ML20245B993
| ML20245B993 | |
| Person / Time | |
|---|---|
| Site: | 07000920 |
| Issue date: | 04/18/1989 |
| From: | Pennington W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20245B982 | List: |
| References | |
| NUDOCS 8904260426 | |
| Download: ML20245B993 (2) | |
Text
,
Troy, New York
SUBJECT:
SAFETY EVALUATION REPORT, LICENSE AMENDMENT APPLICATION DATED FEBRUARY 1,1989, RE DELETION OF PERSONNEL MONITORING CONDITIONS l Background By application dated February 22, 1988, RPI requested a license amendment to exempt their in-house dosimetry program from the requirements of 10 CFR 20.202(c). By letter dated June 24, 1988, staff requested additional information regarding the basis for the proposed exemption. Staff also stated that if RPI determined that personnel monitoring is not required to satisfy 10 CFR 20.202(a), no such exemption is required or necessary and that the license application should be revised accordingly.
By letter dated October 10, 1988, RPI withdrew the exemption request and indicated that personnel monitoring is not required to satisfy the provisions of 10 CFR 20.202(a). However, conditions remain in the license requiring a personnel monitoring program. In the subject application, RPI has requested the deletion of these conditions.
Discussion On February 12, 1988, new 10 CFR 20.202(c) defined accredited dosimetry requirements for personnel described in 10 CFR 20.202(a). This new regulation stipulates that all dosimetry required by 10 CFR 20.202(a) or by license conditions, except direct and indirect reading pocket ionization chambers and extremity dosimeters, must be provided by a dosimetry processor holding accred-itation from the National Voluntary Laboratory Accreditation Program (NVLAP).
Under the existing license, RPI is required to provide a personnel monitoring program for individuals who enter Radiation Installations. The dosimeters used in this program are processed by the licensee who lacks NVLAP accreditation. 1 The licensee has concluded that NVLAP accreditation would not be cost effective nor result in any reduction of exposures to RPI personnel and that all monitored individuals fall outside the population defined by 10 CFR 20.202(a). ;
RPI has requested that the conditions requiring the program be deleted. The licensee has stated that the personnel monitoring program will be maintained to determine that individuals routinely fall outside the population defined by 10 CFR 20.202(a). Moreover, RPI has committed to take specific actions in the event that a dosimeter shows an exposure which indicates that an individual should have been provided with monitoring equipment in accordance with 10 CFR 20.202(a). RPI will report this information to NRC and conduct an ,
investigation to determine whether the exposure actually occurred and to '
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Rensselaer Polytechnic Institute 2 evaluate whether the individual should have been required to wear an accredited dosimeter. If a dosimeter indicates an overexposure, the licensee will treat the situation as'if it had.been registered'in an accredited dosimeter and follow the requirements of 10 CFR Part 20. RPI will document the findings of.the investigations and maintain the documents for a period of at least 2 years.
However, because the NRC inspection frequency for the RPI facility may exceed
- 2. years, the staff believes that the retention period for these documents should be longer. Therefore, the staff recommends the following condition:
Documentation generated in accorc'ance with the licensee's application t dated February 1,1989, shall be naintained for a period of at least 5 years.
The staff believes that the licensee's personnel monitoring program is not--
required under 10 CFR 20.202(a) nor .su) ject to 20.202(c) and that specific actions will be taken if the dosimetry program shows that personnel monitoring is required to comply with 10 CFR 20.102(a).
j Conclusions / Recommendations Based on the discussion, the staff concludes that the current personnel monitoring program is required only by self-imposed license conditions and that deletion of these conditions will not adversely affect the protection provided for the health and safety of RPI personnel and the public or the environment. Therefore, staff recommends approval of the application subject to the above condition, and in accordance with 10 CFR 51.22(c)(14)(v), neither an Environmental Assessment nor an Environmental Impact Statement is warranted.
The amendment application was discussed with the Region I Principal Inspector.
He has no objections to amending the license.
WY W. Scott Pennington Uranium Fuel Section Fuel Cycle Safety Dranch Division of Industrial and Medical Nuclear Safety, NMSS Approved by: ME8di George H. B1dinger, Section Leader UFC:IMUF: ) IR(F I F- IMUF:
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UFFICIAL RECORD COPY