ML20248D700
| ML20248D700 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 03/13/1989 |
| From: | Christopher Boyd BABCOCK & WILCOX CO. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25345, NUDOCS 8904120008 | |
| Download: ML20248D700 (3) | |
Text
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TDR Babcock & WilcoX NNFD RESEARCH LABORATORY a McDermott company P.O. Box 11165 Lynchburg, VA 24506 1165 (804) 522 6000
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4 March 13, 1989 6
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Leland C. Rouse, Chief' D
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Nuclear Safety e
Washington, DC 20555 q,
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Gentlemen:
The Babcock & Wilcox Company, Naval Nuclear Fuel Division Research Laboratory (NNFD-RL), is requesting an exemption from the requirements of 10 CFR 70.24.
Specifically, we request an exemption from having criticality monitors j
to cover the operations in our number one hot cell.
The rationale i
behind this request is attached.
Also attached is a check for $150.00 to cover the initial application fee.
If you should have further questions, please contact me at (804) 522-5753.
Very truly yours, BABC0CK & WILC0X NNFD Research Laboratory Charlie
. Boyd, Jr.
License Administrator l
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Attachment to letter from C. C. Boyd to L. C. Rouse, dated March 13,'1989 The following are' the reasons why NNFD-RL is requesting an exemption from
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the requirements of 10 CFR:70.24.
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1.
If a criticalityLoccurred within Hot Cell No.1, the construction of the cell (42-inch thick' Ilmenite concrete). would prevent gamma and neutron radiation from penetrating the cell.
No injury would' result to persons outside the cell in~ the event a criticality did occur.
Any monitors: placed outside the cell would not be able to detect a t
criticality occurring within the cel_1.
I 2.
The situation with Hot Cell No.1 is essentially the same as the one presented in,-10 ~ CFR 70.24(a) for SNM handled or stored underwater which also does not require monitoring.
3.
Cell entries are made'very infre'quently and'since the SNM handled is irradiated, the SNM is _ required to be removed from the cell before any entries take place.
This prevents a worker from accidentally entering a cell as a criticality is occurring.
4.
A detector located within the cell presents calibration and mainte-nance problems and would increase the -present rate of entries into the cell, which would not be desirable under our ALARA policy.
5.
In the event that a criticality' occurred, it would be detected in the
.off-gas from the ventilation system.
6.
This request does not effect or modify any operations which are currently approved for the hot cell.
It will not effect the health and' safety of any personnel _ on or off-site or have any adverse effect-on the environment.
Therefore, granting this request should not require an environmental impact statement as specified in 10 CFR 51.22(c)(11).
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1 NNFD-RL believes the reasons given above show good cause for an exemption i
from the requirements of 10 CFR 70.24 to provide criticality monitors where SNM is handled in the case of Hot Cell No.
1.
The monitoring requirements will be met in all other areas of our facility as necessary.
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