ML20004E861
| ML20004E861 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 06/04/1981 |
| From: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Voth M EMVUCCM |
| Shared Package | |
| ML20004E862 | List: |
| References | |
| RTR-REGGD-08.012, RTR-REGGD-8.012 NUDOCS 8106150529 | |
| Download: ML20004E861 (2) | |
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WASHINGTON, D. C. 20555 JUN - 4 581 f $. J Docket No.70-687 Materials License No. SNM-639 21 JUN 0 81981* 9 Amendment No. 6 2 vos,,ce yton
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Union Carbide Corporation Medical Products Division ATTN: Mr. Marcus H. Voth Manager, Nuclear Operation P. O. Box 324 Tuxedo, New York 10987 Gentlemen:
Pursuant to Title 10, Code of Federal Regulations, Part 70, Special Nuclear Material License No. SNM-639 is hereby amended to authorize the use of the surface contamination limits for alpha radiation in controlled areas as presented in your letter, dated December 5, 1980 (page 4). Accordingly, those sections of your letter dated April 28, 1969 and November 5, 1970, pertaining to alpha contamination are superseded and Item 9 of License No. SNM-639 is modified to read as follows:
"9.
The sper.ial nuclear material is for use in accordance with the statements, representations and conditions specified in the licensee's applications dated April 23 2
and May 21, 1969; November 5,1970; February 8, June 13, June 29, and A'igust 13, 1973; May 28, 1974; February 11, 1975; August 12,1976; May 3, October 13, and November 17, 1978; June 2, November 26, and December 5,1980, excepting that part of the December 5,1980 letter requesting an exemption from 10 CFR~ Section 70.24."
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All other conditions of this license shall remain the same.
With respect to your request for exemption from 10 CFR Section 70.24(a) for dry oxide or assay sa.nples, we do not believe that you have provided adequate basis for the exemption and, therefore, this request is denied.
Exemptions from the criticality alarm requirements nonnally are based on physical factors that praclude the credibility of a criticality accident, under normal or accident coaditions, such as geometry or tne physical form of the material; or, in the case of your exemption for special nuclear material in the hot cells, tnat C.
8106150 Fag 1
Union Carbide Corporation JUN - 4 1991 the event could occur only in heavily si.ielded circumstances thus providing adequate protection of personc.el.
(In tne latter case, other means must be in place to provide information that an accidental criticality has occurred.)
Your present request appears to be based on administrative controls designed to limit the accumulation of dry oxide at any one location. We agree that accidental criticality is unlikely and that two independent contingencies must occur before such an event is possible, i.e., failure of administrative controls over the accumulation of material in one location and introduction of moderation. However, in the latter instance, you appear to have considered only flooding and have not considered other possible sources of water, such as fire fighting, broken water pipes, etc. There is no evidence that the quantities of material or the geometry of the containers would preclude accidental criticality in the event of introduction of moderation.
Enclosed are copies of Regulatory Guides 8.5 and 8.12.
Installation of criticality accident alarm systens should be in t.ccordance with the guides, each of which references national ANSI standards; if you choose to use different methods to meet regulatory requirements for criticality accident alarm systems, please provide a description of the system and justification for its adequacy.
FOR THE NUCLEAR REGULATORY COMMISSION
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~q Leland C. Rouse, Chief Advanced Fuel and Spent Fuel,
Licensing Branch Division of Fuel Cycle and Material Safety
Enclosures:
Regulatory Guides 8.5 and 8.12 e
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