ML20202E421

Forwards Memo Supplementing T Rehm 851223 Memo.Work Should Be Planned in Advance to Accomplish Actions by Specified Date

ML20202E421
Person / Time
Issue date:	02/10/1986
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	NRC
Shared Package
ML20199D137	List: IA-85-763, Grants,In Part & Denies,In part,860131 Ltr Appealing 851224 Denial of FOIA Request for Documents Re Client Exposure to Radiation at Plant on 850529.Forwards App Docs.W/O Encls ML20199D134 ML20199D170 ML20199D484 ML20199F568 ML20199F575 ML20202E377 ML20202E407 ML20202E421 ML20202E452 ML20202E457 ML20202E477 ML20202E482 ML20202E501 ML20202E508 ML20202E514 ML20202E522 ML20202E533 ML20202E549 ML20202E558 ML20202E565 ML20202E570 ML20202E582 ML20202E587 ML20202E597 ML20202E602 ML20202E605 ML20202E611 ML20202E618 ML20202E623 ML20202E628 ML20202E651 ML20202E661 ML20202E674 ML20202H780 ML20203A811 ML20203D067
References
FOIA-86-80, FOIA-86-82 NUDOCS 8607140371
Download: ML20202E421 (4)

Text

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. February 10, 1986 MEMORANDUM FOR: Office Directors Regional Administrators FROM Victor Stello, Jr.

Acting Executive Director for Operations

SUBJECT:

PRIORITY ACTION LIST Please note the attached memo which supplements the memo previously sent to you from Tom Rehm on December 23, 1985.

You will note that the Comission is requesting staff to plan their work sufficiently in advance to (1) accomplish actions by a specified date, o_r, (2) request of the Commission, permission for an extension sufficient in advance that work can be completed if the Commission does not see fit to grant an extension.

On the short term items, you must act promptly. On the long term items, you must keep an eye on progress. I don't see anything unreasonable about this procedure.

As we discussed in our recent staff meeting we will provide Office Directors, or their designees, an initial opportunity to adjust suspense dates. I expect that when this process is working properly there will be no need for requesting delays except in rare or unusual circumstances.

Please review this list before weekly staff meetings and keep me advised of problems.

Original signed by Victor Stello -

Victor Stello, Jr.

g i g i 860702 Acting Executive Director GARDE 86-80 PDR _

for Operations

Enclosure:

Memo to V. Stello fm Distribution EDO R/F S. Chilk dated 1/29/85 VStello re: Revision to Commission JRoe Tracking Report TRehm JSniezek 0FC :A0/EDO :EDO .  :  :  :  :

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FC Central File NMSS R/F FCUP R/F FEB 061996 DAccol WTCrow MEMORANDUM FOR: Chairman Palladino RECunningham Commissioner Roberts DBMausshardt Commissioner Asselstine VStello, EDO Comissioner Bernthal RFonner, ELD Commissioner Zech RJEverett, RIV LCobb, IE FROM: Victor Stello, Jr.

Docket File 40-8027 Acting Executive Director for Operations PDR LPDR JRoe

SUBJECT:

RESUMPTION OF RECEIPT OF URANIUM CONCENTRATES BY VLTharpe JSniezek SEQUOYAH FUELS CORPORATION RIV ED0 r/f Sequoyah Fuels Corporation, by letter dated January 17, 1986, requested -'

resumption of some activities at the Sequoyah Facility which are not directly related to the startup of production. The staff considers startup as the resumption of production of uranium hexafluoride. Prior to authorizing startup, the staff will review training activities, testing of safety related systems, modifications of equipment, and other issues which may be identified by the Augmented Investigation Team. The licensee is preparing a proposed schedule for startup of production, and plans to brief the staff in the near future. A meeting has been scheduled on February 5, 1986 between Sequoyah Fuels Corporation and Region IV for this purpose.

In the intervening time period, the staff plans to consider authorization for other ancillary activities at the facility such as receipt of uranium concentrates, shipment of product uranium hexafluoride, and purification activities. We have reviewed the request to receive uranium concentrates which were enroute to the facility at the time of the accident and have authorized resumption of this activity. A copy of the letter authorizing resumption and the supporting Safety Evaluation Report are enclosed. The staff plans to keep the Commission informed as we authorize additional activities.

