ML20134H692

Ack Receipt of Transmitting Comments & Concerns on Application by Nasa to Amend Licenses TR-3 & R-93 for Shutdown Test & Research Reactors in Sandusky,Oh

ML20134H692
Person / Time
Site:	Plum Brook
Issue date:	02/05/1997
From:	Mendonca M NRC (Affiliation Not Assigned)
To:	Suppe R OHIO, STATE OF
References
NUDOCS 9702110418
Download: ML20134H692 (6)

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l February 5, 1997

.Mr. Roger L. Suppes Chief, Bureau of Radiation Protection Ohio Department of Health 35 East Chestnut Street #

l Post Office Box 118 Columbus, Ohio 43266-0118 . l

SUBJECT:

APPLICATION FOR AMENDMENT OF LICENSE NO. TR-3 (DOCKET NO. 50-30) AND LICENSE NO. R-93 (DOCKET NO. 50-185) l

Dear Mr. Suppes:

Thank you for your letter of November 25, 1996, transmitting your comments and concerns on the application by the National Aeronautics.and Space Administration (NASA) to amend. licenses for their shutdown test and research l reactors in Sandusky, Ohio.

4 The U.S. Nuclear Regulatory Commission (NRC) completed it's initial review and transmitted a request for additional information (RAI) to NASA by letter dated l November 21, 1996. By letter of December 20, 1996, NASA responded to this RAI. These documents show that courtesy copies were sent to your department.

i Some of the requested information and responses dealt with issues that are similar or identical to those that you raised in your letter. NRC is continuing it's review of the NASA license amendment application and responses. I have transmitted your November 25, 1996, letter to NASA by courtesy copy of this letter.

Thank you again for providing your comments and concerns for NRC consideration. If you have any further questions, I would be pleased to hear from you.

Sincerely, Original signed by:

, Marvin M. Mendonca, Senior Project Manager s Non-Power Reactors and Decommissioning Project Directorate a Division of Reactor Program Management j Office of Nuclear Reactor Reguiation Docket Nos. 50-30 and 50-185 cc w/ incoming: See next page

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. ge t UNITED STATES j j l NUCLEAR REGULATORY COMMISSION t WASHINGTON, D.C. 20tLS4001 February 5, 1997 Mr. Roger L. Suppes Chief, Bureau of Radiation Protection Ohio Department of Health 35 East Chestnut Street Post Office Box 118 Columbus, Ohio 43266-0118

SUBJECT:

APPLICATION FOR AMENDMENT OF LICENSE NO. TR-3 (DOCKET NO. 50-30) AND LICENSE NO. R-93 (DOCKET NO. 50-185)

Dear Mr. Suppes:

Thank you for your letter of November 25, 1996, transmitt'- your comments and concerns on the application by the National Aeronautics . 6 pace Administration (NASA) to amend licenses for their shutdown test and research reactors in Sandusky, Ohio.

The U.S. Nuclear Regulatory Commission (NRC) completed it's initial review and transmitted a request for additional information (RAI) to NASA by letter dated November 21, 1996. By letter of December 20, 1996, NASA responded to this RAi. These documents show that courtesy copies were sent to your department.

Some of the requested information and responses dealt with issues that are similar or identical to those that you raised in your letter. NRC is continuing it's review of the NASA license amendment application and responses. I have transmitted your November 25, 1996, letter to NASA by courtesy copy of this letter. l Thank you again for providing your comments and concerns for NRC consideration. If you have any further questions, I would be pleased to hear ,

from you.  !

l Sincerely, .

% Q w).2 , p ~

l Marvin M. Mendonca, Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-30 and 50-185 cc w/ incoming: See next page

Docket Nos. 50-30/50-185 Mr. Don Campbell Director NASA Lewis Research Center 21000 Brookpark Road M.S. 3-2 Cleveland, Ohio 44135 Mr. Henry Pfanner Manager, Plum Brook Reactor Facility National Aeronautics and Space Administration Lewis Research Center Cleveland, Ohio 44135 l

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FINAL REPLY:

Rogor L. Suppes Ohio Dept. of Health TO:

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I FOR SIGNATURE OF  : ** GRN ** CRC NO:

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' DESC: ROUTING:

COMMENTS ON RENEWAL APPLICATIONS FOR LICENSE NO. Taylor

} TR-3 (DOCKET NO. 50-30) AND LICENSE NO. R-93 Milhoan (DOCKET NO. 50-185) - NASA'S PLUM BROOK RESEARCH Thompson

, REACTOR FACILITY Blaha

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Miller, RI DATE: 12/17/96 Paperiello,NMSS 1

, ASSIGNED TO: CONTACT:

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SPECIT.L INSTRUCTIONS OR REMARKS: i For appropriate action.

