ML20236P233

Forwards Request for Addl Info Re Recipient 870521 Renewal Application for License SNM-1405.Requested Possession Limits Inappropriately Described.Response Required within 90 Days of Ltr Date

ML20236P233
Person / Time
Site:	07001359
Issue date:	11/09/1987
From:	Pennington W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Maschka P IRT CORP.
References
NUDOCS 8711170208
Download: ML20236P233 (8)

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70-1359' SNM-1405'

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g LIRT! Corporation . .

=. i- JATTN: Mr. : Paul :R. Maschka -

Radiation Safety.0fficer; ,

.P.;0.-Box 85317

. -San Diego, California 92138' -

'Gentlem ni-The staff has reviewed yo'ur. renewal application dated-May 21, 1987, and-

' determined that additional information is'needed to proceed with the renewal.. ,

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process., . Enclosed is a . list of the staff's comments and questions :regarding i

'your application. . Please: submit your response (six: copies) as page changes to_

the application or as a supplement within 90 days .of the date of this letter. y

-Should-you have further questions,'please do;not hesitate to call me at.(301) 427-4510.-

Sincerely,.

Win'inal Sign'd EYl l W.S. Pennington '

Uranium Fuel-Section Fuel Cycle.. Safety Branch .  !

Division of. Industrial and 1 Medical. Nuclear Safety, NMSS a

Enclosure:

'As stated-1 DISTRIBUTION.w/encls.

PDR NMSS R/F GDocket270-135923 VLTharpe.

IMUF'R/F._ IMSB R/F WSPennington . Region V. DMcCaughey 1 i

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0FFICIAL RECORD COPY B711170200,971109 PDR ADOCK 07001359 ,

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. NOV g1987 j

COMMENTS AND QUESTIONS RE IRT RENEWAL APPLICATION FOR LICENSE NO. SNH-1405

1. If IRT intends to use SNM in a dispersible form, identify the location of the nearest residence, school, and population center.

2. State the period of time for which the license renewal is requested.

3. The requested possession limits are inappropriately described. The  !

stated materials and mass limits fail to include all of the licenseable  !

material. An example of an acceptable description follows:  ;

A.. Plutonium (enriched Sealed Sources 40 grams to 75% Pu-239) j

4. The requested possession limit for Item L. should not be included in Item K.

5.. In Section 3.1, the application indicates that Item J. will be stored at I 8221 Arjons Road and used at 3030 Callan Road. Please clarify your intentions with regard to Item J.  !

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6. - State the level of management or position responsible for selection of personnel employed in safety-related positions.

7. State the minimum criteria for waiving formal training.

8. IRT should be committed to annual retraining of all employees working with radioactive materials or in areas where they may be exposed to radiation.

9. The>1ast sentence.in Section 6.8.1 discusses Item 3. Please define Item 3.

10. Describe your' provision to ensure that. current operating and radiation procedures, as well as work authorizations, are appropriately located in areas where work is being carried out.

11. Section 6.5 states that all activities involving materials subject to the license are inspected and reviewed. Does the inspection and review program include audits to verify that the radiation safety and criticality programs are being administered in accordance with established criteria?

12. IRT should be committed to maintaining records for a minimum of 2 years, )

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unless otherwise required in 10 CFR Part 20.

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Nov 9' 'L1987 L LCommentsand. Question'sREIRT '2' c 3

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13. Briefly describe your ~ policy'and program for 1eak- t'esting Jof sealed sources.

6 Clearly.~ state frequencies and methodologies's. The enclosed attachments describe the minimum leak testing crite_ria acceptable to the'NRC' staff. -l

< '14. State.the administrative limits.for minimum flow velocity at hood faces and fopened glove boxes and for the maximum differential pressure measurement'

-across HEPA filters. In addition, include the frequency of system checks.

