ML20151D186

Submits Update of Info in Response IE Bullein 79-19 Re Low Level Waste Packaging for Transport & Burial.Burial Site Under License 10-24 No Longer Used.Thomas Gray & Assoc Now Used to Dispose of Low Level Radwaste

ML20151D186
Person / Time
Site:	05000113
Issue date:	06/06/1988
From:	Nelson G ARIZONA, UNIV. OF, TUCSON, AZ
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
IEB-79-19, NUDOCS 8807250001
Download: ML20151D186 (3)

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q DEPARTMENT OF NUCLEAR AND ENERoY ENolNEERINo June 6,1988 United States Nuclear Regulatory Commission Region Y I450 hlaria Lane, Suite 210 License R-52 Walnut Creek, CA 94596 Docket 50-113 Re: Update of information previously sent in response to IE Bulletin No. 79-19 for the University of Arizona TRIGA Reactor Gentlemen:

By letter dated September 18, 1979 the University of Arizona Nuclear Reactor Laboratory provided to you certain information requested in IE Bulletin No. 79-19, dealing with packaging of low-level nuclear waste for transport and burial. Since that time, changes have been made in low-level waste management and procedures at the University. For this reason, we are sending you the following information to update that provided in 1979. Only the sections of the earlier response with significant changes are given here. The remainder of the response remains unchanged.

2. Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee. If a waste collection contractor is used, obtain the appropriate requirements from the contractor.

The University of Arizona burial site maintained under Arizona state license 10-24, described in our former response, is no longer in use. Disposal of low-level radioactive waste is now done through a waste collection contractor (currently Thomas Gray and Associates). This waste is shipped to the appropriate state depending upon the type of waste involved. The statements of requirements 1 placed on the waste burial firm by the applicable states are maintained in the University of Arizona Radiation Ccntrol Office.

3. Designate, in writing, the people in your organization who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

As stated in our earlier response, the persons responsible for the safe packaging of radioactive waste in the reactor laboratory in order to transfer it to authorized staff of the University Radiation Control Office are designated in writing and their names are posted on the Reactor Status Board.

liowever, these persons do not package waste for transport to disposal sites, which is the primary focus of IE 79-19. The Radiation Control Office maintains a staff authorized to collect, sort, and package waste for transfer to the waste collection contractor. These persons have been designated in writing by the Director of the Radiation Control Office as having this responsibility. Their names are posted in the Offices of the Radiation Control Office and in the Nuclear Reactor Laboratory.

4. Provide management-approved, detailed instructions and operating procedures to all personnel involved in the transfer, packaging and transport of low-level radioactive material. Special  ;

attention should be given to controls on the chemical and physical form of the low-level radioactive material and on the containment integrity of the packaging. <

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US Nuclear Regulatory Commission p3SC 2 June 6,1988 Instructions and procedures for packaging of low level waste in the reactor laboratory have been revised since our earher response. The low-level radioactive waste generated in the Nuclear Reactor Laboratory consists primarily of gloves, plastic bags, etc. with low levels of activity of isotepes with short halflives. This material is of low specific activity and the isotopes are classified in transport groups III and IV. According to the transportation regulations provided in 49CFR173.391(a), this material does not require DOT type A packaging. Waste which does not require specific DOT packaging forms is packaged in the reactor laboratory in conformance with University procedures for transfer within the University as required by RC-040, Radiation Control Office Rules for Packaging Radioactive Waste, and is then transferred to a Radiation Control Office facility for processing. This processing includes sorting, separation and compa: tion and repackaging with waste from other University activities in preparation for transport. Reactor Laboratory staff are not authorized to t)ackage or arrange for transfer of any radioactic watte to n disposal site or to the waste collection contractor; that function is reserved for the University Radiation Control Office.

5. Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material. Maintain a record of training dates, attendees, and subject material for future inspections by NRC personnel Only Senior Reactor Operators with administrative and supervisory roles in the reactor laboratory are designated to package waste for and subsequently to transfer it to the Radiation Control Office staff. These persons receive biennial retraining in procedures and instructions. The Radiation Control Office staff members responsible for processing and packaging waste for transport by the waste collection company receive initial training and periodic retraining in the DOT, NRC, and Arizona regulatory requirements.

6. Provide training and periodic retraining to those employees who operate the processes which generate waste to assure that the volume of low-level radioactive waste is minimized and that such waste is processed into acceptable chemical and physical form for transfer and shipment to a low-level radioactive waste burial facility.

Reduction of volume of radioactive waste generated in the operation of this facility depends upon the experimental plans and irradiations which are approved. After authorization by the Reactor Committee the resiew and approsal of individual experiments and irradiation requests is the responsibility of Senior Reactor Operators with administrative and supervisory roles in the reactor laboratory. Reactor operators without administrative or supervisory roles at this facility do not make such approvals. The reactor committee and staff have concluded that it serves no purpose to require this training as a part of the general operator requalification program. Training for those persons who make decisions which could minimize the volume of radioactive waste is included with the training described in item 5 above.

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US Nuclear Regulatory Commission page'3

. June 6,' 1988.

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7. Establish and implement a management-controlled audit function of all transfer, packaging '

and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning- to ensure safety and compliance with

> regulatory requirements.

. Reactor committee members audit reactor laboratory records of isotope generation and transfer of-low 21 ciel radioactive waste for disposal. Radioactive waste generation and transfer is a topic of the annual-Reactor Health Physics audit required by reactor operating procedures. The transfer, packaging, and transport of low lesel radioactive waste by the Radiation Control Office is reviewed ar nually by a review committee which includes members of the University Radiation Safety Committee and the Clinical Radioisotopes Committee.

This updated information h2s been reviewed and spr. roved by the Reactor Committee and the Director of Radiation Control. Office. We will keep you informed of any future changes to this

-information Sineciely, t i sii6 i

George W. Nelson, Director Nuclear Reactor Laboratory GWN/km ec: Ernest T. Smerdon, Dean College of Engineering and Mines B. Westerman, Director Radiation Control Reactor Committee University of Arizona