Ori Binal Signed by y10 tor Stallo Victor Stello, Jr.

Acting Executive Director for Operations

Enclosures:

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FCUP:DAC 40-8027 SUB-1010 Sequoyah Fuels Corporation ATTN: Dr. John C. Stauter Director, Nuclear Licensing Kerr-McGee Center Oklahoma City, OK 73125 Gentlemen:

In accordance with your request dated January 17, 1986, Sequoyah Fuels Corporation may resume receipt for the purpose of storage of uranium concentrates which were enroute to the Sequoyah Facility at the time of the January 4, 1986 accident.

All other activities at the facility shall remain suspended as provided by the confirmatory action letter dated January 17, 1986, between NRC Region IV and Sequoyah Fuels Corporation.

A copy of the Safety Evaluation Report in support of this action is enclosed for your information.

The request for shipping of filled uranium hexafluoride cylinders which was submitted with this request on January 17, 1986, is currently under review. We will advise you when this review has been completed.

If you have any questions related to this action, please feel free to contact Dr. Donald A. Cool of my staff at 301-427-4510.

FOR THE NUCLEAR REGULATORY COMMISSION W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

Enclosure:

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DOCKET NO: 40-8027 LICENSE N0: SUB-1010 LICENSEE: Sequoyah Fuels Corporation

SUBJECT:

SAFETY EVALUATION FOR THE PROPOSED RESUMPTION OF RECEIPT OF URANIUM CONCENTRATES

1. INTRODUCTION Activities at the Sequoyah Fuels Corporation (SFC) Sequoyah Facility have been temporarily suspended as a result of the accident which occurred on January 4, 1986. By letter dated January 17, 1986, SFC has requested authorization to resume receipt of uranium concentrates at the facility for the purpose of storage only. It is SFC's contention that the current status of the facility, as well as the cost and safety advantages, argue for the removal of the suspension for this activity. By letter dated January 31, 1986, SFC clarified that the request applied only to material which was enroute to the facility at the time of the accident.

II. SCOPE OF REVIEW During the review, the staff considered a number of factors in determining an appropriate response to SFC's request. These include the potential for disruption of decontamination activities which are occurring at the facility and the potential for recontamination of areas which have alv;ady been decontaminated. These factors are discussed below.

III. DISCUSSION d

Uranium concentrates are received and stored at the Sequoyah Facility in a fenced yard area west and slightly south of the main process building.

Access to the area is through the main facility gate, with the receiving area and scales in front of the main process building. This area was contaminated as a result of the accident which occurred on January 4, 1986, when a 14-ton cylinder of uranium hexafluoride ruptured and most of the contents lost. The licensee has stated that the storage area, receiving areas, and access routes at the facility have been decontaminated. The decontamination of these areas has been confirmed by inspectors from NRC Region IV. As a result, receiving and storage operations may take place without recontaminating clean areas or contamination of trucks and equipment.

SFC has stated that the decontamination activities at the facility have progressed to the point that activities involving the main access areas and the uranium concentrate storage area will not impact the continued GAMWV

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, decontamination of the remainder of the facility. At the present time, the areas which remain to be decontaminated are located principally within the main process building.

i The receipt of uranium concentrates at the facility is one of the normal operations conducted by SFC. Material is received in sealed 55-gallon drums and stored on pallets within the storage yard. The SFC request is a for storage only of the material in the yard area. As such, the source 4

material does not pose an unusual hazard since it is received and will remain within sealed containers.

2 As part of the submittal requesting resumption of receipt of uranium concentrates, SFC has provided the procedure which will be followed. The '

! - procedure includes provisions for receiving, unloading, and storage, and includes procedures for survey and checks to ensure that trucks are not  ;

contaminated prior to leaving the site. The procedure also provides the plan which would be used should uranium concentrates be received in a damaged drum. This plan provides for redrumming of the material and j cleanup of any spilled uranium.

