ML20246H397

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Safety Evaluation Supporting Amend 2 to License SNM-21
ML20246H397
Person / Time
Site: 07000025
Issue date: 03/08/1989
From: Mccaughey D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20246H384 List:
References
NUDOCS 8903200157
Download: ML20246H397 (2)


Text

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MAR 0 81989 DOCKET N0: 70-25 LICENSEE: Energy Systems Group (ESG)

Rockwell International Corporation  !

Canoga Park, California l

SUBJECT:

SAFETY EVALUATION REPORT, (1) LETTER DATED JULY 26, 1988, RE REVISED RADIOLOGICAL CONTINGENCY PLAN, (2) AMENDMENT APPLICATION DATED DECEMBER 19, 1988, SUPPLEMENTED JANUARY 26, 1989, RE COMPANY NAME CHANGE,-ORGANIZATIONAL CHANGES, AND AUTHORIZATION FOR CHEMICAL ANALYSIS WITH LICENSED MATERIAL

Background

During a routine inspection by NRC's Region V staff, it was observed that ESG's Radiological Contingency Plan dated March 3,1982, did not conform to the present operations at the facility. In subsequent communications between NRC headquarters staff and the licensee, the licensee agreed to'make changes to the Plan without reducing the effectiveness of the Plan and to submit the revised Plan in accordance with Condition 24 of the license. ESG is authorized to make changes in the Radiological Contingency Plan provided that the changes do not reduce the effectiveness of the Plan and that NMSS is notified of the changes within 6 months of the change. The July 26, 1988, letter provided the revised l L

Plan dated July 25, 1988.

During review of the revised Plan, the staff recognized that the organization described in the Plan was not consistent with the organization described in the license. After furcher discussion, the licensee agreed to submit an application for license amendment requesting organizational changes. The licensee submitted an amendment application on December 19, 1988, and supplement dated January 26, 1989.

In addition to the organizational changes, the December 19, 1988, application requested authorization to conduct plutonium chemical analysis at authorized facilities and deleted the description of activities and facilities which are no longer authorized and have been removed from the license.

Discussion A) Organization and Additional Operation The change in the organization has resulted from the merger of Rocketdyne and Energy Systems Group. The resulting subsidiary of Rockwell International, responsible for Materials License No. SNM-21 is the Rocketdyne Division. Since the reorganization was internal and the parent company remains the same, Condition 1 should be revised as follows:

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The remainder of the organizational changes are group and position title i changes. The functional organization is not disturbed, and therefore, staff recommends approval of these changes. ]

In addition to the above changes, the December 19, 1988, submittal requested authorization to conduct chemical analysis with a maximum of 0.1 gram of plutonium at an authorized facility in accord with approved radiation safety l criteria. The staff has determined that the present radiological safety program is adequate to support this operation. To authorize this activity, it is recommended that Condition 8.B.2 be revised as follows:

8.B.2 A maximum of 2 g total Pu for gamma spectroscopy and radiometric counting analysis and a maximum of 0.1 g total Pu for chemical analysis used in any authorized building at the SSFL site in accordance with NRC approved radiation safety criteria.

B) Radiological Contingency Plan Since the last revision of the Plan (March 3, 1982), the Canoga Park facilities and Building 055 at the Santa Susana Field Laboratories site have been deleted from the license as authorized places of use. The changes in this revision delete the sections associated with the Canoga Park facilities and Building 055. In addition, the changes in the organization have been reflected in the update. ESG found that these changes do not decrease the efft.ctiveness of the Plan and are authorized by the license.

Conclusion / Recommendation Staff finds that the proposed changes to the license will have no adverse effect on the public health and safety or on the environment. Approval of the amendment application is recommended. In addition, the staff agrees with the ESG finding that the changes do not reduce the effectiveness of the Plan and recommends that the license should be amended to update the reference to the Plan.

This latter action will be taken for the convenience of the Commission to maintain up-to-date references in the license.

The Region V Principal Inspector has no objection to this proposed action.

MY Signed Sy-David A. McCaughey Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS Approved by: Merri Horn for George H. Bidinger, Section Leader l

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