ML20043G983
| ML20043G983 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 06/14/1990 |
| From: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| To: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 90RC07088, 90RC7088, NUDOCS 9006210403 | |
| Download: ML20043G983 (4) | |
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June 14, 1990 In reply refer to 90RC07088 Mr. Charles'Haughney, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
_ Request for Exemption of Certain Requirements of 10CFR70 and 10CFR73 in the SNM-21 License.
(Rockwell International Docket No.
70-25.)
Dear Mr. Haughney:
Following the recent changes in the SNM-21 license and prior licensed activities, including (1) reduction of the possession limit from 5 kgs to 400
.gm of SNM, (2) withdrawal of the license renewal application and notice of intent to terminate all activities involving SNM (as of April-4,1990),(3) transfer of all accountable SNM from licensed facilities (with-the exception of minor quantities of contamination), (4) submission of the Decommissioning Plan, the necessity for maintaining many of the conditions of the current license.are no longer appropriate. We are, therefore, requesting exemption from the following license provisions and conditions:
1.
Radiological Contingency Plan The most recent revision of the RCP was submitted to NRC on December 22, 1989. The actual quantities of R/A contamination in the Hot Lab has been estimated to be approximately 2.6 curies, mostly of B, y activity from mixed fission products and activation products.
Of this, approximately 0.03 curies is e activity, indicative of uranium isotopes and transuranics.
s 10CFR70.22(i)(1) requires an emergency plan if "... a criticality accident alarm system is required, uranium hexafluoride in excess of 50 kgs in a single container or 1000 kgs total, or in excess of 2 curies of plutonium in unsealed form or as foils or plated sources...."
None of-I0 these conditions apply to the current activities or license.
See below for criticality alarm systems. We do not possess any UF and the Pu 6
contamination is less than 30 mCt.
In addition, the current RCP shows that 1 gm of Pu 239 involved in a fire would only result in 0.005 i
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90RC07088 June 14,-1990 Page 2~
millirem effective dose equivalent at the site boundary.
This conservative calculation is significantly less than the limit of I rem in 10CFR70.22(1)(1)(1).
We therefore request exemption from the requirement to maintain and implement the provisions of the Radiological Contingency Plan.
2.
Program for Control and Accounting of Special Nuclear Material 10CFR70.22(b) requires that licensees possessing SNM exceeding 1 t
effective-kilogram should provide a full description of a program for control and accounting of SNM to show how the licensee complies with the requirements of 670.58, 974.31 or 674.51. This program is included in our existing license (application) as RI/RD86-190, " Fundamental Material i
Controls for Special Nuclear Materials." Since the current possession t
limit is 400 gm, which is less than 1 kg, we request exemption from the requirement to maintain and implement the provisions of.an SNM Control i
and Accountability Plan.
3.
Physical Protection Plan for Special Nuclear Material In Transit 10CFR70.22(g) requires that a plan for physical protection of special nuclear. material in transit in accordance with 6%73.20, 73.25, 73.26, 73.27 and 73.67(a),- (e) and (g), be maintained for 10 kg or more of special nuclear material of low strategic significance. The existing license (application) includes ESG 80-16, " Physical Security Plan for the Transportation of SNM of Moderate Strategic Significance from the Energy Systems Group of Rockwell International Under Special Nuclear Materials License SNM-21." Am=2nent No. 5 of the current licerise is for only 400 gm of SNM, less than 10 kgs. Also, SNM of low strategic significance is defined in 10CFR70.4 as between 15 gm and 1 kg. Actual quantities of a contamination have been estimated at approximately 0.03 curies.
If all of this were Pu239, then it would amount to less than 0.5 gm, below even the limits of the definition of low strategic significance. Due to the licensed possession and actual possessed quantities being below the above limits, and according to the exemption provisions of 10CFR73.5 and 73.6(c), we hereby -request exemption from the requirement to maintain and implement the provisions of the plan for physical protection of SNM in transit.
4.
Physical Security Plan for SNM 10CFR70.22(h) requires that each license for possession of 5 kg or more of SNM include a physical security plan for the protection o# SNM in situ which shows compliance with the requirements of f673.2L, 73.40, 73.45, 73.46, 73.50, 73.60, 73.70 and 73.71. The existing license
-includes such a plan, ESG 80-17, " Physical Security Plan for the Protection of Moderate Strategic Quantities of Special Nuclear Material at the Hot Laboratories of the Rocketdyne Division of Rockwell
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.v 90RC07088 June 14, 1990 Page 3 International. " Since the current license is only to possess 400 gms of SNM, less than 5 kg, we hereby request exemption from the requirements to maintain and implement the provisions of the Physical Security Plan.
5.
Criticality Accident Requirements 10CFR70.24(a) requires that each licensee possessing 450 gni or more of SNH in any combination shall maintain a monitoring system meeting the requirements of $70.24(a)(1) or 70.24(a)(2) and capable of energizing audible alarms if accidental criticality occurs.
10CFR70.24(a)(3) 1 requires the licensee to maintain emergency procedures for post criticality accident evaluation and to conduct drills, 10CFR70.24(b)(2) requires the licensee to maintain decontamination facilities and arrangements for qualified medical services and treatment following radiation emergencies, both onsite and offsite.
Rocketdyne procedures and systems for nuclear criticality safety are described in the Health-and Safety sections of the current license (application). Also, Rocketdyne procedures and systems for emergencies, drills and onsite and offsite medical treatment are described in the Radiological Contingency Plan. The current licensed possession limit is 400 gm, and the actual quantity of SNM contamination is less than 0.03 curies.
Both.these figures are-below the 450 gm limit of 10CFR70.24; therefore, we hereby request exemption from all requirements of 10CFR70.24 pertaining to criticality-accidents and from all requi' ;ments established in part I of the current license (application) relating to criticality control.
Notwithstanding the above request for exemption of certain sections of 10CFR70 and 73 based on the limited activities and trivial quantities of SNM remaining as contamination, the Rocketdyne Division of Rockwell International intends to maintain certain procedures and systems to ensure the health and safety of personnel.
l Rocketdyne will continue to maintain its Master Emergency Plan, which has always been more comprehensive than the Radiological Contingency Plan, in that
-it includes procedures to respond to all industrial accidents, including those
' involving R/A materials.
The Santa Susana Field Laboratory still has extensive ongoing government work involving rocket engine development and testing, and nonradioactive energy related research.
As such, Rocketdyne maintains and will continue to maintain, an effective security department which controls access to the facility.and meets all government security requirements.
All procedures and systems pertaining to radiation protection described in the Health and Safety section of the license (application) and the Decommissioning Plan (Al-78-10) will remain in effect for the duration of the decommissioning and until all facilities under the SNM-21 license have been ' released for unrestricted use, and the license is fully terminated.
i
t 90RC07088 June 15, 1990 Page 4 We request that the aforementioned exemptions be reflected in the same license amendment which the NRC intends to issue approving the Hot Lab Decommission Pl an.- If you have any questions,-please do not hesitate to contact the undersigned at (818) 718-3413.
Very truly yours, ROCKWELL INTERNATI0'.lAL Rocketdyne Division clo P. D. Rutherford, Manager!
Nuclear Safety & Reliability Engineering PDR:dr 4
.