the nuclear criticality and radiation safety of the LRC operations.
5.
Page A-13 (A.7.3)
Connent: The requirement for the SRC to meet at least four times annually could be fulfilled by meeting four times in a single quarter.
Response: Meetings more than once a quarter pose no problem. A minimum semi-annual or annual meeting by the SRC would have been adequate.
6.
Page A-29 (A.9.3.4)
Connent: The statement the waste is not stored for long periods of time does not belong in the license condition section. Furthermore, "long periods of time" is not defined.
Response: The licensee plans to remove the statement.
It need not be added to the demonstration section.
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7.
Page A-31 (A.9.4.6)
Coment:
It is stated the SAS " periodically" audits the activities of the health physics group relating to the latter's auditing of shipping records.
" Periodically" is not defined.
Response: The health physics group has the primary responsibility for auditing shipping records. The secondary audit is an added requirement of the LRC.
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8.
Page A-37 (A.9.5.7.5.3 - middle page)
Consnent: The nuclear safety evaluation overcheck specifies its content.
The content of the overcheck contains demonstration infonnation on what constitutes a second party review.
Response
Including the content of an overcheck does n'ot alter it requirements. The consnents made regarding the minimum qualifications i
for the one performing the nuclear safety evaluation and the one perfonning the overcheck will be incorporated as a license condition.
If there is any further question regarding this action or the proposed license conditions, please feel free to contact me or N. Ketzlach of my staff.
1 L. u W. T. Crow, Section Leader Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosure:
Proposed License Conditions I
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