ML20246N071

Safety Evaluation Supporting Renewed License SNM-1405

ML20246N071
Person / Time
Site:	07001359
Issue date:	05/11/1989
From:	Bidinger G, Mccaughey D, Pennington W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20246N062	List: ML20246N057 ML20246N067 ML20246N071 ML20246N078 ML20246N092
References
NUDOCS 8905190339
Download: ML20246N071 (8)

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- It.Ay 1 1 1989 DOCKET N0: 70-1359 L,

LICENSEE: IRT Corporation (IRT)

SUBJECT:

SAFETY EVALUATION REPORT, LICENSE RENEWAL APPLICATION DATED SEPTEMBER 30, 1988, AND SUPPLEMENTS DATED OCTOBER 21, 1988, AND FEBRUARY 13 and 28, 1989.

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I. BACKGROUND By application dated September 30, 1988, (submitted by letter dated October 14, 1988), IRT Corporation requested renewal of Materials License No. SNM-1405. Since the application was filed more than 30 days prior to i

the license expiration date of December 31, 1988, the existing license has remained in effect in accordance with the renewal provisions of 10 CFR 70.33(b). Supplemental information was submitted by letters dated I'

l October 21, 1988, and February 13 and 28, 1989.

l l License History The original license was issued August 31, 1973, to Intelcom Industries, Inc., (III) for, possession and use of approximately 1,300 grams of uranium and plutonium in encapsulated form. The authorized material, used for testing detection systems manufactured by III, was increased by amendment l

in 1974 when III initiated construction of a subcritical assembly, the Cf-255 Multiplier (CFX). Subsequently, the licensee was authorized to of 0 constructtheCFXwithk'ifcense.99andtochangethenameonthelicense to IRT Corporation. The was amended to reflect these changes and to authorize the use of special nuclear material (SNM) for the development of non-destructive inspection and assay equipment as well as for research and development.

The license was renewed in 1982 authorizing use of SNM at three sites, the laboratories at 7650'and 7070 Convoy Court, San Diego, and at the Linear Accelerator Facility which was in a structure occupied jointly by IRT and General Atomic Company on John J. Hopkins Drive, San Diego, California.

Subsequently, the license was amended to authorize an increase of material and to delete the site at 7070 Convoy Court as a place of use. In 1984, the license was revised to authorize activities at 3030 Callan Road, San Diego, authorize possession and use of Pu-242, replace the Radiation Safety Officer, and change the corporate address. Concurrently, the staff included an additional condition to increase area radiation monitoring. Since the revision, the license was amended to include 8221 Arjons Road as an authorized place of use, to change and reduce the possession limits, to delete the Convoy Court and John J. Hopkins Drive facilities as places of use, and to authorize the implementation of the Physical Security Plan.

More recently, the license was amended to authorize the storage of mixed oxide fuel rods at 3030 Callan Road and to delete the Physical Security )

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1 By letter dated May 21, 1987, IRT submitted a renewal application. By letter dated November 9, 1987, staff requested additional information regarding the application. However, by letter dated May 26, 1988, IRT informed staff that the renewal application was being revised for storage only. Accordingly, staff. ceased action on the renewal application and extended the expiration date to December 31,.1988. By letter dated October 14, 1988, IRT submitted the current renewal application dated September 30, 1988, for the storage only of licensed material.

II. SCOPE OF REVIEW The safety review of IRT's renewal request includes the application dated September 30, 1988, supplements dated October 21, 1988, and February 13 and 28, 1989, and the licensee's compliance history. The additional information requested by staff's letter dated November 9, 1987, is provided in the application.

The licensee has requested that the license be renewed for the storage only of SNM. Therefore, the topics of this review include an evaluation of the licensee's organization, radiation and criticality safety programs, as well as procedures applicable to the storage and preparation for transport of non-dispensable SNM. The renewal application and licensee's compliance history were discussed with Region V staff.

III. DISCUSSION IRT's renewal application demonstrates that there are adequate storage.

provisions and technical staff with qualifications to administer effective radiological and nuclear safety programs. The following sections contain a description of the licensee's requested material, organization, safety programs, and storage facilities, along with additional license conditions developed by the NRC staff.

