ML20206R150

Requests Addl Info Re 860211 Application for License, Including Collection & decay-in-storage of Waste for Disposal as Nonradioactive Matl

ML20206R150
Person / Time
Issue date:	05/27/1986
From:	Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Larsen R LARSEN WAREHOUSING
Shared Package
ML20206Q890	List: ML20206Q885 ML20206R044 ML20206R106 ML20206R150
References
80928, NUDOCS 8704220113
Download: ML20206R150 (6)

Text

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MAY 271986 Larsen Warehousing ATTN: Robert N. Larsen, Owner 501 Foss Park Avenue North Chicago, IL 60064 Re: Application Dated February 11, 1986 for an NRC License Gentlemen:

In order to complete our review of your application, we need additional information on the following items:

1. For Collection and Decay-in-Storage of Waste for Disposal as Nonradioactive Material:

a. Environmental Information If you desire to store iodine-125 for decay for a period greater than 180 days, you will need to submit the information specified in Sections 51.45 and 50.60 of 10 CFR Part 51 and below:

(1) Discuss the need for your activity from an industry standpoint.

(2) Provide a map and description of the site including (1) the location of adjacent buildings and nearby residences, (2) nearby population centers such as office buildings, schools, churches, arenas, stadiums, etc., (3) the exact routes of nearby roads, the railroad, and the interstate highways, and (4) the location of buildings or facilities which could present evacuation problems in the event of a large release of radioactive material.

(3) Provide an accident analysis, including the risks, environ-mental impacts, radiological and nonradiological consequences of

a tornado, earthquake, flood, major fire, or major explosion at

your site. Include consideration of transportation incidents such as might be caused by a train or highway vehicle carrying hazardous material to and from your site.

l Please specify any other Federal, State or local permits or requirements which are required for your operation, and provide the status of the permits and compliance with the requirements.

8704220113 860922 REG 3 LIC30 PDR

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b. Plan to Meet Consequences of Accidents Please submit an analysis of how your facilities, location, and procedures will mitigate the consequences of events which could cause release of radioactive material to unrestricted areas (e.g., consider events such as tornado, flood, fire). Your analysis should include worst case calculations of airborne concentrations at the nearest occupied area downwind from your facility. The discussion and data presented in NUREG-0767 will aid you in the estimation of amount of your inventory that could be released or made airborne in an accident. You may reference previously submitted material or discussions.

c. Personnel Training Program The program specified in your application provides general training in radiation safety. Please submit a description of your training pr.ogram for lab techs, drivers, waste collectors, compactor operators, warehousemen, and other individuals involved in specific aspects of your program. The program should be sufficient to maintain a complement of trained personnel to carry out waste receipt, handling, and disposal operations in a safe manner. The description should include an outline, duration, qualification (s) of instructor (s) and method (s) of determining competency of students.

d. In order to authorize Robert Larsen as your proposed Radiation Safety Officer (RS0) and Chuck Margraf as your proposed authorized user, you will need to submit documentation of their experience with the types, quantities, and uses of materials requested for this license.

e. Instrumentation It is not clear whether the single Ludlum 14C survey meter described in your application is sufficient to ensure availability of proper radiation protection instruments for all aspects of your program nor sensitive enough to detect low activities of iodine-125. Please clarify. In addition, indicate the method and frequency of calibration of all instruments used in your program,

f. Personnel Monitoring Please submit your considerations and/or calculations for not establishing a bioassay or personnel monitoring program for individuals handling iodine-125 waste.

Larsen Warehousing 3

g. Facilities Please submit a description of:

(1) The areas where various processes (e.g., repackaging after decay-in-storage) or measurements will be performed inside your building.

(2) The posting and security procedtires you will utilize for any truck being loaded or unloaded with radioactive waste outside your warehouse or during transport from clients.

(3) Your procedures or precautions you will take for storing volatile or flamable waste in the radioactive storage area indicated in your application. Clarify whether or not any other flammable materials will be stored in the warehouse building and whether the waste drums will be stored on the floor or on wooden pallets. We recomend not storing flamable materials or using wooden pallets. If you do decide to use pallets, please submit ,

justification.

(4) Whether the storage building is constructed of materials that easily burn (e.g., wood or steel framing, firewalls, concrete or wood floor, etc.).

(5) Your ventilation system. Your description should include operational checks, the location of release points to the environment or areas inside the warehouse, and systems used to isolate the system during an event that could cause release of radioactive material (e.g., fire). If you do not have a ventilation system and anticipate storing flamable or volatile waste, please justify the lack of a system in terms of the flash points of this type of waste.

