ML20203M970
| ML20203M970 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/1985 |
| From: | Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wester R R.M. WESTER & ASSOCIATES, INC. |
| Shared Package | |
| ML20203M946 | List: |
| References | |
| NUDOCS 8605020320 | |
| Download: ML20203M970 (6) | |
Text
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0,* F E rog UNITED STATES
- g. 'g NUCLEAR REGULATORY COMMisslON
[ o REGION lit E if 799 ROOSEVELT RO AD o cLEN ELLYN, ILUNOIS 60137 JUL1g,og
/
R.M. Wester and Associates, Inc.
ATTN: Robert M. Wester President 3317 Highway 94 North St. Charles, M0 63301 Re: Your Application, Dated March 4,1985, For An NRC License To Collect, Ston. . Repackage, And Transport Radioactive Waste Gertlemen:
As discussed in several telephone conversations between Robert M. Wester and me, we need additional information and/or clarification on the following items in order to complete our review.
- 1. It appears that your request is to obtain a license for the following:
- a. Repackaging of waste including compaction from cus'tomers for transfer to licensed land burial facilities (Class 2 as in Section 15 of your application).
- b. Collecting and storing of waste from customers for transfer to licensed burial . facilities (Class 3 as in Section 15 of your application).
- c. Collecting and decay-in-storage of waste from customers for disposal as nonradioactive material (Class 1 as in Section 15 of your application).
Please confirm if our assumption is correct. If not, please describe any other uses for which you desire to be authorized.
- 2. Environmental Information Two items of your request require the submission of environmental information pursuant to Section 51.41 of 10 CFR Part 51, total possession limit above 50 curies (i.e.,150 curies for elements with atomic nos.1-83) and storage period greater than 180 days (i.e., decay-in-storage until background radiation levels are achieved). Note that Section 51.22 of 10 CFR Part 51 provides a categorical exclusion from the submission of this information for persons receiving and storing waste below these limits (No.14(xfi)).
In order to obtain authorization for either of these items you will need to submit the information sepcified in Sections 51.45 and 51.60 and below:
- a. Discuss the need for your activity from an industry standpoint.
8605020320 860313 REG 3 LIC30 PDR
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- b. Provide a map and description of the site including (1) the location of adjacent buildings and nearby residences, (2) nearby population centers such as office buildings, schools,' churches, arenas, stadiums, etc., (3) the exact routes.of nearby roads, -the railroad, and the interstate highway, and (4) the location of buildings or facilities which could present evacuation problems.in the event of a large release of radioactive material.
- c. Provide an accident analysis, including the risks, environmental impacts, radiological and non-radiological consequences of a tornado, major fire, or major explosion at your site.
earthquake, flood, tion of transportation incidents such as might be Include considera caused by a train or highway vehicle carrying hazardous material to and from your site.
- d. Please specify any other Federal, State or local permits or requirements which are required for your operation, and provide the status of the permits and compliance with the requirements.
- 3. Assistant Radiation Safety Officer Please provide the name and qualifications of your assistant RSO. This
- individual must have experience in handling the types and quantities of materials you propose to use.
- 4. Personnel Training Program ~
The program specified in Section 8 of your application provides general training in radiation safety. Please submit a description of your training program for lab techs, drivers, waste collectors, compactor operators, warehousemen, and other individuals involved in specific aspects of your program. The program should be sufficient to maintain a complement of trained personnel to carry out waste receipt, handling, and disposal operations in a safe manner. The description should include an outline, duration, qualification (s) of instructor (s) and method (s) of determining competency of students.
- 5. Radiation Protection Instruments Specify the number, range and type (i.e., type of radiation detected) instruments that will be available for radiation protection aspects of your program (e.g., area surveys, effluent monitoring, air monitoring, etc.).
In addition, indicate the method and frequency of calibration of these instruments.
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- 6. Personnel Monitoring e
- a. Please specify the individual responsible for assigning personnel monitoring devices in accordance with the criteria specified in Section 4 of your manual.
- b. Bioassays for radionuclides other than fodines Your bioassay program as described in Section 12 of your manual for
. radionuclides other than iodines is based upon air concentration measurements rather than activities of material used. Please describe how your air sampling system is implemented to ensure that concentrations measured accurately reflect those a worker may inhale or ingest in the body during a particular process. If this ensurance can not be made, you will need to modify your procedures for obtaining bioassay samples, such as urine, to be based upon activities and types of radioactive material being handled. In addition, please modify these procedures to include a " baseline" program (e.g., pre-operational).
- 7. Facilities
- a. Please submit a description of the following:
- 1. The site including adjacent population centers, routes of access for evacuation and emergency equipment and means of limiting potential release to adjacent populations.
