ML20210D300
| ML20210D300 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 01/20/1987 |
| From: | Olsen A BABCOCK & WILCOX CO. |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20210D305 | List: |
| References | |
| 27816, NUDOCS 8702100056 | |
| Download: ML20210D300 (8) | |
Text
_
~
7dM RETURN M 3M-55
-3g
/ &
N
/
k
\\
Research & Development Division Babcock & Wilcox e
_w tynchnur R....rcn c.ni.e
(# RWVPgQC)}3N E-e o so "'as Lynchburg, Virginia 24506-1165 2
(804) 522-6000 January 20, 1987 u.s.$
g a sec* a 8
/
\\U Uranium Fuel Licensing Branch i,
ATTN: Mr. W. T. Crow, Acting Chief Division of Fuel Cycle & Material Safety NMSS U. S. Nuclear Regulatory Commission Washington, DC 20555
Reference:
Renewal Application - License SNM-778, Docket 70-824
Subject:
Response to Questions Gentlemen:
This is to respond to questions and comments made by the NRC staff re-garding the referenced application.
The responses are in the form of revised pages to the application. The responses are summarized in the attachment entitled Comments and Re-sponses.
The instruction sheet for entering the revised pages in the j'
application manual is the second attachment.
The revised pages are also attached. Changes are indicated with vertical lines in the right margin opposite the line(s) where the change appears.
The questions and comments from the staff were transmitted by phone and the wording in the first attachment may be somewhat different from that i
originally worded.
However, I believe that the meaning of each question is accurate. Several changes in the application were made by the LRC, unilaterally.
These changes are listed in the first attach-ment and designated by an asterisk (*).
If you have additional questions or need additional clarifications, please contact me.
e p
Very truly yours, 8
g BABC0CK & WILC0X pocWG Lynchburg Research Center 3
g 9
tgSSuon
/
A. F. Olsen hyp5 Senior License Administrator Jhc C) p Attachments 4
g
,e
- Q
8702100056 870120
~
DR ADOCK 07000824 PDR
,_m
Da di NJ.
"[d CONIflt ILO, Y![
- MIEOFC00, 8/U M D.5.iEliciD._ _ M /..__/ [
FCUF.__
FDR FCAF u LPDR -
I S E REF. _
U.!Cd:MiD3_
FCTC _ __
OliiER _
DATE/.]
liUI;AL,.
~
LICENSE SNM-778 RENEWAL APPLICATION COMMENTS AND RESPONSES PAGE SECTION Cl-2 1.4.2 The possession limit was changed from 0.27 Kg. to 0.53 Kg.
C1-2 1.4.7 The possession limit was changed from 0.31 Kg to 0.05 Kg.
01-2 1.4.10 Added "& Transuranium Elements" which was inadvertently deleted frem the present authorization. This item is for irradiated fuel.
Fission products alone is not adequate for the material description.
1-3 1.4.13 Change " curries" to " Curies".
The recommended change has been made.
1-4 1.6.8 This defined term is not used in the text.
It should be removed.
The section has been deleted.
1-4 1.6.10 The definition of calibration should include a recognition that the range and accuracy of the instrument are important factors in calibration.
The definition has been modified to include these factors.
2-3 2.3.1.X This section should include a designated position that will be responsible for resolving comments and recommendations made by the SRC I
A new section 2.3.1.6 has been added to address the Comment.
2-5 2.4.1 This section should include the requirement that the Manager, Lynchburg Technical Operations appoint the members of the Safety Review Committee.
l The recommended change has been added.
No mention is made of respiratory protection l
2-7 2.6.4
[
retraining. A time interval should also be specified for this retraining.
A new section (2.6.5) has been added to address this comment.
2-7 2.6 This section does not specify the position l
responsible for performing the training.
l l
A new section (2.6.6) has been added to address this comment.
J
2-7 2.6 Thsrs chruld be provicicna addr 22:d fer training in Nuclear Criticality Safety.
A new section (2.6.7) has been added to address this comment.
2-7 2.7 There should be provisions added to this section for technical procedures.
Section 2.7 has been revised such that Section 2.7.1 address Area Operating Procedures and Section 2.7.2 address Technical Procedures.
2-12 2.10.2 This section does not provide for retention of the records of audits performed by the Nuclear Safety Officer.
The section has been revised to address the comment.
2-12 2.10 The are no provisions for retaining records of emergency responses.
A new section (2.10.4) has been added to address the comment.
2-X The organization charts that appear in section 11 should be added to section 2.
No names should appear for the positions.
Pages 2-13 and 2-14 have been added with the organization charts.
3-1 3.1.1.1 The reference to 10 CFR 20 should be made more specific.
Section 3.1.1.1 has been revised to address the comment.
l 3-1 3.1.1.2 This section does not provide for the approval of RWP's in the absence of the principle approvers.
l Thc Ocetion has been revised to address the l
comment.
l 3-1 3.1.1.3 A statement should be added to specify that RWP's l
should address the radiological protection requirements for the operation.
The section has been revised to address the l
comment.
i l
l 3-3 3.2.2 Mention should be made in this section regarding the direction of air flows.
j A new section (3.2.2.1) has been added to address l
the comment.
w m
3-3 3.2.2.3 The cpecificaticn for the fl w rits in tha stack monitoring system is not needed provided that the specification in 3.2.2.2 remains in effect.
