ML20086P940

Expresses Opinion That 10CFR20.1601(c) Can Readily Relieve Any Burden on License R-56 Operations,In Response to NRC 950605 Request for Input on Burden Associated W/Controlling Radiation Beams at Facility

ML20086P940
Person / Time
Site:	05000083
Issue date:	07/11/1995
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	Weiss S NRC (Affiliation Not Assigned)
References
NUDOCS 9507270221
Download: ML20086P940 (2)

Text

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UNIVERSITY OF

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[ Nuclear Reactor Facility 202 Nuclear Sciences Center

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~ Department of Nuclear Engineering Sciences P.O. Box 118300 Gainesville, Florida 32611-8300 Tel: (904) 392-1429 Fax:(904) 392-3380 t

July 11,1995 p:

Dr. Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Project Support Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Control of Access to Radiation Beams In response to your request for input on the burden associated with controlling radiation ,

beams at our facility dated June 5,1995, it is our considered opinion that 10 CFR 20.1601(c) can readily relieve any burden on our R-56 license operations. The reason for this evaluation is that we will probably never need to make a submission under 20.1601(c). We do relatively little beam work at our facility; frequently there is no high radiation area or other area above 100 mR/hr involved when we do beam work. However, even when such is the case, such work is relatively easily controlled by continuous direct licensee surveillance that is capable of preventing unauthorized entry per 10 CFR 20.1601(b). This is possible because such work at our facility is usually a short term experiment. Therefore, we see little problem for our facility in having to make a submission under 20.1601(c) for approval since it is unlikely we would ever need to do so.

In consideration of other facilities, a few words may be appropriate and useful. It is certainly possible for higher power, multi-beam facilities to have several to many different areas for which they would need approval of alternative methods for controlling access to high radiation areas. One of my concerns here is that a Commission analysis and review of such alternative methods may require substantial additional critical path experiment time. If f the problem with critical path can be resolved, for example by initial approval (perhaps for  !

30 days) with subsequent detailed review, then the burden may be partially eliminated. l However, there are some other concerns as well. First, I strongly believe that adherence to l the guidance in ANSI /ANS-15.11 (1991) will provide adequate controls. This is an industry '

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Dj. Scy'mour H. Weiss Page 2 July 3,1995 standard that should be supported. Secondly, I believe that labelling beams as high radiation areas, especially in the larger facilities with multiple collimated beams such as the 10 MW MURR or the 20 MW NIST reactor facilities, may be counterproductive. Radiation control personnel at these facilities certainly need to assure proper controls, but I do not believe the proper route is to label these beams as high radiation areas. I2 belling such areas as high radiation areas using such controh may be inappropriate and ineffective, especially since these beams literally are not what is usually considered to be a high radiation area. Special training is needed and given in any facility where such beams are used, but I do not think the proposed rule change will be in the best interest of facility personnel safety or ALARA consideration at such facilities.

At any rate, our point is that we are at the lower power end of such concerns so our response may be relatively unique. Even in our case, special training and controls are implemented in any situation where access of any kind to a 100 mR/hr area is possible; we certainly consider ANSI /ANS-15.11 to provide for adequate controls. We urge the Non-Power Reactors and Decommissioning Project Directorate to give adequate consideration not only to our facility but especially to all the larger, higher beam use facilities at 500 kW and higher levels where this proposed rule change could be an ineffective and perhaps counterproductive change when overall radiation safety and ALARA are considered.

If you should have further questions, please feel free to contact us. Thank you for your consideration.

Sincerely,

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William G. Vernetson Director of Nuclear Facilities WGV/dms Copics: D. Simpkins RSRS l

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