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15. Prt lide o conceptual plan 1for decontaminating the facility and site'so the. facility and grounds can be released for unrestricted use. Include an estimate of the costs involved and a description' of the financial' arrangements made to ensure that funds will be available at the time of"

. decommissioning. The following indicates the; type and scope of the information required:

A. Procedure-1.- - Removal of radioactive materials (bulk cleaning prior to .

I decontamination). i 1

2. Pre-survey (prior to start of decontamination).

,3. . Equipment disposal (decontamination or burial). .j

4. Facility surface cleanin andstructuralsurfaces)g(methodsfordecontaminatingwalls

5. Liquid ' effluent system (plans for decontamination or disposal). l

6. Floors '(decontamination' or' rr<noval)L

7. Ventilation system (decontamination or burial).

B. Final report.to NRC requesting release.  !

The plan should include:

All.of the assumptions that were made in arriving at cost estimates.

i Whether equipment and facilities would be decontaminated or buried.

If buried, whether onsite, or commercial, etc.

A statement that prior to the start of decontamination a detailed decommissioning plan including a proposed closecut survey plan will be submitted to the NRC for review and approval. ,

C. Estimated Cost for Decontamination This section should present a breakdown of the estimated costs for decontaminating the facilities and grounds, i.e., labor, material,  ;

transportation, burial, etc.

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' 3- ~ NOV- ~'1987 9

.CommentsandQuestions.;RE'IRT. 3.

D D.. 1 Financial Assurance:

.Thi.s~should be a document separate from the: decommissioning plan-that is a commitment from a corporate official-(Pres.,JV.-Pres.,

. Controller) that funds will be'made_available for~the' purpose of?

decontaminating the facility so that'it can be released for- j!

unrestricted use. ,

l 16'. Briefly describe 3rocedures for personnel contamination surveys and -  !

decontamination w1en work' involves dispersible material.

17.1 In:Section 9.6.3, the[ application states that G-M survey meters are l calibrated annually. However, Regulatory Guide 8.24 states that D' instrument calibrations should be made at least semi-annually.,

i ~I18.' For.the instruments described in Items 1 thru'3 of Section 9.6.3, stat'e-

. calibration' frequencies, minimum detection limits, and ranges.

19. Does IRT provide for the ' calibration of the self-reading pocket dosimeters Land air sampler gas

flow meters stated in Sections 7.2.1 and 9.6.4, respectively? ~ If-yes, provide calibration frequencies.

'20. Briefly, describe'the nature of temporary offsite operations involving SNM.

~ 21; The application should include a description or copy of IRT's emergency.

procedures forl fires,-release'or. loss of material, accidental contamination i of personnel, etc. In-addition, the description should state the locations and. quantities =of toxic and hazardous chemicals which, if involved in a fire.  :)

spill, or explosion, could result in the release or loss of control of SNM. j I I

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NOV 9 1987-m i

LICENSE CONDITION FOR' 1

' PLUT0NIUM ALPHA ~ SOURCES'

< AUGUST 1987-l

A. -Sources-when not in use shall be stored in a closed container adequately

! designed and constructed to contain plutonium which might otherwise be

' -released during storage.

B.. At least-once everyl3 months, the licensee'shall test the source for loss of plutonium in one of the-following ways using radiation detection instrumentation capable of detecting 0.005 microcurie'of alpha contamination:

l (1) By measurement of:the source of potential alpha contamination through "

surveys of the storage container and areas in which"the source is used;.

or l

.1 (2) By wiping thoroughly the external surfaces of the source mount, other than the radioactive surface ofJthe source, with a piece of filter paper ,

of high wet strength and low porosity moistened with a solution which I will-not attack the mount and, after the paper is allowed.to dry,

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l' measuring the radioactivity on the paper.

-C. Iflany survey or measurement performed as required by B.(1) or' B.(2) above discloses thesloss of more than 0.005 microcurie of plutonium from the source or if a source has-been damaged or broken, the source shall'be w deemed tofbe losing plutonium. The licensee shall immediately withdraw it from use, and cause-the source to be decontaminated and repaired, or disposed of inL accordance with the ~ Commission's regulations. Within 5 days after determining that any' source has lost plutonium, the licensee shall file a. report with the Division of Industrial and Medical Nuclear Safety.