SFC has indicated that there are financial, health, and safety reasons l 1 for allowing receipt of uranium concentrates at the facility. The financial

] aspects are primarily born by the owners of the uranium, most of which are

utilities. SFC provided a letter from Exxon Nuclear to support this I contention. The health and safety reasons for allowing receipt of uranium concentrates stems from the cresent use of temporary storage areas in interstate commerce for uran'ium which was enrcute to the Sequoyah Facility at the time of the incident. Material in interstate commerce, which is being held at temporary locations while in transit, does not provide the security that storage at the licensed facility would provide and increases j the probability that members of the public could be exposed to the material.

j The staff has discussed this proposal with members of NRC Region IV including Mr. R. J. Everett. The proposal and procedures have been reviewed by Region IV, and they have indicated that they support the proposed resumption of receipt and storage. The staff has also discussed the proposal with Mr. T. Makris, EPA, Mr. J. Miles,' OSHA, and Mr. Robert

! Craig, State of Oklahoma. They have indicated that the proposed action

! will not interfere with any of their activities, and that they have no I objection to NRC authorizing receipt of these concentrates.

IV. CONCLUSIONS AND RECOMMENDATIONS l

Upon review of the request for authorization to receive and store uranium j concentrates at the Sequoyah Facility which were enroute to the facility ,

at the time of the January 4, 1986 accident, the staff finds that the '

4 resumption of this activity would serve to protect public health and safety l by reducing the potential for public exposures. The proposed activities

! would not interfere with decontamination activities at the facility and will not interfere with any enforcement actions which the NRC might wish to pursue.

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Sequoyah Fuels Corporation 3 NRC Region IV has indicated that the Region concurs in allowing uranium concentrate receipt and storage.

The staff therefore recommends that Sequoyah Fuels Corporation be authorized to resume receipt of uranium concentrates which were enroute to the facility and storage of these source materials in the designated area of the facility.

The staff recommends that all other activities remain suspended as provided by the confirmatory action letter dated January 17, 1986, between NRC Region IV and Sequoyah Fuels Corporation.

Donald A. Cool, Ph.D.

Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS Approved by:

W. T. Crow, Section Leader 1

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FEB 111996 Docket No. 50-445 ..

MEMORANDUM FOR: Chairman Palladino Comissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech FROM: Victor Stello, Jr.

Acting Executive Director for Operations

SUBJECT:

COMANCHE PEAK UNIT 1 - ORDER EXTENDING CONSTRUCTION PERMIT On January 29, 1986, we reported to you that the construction permit for Comanche Peak Unit I had expired as of August 1,1985. -

The enclosed Order extends the latest construction completion date until August 1, 1988.

%iginal atgned by Nictor Stella Victor Stello, Jr.

Acting Executive Director for Operations

Enclosure:

Order cc: SECY(2)

OGC OPE OPA ELD Distribution:

Docket or Central VStello NRC PDR JRoe Local PDR OSniezek (EDMeading File PD# 5 Reading File T. Pehm D. Eisenhut T. Novak AD/BWR, PWR-A, B p' J. Heltenes, AE00 C. Trammell M. Ruspbrook

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COMANCHE PEAK STEAM ELECTRIC STATION, UNIT 1 DOCKET NO. 50-445 ORDER EXTENDING LATEST CONSTRUCTION COMPLETION DATE The Texas Utilities Electric Company, Texas Municipal Power j h Agency, Brazos Electric Power Cooperative, Inc., Tex-La Electric Cooperative of Texas Inc. (Applicants) are the holders of Construction Permit No. CPPR-126 issued by the Atomic Energy Commission 1 on i December 19, 1974 for construction of the Comanche Peak Steam Electric i

Station Unit 1, a nuclear facility utilizing a Westinghouse Electric Corporation nuclear steam supply system presently under construction at l the Applicants' site in Somervell County, Texas.

By letter dated January 29, 1986, as supplemented on February 4, i 1986, the Applicants filed a request for extension of the latest

construction completion date specified in Construction Permit j ,

No. CPPR-126 to August 1,1988. The Applicants state that, although

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construction on Comanche Peak Unit I was essentially completed early in 1985, major efforts to reinspect and reanalyze various structures, systems, and components are currently underway. These efforts are

being conducted by the Applicants' Comanche Peak Response Team to i

i 1/ Effective January 20, 1975, the Atomic Energy Commission was abolished and its regulatory authority transferred to the Nuclear i Regulatory Commission.

