ML20211H798
| ML20211H798 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 09/30/1997 |
| From: | Weber M NRC |
| To: | |
| Shared Package | |
| ML20211H775 | List: |
| References | |
| NUDOCS 9710070138 | |
| Download: ML20211H798 (4) | |
Text
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' gp uog It UNITED STATES
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NUCLEAR REGULATORY COMMISSION 1
WASHINGTON. D.C. 9064Hooi
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September 30, 1997 j.
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70-1100 LICENSEE: Combustion Engineering (CE)
Windsor, Connecticut
SUBJECT:
SAFETY EVALVATION REPORT:- APPLICATION DATED april 16, 1997,
-AMENDMENT 10 REQUEST TO DOWNGRADE LICENSEE ACTIVITIES.
1 BACKGROUND l
By letter dated April-23, 1996,- CE-requested an amendment to downgrade License SNM-1067 from research and development activities to the limited ongoing decommissioning activities of Building 21 and storage, handling, and packaging of low-level radioactive wastes (LLRW) for dis)osal.
The staff reviewed the application and transmitted comments to CE sy letter dated November 8, 1996. CE responded by a supplemental application d.*ted December 20, 1996.
The staff's review of.the application was delayed during the first quarter of 1997 due to discussions over the Nuclear Regulatory Commission's (NRC's) legal authority to regulate the possession limit of 1000 grams of U-235 material contained in enriched uranium as LLRW. CE's original position was that these wastes originated under contracts performed by CE for the Atomic Energy Commission in the late 1950's and 1960's.
Therefore, CE concluded that the NRC did not have legal authority to-regulate these wastes, including the wastes from such contract operations that have been collected by CE for disposal by the Department of Energy (DOE) under the formerly Utilized Site Remedial Action Program (FUSRAP).
However, as a result of the NRC/CE discussion, CE accepted NRC's position that the possession limit specified in License SNM-1067 of 1000 grams of U-235 material contained in enriched uranium applies to enriched uranium LLRW r.ow located on-the Windsor site that has been collected by CE. The possession limit of 1000 grams also covers any such FUSRAP U-235 that is further collected by CE. The details of the NRC/CE discussion on this subject were described in letters from L. Bickwit, Jr. to NRC dated March 4, 1997, and from NRC to L. Bickwit, Jr. dated March 28, 1997.
Based on the' outcome of the NRC/CE discussion described above, CE revised the application to downgrade the license and resubmitted it by letter dated April 16, 1997.
This submittal superseded the two previous submittals of
-April 23 and December 20, 1996. As a. result of two teleconferences with CE representatives on August 13 and September 17, 1997, CE submitted supple-mental applications dated August 21 and September 19, 1997, respectively.
9710070138 970930 PDR ADOCK 07001100 C
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In the license application, CE specifically requests the following:
1.
To delete the following authorized ?ossession limits:
(a) 341 grams of U-235 enriched uranium, (b) 10,000 (g of natural and/or depleted uranium, (c) 8.0 grams of plutonium sealed sources, and (4) 700 grams of U-235 as residual uranium oxides.
In addition, to delete reference to all buildings except Building 21 and delete authorization for all activities except those related to:
(a) the decommissioning of Building 21 and (b) the storage, handling, and packaging of low-level wastes for disposal; 2.
To delay Building 17 decommissioning; 3.
To clarify that the possession limit of 1000 grams of U-235 material I
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contained in enriched uranium applies only to low-level radioactive l
wastes located on the Windsor site that have been or will be collected I
by CE and are to be included in the DOE FUSRAP for disposal; and 4.
Modification of the current Radiation Protection Program to reflect the proposed reduced scope of licensed activities.
DISCUSSION CE's requests for the downgraded license are discussed below:
1.
To delete authorized oossession limits. reference to all buildinas except Buildina 21. and authorization for most activitin All the authorized materials, laboratory activities and buildings that CE requested to be deleted from License SNM-1067 were incorporated into the Broad Scope Materials License 06-00217-06 on September 5, 1996.
The Broad Scope License also includes provisions for a decommissioning funding plan for the buildings that were recently incorporated into that license.
The existing decommissioning funding for License SNM-1067 remains intact and would be continued while Building 21 is being decommissioned.