IRT has re-quested the following licensed material for storage only:

Material Form Quantity A. Plutonium enriched to A. Sealed sources A. 1 gram Pu 98 w/o Pu-239 B. Plutonium enriched to B. PuBe neutron sources B. I gram Pu 80 w/o Pu-238 C. Plutonium enriched to C. Mixed oxide fuel rods C. 365 grams Pu 75 w/o Pu-239 as sealed sources D. Uranium enriched to D. Mixed oxide fuel rods D. 277 grams U-235 10 w/o U-235 as sealed sources E. Uranium enriched to E. Sealed sources E. 35 grams U-235 1 20 w/o U-235 i

F. Uranium enriched to F. Non-dispersible solid F. 46 grams U-235 10 w/o U-235 sintered fuel pellets

[; .. O ,o IRT, Corporation (IRT) 3 MAY 111989 The material described in Items A., B., E., and F. will be stored at either 3030 Callan Road or the Manufacturing Facility located at 8221 Arjons Road, Suite F, San Diego, California. The material described in Items C. and D. will be stored at the Arjons Road Manufacturing Facility.

In order to clarify the authorized use of the licensed material and to exclude demonstrative information from the license, the staff recommends the following conditions:

Authorized use: For storage only in accordaace with the statements, representations, and conditions specified in the licensee's application dated September 30, 1988 (transmitted by letter dated October 14,1988), and supplements dated October 21, 1988, and February 13 and 28,1989. Pages 9 through 20 in Chapter 4, pages 47 through 55 and instrument manufacturers and model numbers in Chapter 8, and Appendices I and II of the September 30, 1988, application are not incorporated into the license.

Authorized place of use: Items A., B., E., and F. shall be stored at the licensee's existing facilities located at 3030 Callan Road or 8221 Arjons Road, Suite F, San Diego, California. Items C. and D.

shall be stored at the licensee's facility located at 8221 Arjons Road, Suite F, San Diego, California.

Organization and Administration The radiation and health physics group reports to the Vice President of Finance and Administration. Managers of the operating groups and divisions report directly to the IRT President. Line managers have responsibility for the establishment and administration of safe operations and are aided by independent review committees appointed by the President. Radiation and criticality safety are managed by the Radiation Safety Officer (RS0), who is also a member of the Radiation Safety Committee (RSC). The health physics staff reports to the RSO.

The RSC composed of at least five members is guided by a policy committed to ALARA. The policy commitment to ALARA is achieved through audits, review of procedures, and review of storage and transport preparation activities. The RSC is responsible for reviewing and establishing and procedures, investigating significant incidents, and reconnending remedial actions to management. In addition, the RSC ensures that unsafe practices and items of non-compliance are corrected prior to continuance of any activity.

The RSO is responsible for the review and inspection of procedures in all aspects of radiation and criticality safety. In addition, the RSO and Health Physicist are jointly responsible for maintaining a file of required records, investigating design criteria, and taking charge of all radiological emergencies and subsequent remedial action.

The Health Physicist is responsible for investigating incidents involving radioactive materials, determining corrective actions, and reporting findings to the RSO and RSC. The Health ihysicist enforces the policies of the R50 and requirements of Radiation Work Authorizations. Furthermore, the Health Physicist is authorized to suspend an activity that violates these policies or requirements.

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j Qualifications The minimum education and experience requirements for the RSO include an l accredited college degree in physics, biological sciences, engineering, or other relevant fields and 3 years applicable experience involving radioactive materials, radiation sources, special nuclear material, and 3 radiation safety, or a minimum of 6' years applicable experience involving {

radioactive materials, radiation machines, special nuclear material, radiation safety, and administrative practices in the radiation safety field.

The Health Physicist is required to have a minimum of 3 years experience involving radioactive materials, radiation producing machines, special nuclear material, and radiation safety.

Members of the RSC must have expertise in their fields. Technical members are required to have, as a minimum, an accredited college degree in their specialty and 2 years related experience. Non-technical members must have at least 5 years experience in their field of specialty.

The resumes amply demonstrate the licensee's, criteria to fill with qualified individuals the positions of R50, Health Physicist, and the RSC membership.

Procedures An activity involving the storage or preparation of licensed material for transport will be performed in accordance with a Radiation Work Authorization (RWA). The RWA describes the proposed activity, procedures, equipment, and radiological and criticality safety features. In addition to the descrip-tive information, the RWA includes the names and signatures of involved personnel and identifies those responsible for the material. Prior to 1 commencement of the activity, the RWA must be reviewed and approved by the RSO and RSC. Once a RWA is issued, no changes or renewals are granted without RSO approval. Changes concerning the quantity of licensed material must be reviewed and approved by the RSC.