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verify both design and construction adequacy as well as to respond to numerous issues - raised in the operating license proceeding , ,,by the This activity has NRC's Technical Review Team, and by other sources.

been ongoing since the fall of 1984. The Applicants anticipate that it will not be complete before the second quarter of 1986. Because of l

l uncertainties associated with these activities and with the hearing process, the Applicants request an extension until August 1, 1988 to cover such contingencies.

' As discussed more fully in the staff's related Evaluation of Request dated February 10, 1986, we have concluded that good cause has been ,,

shown for the delay, and that the requested extension is for a reasonable period. We have further concluded that the requested extension involves no significant hazards consideration, and therefore no

> prior public notice is required.

The NRC staff has prepared an environmental assessment and finding of no significant impact which was published in the Federal Register on February 7, 1986 (51 FR 4834). The NRC staff has concluded that this action will not have a significant impact on the quality of the human environment and therefore no environmental impact  ;

statement need be prepared.

The Applicants' letter dated January 29, 1986, as supplemented on )

February 4, 1986, and the NRC staff's letter and evaluation dated February 10, 1986 issued in support of this Order are available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C., and at the Somervell County Public Library, l

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On the Square, Glen Rose, Texas 76043.

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IT IS HEREBY ORDERED that the latest completion date for CPPR-126 be extended to August 1,1988. _

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! Thomas M. Novak Acting Director Division of PWR Licensing-A Date of Issuance: February 10, 1986 4

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1. UNITED STATES

, 8  % NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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MEMORANDUM FOR: Chairman Palladino i Comissioner Roberts  !

Comissioner Asselstine ,

Comissioner Bernthal 1 Comissioner Ze::h FROM: Victor J. Stello, Jr. .

Acting Executive Director  !

for Operations

SUBJECT:

STAFF ACTIONS CONCERNING THE ENVIRONMENTAL QUALIFICATION (EO) EXTENSION FOR THE FORT ST. VRAIN NUCLEAR GENERATING STATION 1

On November 26, 1985, the Commission issued a Memorandum and Order in the subject proceeding approving an extension of time for achieving full compliance with the requirements of 10 CFR 50.49 until May 31, 1986. The Comission's acceptance of the licensee's proposal to allow operation in the interim was conditioned by a limit of thirty-five percent of full power and the submission by the licensee of acceptable confirmatory analyses and data in several areas. Actual authorization of operation up to thirty-five percent was to be made by the Directoi of NRR upon finding the licensee's confirmatory analyses acceptable.

The licensee has made the required submittals and the staff is preparing to process the authorization in the form of an approval by the Director of NRR -

of the conditions for operation during the period of extension. These conditions do not involve changes in the existing license conditions or in technical specifications but they do involve procedures for dealing with accident conditions which are somewhat different than those that would be used if the presently unqualified equipment was qualified. Not all of the alternate equipment to be used in the event of an accident is fully safety grade but there is a high degree of assurance that, given the low power level and the limited time period involved the facility can be safely shut down, and maintained shutdown, in the event of an accident by utilizing these alternate procedures and equipment.

While there could be small changes in some accident evaluation calculations, l we do not interpret the Comission's Memorandum and Order to require that these changes be considered as a matter separate and apart from the CONTACT: K. Heitner 49-27364 _ (C M-/- [

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extension. Therefore, we conclude that a letter to the licensee from the Director of NRR, summarizing his findings is sufficient to authorize the limited operation and that a license amendment is not required to support this authorization.

Original signed by, Victor Stelle -

Victor J. Stello, Jr.

Acting Executive Director for Operations cc: S. J. Chilk, SECY J. E. Zerbe, Director, OPE H. E. Plaine, Director 0GC DISTRIBUTION:

_ Central Files NRC PDR Local PDR ED0 Reading SSPD Reading TRehm HDenton DEisenhut FMiraglia FSchroeder RBernero HThompson JHeltemes PNoonan .

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VStello PDR JGDavis LPDR The Honorable Robert W. Edgar DBMausshardt SECY (3)

United States House of Representatives RECunningham OCA Washington, D.C. 20515 RCRouse GJohnson, ELD ,

PLoysen

Dear Congressman Edgar:

FBrown Thank you for your letter of December 15, 1985, forwarding questions raised by a concerned citizen in Pennsylvania about waste volume reduction.

