ML19332A874
| ML19332A874 | |
| Person / Time | |
|---|---|
| Site: | 07001007 |
| Issue date: | 06/27/1980 |
| From: | Cunningham G GENERAL ELECTRIC CO. |
| To: | |
| References | |
| 16782, NUDOCS 8009180509 | |
| Download: ML19332A874 (2) | |
Text
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GENER AL $ ELECTRIC
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ENGINEERING h
GENERAL ELECTRIC COMPANY, P.O. box 460, PLEASANTON, CALIFORNIA 94566 DIVISION t
June 27,1980 i
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Uranium. Fuel Licensing Branch Division o') Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1
Attention:
W. T. Crow
,1
Reference:
License SNM-54 Docket 70-01007 4 -
Dear Mr. Crow:
1 Section 3 of Annex B to License SNM-54. requires emergency plans for
"...various types of emergencies that can be anticipated,-i.e., internal accidents such as criticality, fire...". However, License Condition 27 permits the discontinuation of criticality alarms in areas when one safe batch of SNM is handled and where one safe shipment of SNM is stored.
c Condition 33 permits exemption from the requirement.for criticality drills l
when all site areas meet the requirements of Condition 27.
In order to provide consistency, General Electric requests a new License Condition 34 to read as follows:
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- 34. -Whenever all areas of the licensee's San Jose facility are exempt from tne criti.cality monitoring provisions of 10CFR70.24 pursuant -
to License Condition No. 27 and from the evacuation drill require-
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ments of-10CFR70.24 pursuant to License Condition-No. 33, the licensee is also exempt from the criticality emergency plan requirement of Paragraph 3 of Annex B to this License.
I This request for amendment is consistent with Conditions 27 and 33 in that L
if no drills or criticality monitoring are required, no purpose is served by ' requiring a criticality emergency plan.
J.
4 In addition, General Electric also requests a new License Condition No. 35 to read as follows:
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'35.
Whenever all are's of the licensee's San Jose facility are exempt a
i from the criticality monitoring provisions of 10CFR70.24 pursuant 4
. to L' cense Condition No. 27, the evacuation drill requirements of d --
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GEN ER AL ffj ELECTRIC
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Mr. W. T.' Crow June 27,1980 35.
(continued) 10CFR70 pursuant to License Condition No. 33, and the criticality energency plan requirements of Annex B pursuant to License Condition No. 34'and when all SNM at the San Jose site is unirradiated, the licensee is 'also exempt from the requirement for periodic drills -of the radioactive emergency plan contained in Paragraph 9 of Annex B to this license.
This request is based on the following considerations:
(1) The quantities of SNM authorized under License SNM-54 are too limited to result in a " radiation emergency" which could involve significant portions c f the site or the environs by any means other than a criticality accident.
(2) Whenever the provisions of License Conditions No's 27, 33 and 34 are met, the possibility of a radiation emergency resulting from criticality is eliminated.
(3) There is no irradiated SNM at the San Jose site.
License Condition No. -23 requires that "... the flow rates of all process ventilation. stacks and vents must be checked annually and whenever any pro-cess chango/ with potential to alter flow rate are made." However, reduc-tions in activity at the San Jose site (particularly in the fuels laboratory area) have resulted in the discontinuation of activities involving SNM in some areas. Although these areas are not decommissioned, they are in a stand-by status with no SNM inventory.
As no SNM is in process in these areas, there is no need to require exhaust ventilation flow rate checks in such areas (i.e., there are no activities which could result in the release of materials), and General Electric requests that License Condition No. 23 be amended to read:
... changes with potential to alter flow rate are made. Such flow rate j
checks may be eliminated in areas where activities involving the use of I
SNM'has been discontinued.
Flow checks must be reinstated whenever SNM activities are renewed."
i As these amendments are minor in nature, a check for $1,400.00 is enclosed.
If you have any questions on these requests, please contact me on (415)-
86 2-2 211, Ext. 4330. Thank you.
Sincerely, G. E. Cunningham Senior Licensing Engineer
/11 enclosure i5-16782 t -
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