(6) Your considerations for systems where there is a potential for release of radioactive material to unrestricted areas (e.g.,

check valves in incoming water lines, drains to a holdup tank, methods to mitigate release of water through sewer lines or into watersystems,etc.).

(7) The procedures you will utilize to provide adequate spacing between storage areas for future access for removal of drums, fire fighting, etc.

(8) Any other uses of the facilities other than those proposed. If there are other uses, you will need to submit a description of

Larsen Warehousing 4 the system used to prevent unauthorized access or removal of material from your radioactive storage areas.

(9) Your fire protection system. Indicate whether the proposed system will satisfy local building and fire codes and confirm that an inspection will be performed by the local Fire Chief.

In addition, indicate access to water supplies.

(10) Your automatic fire detection system or consideration for such.

The description should include the type of detector (e.g.,

smoke, heat), the cutoff points for alarm, and operational checks.

(11) The time it will take for the local fire department to respond to a fire at your facility, and the rating the fire department has been given to qualify it for handling the type of materials that might be involved in a fire at your facility.

h. Describe arrangements that have been made with the local fire department to inform the staff of your operation and instruct them in any appropriate emergency procedures.

i. Packaging of Waste (1) Please submit a copy of the instructions you will provide to customers for packaging of radioactive waste for each type of program you will run (e.g., for pick-up and transport to your facility for decay-in-storage or repackaging). The instructions should include references to appropriate sections of the regulations such as Section 20.311 of 10 CFR Part 20 for each waste program.

(2) Describe your quality control program for ensuring waste is appropriately packaged and labeled at customers' facilities or points of collection and your storage facility in accordance with NRC and Department of Transportation (00T) regulations.

j. Transportation of Waste to Your Warehouse (1) Describe the safety measures you will utilize in transporting waste to your warehouse (e.g., fully secured and away from the passengercompartment).

(2) Please expand your instructions to personnel to include transportation procedures to ensure that they are in accordance

0 Larsen Warehousing 5 with Department of Transportation (D0T) regulations. As a minimum, the instructions should address labeling containers, securing containers within vehicles, placarding vehicles, and surveying radiation levels.

k. Area Survey Program (1) Please modify your procedures to analyze wipe tests with an instrument, other than a GM survey meter, that is sufficiently sensitive to detect activities of iodine-125 in the range of 200 dpm per 100cm2 (2) Define your decontamination, action level equal to normal background levels. We recommend a level of 200 dpm per 100cm2 for wipe test results.

1. Inventory Control System Please submit a description of the procedure (s) you will use to ensure that material will remain in the warehouse only on a first-in, first-out concept,

m. Decommissioning Please discuss your decomissioning plans in the event you choose to release the site for unrestricted use. Your discussion should include contamination limits in accordance with the enclosed guide and the provisions you will employ to ensure that you will have the funding and personnel available to carry out the decomissioning.

2. For Storage of Gauges Containing Radioactive Material

a. Submit responses to information requested in Items 1.d., i.e.,

1.g.(1)., 1.g.(2), 1.g.(4), 1.g.(8), 1.g.(9), and 1.h.

b. Describe your procedures for receipt of gauging devices to ensure devices have shutters locked in the closed position and exposure levels are in accordance with manufacturer's labeling.

c. Indicate the manufacturer (s) from whom the sources will be received.

Specify that the manufacturer's packaging, labeling, and shielding will not be altered and that redistributed sources will be accompanied by the manufacturer-supplied package insert, leaflet, brochure or other document that provides radiation safety instructions for handling and storing the sources.

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d. Submit procedures you will utilize for transferring or redistributing gauges to authorized recipients (e.g., surveys for leak test and exposure readings prior to transfer).

e. Submit information as requested in Item 1.j. of this letter for any proposed transport of gauges from your warehouse to authorized recipients.

If you have any questions or require clarification on any of the information stated above, you may contact us at (312) 790-5625.

We will continue our review of your application upon receipt of this information. Please reply in duplicate, within 30 days, and refer to Control Number 80928.

Sincerely, Original Signed by Bruce S. Mallett, Ph.D., Chief Materials Licensing Section

Enclosures:

1. 10 CFR 51 and 20

2. NUREG-0767 cc w/ enclosures:

Standard Nuclear Consultants bec w/o enclosures:

R. Lickus, RIII RIII N'

Mallett/jl 5/39 /86