Asindicatedbytheletteryoureceived,wearereviewinganappbcationby Babcock & Wilcox to compact and incinerate low-level radioactive waste at its Parks Township, Pennsylvania facility. The report on our environmental review will include evaluation of non-radiological as well as radiological impacts, and we plan to include specific information on dioxins. Babcock & Wilcox's proposal includes the incineration of small quantities of the chemicals toluene, xylene, and benzene which are used as scintillation fluids for radiometric counting. The combustion products from these chemicals will be included in our considerations.

In answer to the first of your specific questions, there is a wealth of information regarding the fate of materials that are burned. This information is contained in a variety of handbooks, texts, reports, and other documents.

The toxicity of most of the products of combustion is known also. Specific-information, however, about the chemical toxicity of combustion products can better be provided by EPA. ,

As for your second specific question, we cannot answer for EPA. However, it should be noted that Babcock & Wilcox has applied for an Air Quality Permit from the Pennsylvania Department of Environmental Resources, which'has permitting authority under EPA's Clean Air Act and which will require pre-operational burn tests as a condition of any permit it may issue.

If we may be of further assistance in this matter, please let us know.

Sincerely, y (S! ped) T. A. rdm q(k jy

1. fbVictor Stello, Jr.

P Acting Executive Director' ,

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FROM: DUE: 02/06/86 EDO CONTROL: 01378 DOC DT 02/06/86 CHAIRMAN PALLADINO FINAL REPLY:

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FEB 121986 NEMORANDUM FOR: Comissioner Asselstine FROM: Victor Stello, Jr.

Acting Executive Director for Operations .

SUBJECT:

RESPONSES TO QUESTIONS IN YOUR MEMORANDUM DATED JANUARY 27, 1986 Enclosed are the staff responses to the questions in your memorandum dated January 27, 1986, related to the Sequoyah Fuels Corporation facility accident.

Original signed by yictor Steno Victor Stello, Jr.

Acting Executive Director for Operations

Enclosure:

As stated cc: Chairman Palladino Commissioner Roberts Commissioner Bernthal Commissioner Zech PE GC SECY DISTRIBUTION EDO 001367 w/ encl.

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QUESTION 1 I WOULD LIKE SOME INFORMATION ABOUT THE UF 6 CANISTERS.

SPECIFICALLY, I WOULD LIKE TO KNOW HOW THEY ARE MADE, WHETHER THE NRC OR ANY OTHER AGENCY CERTIFIED THEIR DLSIGN, WHETHER ANYONE INSPECTS THEM, AND WHETHER ANYONE HAS LOOKED INTO TRANSPORTATION ACCIDENTS INVOLVING THESE CANISTERS. APPROXIMATELY 6 ARE THERE IN THE U.S. PER HOW MANY SHIPMENTS OF UF YEAR?

ANSWER.

THERE ARE A NUMBER OF CYLINDER DESIGNS FOR TRANSPORT OF UF 6 STANDARD UF 6 CYLINDER MODEL NOS 5A, 8A, 12B, 30B, 48A, 48X, 48F, AND 48Y (THE NUMERICAL PREFIX INDICATES CYLINDER DIAMETER IN INCHES)

ARE FABRICATED IN ACCORDANCE WITH SECTION VIII 0F THE ASME BOILER AND PRESSURE VESSEL CODE EVEN THOUGH UF 6 AS OFFERED FOR TRANSPORT IS A SOLID AND IS NOT UNDER PRESSURE. THE CYLINDER INVOLVED IN THE ACCIDENT AT THE SEQUOYAH FUELS CORPORATION WAS A MODEL NO.

48Y.

THE MODEL NO. 48Y CYLINDER WAS ORIGINALLY DESIGNED FOR USE BY THE ATOMIC ENERGY COMMISSION AND HAS BEEN IN WIDESPREAD USE FOR MORE THAN 15 YEARS. THE NRC CERTIFIED THE MODEL NO. 48Y CYLINDER DESIGN ON JANUARY 22, 1976, AS MEETING THE NORMAL CONDITIONS OF TRANSPORT (E.G., 1-F00T FREE DROP, 130*F DAY IN SUNLIGHT, ETC.). THE NRC ASSELSTINE/NMSS 2/06/86

