ML20206K545

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Forwards Comments & Request for Addl Info Re 840529 Application to Renew License SNM-561.Addl Info Requested within 60 Days of Ltr Date
ML20206K545
Person / Time
Site: 07000622
Issue date: 04/15/1987
From: Pennington W
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Mccahill J
ARMY, DEPT. OF, ARMAMENT RESEARCH, DEVELOPMENT &
References
NUDOCS 8704160371
Download: ML20206K545 (5)


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p FCUF:WSP APR 151987 70-622 SNM-561 Department of the Army Armament Research and Development Center ATTN: Mr. James McCaHill Radiation Protection Officer Dover, New Jersey 07801 Gentlemen:

We have completed the initial review of your renewal application for License No. SNM-561, dated May 29, 1984, and find that additional information is needed to complete our evaluation.

Enclosed is a list of the staff's coments regarding your renewal application. Please submit six copies of the requested information within 60 days from the date of this letter so that we may reissue your license in accordance with our review schedule.

If I can be of assistance, please call me at (301) 427-4510.

Sincerely, Original Signed By:

W. Scott Pennington Uranium Fuel Section Fuel Cycle Safety Branch Division of Fuel Cycle, Pedical, Academic, and Comerical Use, HMSS

Enclosure:

As stated

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s APR 151987 Coments on Department of Army Ap)11 cation for License Renewal SNM-5 51 1.

Provide a map of your facility indicating the areas of use and storage of special nuclear material (SNM). Clearly define your restricted areas and how they are controlled.

2.

Clearly define your research and development activities and for each of these activities, specify the location of use of SNH.

3.

Describe the quality assurance program associated with the review, updating of standard operating and radiation protection procedures, and your comitment to this program.

4.

Clearly describe the audit and inspection program of your radiation safety program and the frequency with which it is performed.

5.

List those individuals who are authorized to suspend an activity when operations personne1' disregard specified procedures and regulations which could result in unnecessary exposure to personnel and spread of contamination.

6.

Include an analysis of personnel exposures for the past 2 years.

7.

State your comitment to decomission your facility at the end of its operation in accordance with the enclosed criteria, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Tennination of Licenses for Byproduct, Source, or.

Special Nuclear Material," dated July 1982.

Appendix A 8.

Include the percent enrichment of SNM in your possession ' limits.

9.

State the length of time for which the license is requested.

10. According to Mr. Frank Dunfrund (alternate RP0), the 1984 renewal application is for storage only of the 1,716 grams of U-235 as sealed MTR-type fuel elements. List the uranium as "for storage only."

Appendix B

11. Clearly define the chain of command and the specific positions of your-organization, and list the education and training requirements for each of these positions. Also, include a list of the names and resumes of the individuals filling these positions to demonstrate they are qualified.

x APR 151987 2

Appendix D

12. Correct typing errors in the second and third sentences of the first-paragraph.

Appendix.E

13. Describe the provisions for fire detection and suppression in Building 3030 (storage area for MTR-type fuel elements).

Appendix G Section(C)

14. State the criteria which initiates the changing of HEPA filters.

Emergency Procedures

15. State frequencies of maintenance, checks, and calibrations of radiation monitoring equipment and dosimeters dedicated for emergency use only.

Appendix H

16. Describe the procedure to ensure neutron generators (batteries) are not leaking Pu-238.
17. Second sentence, fourth paragraph - Do you seriously intend to calibrate counting instruments with each use?
18. Alpha check sources should be tested quarterly for leakage.
19. Your leak testing procedures must state that within 5 days after determining a source has a leak, a report will be filed at the Division of Fuel Cycle, Medical, Academic, and Commercial Use Safety, ~U.S. Nuclear Regulatory Commission, describing the source test results, cause of failure, and corrective action taken.

AMC Regulation No. 385-25

20. Describe your work permit and standard operating procedure (SOP) program.

Discuss how the work pemit system will be changed to allow more safety control as stated on page 10 of your written procedures. Discuss the procedure for making S0P revisions and the approval process.

21. Describe in detail your ALARA program. This should identify the data to be collected, the ccomittee that reviews the data, and to whom the results of these reviews will be given.
22. Describe content and frequency of retraining for radiation workers, emergency and security personnel, and radiological protection staff.

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23. Descrit'e the methods of assuring that individuals understand training they receive.
24. Specify the characteristics of your film badges (type, range, sensitivity) and state the frequency of badge turnover.
25. Describe in detail how all radioactive material is disposed of properly.
26. Transfer of unwanted radioactive materials to Building 3030 should be coordinated and approved by the RP0 or his designated alternate.
27. Subparagraph F on page 32 states that pocket dosimeters which leak more than 5 percent of full scale after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a radiation free area should be repaired. This conflicts with Appendix D which states that leakage for calibrated dosimeters is less than 2 percent of full scale within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
28. Paragraph 33 (Records) - State the length of time that radiation safety records are retained and address the documenting of abnonnal occurrences.

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