ML20246F677
| ML20246F677 | |
| Person / Time | |
|---|---|
| Site: | 07001359 |
| Issue date: | 06/19/1989 |
| From: | Crosbie K IRT CORP. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8907130351 | |
| Download: ML20246F677 (4) | |
Text
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June 19,1989 888 rp o
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U.S. Nuclear Regulatory Commission D
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Attention:
Mr. Leland C. Rouse, Chief D
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Fuel Cycle Safety Branch Division of Industrial & Medical q
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Nuclear Safety, NMSS
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Reference:
Docket 70-1359; Ucense # SNM-1405 l
License Renewal Application dated September 30,1988 IRT Document "lRT 4171-013"
Subject:
Possession limit error in original submission Gentlemen:
In reviewing IRT's new " storage only" license for purposes of preparing a Radiation Work Authorization to relocate the SNM to the storage vault, I discovered that the possession limits for Plutonium are in error in addition to the 1 gram of Plutonium enriched to 98 w/o Pu-239 we have on hand a 5 gram scaled source belonging to the Department of Energy. I believe the 1
error occurred because it was anticipated that this source would be returned to DOE. We are in the process of returning all DOE accountable materials and this process is proceeding at a very slow pace.
We are not in compliance with our new license at this time. l, therefore, submit this request to increase item 8A of the license to 6 grams. I do not believe that this small increase will have an effect on the original evaluation of the license.
Enclosed are six (6) copies of page 5 of our application with the new limit.
If you have any questions or need further information, please call me at (619) 450-4343, extension 450.
l Thank you.
I IRT Corporation Yk b K. L Crosbie, P. E.
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Radiation Safety Officer ITIT CORPORATION o 5h f E
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- 3. POSSESSION LIMITS 3.1 TOTAL LICENSE LIMIT
- 8. Limit
- 6. Material
- 7. Form (grams)
A.
Pu (enriched to 98%
A.
Sealed sources 6
B.
Pu (enriched to 80%
B.
PuBe neutron sources
-1 Pu-238)
C.
Pu (enriched to 75%
C.
Mixed oxide fuel rods 365 Pu.239) as sealed sources D.
U-235 (enriched to <10%)
D.
Mixed oxMe fuel rods 277 as sealed sources E.
U-235 (enriched to>20%)
E.
Sealed sources 35 F.
U-235 (enriched to <10%)
F. Non-dispersible solid 46 sintered fuel fuel pellets The total quantity of SNM does not exceed the amount specified in 10 CFR 73.2 (y),"Special Nuclear Material of Low Strategic Significance."
9a.
Authorized Use All items are to be used for storage, for preparation for transfer to another licensed entity, and for disposal as waste.
9b.
Authorized Place of Use All items will be stored at the Manufacturing Facility located at 8221 Arjons Road, Suite F San Diego, California 92126.
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June 19,1989 Page 5
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3.2 FORM OF LICENSED MATERIAL-The SNM specified in the possession limits is in the form of sealed ' sources, sealed fuel rods, sintered oxide fuel pellets, and encapsulated foils.
l; 3.3 EXEMPTION FROM REQUIREMENTS SET FORTH IN 10 CFR 70.24 The mass limitation given in Section 3.1 for 2 'U when coupled to the maximum -
v :Ighted mass of Pu'(weighting factor of 2.5) is below critical mass for homogenized sys.2ms of various enrichments with optimum moderation and full. reflection as given in Figure 13 of TID-7028.
The materials are not in a form to be homogenized and there are no massive moderators or reflectors of beryllium, heavy water or graphite present in the storage -
areas.
O' O
September 30,1988 Page 6
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