QUESTION 1. (CONTINUED) 2 CERTIFICATION WAS NOT RENEWED AFTER NOVEMBER 30, 1985, BECAUSE OF A RULE CHANGE, EFFECTIVE SEPTEMBER 6, 1983, WHICH RECLASSIFIED NATURAL URANIUM SUCH THAT NRC CERTIFICATION WAS NO LONGER REQUIRED. -

MODEL NO 48Y CYLINDERS ARE FABRICATED BY A NUMBER OF MANUFACTURERS

.WHO ARE CERTIFIED BY THE ASME. FINISHED CYLINDERS ARE STAMPED WITH THE ASME CODE "U" SYMBOL INDICATING THAT THE CYLINDER MEETS ASME FABRICATION, TEST, AND INSPECTION REQUIREMENTS AND ARE REGIS-TERED WITH THE NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTORS.

CYLINDERS ARE PERIODICALLY INSPECTED AND TESTED THROUGHOUT THEIR SERVICE LIVES AT INTERVALS NOT TO EXCEED FIVE YEARS. THESE PERIODIC INSPECTIONS CONSIST OF AN INTERNAL AND EXTERNAL EXAMINATION OF THE CYLINDER BY A QUALIFIED INSPECTOR, AN ASME CODE-TYPE HYDROSTATIC STRENGTH TEST, AND AN AIR-LEAK TEST. THE CYLINDERS ARE ALSO INSPECTED 1

BY USERS EACH TIME THEY ARE RECEIVED AND BEFORE AND AFTER FILLING.

THE PACKAGING AND TRANSPORT OF NATURAL UF ARE SUBJECT TO THE 6

REQUIREMENTS OF THE DEPARTMENT OF TRANSPORTATION (DOT). THE DOT REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENT OF NATURAL UF INCLUDE 6

PACKAGING IN STRONG, TIGHT PACKAGES S0 THAT THERE WILL BE NO LEAKAGE OF RADI0 ACTIVE MATERIAL NORMALLY INCIDENT TO TRANSPORTATION.

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TRANSPORTATION ACCIDENTS INVOLVING UF WERE ADDRESSED IN WASH-1248, 6

" ENVIRONMENTAL SURVEY OF THE URANIUM FUEL CYCLE," APRIL 1974.

i ASSELSTINE/NMSS 2/06/86

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QUESTION 1. (CONTINUED) 3 WASH-1248 PROVIDES THE SUPPORTING DATA FOR TABLE S-3 0F 10 CFR 51.51. THERE HAVE BEEN ACCIDENTS INVOLVING THE SHIPMENT OF UF6 '

THE MOST RECENT WAS THE SINKING OF THE FRENCH CARGO SHIP MONT LOUIS -

ON AUGUST 24, 1984, IN THE ENGLISH CHANNEL. THE CARGO INCLUDED 30 MODEL NO. 48Y CYLINDERS WITH NATURAL UF AND 22 MODEL NO. 30B 6

CYLINDERS WHICH WERE EMPTY. THERE WAS NO LOSS OF UF 6 TO THE ENVIRONMENT.

THERE HAVE BEEN THOUSANDS OF UF 6 SHIPMENTS. BASED ON A SURVEY CONDUCTED IN 1975, THERE WERE 2,050 ROAD AND 2,500 RAIL SHIPMENTS OF NATURAL UF6 . IN FY 83, OVER 4,000 SHIPMENTS OF UF , NATURAL 6

AND ENRICHED, WERE REPORTED BY THE DEPARTMENT OF ENERGY; THE STAFF DOES NOT HAVE INFORMATION ON THE NUMBER OF COMMERCIAL SHIPMENTS.

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l-QUESTION 2A. TO WHAT EXTENT DOES THE NRC CONSIDER CHEMICAL HAZARDS WHEN IT LICENSES MATERIALS LICENSEES?

ANSWER.

UNDER THE ATOMIC ENERGY ACT OF 1954, AS AMENDED, THE COMMISSION'S PRIMARY RESPONSIBILITY IS TO REGULATE THE USE OF SOURCE, BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL IN ORDER TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC AND OF THOSE WHO MAY BE OCCUPATIONALLY EXPOSED.

