ML20154A327
| ML20154A327 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 08/05/1988 |
| From: | Toy H Battelle Memorial Institute, COLUMBUS LABORATORIES |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 24621, NUDOCS 8809120152 | |
| Download: ML20154A327 (8) | |
Text
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~A August 5, 1988 Mr. Leland Rouse
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Advanced Fuel and Spent Fuel Licensing Branch
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Division of Fuel Cycle and
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US Nuclear Regulatory Commission i
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Dear Mr. Rouse:
REQUEST FOR AMENDMENT TO LICENSE NO. SNM-7; DOCKET 70-8 This is a formal request for an amendment to Special Nuclear Materials License SNM-7 to authorize controlled field studies utilizing up to a maximum of three (3) curie.s of carbon-14.
The amendment would provide for conducting controlled field studies with nuclide labeled compounds as described herein.
The information provided in su) port of this requested amendment was developed following discussions with mem)ers of Region III. Specifically, discussions were held with Mr. John Madera and Ms. Kathy Grades relative to the information required for your review. At the time, these discussions were initiated we assumed that Region III would review our request.
- However, later discussions with your Mr. Pete Loysen advised that the request for this amendment was to be processed through your branch.
l The following information is provided in support of the requested amendment:
1 m
General Description The field studies involve the application of carbon-14 labeled insecticides, fungicides, herbicides or similar compounds to field or garden crop plants or the soils in which these plants are grown. Objectives of these studies l
include determination of intermediate and ultimate distributions and fate of the compounds and their metabolites in the plants and/or the soils.
The soils and plants are to be contained in defined plots situated on Battelle property located at the Life Sciences Area in West Jefferson, Ohio. A Jescription of the Battelle West Jefferson Life Sciences Area is contained in the Battelle Columbus License Application BCL 1081 dated, October 1981 with revisions dated, March 14, 1988.
The compounds will be applied by standard methods including, as appropriate for the individual study, spraying, dusting, seed treatment or combinations.
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August 5, 1988 i
Plot General Description. Security. and Limits Each plot will be no more than 10 square meters in area and will be shaped.as most convenient for the study.
No more than 50 plots will be in operation at any one time.
All operational plots will be centained within one or not more than 5 integral areas that will be fenced and secured by locked access to prevent entry by unauthorized personnel, domestic animals and most wildlife.
Plots containing plants which may be attractive to birds as a food or other attributes will be covered by a suitable barrier to prevent access.
Plots will be located and situated so they will not be subject to overflow, flooding, or otherwise dispersed by natural streams or man-made systems.
No more than 50 millicuries total activity will be applied to any single plot. Activity contained in materials collected and secured as radioactive waste will no longer be considered as ) art of the 3 curie inventory.
This activity will be possessed wit 11n the general provision
- of license SNM-7.
Radioactive wastes will be collected, processed and disposed as expeditiously as possible within economic constraints.
Each plot will be provided a perimeter barrier set at least 8 inches into the soil to restrict lateral migration of the chemical into contiguous soil areas.
Radiological Safety All current radiological safety and health physics license conditions shall apply for these operations. All radiological aspects will be under the general purview of the Radiological Safety Committee and the Radiological Safety Officer. Radiological safety and health physics support will be provided for every field project and will be performed by the Research Department, Health and Safety personnel, or by the BCD Health Physics Services Group.
Each project which will involve these field studies will be reviewed and approved on a case by case basis by the BCD Radiological Safety Officer or the BCD Radiological Safety Comittee. Non-radiological risks will be reviewed and considered by personnel of appropriate expertise, t
o Mr. Leland Rouse 3
August 5, 1988 Preparation of labeled chemicals for application will be conducted according to provisions for laboratory operations currently authorized by the license.
Persons applying labeled chemicals by methods which may involve risk of intake shall be provided training in the use of and required to use appropriate preventive and protective equipment.
Full-face respirators y=th appropriate chemical cartridges, impervious gloves, clotning, sleeve covers and boots will be maintained available and used as needed. Good laboratory practice by all persons handling and applying labeled materials and handling objects, equipment, and materials which may be contaminated by labeled materials will be implemented at all times.
Harvesting. Processing. and Waste Sampling of soil and plant tissues may be conducted periodically during the course of the study.
Plant tissue and residue remaining after analytical procedures are completed will be managed as radioactive waste according to the contained nuclide concentration.