Audits The licensee has committed to perform annual audits of the radiation and criticality safety programs. The R$0 shall perform the audit and submit a report to the RSC for review. The RSC provides the report and their comments and recomr.endations to the appropriate divisional Vice President and to the company President.

Training Training of personnel is through IRT's " Radiological Safety Orientation Course," which is supplemented by handouts and is terminated by examination.

Retraining is conducted annually. The course outline supplied by the licensee demonstrates a comprehensive program covering a broad spectrum of radiation physics and safety.

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- O( h IRT Corporation.(IRT) 5 MAY 11 1989 Calibration of Instruments The licensee has a range of radiation detection and measurement instruments g which are listed in the renewal application. With the exception of the semiannual calibration.of G-M survey meters, IRT has committed to calibrate radiation detection instruments on a quarterly basis. Instrumentation utilized for the assay of smear samples is calibrated weekly.

Records The licensee will maintain documents produced for.the radiation and criticality safety program for 3 years. However, the licensee has not committed to retain records in accordance with the requirements of 10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal."

Therefore, staff recommends the following condition:

Notwithstanding the retention limit specified in Section 5.9 of the application, the licensee shall maintain records of radiation surveys and monitoring, personnel exposures, and the disposal of licensed materials in accordance with 10 CFR 20.401.

Radiation Safety The following is a brief description of the.IRT radiation safety program as it pertains to the storage and preparation for transport of licensed -

material:

1. Access Control Access to the storage facilities is controlled with locked doors and motion detectors. When preparing licensed material for transport, the licensee may post and control access to other areas with fences, ropes, or other barriers for the purpose of radiation safety.

2. Radiation Surveys The frequency and types of surveys are determined by the Health Physicist, RSO, and RSC. The basis for surveys is determined by the type of activity and hazards involved.

3. Personnel Monitoring Film badges, pocket dosimeters, and finger ring dosimeters are used for detection of external exposure The film badges which measure X-ray, gamma, beta, and neutron exposures are changed on a monthly basis. The badges and finger dosimeters are commercially processed, and exposures are reported to the licensee. Personnel monitoring devices are provided in accordance with the requirements of 10 CFR Part 20.

4. Sealed Sources The licensee will leak test sealed and alpha sources every 6 months and 3 months, respectively. However, the licensee has not provided an action level or commitment to remove leaking sources from use.

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IRT Corporation (IRT) 6 Therefore, staff recommends the following conditions to specify 'q criteria for leak testing of plutonium, uranium, and plutonium alpha sources;and to relieve the licensee from leak testing stored sources:

Sealed plutonium sources shall be subject to the leak testing and actions specified in the enclosed " License Condition for Leak Testing Sealed Plutonium Sources," dated August 1987.

Sealed uranium sources shall be subject to the leak testing and actions specified in the enclosed " License Condition for Leak Testing Sealed Uranium Sources," dated August 1987.-

Plutonium alpha sources shall be subject to the leak testing and actions specified in the enclosed " License Condition for Plutonium Alpha Sources," dated August 1987.

Nuclear Criticality Safety l 1. Arjons Facility Storage l

E The Arjons Facility storage will be used for storage only of licensed-material. This is a vault-type storage room measuring 36-inches deep, 54-inches wide, and 84-inches high. The rear wall is a 4-inch thick reinforced concrete wall which is part of the existing building. The l side and front walls are concrete filled 8-inch thick blocks. The i ceiling is a 1/4-inch steel plate covered with 2 inches of concrete.

The door is made of steel. The Pu/U mixed oxide fuel rods will be stored inside two 3-inch diameter steel pipes. The pipes will be capped at both ends. These pipes will stand on end, one in each rear corner of the vault secured to the wall by clamps. A steel cabinet positioned between the two pipes will store the remainder of licensed material.

Storage of the licensed material in the vault is based on limited mass, limited volume, and forced separation of unmoderated SNM units (H/X 1 2) and on a surface density and a maximum density per square foot for moderated units. Considering the limited quantity of the SNM contained in the two 3-inch diameter pipes separated by approximately 49-inches edge-to-edge, subcriticality is assured. .The other 83 grams of licensed material is also a very subcritical quantity of SNM.