IN GENERAL, RADI0 ACTIVE MATERIALS, AS DEFINED IN THE ATOMIC ENERGY ACT, ARE TO BE FOUND IN THE FORM OF CHEMICAL COMPOUNDS, SOLUTIONS, OR MIXTURES AND ALLOYS WITH OTHER NONRADI0 ACTIVE ELEMENTS. NO MATTER WHAT CHEMICAL OR PHYSICAL FORM THE RADI0 ACTIVE MATERIAL MAY TAKE, IT REMAINS SUBJECT TO THE COMMISSION'S AUTHORITY AND ITS HAZARDS ARE CONSIDERED. THIS CONSIDERATION EXTENDS TO THE CHEMICAL HAZARDS WHICH MAY BE ASSOCIATED WITH MATERIAL THAT IS ALSO RADIO-ACTIVE. FOR EXAMPLE, WHEN EXPOSURE TO SOLUBLE URANIUM (SUCH AS URANIUM HEXAFLUORIDE) IS CONSIDERED, THE LIMITING FACTOR IS THE CHEMICAL T0XIC EFFECTS OF THE MATERIAL TO THE KIDNEY.

IN SOME LICENSED FACILITIES, ANCILLARY CHEMICAL PROCESSES ARE EXECUTED THAT IN THEMSELVES DO NOT INVOLVE NUCLEAP MATERIALS. FOR EXAMPLE, A PLANT FOR CONVERSION OF URANIUM OXIDE TO URANIUM HEXA-l FLUORIDE WILL HAVE A SEPARATE OPEPATION FOR THE PRODUCTION OF FLUORINE TO BE USED IN THE CONVERSION PROCESS. SUCH A SEPARATE ASSELSTINE/NMSS 2/06/86

QUESTION 2A. (CONTINUED) 2 CHEMICAL PROCESS HAS NOT BEEN REGULATED BY THE COMMISSION SINCE IT DOES NOT INVOLVE NUCLEAR MATERIAL. THEREFORE, THE STAFF HAS NOT EXPLICITLY CONSIDERED ALL THE CHEMICAL HAZARDS OF THESE _

OPERATIONS IN ITS SAFETY REVIEWS. HOWEVER, THE POTENTIAL ENVIRON-MENTAL IMPACTS OF THESE ANCILLARY CHEMICAL OPERATIONS ARE CONSIDERED BY THE STAFF IN ITS REVIEWS UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT, I

ASSELSTINE/NMSS 2/06/86

QUESTION 28. TO WHAT EXTENT DOES NRC INSPECT MATERIALS LICENSEES FOR CHEMICAL HAZARDS OR VIOLATIONS OF ENVIRONMENTAL REQUIREMENTS RELATING TO CHEMICAL RELEASES? DOES ANY OTHER AGENCY, STATE OR FEDERAL, INSPECT FOR THIS?

ANSWER.

THE NRC INSPECTS CHEMICAL HAZARDS AT FACILITIES LIKE THE SEQUOYAH FUELS PLANT THAT COULD REASONABLY BE EXPECTED TO IMPACT ON RADIO-LOGICAL SAFETY (SEE Af!.SWER TO QUESTION 3) . REQUIREMENTS FOR INSPECTIONS OF SUCH CHEMICAL HAZARDS ARE DEVELOPED SPECIFICALLY FOR EACH FACILITY AND THE CONDITIONS OF THE LICENSE. NRC NOTES RESULTS OF CHEMICAL ENVIRONMENTAL RELEASES IN THE COURSE OF INSPECTING FOR RADIONUCLIDE EFFLUENT RELEASES. THE STAFF IS PRESENTLY EXAMINING THE QUESTION OF THE DEGREE TO WHICH OTHER FEDERAL / STATE AGENCIES INSPECT OR OTHERWISE REGULATE NUCLEAR FUEL PROCESSING FACILITIES LICENSED BY THE NRC, ASSELSTINE/NMSS 2/06/86 l

QUESTION 3. TO WHAT EXTENT DOES THE NRC INSPECT FACILITIES LIKE THE SE7UOYAH FUELS CORPORATION FOR OTHER THAN HEALTH PHYSICS?

ANSWER.