On completion of the specific study in an individual plot, soil cores will be taken and all plant parts and residue and soil containing a nuclide concentration greater than 0.0008 microcuries per gram of tissue or soil will be removed from the plot and managed as radioactive waste. All plant parts and soil containing a nuclide concentration less than 0.0008 microcuries per gram will be handled as dictated by other than rediological considerations except plant parts will be controlled in all cases so that they will not be available for human consumption or animal feed.
Environmental Constraints of Labeled Materials A housing unit of light framework covered with plastic sheeting over the top and all sides will be positioned over each plot to which labeled materials will be applied to confine labeled material aerosols during application.
Slits will be made in the sheet plastic top and sides as necessary to insert and manipulate the materials application devices.
Slits not in use will be closed with tape and/or sheet plastic or other positive means of closure.
For radioactive material aerosol applications which occur during daylight hours, the housing unit will be left in place for
Mr. Leland Rouse 4
August 5, 1988 approximately one hour to allow settling of the aerosol. The housing unit will then be removed to minimize plant "scorching."
After use the housing unit will be treated '.s contaminated, will be cleaned and determined as clean by appropriate survey or will be appropriately disposed as contaminated.
Restrictions on Application of Labeled Materials Weather forecasts will be monitored and applications of labeled materials will not be made during periods in which thunderstorms, heavy rains or other severe weather disturbances are considered probable within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by a reliable forecasting service.
Labeled materials will be applied only during times when winds are light. Applications will, in general, be made during evening hours when winds tend to be light.
Labeled naterials applications will be immediately suspended if unfavorable weather conditions develop or threaten to develop.
Coordination of Field Studies with Ohio State Health Department This requested amendment has been discussed and reviewed by the Radiological Section of the Ohio State Health Department.
Several procedures relative to radiological safety have been incor) orated in our planning as a direct result of their review.
As noted below, t1e radiological state officials will be afforded the opportunity to be present during field operations.
Notification of Ohio, State Health Departunt The Radiological Section of the Ohio State Health Department will be notified sufficiently in advance of the first operations in order to be present and observe the operations should they so desire.
We would trust that the information provided is comolete and will enable you to perform your review and subsequent issuance of the requested amendment.
We shall be happy to provide whatever additional information you may require for your review.
Please contact me on (614) 879-5228, should you have questions, i
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h-Mr. Leland Rouse 5
August 5, 1988 A review of appropriate fees for this amendment as stipulated in 10 CFR Part 170 wauld appear to indicate the requested amendment would fall under 170.31 Section 3L. Accordingly, we are enclosing our check for $120.
Very truly yours 4
jvfofgo cr Harley L. Toy NRC Licensing Coordinator HLT:jv cc: Robert Quillin 4
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PCOCHA5E ORDEO B ATTELLE MEMC ?RI AL IN 5TITUT E ANTu'CMBACK PAOCEDURE:
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AREA CODE 614 - 42< 6424 ggig VCE M SENT. COLUusc00rw-c-
Att CCas tSPONDENCE AND PHONE CAtts con-I U S i.UCLEAR REGULATORY COtuiI S S IOrd CreNmc ims cette snouto et oietcito to twe OFFICE OF RESOURCE 11At4AGEMEt4T auf ta wwost NAmt Ant 4=s snow.
DIV OF ACCOUt4 tit 4G & fit 4ANCE L
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A PPLICABLE PURCHA5E A T T ti :
LELA!4D ROUSE ORDER SUPPLEMENTS C oANT:Tv DESCRIPTION PRICE INST R UC T lON S TO COVER THE FEE FOR AN AMENDMENT TO SPECIAL P4UCLEAR
$120.00
- 1. lavoices - Submit in dupiscs.
MATERIALS LICENSE SNM-7 to "Attention: Accounts Payable."
2 Purchase, Order No-her - Show on all packages, invoices, ship-j P "9 DiII5' C-i
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ENCLOSED IS OUR CHECK FOR
$120.00 3' Sales Tae - Exclusive of orders for-~ construction (as defined on reverse side hereof) Ohio sales use taxes are not to be paid orby self er by authority of Ohia Dept.of Tamation, Permit 98000125 4 Acknowledgernent - Please ack-nowledge receipt of this Purchase Order.
5 had - Bill of Lading. Express Receipt or Shipping Memorandum far each shipment.
6 insurance - No insurance charges hich increase shippag cost shall be ol: owed.
7 Shipping - Do not ship via parcel certified mail or urireg-post, d mail if shipment has value estere in excess of $500.00 or via registered m ail of in excess of
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