Section 3.2.2.3 has been deleted.
- 3-4 3.2.2.9 The requirement for a prefilter in the hood off gas does not apply to several hoods in use at.the LRC.
The prefilter is not a necessary requirement.
The section has been revised to delete the requirement for prefilters.
3-4 3.2.3.1 No mention is made of a calibration interval for portable survey instruments.
Section 3.2.3 has been revised to address this comment and to place Portable instruments is a separate section (3.2.3.1).
- 3-5 3.2.3.3.2 The last sentence in this section is not correct.
Stationary air samplers cannot be used to determine concentrations in the workers breathing zone.
The last sentence in this section has been deleted.
3-6 3.2.4.1.2 There should be a provision for the weekly checking of the differential pressure across HEPA filters.
The section has been revised to address this Comment.
3-7 3.2.4.1.3 There should be a provision for the weekly checking of the differential pressure across the hot cell face.
The section has been revised to address this Comment.
- 3-7 3.2.4.1.4 The requirement in the first sentence in this section is not attainable with the presently designed and installed ventilation system.
Respiratory protection equipment is worn by all personnel when the cell door is open. Therefor, this requirements is unnecessary. The second 1
sentence is a restatement of the last sentence in Section 3.2.4.1.3 and it is not necessary to restate it in Section 3.2.4.1.4.
The section has been deleted.
3-7 3.2.4.2 This section is confusing and should be clarified.
l l
Section 3.2.4.2 has been rewritten.
r
3-8 3.2.4.3.1 The d2 criptien of the urcnium biczrery program does not adequately address response actions.
This section has been totally revised.
3-9 3.2.4.3.2 In item 1, there needs to provisions for additional sampling.
Item 1, has beta revised to respond to the comment.
3-9 3.2.4.3.2 In item 2, the action levels should be taken regardless of the type of compound.
Item 2, has been revised to delete the specified compounds.
3-10 Table The units in the Action Level column are confusing.
The Action Level units have been changed.
3-13 3.2.4.5.1 A statement is needed that the program shall be conducted in accordance with 10 CFR 20.103.
The section has been revised to address the comment.
- 3-13 3.2.4.6.1 In the table in this section, delete the requirements for surveying the Building A Labs.
Building A has been decontaminated and licensed material is no longer permitted in the building.
The table has been revised to respond to the comment.
3-14 3.2.4.7.2 In line 2, remove one "within".
The change has been made.
3-15 3.2.4.9.2 A provision should be added to specify the frequency for reading and recording the exposures indicated on personnel monitoring devices. Tne section should also specify that the dosimenty should be worn in the restricted area. This section should specify an action level and the position responsible for implementing the indicated act' ion.
The section was revised to address the comments.
3-15 3.2.4.9.3 The requirement for weekly checking of visitor TLD's cannot be accomplished without a fully qualified TLD reading system, which the LRC does not have.
The requirement has been deleted.
4 4.2.1
-Rivisions to this esction should be mada in accordance with agreements reached between Mr. N.
Ketzlach and the Nuclear Safety Officer.
The section was accordingly revised.
5-2 5.1.4 A commitment should added here to require compliance with 40 CFR 61.
The commitment has been added.
5-3 5.2.2 This section should be revised to specify the frequency for all environmental sampling.
The section was revised accordingly.
7-1 7.0 This section should be revised to reflect a more
' realistic date for completion of the
- decontamination project.
The section now specifies 1987.
11-7 11.3.2 Update the resume to reflect organizational changes made since the renewal application was submitted.
The section was revised accordingly.
11-9 11.3.3 Update the resume to reflect organizational changes made since the renewal application was submitted.
The section was revised accordingly.
11-17 11.5.1 In line No. 1, the title of a specific individual should be specified.
The section was revised accordingly.
11-23 Fig. 11-1 The figure should include the names of the individuals at the LRC that fill the indicated positions.
The figure has been so revised.
11-24 Fig. 11-2 The figure should include the names of the individuals at the LRC that fill the indicated positions.
]
The figure has been so revised.
12-13 Table 12-3 Remove the " Class W and Y Compounds Only" from the title.
The table was revised accordingly.
12-14 Table 12-4 Remove the " Class W and Y Compounds Only" from the title.
The table was revised accordingly.
12-14 Table 12-4 Reevaluate the values used as action levels used in the table.
The table was revised to address the comment.
12-15 Table 12-5 Revise the table to agree with that specified in the license section 3.2.4.3.1.
The table was revised acc6rdingly.
Table 12-6 deleted.
12-24 Table 12-12 What does the asterisk (*) in column 3 of the table indicate.
The asterisk has no meaning and has been removed from the revised table.
- 12-24 12.8.6 The commitment to comply with 40 CFR 61 makes this demonstration in appropriate.
The section has been deleted.
12-39 12.11.4 Correct the spelling of the first "to" in line 6.
"to" has been changed to "too".
12-39 12.11.6 The word "results" in the last line should be changed to "resulted".
The change has been made.
13-1 13.1 In the first dot, the word " background" does not indicate that this sample is taken at the site boundry.
The word " background" was changed to " site boundry" 13-1 13.1 In the last line, change " Tables 2-2 through 2-6" to " Tables 2.2 through 2.6" The change has been made.
i 13-1 13.2 Describe how compliance with 40 CFR 61 will be demonstrated.
A new first paragraph has been added to respond to the comment.
I