ML20206P501

Responds to NRC Re Violations Noted During Insp of Licenses SNM-7 & R-4 on 870112-16.Corrective Actions: Application for Amend to License SNM-7 Authorizing Residual Contamination Associated W/Decommissioned Facility Filed

ML20206P501
Person / Time
Site:	Battelle Memorial Institute, 07000008
Issue date:	03/06/1987
From:	Toy H Battelle Memorial Institute, COLUMBUS LABORATORIES
To:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8704210197
Download: ML20206P501 (2)

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OBallelle Columbus Division ou bus 41201-2691 Telephone (614) 4244424 j March 6, 1987 Telex 24-s4s4 Docket Nos.70-008 and 50-006 p Mr. W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Shafer:

This is in reference to your letter of February 10, 1987, relative to the routine inspection of activities conducted under Battelle Columbus Licenses r Nos. SNM-7 and R-4 performed by your Mr. George M. France, III on L_

January 12-16, 1987.

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The following information is provided in response to the Notice of Violation relative to the failure to submit a timely renewal application for License No. R-4, Retired Research Reactor which authorized possession of residual activity and which is classified as a " possess but not operate" license.

As discussed during the inspection with your Mr. France, we inadvertently allowed the R-4 Retired Battelle Research Reactor to expire without a timely renewal. As noted during our discussions, we were operating with the understanding that the Technical Specifications as set forth in amendment No.

13 to R-4 governed the operation of the retired facility. This information was conveyed in a formal letter to Mr. Herbert Berkow of Reactor Regulation at headquarters on December 10, 1987. This same information was discussed by telephone with Mr. L. R. Greger of your office. Following these discussions and correspondence, we advised Mr. Lee Rouse of NMSS that we would make application for an amendment to our Battelle Columbus Materials License No.

SNM-7 to authorize the residual contamination associated with the decommissioned retired Battelle Research Reactor. A copy of our requested application for an amendment to accommodate and control the residual contamination is enclosed.

We trust the information listed above meets the following requirements in response to the violation (Supplement I).

(1) The request for an amendment to authorize the residual contamination at the BRR fulfills the requirement for corrective action taken, (2) upon issuance of an amendment to SNM-7 the control of residual contamination will become a formal procedure within our contamination surveillance and monitoring program and renewal will be timely, and (3) full compliance will be achieved pending evaluation of our requested amendment. ,

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Mr. W. D. Shafer, Chief 2 March 6, 1987 We would trust that the information provided is fully responsive to the-resolution of the Notice of Violation. We sincerely regret our oversight in failing_to submit a timely renewal application for R-4 license. Should you require further information, please contact us.

Very truly yours,

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Harley L. Toy Manager Nuclear Services and NRC Licensing Coordinator HLT:jv Enc. (1) l 4

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OBaHelle Columbus Division 505 Kmg Asenue March 6, 1987 ' columbus. ohia 4 Uot-m" Telephone th14 424-h424 Docket 70-8; Request for Amendment to License No. SNM-7 Mr. Leland Rouse Advanced Fuel and Spent Fuel Reprocessing Division of Fuel Cycle and Material Safety U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Rouse:

This is a formal request for an amendment to Battelle Columbus License SNM-7 to authorize the possession of not more than fifteen (15) curies of old fission and activation products that remain in the decommissioned and retired Battelle Research Reactor. This residual activity was previously authorized and possessed under License No. R-4 a " possess but not operate" retired research reactor. This residual radioactivity will be completely removed at a later date when all the nuclear facilities at our West Jefferson Nuclear Sciences Area are decontaminated and decommissioned.

In support of this requested amendment, we have enclosed revised pages to our Renewal Application Document, BCL 1081. Revised pages are enclosed for pages vii and 1.9.

We have also enclosed our check for $150 to cover the processing fee associated with this administrative action.

Should you require additional information in order to proceed with the amendment please call me at (614) 879-5228.

Very truly yours, #

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Harley L. Toy Manager Nuclear Services and NRC Licensing Coordinator r \

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development activities are conducted. This part d; scribes the internal proccdures and management philosophy for conducting assured health and safety perfonnance in all the Laboratories' activities. The procedures and descriptions outlined in Part II may be changed without prior notifi-cation or approval of the NRC. provided that the changed procedures remain within the overall criteria stated in Part I of this renewal application, and that the changes are made with the appropriate Battelle-Columbus internal review (Radiological Safety Committee) and approval steps as outlined in Part I.

Maximum Quantity of Special Nuclear Material and Byproduct Material Which Licensee May Possess at Any One Time Under This License Special Nuclear Material West Jefferson Site Byproduct, Source, and/o'r Chemical and/or Maximum Amount that Special Nuclear Material Physical Form Licensee May Possess At Any One Time Under This License (a) Uranium enriched in the Any 125 kilograms of contained U-235 plus the associated U-235 isotope (3) and unseparated plutonium

--irradiated Uranium enriched in the Any 1900 grams of contained U-235 isotope U-235

--unirradiated Plutonium (Pu-238 Sealed source 13 grams principal isotope)

Plutonium (Pu-239 0xide 17 grams principal isotope)

Residual Radioactivity Old Fission 15 Ci Associated with the and Activation Retired Battelle Products Research Rea'ctor (a) NOTE: Licensee is also authorized to possess any source material that may be contained in the irradiated uranium of the first item above.

Occument No. RENEWAL APPLICATION BCL-1081 Revision No. 2 Date 3/6/87 Pace vii Supersedes Revision No. O Date Pace

l.3.4. Hot Cell Radioactive Work Permit Prior to start-up of any operations in the Hot Cell Laboratory involving a potential radiation hazard, a Radioactive Work Permit must be filed with the resident Health Physicist, and the Industrial Safety Representative before operations are initiated. The ALARA considerations are also addressed by the RWP. The form also addresses the description of the work, necessary protective clothing and equipment to be utilized. Preoperational personnel dose estimates are required before the work can be initiated. The Radioactive Work Permit is discussed in greater detail in Part II.

1.3.5. Control of Residual Contamination at the Retired Battelle Research Reactor The Radiological Safety Officer (RS0) shall serve as the Retired Facility Site Representative for the Retired Battelle Research Reactor (BRR). His responsibilities shall include internal submission of radiation monitoring reports for the BRR to the Manager of Nuclear Services. Further, annual radiation monitoring reports shall be submitted to NMSS.

The RSO shall control access to the BRR and review, and approve all applications for the usage of space at the BRR which is housed in Building JN-3.

Document No. RENEWAL APPLICATION BCL-1081 Revision No. I Date 3/6/87 Pace 1.9 Supersedes Revision No. O Date Pace