ML20215M375
| ML20215M375 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 04/27/1987 |
| From: | Olsen A BABCOCK & WILCOX CO. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20215M379 | List: |
| References | |
| 28130, NUDOCS 8705130208 | |
| Download: ML20215M375 (6) | |
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' RETURN 'TO L 396-SS 78dM Research & Development Division :
B8bCOCk &. WilCOX -
- Lynchtnarg Research Center
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P. O. Box 11165 -
Lynchburg, Virginia 245061165 (804) 522-6000
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April 27, 1987
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APR2 81sg7 ) 'Q Division of Fuel Cycle, Medical, Academic, and Commercial Use Safety Attn: Mr. Leland C. Rouse, Chiaf NM Eyj'ssy C
TueT Cycle & Safety Branch s
MNSS U.S. Nuclear Regulatory Commission 4
9 Washington, D.C.
20555
' Gentlemen:
This letter forwards changes to the renewal application for License
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SNM-778 in response to. questions by the NRC staff and of changes to the organization of the Lynchburg Research Center.
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y Responses to 1the Staff's questions and comments are = described in the firs t attachment.
The second attachment is instruction sheets for
. inserting - the replacement pages in the application.
Changes to the
-application are denoted by vertical lines in the _ right margin opposite the line where a change has been made.
. The -organization change is extensive.
The Lynchburg Research Center is to become a part of B&W's Naval Nuclear Fuel Division (NNFD).
The name of -the Center will change to NNFD Research Laboratory.
The level of management that the Manager of Safety and Licensing reports to under the new organization is the same as that under the Research and Development
' Division.
The; organizational units and personnel responsible for safety-
- and compliance on a day-to-day basis remains unchanged.
L Many of the personnel performing activities at the Laboratory will not be associated with the Laboratory nor the NNFD. For this reason, we plan to ifnstitute the' position of Area Supervisor.
The Area Supervisors will
. report.to the Facility Supervisor, and the number of Area Supervisors will depend on the utilization of the areas within the Laboratory. This is explained in section 2 of the updated application.
Throughout the development of the application, prior to this revision, it was assumed p-p-
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that persons performing work at the Laboratory would be employees of-the Laboratory..
The ? term " employee" was used-pervasively throughout the application as was the-term "LRC."
The majority of the changes found in thi,s document revision are corrections of that-terminology.
Changes in
' the way." that workers are controlled and classified also will. result.-in the changes to.~the~ training programs that will be presented to them.
These training program changes are described in section 2.
I 'believe that the changes made in this revision to ' the renewal application will not decrease lthe safety of operations at the Laboratory.
If you have questions or need clarifications, please contact me.
Yours truly, i
BABC0CK & WILC0X COMPANY Arne F. Olsen Senior-License Administrator Lynchburg Research Center mrf s
pc-Administrator, Region II, U.S. Nuclear Regulatory Commission i
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m DEMONSTRATION AND CONDITIONS FOR LICENSE SNM-778 REVISION 4 AMENDMENT 0 RESPONSES TO NRC COMMENTS ON RENEWAL APPLICATION Section Comment and Response 2.7.2.1 The NRC felt that technical procedures should not be approved by the Health Physics Engineer because there is no experience requirement specified for that position.
They felt that the Supervisor, Health and Safety, was a preferable approving individual. This comment also applies to Section 11.3.2.
Response
Section 2.7.2.1 has been revised to specify that the approval of Health Physics technical procedures shall be by the Senior Health Physics Engineer.
Section 2.2.6 has been revised to specify the position of the Senior Health Physics Engineer.
Section 2.5.6 specifies that the Senior Health Physics Engineer must have a BS and two years of radiation-control-related experience or an MS degree and one year of radiation protection experience.
2.7.2.1 Should the heal th Physics Engineer position be specified in the license conditions?
Response
The position of Health Physics Engineer should not be specified because the position is not specifically mentioned in the text since each place the title appeared has been replaced with Senior Health Physics Engineer.
3.1.1.7 The NRC stated that this section needs to specify the term of Standing RWP's.
Response
Section 3.1.1.7 has been revised to specify the term of Standing RWP's to be six months.
3.2.4.2.2 The term " daily" is inappropriate in this section.
Respon::e Section 3.2.4.2.2 has been revised to sta te " weekly" in place of
" daily."
3.2.4.2.3 The term " weekly" is inappropriate in this section.
Response
Section 3.2.4.2.3 has been revised to state " daily" in place of
" weekly."
3.2.4.2.4 The NRC felt that the two-week period between removal of air sample filters and their evaluation was too long.
It was suggested that a seven-day period would be better.
Response
Section 3.2.4.2.4 has been revised to clarify that air sample filters receive a preliminary evaluation within one working day af ter their
0 removal and that the final evaluation will be performed within seven working days following their removal.-
3.2.4.2.5 NRC felt that the Supervisor, Health and Safety, rather than the Health Physics Engineer -was the more appropriate individual to make evaluations of air sample results that indicate airborne activity at levels between 10% and 25% of the applicable MPC because no experience requirement is specified for the Health Physics Engineer.
Response
Section 3.2.4.2.5 has been revised to specify the Senior Health Physics Engineer would perform these evaluations.
3.2.4.3.1 NRC requested that this section be revised to specify who is covered in the uranium bioassay program.
Response
Section 3.2.4.3.1, item 2, has been revised to specify that all workers who routinely work in uranium handling areas shall be subject to the program.
3.2.4.3.2 In item c in the table, the NRC thought that 4 DPM/L was too large a value.
Response
Item c was deleted and a new action (#2) was added to item b requiring the Supervisor, Health and Safe ty, to consider worker restriction. This change was made in Table 12-5 in section 12.,
3.2.4.3.2 In items d and e of the table, the NRC thought that the values of 16E-8 were too large and questioned if these values apply also to americium or only to plutonium.
Response
Item d and e of the table were redesignated c and d as a result of the response to the previous comment.
Items c and d of the table have been revised to 1.6E 8 Ci and Pu-239 is specified.
These changes were also made to Table 12-4 in section 12, 3.2.4.7.2 The NRC suggested that the word " discovery" be replaced by " survey" in three places.
Response
The word " survey" was added in the three places.
11.4 A section should be added to describe Technical Procecures.
Response
Section 11.4 was renumbered 11.3.
Subsection 11.3.2 was added to describe Technical Procedures.
11.5.4 In line 7, the word " periodic" should be replaced witt "two years."
Response
Section 11.5.4 was renumbered 11.4.5.
The term " periodic" was replaced with " biennial."
12.8.5.2 The last sentence should appear in a license condition.
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Response ~
The requirement that the Supervisor, Health'and Safety, must approve any individual to leave a contaminated area who is contaminated above background levels appears in Section 3.2.1.2.
12.9.8 At the end of the paragrapgh, the term "at least annually" should be replaced with "at 12-month intervals."
Response
Section 12.9.8 has been revised to incorporate the comment.
' Table 12-10 The NRC questioned the values given in Table 12-10.
They thought
- that the values should be background.
Response
Table 12-10 has been deleted.
Table 12-11 was renumbered to 12-10
'and revised to delete levels _ of smearable contamination which are inappropriate for clothing surveys.
12.10.2.1 The values stated in the.last two paragraphs of this section are too large, and what are the units for the last set of values in the second paragraph?
Response
The units of the values were found to be in error and changed from
" grams /L1ter"' to " micrograms / Liter."
The units for the last values in the second paragraph are DPM per sample, and this was added to the paragraph.
12.8.5.3 The date on the referenced document should be changed from " November, 1976" to " July,1982."
Response
The recommended change was made.