ML20198Q934

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Forwards RAI Which Is to Be Completed Before Final Action Can Be Taken Re 970916 Application Requesting Termination of Radioactive Matls License
ML20198Q934
Person / Time
Site: 07000893
Issue date: 11/05/1997
From: Tom Pham
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Bowie R
FLORIDA INSTITUTE OF TECHNOLOGY, MELBOURNE, FL
References
TAC-L31014, NUDOCS 9711130091
Download: ML20198Q934 (3)


Text

.. .

. November 5, 1997 Mr. Robert C. Bowie

.Vice President for Financial Affairs Florida Institute of Technology 150 West University Boulevard Melbourne. Florida 32901-6988

SUBJECT:

REQUEST FOR TERMINATION OF YOUR NRC LICEi4SE (TAC NO. L31014)

Dear Mr. Bowie:

1 This refers to your application dated September 16. 1997, which provided the h notification required um er 10 CFR 70.38(d) requesting the termination of your NRC radioactive materials license. We have assigned your request TAC No. L31014. Please reference this number in any future correspondence associated with this request.

Upon review of your submittal, whP.h induded a com)leted Form NRC-314

" Certification of Disposition of Materials." and a Radiation Survey Report, we have determined that your submitted radiation survey was not complete and adequate to sufficiently demonstrate compliance with pertinent regulations specified in 10 CFR 70.38(j) and criteria for exposure rates, and to further confirm absence of potential activation of adjacent materials at your site.

Therefore, we have identified additional information that is needed b" ire final action can be taken en your request. You should prcvide the adu t.ional I

information, as specified in the enclosure, within 45 days of the date of this letter.

We are available to meet with your staff to discuss the present status of your facility and appropriate steps to complete the decommissioning orocess in an acceptable and timely manner. If you have any questions regarding this

. licensing action or wish to arrange a meeting to discuss our concerns pertaining to your submittal. please contact me at (301) 415-8154.

Sincerely.

Thomas N. Pham Project Manager Licensing Section 1 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70 893 .-

License SNM 844

Enclosure:

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Request for Additional Information

- Application Dated September 16, 1997 Florida Institute of Technology Docket No.70-893 License No. SNM-844 Please provide the fcllowing information:

a. Records of your disposition of the licensed materials in accordance with NRC requirements (comp'eted DOE /NRC Form 741, " Nuclear Material Transaction Report") when you transferred the Pu-Be neutron source to Los Alamos National Laboratory and the uranium subcritical assembly core to Lockheed Martin Energy Systems Y-12 Plant.
b. Records and results of your past source leak tests to demonstrate to the NRC that the source never 1 caked, while botn in your custody and upon arrival at the ultimate destination indicated on the submitteo NRC Form 314. The information on leak test results that you will submit to the NRC may warrant review of the decommissioning under Type I criteria for your facility.

In addition, we have determined that your submitted Radiation Survey Report was 'ncomplete and inadequate. For example, your submittal does not meet the requirements of 10 CFR 70.38(j) in reporting the results of your survey. Further, the information you provided would not suffice in demonstrating compliance with the SpR/hr criterion for exposure rates above background or in ) roving the absence of possible release of licensed materials to t1e environment, neutron activation of adjacent structures and materials, or contamination of work areas.

Based on guidance in NUREG/BR-0241, "NMSS Hendbook for Decommissioning Fuel Cycle and Materials Licensees." for a Type I decommissioning, the licensee must demonstrate that the source never leaked pr submit the results of a Final Status Survey (FSS). If the information requested above (leak test results) is not available or if it is inconclusive regarding the potential for contamination as a result of leakage, you must submit an FSS. Therefore, if you elect to demonstrate that your facility is suitable for unrestricted use by conducting an FSS, your facility should design the survey to be of sufficient scope and quality to make this den'onstration. In preparing for the FSS, your facility should establish a method to identify individual measurement / sampling points. such es establishing reference grids on each surface in the indoor area involved in licensed materials. At a minimum, your facility's termination survey should consist of:

1. 100 percent scanning of all surfaces in the area of the facility where licensed materials were used or stored using an appropriate radiation detection instrument (including scan sensitivity):

ENCLOSURE

i 2

2. evaluations for total and removable radioactive materials at each area exhibiting elevatpd radiation levels or at a frequency of one wipe comprising 100 cm per grid; and
3. evaluations of radiation levels at one meter above surfaces.

Particular attention should be afforded any drains, air vents, or other fixtures or equipment that may have become contaminated during licensed materials use. This is especially significant in situations where renovations '

have occurred and potentially contaminated areas may be inaccessible under current conditions.

The information that should be submitted to the NRC to support the FSS should '

consist of: ,

I a brief description of the remediation activities undertaken by your facility:

2. a detailed drawing of the licensed materials use areas indicating the sampling locations:
3. a table showing the results of the radiation levels and removable contamination surveys keyed to the detailed drawing (organized by survey unit):
4. the training and qualifications of the individual (s) performing the decontamination and surveys: and
5. a description of the type of equipment used by your facility to evaluate the wipes and perform the surveys. This description should include all information required to determine the appropriateness of the equiament for determining the radiological a status of your facility suc1 as last calibration date, type of radiation detected, sensitivity of detection, efficiency, etc.

I

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