ML20203M973
| ML20203M973 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1985 |
| From: | Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | St Mary F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20203M946 | List: |
| References | |
| NUDOCS 8605020322 | |
| Download: ML20203M973 (4) | |
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MAY 17 885 MEMORANDUM FOR: Francis A. St. Mary, Project Manager Material Licensing Branch FROM: Bruce S. Mallett, Ph.D., Chief i Materials Licensing Section
SUBJECT:
R.M. Wester and Associates, Inc., Application for a New License as a Waste Broker As discussed with John Hickey and you in recent telephone conversations, we have. received an application from R.M. Wester and Associates, Inc. to obtain a license for the following: '
- 1. Repackaging of waste including compaction from customers for transfer to licensed land burial facilities. )
- 2. Decay-in-storage of waste for disposal as nonradioactive material. '
- 3. Collecting and storing of waste from customers for transfer to licensed land burial facilities.
We have reviewed the application and plan to request information and/or a clarification of the following items:
- 1. Name and qualifications of assistant RS0 if different than E.J. Olgivie, II.
- 2. Training program for lab techs, drivers, waste collectors, compactor -
operators, warehouseman.
- 3. List of radiation protection instruments and calibration methods.
- 4. Personnel Monitorfrg
- a. Individual responsible for assigning devices
- b. Bioassays
- 1. Describe how action levels based upon air measurements, as proposed, relate to level measured (e.g., if for H3, urinary levels).
- 2. Modify program to include baseline data.-
l 8605020322 860313 REG 3 LIC30 l PDR '
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- 5. Facilities
- a. Description of site incluo..ig 2. 3 cent population centers, routes of access for avecuation and emergency equipment, means of limiting potential release to adjacent populations.
- b. Description of areas where various processes (e.g., repackaging) will be performed.
- c. Description of ventilation system.
- d. Description of systems to prevent unauthorized access or removal of material and for fire protection sufficient to limit off-site hazard (e.g., adequate distance between sprinklers, adequate number of extinguishers, operation check of system).
- e. Modification of Section 3 of Manual, Item 2 to not allow variances to 20.105 limits for unrestricted areas. If need variance, provide radiation levels needed, keyed to areas, administrative controls to maintain levels less than 500 mrem per year and ALARA considerations.
- 6. Monitoring Program
- a. Description of methods and frequency for sampling of air and water effluents.
- b. Specification of name of individual responsible.
- 7. Instruction To Customers a.
Clarification of whether or not Section 15 of manual contains these instrucitons. If not, need instruction for packaging.
- b. Modification of instructions to include instructions for following appropriate sections of regulations (e.g., Part 20, Section 20.311 onmanifestos).
- c. Instructions only reference parts of Section 20.311 referring to packaing. Modify to include instructions to customers when transferring to R.M. Wester as waste collector.
- d. Description of quality control program for ensuring waste appropriately packaged and labeled at storage facility and customers facilities or points of collection.
- 8. Specification of inventory control system.
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- 9. Compaction
- a. Description of method to monitor breathing zone and exhaust stream.
Filtration system must be capable of handling type of radionuclides in waste to be compacted (e.g., iodines).
- b. Description of system for monitoring filter blockage.
- c. Specification of surveys (type and frequency) for contamination control around unit.
- d. Specification of operator procedures to include:
- 1. protective clothing
- 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. Description of type of compactor.
- f. Description of type of waste to be compacted.
- 10. Specification of length of time waste will be stored at facility prior to going to waste site.
- 11. For decay-in-storage, should commit to holding for minimum of 10 half lives unless microcurie amounts of I-125 from in vitro labs.
- 12. Description of posting, security, for trucks being loaded or unloaded outside warehouse and during transport to waste burial site.
The licensee is willing to reduce the scope of the request to a total possession limit of 50 curier in order to meet categorical exclusion number 14(xii) in Section 51.22 of 10 CFR Part 51 for the repackaging and collection portion of the request.
Since this type of application review has not been performed previously in Region III, we ask NMSS for assistance. We would like to have an individual who has reviewed these types of applications provide input to Region III in the form of modification of the items we propose to address and/or additional items. I have enclosed a copy of the application for your use.
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4 As discussed on the telephone, the applicant is in a financial bind and will accept any portion of the license that we can authorize in a short period of time. I would like to send a deficiency letter to R.M. Wester by the end of May. Please let me know if NMSS cannot provide a response to Region III by that point in time.
Sincerely, 3 Original Signed By Bruce S. Mallett, Ph.D., Chief Materials Licensing Section cc: W. Axelson, RIII J. Hickey, NMSS 1
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Mallett/cm 05/15/85