ML20197C785

Requests Addl Info Re 850211 Application for License for Waste Storage Facility.Types & Quantities of Matl to Be Possessed Denoting Limits & Radiological Contingency Plan Requested

ML20197C785
Person / Time
Issue date:	06/11/1985
From:	Adam W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Scoville J U.S. ECOLOGY, INC. (FORMERLY NUCLEAR ENGINEERING
Shared Package
ML20197C671	List: ML20197C670 ML20197C676 ML20197C710 ML20197C735 ML20197C747 ML20197C785
References
78322, NUDOCS 8605130601
Download: ML20197C785 (3)

Text

l ei JUN 111985 U.S. Ecology ATTN: J.J. Scoville President 9200 Shelby,alle Road Louisville, KY 40222 Control No. 78322 Gentlemen:

We have reviewed your application dated February 11, 1985 requesting an NRC Byproduct Materials License for a waste storage facility and find that we will need additional information as follows:

1. We note that Item 5.B. of your application specified a possession limit of 20 curies for "any radioactive material". This limit would allow you possession of quantities of certain radioisotopes that would be in excess of those specified in Table 1 of NUREG-0767 " Criteria for Selection of Fuel Cycle and Major. Materials Licensees Needing Radiolcgical Contingency Plans". In response to this item, you should either:

a. Resubmit the types and quantities of material you wish to possess, denoting possession limits for those isotopes listed in NUREG-0767.

These possession limits should not exceed those values listed in Table 1 of NUREG-0767 or:

b. Submit a radiological contingency plan in accordance with NUREGS-0767 and 0762 (enclosed).

2. In order to meet the categorical exclusion specified in 10 CFR 51.22(c)(14)(xii)

(enclosed) with regard to submitting an environmental impact report, you need to specify a total possession limit for all packages held in interim storage at the same time of 50 curies or less and a total retension time for any package of 180 days or less.

If you feel you will be unable to operate under these constraints, you may need to file an environmental report as outlined in 10 CFR 51.45.

3. Pleast clarify which of the individuals that you have designated as Radiological Control and Safety Officers / Authorized users will be on-site on a full-time basis to direct the day-to-day operations at your facility.

8605130601 060306 REG 3 LIC30

.,a U.S. Ecology 2

4. Please supplement and resubmit your facility description to include:

a. A description of the site, includfr.g adjacent population centers, routes of access for evacuation and emergency equipment, means of limiting potent.fal release to adjacent populations.

b. A description of areas where various processes (e.g., repackaging, if applicable) will be performed.

c. A description of ventilation system at your facility including whether the facility will be maintained under negative pressure and what verifications of flow rates will be performed, including their frequency, to ensure ventilation systems are performing at expected levels.

5. Please describe your procedures for maintaining inventory control on a day-to-day basis i.e., verification that possession Ifmits are nct exceeded.

6. Please clarify whether the instructions in Attachment 4-1 are the instructions that will be supplied to your customers. If not, please supply a copy of these instructions and be sure they include methods for insuring compliance with 10 CFR 20.311.

7. Please clarify in what category of occupationally exposed individuals you have placed vehicle drivers and include an outline of the instruction that will be provided to these individuals as well as the frequency of retraining.

8. Please describe your fire protection plan and include those elements and features described in Regulatory Guide 3.16 which are appropriate for your facility and operations. You should describe the elements of your fire protection program in sufficient detail to enable us to assess its capability. Describe at least, fire detection and suppression including details of your sprinkler system and hoses and other extinguishers, training of personnel, support and response organizations, and inventories of uncontained combustible materials. You should confirm that truck trailers will not be used as additional storage space and that while truck trailers are parked at the facility for either loading or unloading, that they will be labeled such that the Fire Department would be alerted to the fact that they are loaded with radioactive waste. Additionally, you should state the approximate time you will hold truck trailers at the dock area pending unloading.

9. With regard to special nuclear material, please describe what precautions and/or limitations on the form of this material you will accept to avoid any incidence of criticality exposure. If you anticipate receiving any special nuclear material in the form of neutron sources, please describe what precautions will be followed with respect to shielding and personnel monitoring.

e_ _ .__ .__

ci

,

U.S. Ecology 3' .

10. If it is -your intent to either open packages (drums) or perfonn compaction of waste at your facility, please:

a. Please provide:a description of your method to monitor breathing zones -

and the exhaust streams.around the compactor. The filtration system must be capable of handling the type of radionuclides in waste to be compacted (e.g., fodines and particulates) '

b. Describe your system for monitoring filter blockage..

f.

c. Specify the type and frequency of surveys for contamination' control '

around the unit. .!

d. Outline the operator procedures and include: I

-l

1. protective clothing to be worn

2. checking for proper functioning of equipment

3. method of handling waste in " parent" drum

4. method of examining defects in drums after compaction -

e. Describe the type of campactor. I

f. Describe the type of waste to'be compacted (presumably dry waste only). .

It it is not your intent to repackage waste, open drums or' compact waste,, i please clearly state this. '

l We will continue our review of your application upon' receipt of this infonnation. [

Please reply in duplicate, within 30 days, and refer to Control Number 78322.

A

. Si nce rely ,-- i i

Original Signed By  ;

William J. Adam, Ph.D.. L Materials Licensing Section

Enclosures:

1. NUREGS 0762 and 0767 '

2. 10 CFR Part 51

3. -Regulatory Guide 3.16 [

i RIII A /cm 06/05/85 '

y*: '