ML20154D778

Responds to 980720 RAI Re Rev 11 of Renewal Application.Encl Details Answers to Six Questions Raised by NRC Staff

ML20154D778
Person / Time
Site:	Westinghouse
Issue date:	09/30/1998
From:	Goodwin W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
CON-NRC-98-049, CON-NRC-98-49 TAC-L31068, NUDOCS 9810070337
Download: ML20154D778 (4)

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Westinghouse Commercial Nuclear orawer n Electric Corporation Filel Division fffff/ggparana292w s

NRC-98-049 September 30,1998 i

U. S. Nuclear Regulatory Commission ATfN:

Mr. Charles E. Gaskin Licensing Section 1, Licensing Branch FCS&S Division, NMSS 11545 Rockville Pike Mail Stop T8D14 Rockville, MD 20852-2738

SUBJECT:

REVISION 11 OF THE RENEWAL APPLICATION - INCIDENT REPORTING - (TAC NO. L31068)- RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAl)

This is a response to your July 20,1998 RAI concerning the subject request for licen:,ing action.

As explained to your Mr. Harry Felsher on September 11,1998, Westinghouse did not receive the original mailing of your RAI letter. We thank Mr. Felsher for promptly faxing us a copy, and for extending the respw date to October 2,1998.

The enclosure details our answers to the six (6) questions raised by NRC Staff. If you have any further questions or comments regarding this response, please contact me at (803) 776-2610, Extension 3282.

Sincerely, WESTINGHOUSE ELECTRIC COMPANY i

W.- L. Goodwin, Manager

\\k Regulatory Affairs

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Docket 70-1151 License SNM-1107

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Enclosure:

As stated 9810070337 900930 PDR ADOCK 07001151.

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WESTINGHOUSE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (TAC NO. L31068) 1.

On page 1.12, the definition of "Significant Removable Contamination" differs significantly from the reporting requirements in 10 CFR 70.50(b)(3) which uses the l

term " spreadable radioactive contamination." Your proposed radiation level is well above normal levels for release from controlled areas and exceeds the DOT limit for l

transporting of surface-contaminated objects. Finally, it is questionable whether or not l

these limits should be in the license application. (There was no scan area specified.)

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In this case, the Amendment Application should be modified to comply with 10 CFR 70.50(b)(3).

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Response

l We agree to changing the criterion on Page 3.19 and the definition on page 1.12 from "significant removable radioactivity contamination" and "significant removable i

contamination" to "significant spreadable radioactive contamination" - for consistency l

with 10 CFR 70.50(b)(3). However, although we realize that the proposed level is l

"well above normal levels for release from controlled areas and exceeds the DOT limit for transporting of surface-contaminated objects, we would no_t be releasing a contaminated patient without properly protecting against uncontrolled spreading of the contamination. In fact, we would use plastic wrap (or equivalent means) to contain the contamination; and, we would take appropriate action in our Medical Facility, and at the hospital, to avoid spreading contamination.

Further, we have " letters of agreement" with both the Emergency Medical Service and the hospital regarding their l

handling of our contaminated patients. And finally, all contaminated articles would be returned to our facility for appropriate disposition.

With repect to the 9,000 duintegrations per minute (dpm) proposed, we believe that since 10 CFR 70.50(b)(3) does not quantify a limit, we should do so in our License commitment to promote clarity. This limit was selected since it represents only 10-percent of the most restrictive Annual Limit on Intake (ALI) for uranium. The scan l

area was not specified because the 9,000 dpm refers to total contamination on an affected patient (skin and clothing).

2.

The entire Chapter 3 is still numbered as Revision 10 instead of Revision 11.

Response

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Chapter 3 will be numbered as Revision 11. (See response to Question 6 for additional information regarding revision correction.)

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A 3.

On page 3.18, Section 3.7 indicates that decisions will be made whenever the cognizant

~ regulatory function engineer arrives at the site. How is safety assured until that person arrives onsite and how long should the onsite personnel wait before declaring that the incident " clock" has started? Further the qualified emergency coordinator should be sufficiently trained in all procedures to make " event" decisions. Indeed, that person should perform the duties of a cognizant regulatory function engineer vithin the operating parameters of the specific procedures.

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Response

This commitment was based upon NRC Staff input via NRC Inspection Report No. 70-1151/97-205 - "0700 hour0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />si Regulatory Engineer onsite... Four-heur notification clock should have started at this time." Safety is assured by the onsite Emergency i

Coordinator until the cognizant regulatory function engineer arrives at the site and makes an initial " eyes-on" assessment. Emergency Coordinators have been trained to make 1-hour netifications.

Emergency Coordinators will be trained to make preliminary 4-hour notifications if they cannot contact a cognizant regulatory fundian engineer, at first attempt at call-in, to come promptly into the Plant. We do not believe it is credible that a cognizant regulatory engineer cannot be contacted to respond in time to make 24-hour notifications.

4.

On page 3.20 there is a commitment for an informal notification.

Informal notifications are not part of the license and should also be removed from your i

submittal.

Response

The commitment for informal notification will be removed from the submittal.

5.

On page 3.19, clarify Section 3.7.3(c.4) regarding what is damaged and/or breached.

The License Application should be modified to comply with 10 CFR 70.50(b)(4).

Response

Section 3.7.3(c.4) will be changed to read "Any incident for which a fire or explosion

. damages nuclear fuel'and the damage affects the integrity of the licensed material or breaches its container, when the quantity of material involved is greater than five times the lowest Annual Limit on Intake (ALI) specified in Appendix B of 10 CFR 20.1001-20.2401 for the material."

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6.

Revision 10 also modifies pages in Chapter 3. These pages need to be addressed in the changes to the License Application in Revision 10 or Revision 11.

Response

As explained to NRC Licensing representatives at the August 10-13,1998 inspection of the Westinghouse facility, a considerable mixup of the License Application had resulted from inadvertent Westinghouse confusion of revision nunf s versus amendment numbers. As further explained in a followup telecon, the coihusion was resolved and all controlled copies of the License Application were fixed to include only information that has been approved by NRC Staff.

As soon as agreement is reached that all NRC Staff requests for additional information relevant to this revision (11) have been resolved, the currently approved Chapter 3 will be changed to reflect og the results of the resolution; and, Revision 11 will be promptly submitted to NRC Staff.

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