ML20003G871
| ML20003G871 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 02/09/1981 |
| From: | Mcgovern J UNION CARBIDE CORP. |
| To: | Rolonda Jackson NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 18518, NUDOCS 8105040087 | |
| Download: ML20003G871 (3) | |
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UNION CAESIDE COH?3 RATIO?!
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Attn:
Mr. R. Jackson Gentlemen:
The Materials and Plant Protectio t Amendment 3 to the Union Carbide Corpcra-tion SNM-639 license, item 7 2 prescribes i tem checks of discrete i tems and centainers of SNM daily.
It is requested that the wording of item 7.2 be amended to read as follows:
" Accurate records shall be established and maintained which provide en a daily basis knculedge of the identity and lo-cation of all unieradiated SNM in discrete items and containers.
This change is requested because daily item checks of irradiated SNM has beccme impractical; hcwever, by reason of the fact that this material has been i rradiated, it is rendered self-protected within the definition of 10 CFR 73.6 b.
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'U.S.N.R.C. Katerial Control
& Account. Licensing Branch Febru ry 9,1981 There are from 75 to 100 discrete items or containers which hold irradiated SKM at any time during routine operation. a general breakdown of these items follows:
Location item Quant i ty Radiation level @ 3' Reac tor Irradiation 23 ea.
~5000 Rem /hr. each Core Target Hot Irradiation Cell Ta rget I to 6 ea.
5000 Rem /hr. each Het U & fission eH g{aste 20 to 60 ea.
100 to 5000 Rem /hr. each
(~15 gms ea.) in septum sealed bottles.
Hot U 0xide with I to 26 ea.
100 to 1000 Rem /hr. each Cell fi ssion pdts.
It is not practiable to perform daily item checks on irradiation targets in the reactor core because it would require that the reactor be shut down each day and all of the targets would have to be removed. This would seriously hinder efficient isotope productic... All other Irradiated SKM is located in the hot cells where procescing goes on practically continusculy 6 days per week. Radiochemical separation operations would have to be interrupted if daily item checks were required.
Because these items are self protected by contained radioactivity and be-l cause of the security measures employed, we believe that daily item checks of this material are unnecessary. Any unauthorized diversion would require special knowledge and equipment which would prevent such diversion from being carried out without detection. Daily item checks will be made on all unirradiated material.
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PDDR ORIGINAL.
i 1UCC Physical Security Plan forwarded to the Commission 5/18/30.
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'U.S.M.R.C. Material Control
& Account. Licensing Branch February 9,1931 The new wording of 7 2 that is hereby requested also omitted the word
" quanti ty" as an ingredient of the item check. Al though each MBA custodian could assess the approximate amount of material contained in discrete items other than sealed targets by noticing the volune of solution, quantity of powders and qualities such as colors and textures of material, an absolute determination of quantity cannot be made unless the material contained is sampicd and assayed.
Since we do not believe it is the intent of this license condition to re. 're daily assays, we request tha t the word " quanti ty" be left out.
For the above reasons, we believe this license change can be made without endangering life, preperty and the commen defense.
A check in the amount of $150.00 is enclosed for the fee prescribed by 10 CFR 170 31. 1. G for an administrative license amendment.
Thank you for your consideration.
Very truly yours,
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James J. McGovern Business Manager Radiochemica ls JJMcG:js Enclosure (CHECK $150.00)
P90R ORIGINAL
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