Kvh 2. The areas where various processes (e.g., repackaging) will be jfp - perfonned inside your building.
- 3. Any ventilation system used to limit exposure of the concentrations of radioactive material in air. -
- 4. The systems used to prevent unauthorized access or removal of material and for fire protection sufficient to limit off-site hazard (e.g., adequate distance between sprinklers.. adequate number of extinguishers, operation check of system).
- b. We cannot authorize you to handle areas as unrestricted as proposed in Item 2 of Section 3 of your manual. We can allow you to have radiation levels in unrestricted areas greater than those specified in Section 20.105 of 10 CFR Part 20, provided you specify the radiation levels, keyed to a specific area; your administrative controls to maintain individual exposures to less than 500 mrem per year; and how the proposed levels are in keeping with the ALARA concept.
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R.M. Wester and Associates, Inc. 4
- 8. Air Monitoring Program Please describe your program for sampling of air and water effluents to ensure that levels in restricted and released to unrestricted areas are less than those specified in 10 CFR Part 20. The description should include procedures, type of equipme w. Jsed, frequency, and individual responsible for overseeing.
- 9. Packaging Of Waste
- a. Please submit a copy of the instructions you will provide to customers for packaging of radioactive waste for each type of program you will run (e.g., for pick-up and transport as prepackaged waste to a burial site by your facility, for pick-up and transport to your facility for decay-in-storage or repackaging). The instructions should include references to appropriate sections of the regulations such as Section 20.311 of 10 CFR Part 20 for each waste program. '
- b. Describe your quality control program for ensuring waste is appropriately packaged and labeled at customers facilities or points of collection and your storage facility in accordance with NRC and Department of Transportation (00T) regulations and conditions of the burial site license.
- 10. Inventory System ~ '
Describe your procedures for controlling and maintaining inventories of radioactive materials to ensure that possession limits are not exceeded for material in transit or stored and material is accounted for at all times while under your license.
- 11. Compaction Of Waste Please submit a description of the following items concerning the use of compaction as a method of repackaging waste:
- a. The type of compactor.
- b. The types, quantities, and concentrations of waste to be compacted.
- c. An analysis of the potential for airborne release of radioactive I material. !
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- d. The ventilation and filtering system used in conjunction with the compactor. The system must be capable of handling the type of radionuclides in the waste to be compacted (e.g., charcoal filter for iodines). If filtration is used, please include a description of your procedures for monitoring filter blockage. 1 l
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- e. The method used to monitor concentrations of radioactive material released into breathing zones or exhaust systems.
- f. The surveys (type and frequency) you will perform for contamination control around the compactor,
- g. The step-by-step instructions to compactor operators. The instructions should address protective clothing to be worn, checking for proper functioning of equipment, the method of " handling" waste in the
_ " parent" drum, and the method of examining defects in drums after compaction.
- 12. Materials Handling Procedures In Section 15 Of Manual Please specify the length of time you propose to store your " Class 3" waste prior to shipment to a licensed burial site. If it will be longer than 180 days, you will need to supply the information requested in Item 2 of this letter.
- 13. Radioactive Materials Package Receipt Program Please modify the procedures specified in Section 14 of your manual to include Section 20.311(e) for waste that is only handled in prepackaged form. -
- 14. Access Control Describe the posting and security procedures you will utilize for any truck being loaded or unloaded with radioactive waste outsido your warehouse or during transport to a waste burial site.
- 15. Radiological Contingency Plan -
Please submit a plan utilizing the format specified in the enclosed NUREG-0762. The plan should include precautions taken to alleviate the consequences of events that can cause the release of radioactive material or exposure of individual (e.g., spacing of storage containers to preclude damage via vehicles moving inside storage areas, not permanent storage of waste in gaseous or liquid form, flammable waste stored in an area with a sprinkler system, etc.). You may excerpt information from that submitted i for other items in this letter, if you find this appropriate. I
- 16. Transportation Of Waste To And From Your Warehouse
- 1. Describe the safety measures you will utilize in transporting waste to and from your warehouse (e.g., fully secured and away from the passenger compartment).
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- 2. Please expand your instructions to personnel to include transportation procedures to ensure that they are in accordance with Department of Transportation (DOT) regulations. As a minimum the instructions should address labeling containers, securing containers within vehicles, placarding vehicles, and surveying radiation levels.
If you have any questions or require clarification on any of the information stated above, you may contact us at (312) 790-5625.
~ We will continue our review of your application upon receipt of th's information.
Please reply in duplicate, within 30 days, and refer to Control Number 78468.
Sincerely, huu/$kh Bruce S. Mallett Materials Licensing Section
Enclosures:
- 1. 10 CFR Parts 20 and 51
- 2. NUREG-0762 l
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