CE has submitted a separate amendment request to complete decommissioning of Building 21.
Because those activities proposed to be deleted from License SNM-1067 have been appropriately incorporated into the applicable broad scope materials license and those remaining activities are already appropriately incorporated into License SNM-1067. CE's requests are acceptable.
2.
To delav Buildina 17 decommissionino Building 17, the former uranium fuel fabrication building, has been undergoing decontamination and decommissioning under License SNM-1067 since CE ceased its uranium fuel operation in 1993.
At the present time, 70 percent of the area meets NRC limits for an unrestricted area.
CE requested the delay to allow the building to be used for CE's existing reactor field services operation under the Broad Scope Materials License 06-00217-06. Use of Building 17 would make it unnecessary for CE to construct a new building on the Windsor site for 1
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3 such work. CE has committed to resume the decontamination operation of the butiding after the field services operation in the building has ceased.
CE discussed this matter with the NRC staff in a meeting held on February 7, 1996, and NRC staff indicated that CE's proposal does not appear to be contrary to current regulations.
NRC's meeting minutes were issued on February. 16, 1996.
Because CE's request to delay decommissioning of Building 17 is within NRC regulations and License SNM-1067, the staff has concluded that it is acceptable.
3.
To clarify that the oossession limd t of 1000 arams of U-235 material contailed in enr' ched uranium adol' os to LLRW now located on the Windsor site t lat have been or will be collected by CE I
CE's original position regarding these. wastes was that they originated -
under contracts performed by CE for the Atomic Energy Commission in the late 1950's and 1960's. Therefore, CE originally concluded that the NRC dirl not have legal authority to regulate these wastes, including the wastes-from-such contract operations that were collected by CE for disposal by DOE under the FUSRAP.
However, CE accepted NRC's position that the possession limit specified in License SNM-1067 of 1000 grams of U-235 material contained in enriched uranium applies only to enriched
' uranium LLRW now located on the Windsor site that has been or will be collected by CE.
Because CE's request makes License SNM-1067 consistent with NRC's position regarding the required scope of the possession limits for enriched uranium, CE's request is acceptable.
4.
To modify the Radiation Protection proaram CE requested that the current Radiation Protection Program be modified to reflect its limited activities under the proposed downgraded License SNM-1067. These modifications include:
6 a.
Deletion of the position of the Supervisor of Chemistry Services and his responsibilities for safe conduct of laboratory operation.
Because the authorization-for laboratory operations will be deleted by this licensing action, the position of-the Supervisor of Chemistry Services is no longer necessary. With the deletion of the Supervisor of Chemistry Services, the Radiation Safety Officer will report to the Radiological Services Leader at the Windsor site, b '. Deletion of the Safc0 Committee due to the lack of activities for the Committee to review, Routine inspections by the Radiation Safety Officer and an annual audit of the Health Physics Program
-will provide management control.
c.
Deletion-of the ventilation system requirements for laboratory buildings-since all laboratory cperations authorized under License SNM-1067 will cease, d.
Deletion of the liquid and airborne effluents monitoring procedures for laboratory operations and the environmental monitoring program since the potential sources of liquid and airborne effluents related i
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to activities authorized under License SNM-1067-will be removed.
Although CE has requested the removal of the Environmental Monitoring Program from License SNM-1067, the same Environmental Monitoring Program will be implemented under the Broad Scope License i
06-00217-06, i
The staff has reviewed CE's requests for modification to the Radiation
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Protection Program and has determined that they are acceptable and i
consistent with limited activities that will be carried out under License SNM-1067.-
l CATEGORICAL EXCLUSION
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-This amendment is ne which is-administrative and procedural in nature and does not constitute a change in process operations or equipment.
Therefore, in accordance with 10 CFR 51.22(c)(ll), neither an Environmental Impact Statement nor an Environmental Assessment is warranted for the proposed
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licensing action.
CONCLUSION / RECOMMENDATION r
The NRC staff has reviewed CE's proposed amendment and has determined that the proposed changes will have no adverse effect on public health and safety or the environment.
Therefore, approval' of the amendment is recommended.
I The Region 1 project inspector has no objection to the propos d amendment.
hjfbF' Principal Contributors 33 t 7Ff,s',<,/f 7,, I Sean Soong l
Susan Chotoo M
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