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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: ' CRC-96-1233 LOGGING DATE: Dec 12 36 ACTION OFFICE: EDO AUTHOR: RCGER SUPPES AFFILIATION: OHIO ADDRESSEE: SECRETARY OF COMM/DSB LETTER DATE: Nov 25 96 FILE CODE:

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SUBJECT:

COMMENTS ON RENEWAL APPLS FOR LIC NO. TR-3 (DOCKET NO. 50.30) AND LICENSE NO. R-93 (DOCKET NO. 50-185)

ACTION: Appropriate DISTRIBUTION: CHAIRMAN SPECIAL HANDLING: NONE CONSTITUENT: l l

NOTES: l DATE DUE:

SIGNATURE: . DATE SIGNED:

AFFILIATION:

l EDO -- G960951

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OHIO DEPARTMENT OF -EALTH l l

246 N HIGH STAEET post Othee Bos s ie M GEOnGE V vo!Nov CH Govemor C:fur ts ONo 4326Er0118 Teteprere f 74, M6 3543 PETER SoMW M O Ph O 3, rec.or ce wepn Secretary of the Commission November 25,1996 U.S. Nuclear Regulatory Commission l ATTN: Docketing and Services Section Washington, D.C. 20555-0001 Re: Comments on renewal applications for License No. TR-3 (Docket No.50-30) and License No. R-93 (Docket No. 50-185).

The Ohio Department of Health has received copies of the license renewal applications for the licenses issued to NASA's Plum Brook Reactor Facility, referenced above. These applications have been reviewed by the Bureau of Radiation Protection Licensing staff. The State has several j comments and concerns which are submitted for your consideration. The principal concern is continued licensing of a closed research reactor with no decommissioning actions. We will be pleased to discuss any issues or concerns with the NRC licensing stafT.

Sincerely, ,

O ge Roger L. Suppes Chief, Bureau of Radiation Protection Ohio Department of Health i

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.cfMS i

The following are concerns and comments on the applications for renewal of the NRC licenses NASA's Plum Brook Reactor Facility. Two applications are involved, one for the Plum Brook Reactor and one for the Mock Up Reactor at the Plum Brook facility (located inside the reactor facility). The concerns and comments apply to both applications.

1. The applications request renewal of the NRC licenses for a period of 20 years. Since the reactors were closed in 1973, this would result in a custodial period of approximately 43 years. The NRC regulations in 10 CFR 50.82(b)(ii) state that a decommissioning altemative is acceptable ifit provides for completion of decommissioning without significant delay. A custodial period of 43 years with no decommissioning activity is a significant delay, and NASA should provide an alternative to no action at all.

The applications state that NASA has no forseeable plans to dismantle the facility.

The NRC requirements in 10 CFR 50.82(b)(iii) provide alternatives to immediate decommissioning to protect public health and safety and for lack of radioactive waste disposal capacity. NASA has provided both reasons in its applications. Further decay of radionuclide inventory with resulting lower personnel exposure is stated as a health and safety reason, however, after 23 years most of the radioactive decay available in a reasonable time period should have occurred.

The lack of available radioactive waste capacity is also cited. However, this has not been true for the past 23 years. Disposal capacity is certainly limited, but it does exist.

There is no evidence that NASA has attempted to obtain approval for any disposal volume for any level of decommissioning or elevated level of cleanup activities.

2. The section on Inspections, tests, surveys includes only general categories and lists environmental considerations only in the general title environmental radiological surveys. The application states that tritium is located in the reactor vessel in a beryllium matrix and may be mobile in the right circumstances, and that the reactor vessel is continuously purged with nitrogen gas. This provides a potential release pathway, but no effluent monitoring system is described.

3. Figure 2 of the application provides a Generic Organization Chart, but does not provide a chart of the actual organization. A directorate is described, but no specific directorate is mentioned. This may have an influence on the amount of attention and resources allocated to the Plum Brook Reactor Facility.

On the generic organization chart the Radiation Safety Officer and the Plum Brook Reactor Manager are in the same directorate, but not in the same organizational line.

The application states that the Radiation Safety Officer is responsible for organization, j administration and direction of the radiological control and monitoring program.

However, health physics and maintenance functions appear under the Plum Brook Management Office in the organization chart. Some additional detail in program operation should be included describing the phy sical location and operation of the Radiation Safety Officer and the radiation safety office.

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4. The applications state that all byproduct waste materials have been disposed. This may mean all byproduct wastes packaged as wastes rather than all waste materials in the facility. Removal of all materials which are not reactor components would be a significant ALARA consideration.

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