THE WORDS " HEALTH PHYSICS" AS USED IN THE QUESTION HAS BEEN INTERPRETED FOR THIS ANSWER TO REFER TO A SPECIFIC PROGRAM FOR PROTECTION OF EMPLOYEES FROM RADIATION; E.G., 10 CFR PART 20 0F THE NRC'S REGULATIONS.

THE NRC POLICY AND GUIDANCE FOR INSPECTING FUEL FACILITIES SUCH AS THE SEQUOYAH FUELS CORPORATION ARE CONTAINED IN CHAPTER 2600 0F THE NRC'S INSPECTION AND ENFORCEMENT MANUAL. THIS NRC INSPECTION PROGRAM WAS DEVELOPED USING THE PHILOSOPHY THAT ALL CONDITIONS, OPERATIONS, OR PROCEDURES RELATED TO THE PLANT THAT COULD REASON-ABLY BE EXPECTED TO IMPACT ON RADIOLOGICAL SAFETY SHOULD BE EXAMINED. HEALTH PHYSICS, OR SPECIFICALLY CHAPTER 2600, MODULE l

NUMBER 83822, RADIATION PROTECTION, IS ONLY ONE OF TEN OR MORE l INSPECTION PROCEDURES THAT COMPRISE THE OVERALL INSPECTION PROGRAM AT THIS TYPE OF FACILITY. THIS MODULE INCLUDES:

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QUESTION 3. (CONTINUED) 2 MODULE NUMBER TITLE 83822 RADIATION PROTECTION

1. RADIATION PROTECTION PROCEDURES

2. INSTRUMENTS AND EQUIPMENT

3. EXPOSURE CONTROLS

4. POSTING AND LABELING

5. SURVEYS

6. NOTIFICATION AND REPORTS OTHER IMPORTANT INSPECTION MODULES THAT ARE COMPLETED DURING THE ANNUAL ROUTINE INSPECTION OF THIS FACILITY ARE:

MODULE NUMBER TITLE 88005 MANAGEMENT ORGANIZATION AND CONTROLS

1. ORGANIZATIONAL STRUCTURE

2. PROCEDURE CONTROLS

3. REVIEWS AND AUDITS

4. SAFETY COMMITTEES

5. QUALITY ASSURANCE PROGRAMS ASSELSTINE/NMSS 2/06/86

l QUESTION 3. (CONTINUED) 3 MODULE NUMBER TITLE 88010 OPERATOR TRAINING / RETRAINING

1. NEW EMPLOYEE INDOCTRINATION -

2. ONGOING TRAINING

3. RETRAINING 88020 OPERATIONS REVIEW '

l. CONDUCT OF OPERATIONS, FACILITY, MODIFICATIONS AND CHANGES, SAFETY LIMITS /LCOS

2. HOUSEKEEPING

3. FUEL HANDLING AND STORAGE 1

88025 MAINTENANCE / SURVEILLANCE TESTING

1. MAINTENANCE

2. SURVEILLANCE TESTING

3. CALIBRATIONS 88035 RADIOACTIVE WASTE MANAGEMENT

1. LIQUID EFFLUENTS

2. AIRBORNE EFFLUENTS

3. RECORDS AND REPORTS

4. EFFLUENT MONITORING INSTRUMENTS ASSELSTINE/NMSS i 2/06/86 l

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4 QUESTION 3. (CONTINUED) 4 MODULE NUMBER TITLE

5. PROCEDURES

6. RADIOACTIVE SOLID WASTE -

7. WASTE BURIAL

8. STORAGE OF HIGH LEVEL LIQUID WASTE 86740 TRANSPORTATION OF RADIOACTIVE MATERIALS

1. ROUTINE MAINTENANCE OF REUSABLE PACKAGES

2. PACKAGING AND TRANSPORTATION ACTIVITIES 88045 ENVIRONMENTAL PROTECTION

1. MANAGEMENT CONTROLS

, 2. QUALITY CONTROL / ANALYTICAL MEASUREMENTS

3. PROGRAM IMPLEMENTATION 88050 EMERGENCY PREPAREDNESS

1. OFF SITE SUPPORT AGENCIES

2. EMERGENCY PLANS, PROCEDURES, FACILITIES AND EQUIPMENT

3. TESTS AND DRILLS

4. FIRE PROTECTION ASSELSTINE/NMSS 2/06/86 l

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