2. 3030 Callan Road Storage Vault The Callan Road storage vault will be used for the storage only of i 2 grams of plutonium in the form of sealed sources, 35 grams of U-235 as sealed sources, and 46 grams of U-235 in the form of non-dispersible solid sintered fuel pellets.

The walls and ceiling are 8-inch thick reinforced concrete block. The room is 6-feet deep, 6-feet wide, and 8-feet high. The SNM will be stored in metal cabinets 18-inches deep, 36-inches wide, and 72-inches high. The 33 grams of SNM authorized for storage in this facility is considerably less than a critical mass as defined in 10 CFR 150.11.

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, .3. 10 CFR 70.24 Exemption H

In Section 3.3 of the application,'the licensee requests an exemption i, from the monitoring requirements.of 10 CFR 70.24. Because the SNM.

"'. will be in storage only, there is a sound basis for granting thez licensee an exemption from the requirements of:10 CFR 70.24. This b ,  ! exemption is authorized by law .and wil1 ~ nc' : endanger life or property or:the common defense and security and is otherwise in the public l- interest. Therefore, the following license condition.is recommended:

ll The licensee is hereby exempted from the requirements of 10 CFR 70.24,. insofar as this. requirement applies to materials' possessed.

L' under this license.

Effluent' Control.

Liquid waste as a result'of decontamination or cleanup is' discharged.to the sanitary sewerage system in accordance with 10 CFR 20. 403.

The solid waste generated by decontamination activities is minimal.

Accumulated liquid,'not' meeting 10 CFR 20.303 requirements, and solid wastes are packaged.and' transported in accordance with DOT regulations to.a licensed facility for processing and disposal.

Because the=licens'ed material is non-dispensable and will..be used for storage only, gaseous effluents aid airborne radioactivity will not likely occur under~ normal conditions.

Environmental Impact In accordance with 10 CFR 51.21, the staff has' prepared an assessment of

environmental impacts resulting from the storage of the licensed material.

The Environmental Assessment was prepared and issued on February 22, 1989.

This assessment supports a Finding ~of No~Significant Impact which was published in the Federal Register on March.1, 1989.

Emergency Planning Because of the physical forms and storage conditions of the ricensed material, the staff has determined that a Radiological Contingency Plan is not required. Further, other activities at IRT should not pose a significant hazard to the material. In the event of a radiological emergency, the RSO and Health Physicist are jointly responsible for directing the licensee's response and instituting remedial actions.as provided by general emergency procedures.

IV. COMPLIANCE HISTORY Since the license was renewed, Region V has conducted three safety inspections of IRT operations. During the inspections, two violations were identified regarding the completion of annual audits and refresher training.

These items of non-compliance were primarily of an administrative nature and had no adverse effect on personnel or the general public. The licensee has taken actions to correct the identified violations.

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• U V 1 IS O IRT Corporation (IRT) 8 V. DECOMMISSIONING The application provides a decommissioning plan with estimated costs.

The licensee also states that IRT is financially qualified for any decontamination of authorized places of use.

The licensee has committed to release facilities and equipment for unrestricted use in accordance with NRC decontamination guidelines.

To update this guidance, the following condition is recommended:

Prior to the release of facilities and equipment for unrestricted use, the facilities and equipment shall be decontaminated in accordance with the enclosed, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated August 1987.

VI. CONCLUSION AND RECOMMENDATION Upon completion of the safety review of the licensee's application and discussion with the Region V Inspector regarding the licensee's compliance record, the staff concludes that the licensee has the necessary storage provisions and technical staff to administer effective radiation and criticality safety programs. Conformance by the licensee to their proposed conditions as well as to those establishE by the IMUF staff, should ensure a safe operation and a quick detection of unfavorable conditions, resulting in corrective actions being taken.

Based on this conclusion and the above discussion, it is recommended that the license be renewed for a 5 year period in accordance with the application and subject to the conditions developed by the staff. The Region V staff has no objections to renewing the license.

M p aHT Sffdnaged by David A. McCaughey W. Scott Pennington Uranium Feel Section Uranium Fuel Section Fuel Cycle Safety Branch Fuel Cycle Safety Branch Division of Industrial and Division of Industrial and Medical Nuclear Safety, NMSS Medical Nuclear Safety, NMSS MW hy ~

Approved by:

George H. Bidinger, Section Leader Uranium Fuel Section OFC:IMUF: ,A :IMUF :IMUF IMUF:

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