U. S. Nuclear Regulatory-Commission Washington, DC 20555, describing the source, test results, extent of contamination, and corrective action taken.

A copy of the report shall be sent to the Administrator of the_ nearest NRC Regional Office listed in Appendix D of Title 10, Code of Federal Regulations,- ,

1 Part 20. i D .' Records of test results shall be kept in units of microcuries and maintained for inspection by the Commission.  :

E. _Notwithstanding the periodic test required by Paragraph B, any plutonium alpha source containing not more than 0.1 microcurie of plutonium is exempted from the above requirements.

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NOV ,9.1987 a . .

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' LICENSE CONDITION FOR' LEAK TESTING' SEALED PLUT0NIUM SOURCES' AUGUST'1987.

LA. Each plutonium source shall-be tested for_ leakage at intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that

'i a test'has been made within 6 months prior to the transfer, the sealed source shall .not be put Linto ~ use until tested.

I B. . =The test shall be capable of detecting the presence of 0.005 microcurie'of alpha contamination on the test sample. The test sample. shall be taken from the source or from appropriate accessible surfaces of the' device in  !,

which the sealed source is permanently or semipennanently mounted or stored.

Records 'of leak test.results shall be kept in units of microcuries and l maintained for inspection.by the Comission. -

C. If;the test' reveals the presence 'of 0.005 microcurie or more of removable alpha contamination,; the licensee shall immediately withdraw the sealed source from use.and shall cause it to-be decontaminated and repaired by a

.. person appropriately licensed to make such repairs or to be disposed of in accordance with the Comission's regulations. ' Within 5 days after determining that any source has leaked, the licensee'shall file a report with the Division of Industrial and Medical Nuclear Safety, U.S. Nuclear Regulatory Comission, Washington, DC 20555, describing the source,-test results, extent of. contamination, apparent or suspected cause of source-failure, and' corrective action taken. A copy of the report shall be sent to the Administrator of the nearest NRC Regional Office listed in Appendix D ,

of Title 10, Code of Feder,a1 Regulations,'Part 20. - l The periodic leak test. required by this condition does not apply to sealed l D.

sources that are stored and not being used. The sources excepted from this  ;

test shall be tested for leakage prior to any use or transfer to another  ;

person unless they have been leak tested within 6 months prior to the date i of use or transfer.

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NOV '9 1987 ~

. LICENSE CONDITION FOR LEAK TESTING SEALED URANIUM SOURCES AUGUST 1987 A., Each uranium source shall be tested for leakage at ' intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that a test has been made within 6 months-prior'to the transfer, the sealed source shall not be put into use until tested.

.B. The test shall be capable of detecting the presence of 0.005 microcurie of alpha' contamination on the test sample. The test sample shall be taken from the source or from appropriate accessible surfaces of the device in which the sealed source is permanently or semipermanently mounted or stored.

Records of leak test' results shall be kept in units of microcuries and 1 maintained for inspection by the Commission. I C. If the test reveals the presence o'f 0.005 microcurie or more of removable alpha contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed of in accordance with the Commission's regulations. Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of Industrial and Medical Nuclear Safety, U.S. Nuclear Regulatory Commission, Washington, DC 20555, describing the source, test results, exten.t of 1 contamination, apparent or suspected cause of source failure, and the corrective action taken. A copy of the report shall be sent to the Administrator of the nearest NRC Regional Office listed in Appendix D of Title 10, Code of Federal Regulations, Part 20.

D. -The periodic leak test required by this condition does not apply to sealed sources that are stored and not being used. The sources excepted from this  ;

test shall be tested for leakage prior to any use or transfer to another {

i person unless they have been leak tested within 6 months prior to the date of use or transfer.

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