ML18206A586
| ML18206A586 | |
| Person / Time | |
|---|---|
| Site: | 03034588 |
| Issue date: | 05/14/2018 |
| From: | Cender L B NRC/RGN-III |
| To: | Hommel F St. Mary's Cement |
| References | |
| 602287 | |
| Download: ML18206A586 (5) | |
Text
NRC FORM 699 ,..,.,..,~..._,\
(03-2013) U.S. NUCLEAR REGULATORY COMMISSION CONVERSATION RECORD ..........
NAME OF PERSON($)
CONTACTED OR IN CONTACT WITH YOU Frederick Hommel E-MAIL ADDRESS frederick.hommel@vcimentos.com ORGANIZATION St. Marys Cement U.S. LLC LICENSE NUMBER(S) 21-32044-01 SUBJECT License Renewal Request -Additional Information Required.
SUMMARY
DOCKET NUMBER($)
030-34588 CONTROL NUMBER($)
602287 DATE OF CONTACT 05/14/2018 TELEPHONE NUMBER (231) 237-1367 DATE OF SIGNATURE 05/14/2018 TYPE OF CONVERSATION DE-MAIL [Z] TELEPHONE
[Z] INCOMING D OUTGOING You recently submitted additional information to support your request to renew your NRC license. After reviewing your response it appears that there are additional items that must be corrected or addressed.
Please see Page 2 of this document for further details. In accordance with IO CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Continue on Page 2 ACTION REQUIRED (IF ANY) Please submit your response by no later than May 31, 2018. Please feel free to contact me at 630-829-9712 or via email if you have any questions.
Continue on Page 3 NAME OF PERSON DOCUMENTING CONVERSATION Laura B. Cender SIGNATURE
)/1 t.( / Zol g NRC FORM 699 (03-2013)
Page 1 of 2 NRC FORM699 (03-2013)
SUMMARY
- (Continued from page 1) U.S. NUCLEAR REGULA TORY COMMISSION CONVERSATION RECORD (continued)
- 1. On March 20, 2018 you submitted a number of documents to the NRC regarding your license renewal request. Please provide a signed and dated cover letter referencing the documents submitted.
- 2. Please provide a second/separate signed and dated cover letter for your responses to the new items listed below. 3. In your response to Item 10.2 it appears that you will have your own survey meters at your facility.
If this is the case, you must commit to using instruments that meet the criteria described in Section 8.10.2 ofNUREG 1556 Vol. 4 Rev. 1 (box 2 on Page B-3) in addition to the third statement that you already committed to that confirms that survey instruments will be calibrated by an entity authorized by the NRC or an Agreement State. See attached.
- 4. In your response to Item 10.6 it appears that you selected the option for cases where the devices requested on the license do not meet the safety conditions specified in 8.10.6 ofNUREG 1556 Vol. 4 Rev. 1. The devices authorized on your license actually do meet these requirements, and you may instead select the first option associated with Item 10.6 of your application.
You may also request in the cover letter to withdraw the procedures submitted from being tied down on the license. See attached.
- 5. The information provided indicates that when switching out depleted sources with new replacements that the sources may be stored a temporary storage location on-site at your facility.
Please provide a facility diagram showing the location of this temporary storage area in relation to the plant overall. You have flexibility with how you provide this information, for example you may use a satellite map image to show your overall facility, and then use markings to add the storage location.
Drawings of the facility are also acceptable.
- 6. The reviewer noted a safety concern in your Radiation Safety Policy Section 2.2 "Cross Belt Analyzer is Threaten by Fire". In this section you describe a situation where the devices could be damaged by fire, but have not been damaged yet. As your procedure is currently written, in this situation the RSO would remove the sources from the device, seal them in a wax lined or water filled drum, and transport the sources to another secure area. With the information currently provided this procedure is unacceptable from a safety standpoint.
At a minimum the following information would need to be provided for the NRC to approve your use of such a procedure:
I. A record showing that the RSO has completed source retrieval training with the device vendor. 2. Your procedure should describe your use of a survey meter during the source removal, sealing of the source, and during/after transportation to a new area. 3. The individual performing this task would need to be wearing dosimetry, which you are not currently committed to having available for workers. 4. There should be more defined consideration of the RSO's safety regarding the fire risk. Fires can move very quickly and unpredictably, and as the procedure is written and with the time required to complete the source removal task, the RSO may be taking on unnecessary risk to their own health and safety. An individuals health and wellbeing is always more important than protecting a source from damage. The RSO can help mitigate risk to themselves, to the public, and to the sources by coordinating with the responding fire department and working with the gauge vendor if there is fire in the area near a nuclear device. Please confirm in your response that you will not implement or perform this emergency procedure without explicit NRC approval.
NRC FORM 699 (03-2013)
Page 2 of ?-
Item No. and Title Suggested Response Yes Alternative Procedures Attached 9. Facilities and We will ensure that the location of each fixed gauge D Equipment meets the criteria in Section 8.9, "Facilities and Equipment," in NUREG-1556, Volume 4, Revision 1, "Consolidated Guidance About Materials Licenses:
Program-Specific Guidance About Fixed Gauge Licenses." OR Provide confirmation that the fixed gauge is D secured to prevent unauthorized removal or access, and submit specific information demonstrating that the proposed conditions will not impact the safety or integrity of the source or device. Address any instances in which the proposed conditions exceed any conditions listed in the SSD reaistration certificate.
10.1 Radiation The applicant should not submit its audit program Need not be submitted with Safety Program -to the NRC for review during the licensing phase. application.
Audit Program The audit program will be reviewed during NRC inspections.
10.2 Radiation Surveys according to 10 CFR 20.1501 will be D D Safety Program -performed by a person specifically authorized by Radiation the NRC or an Agreement State to perform these Monitoring surveys. Instruments OR We will use instruments that meet the criteria in D Section 8.10.2, "Radiation Monitoring Instruments," in NUREG-1556, Volume 4, Revision 1, "Consolidated Guidance About Materials Licenses:
Program-Specific Guidance About Fixed Gauge Licenses" and one of the following two choices: Each radiation survey meter will be calibrated D by the manufacturer or other person authorized by the NRC or an Agreement State to perform radiation survey meter calibrations.
OR We will implement the model radiation survey D instrument calibration program in Appendix F, "Model Radiation Survey Instrument Calibration Program," in NUREG-1556, Volume 4, Revision 1, "Consolidated Guidance About Materials Licenses:
Program-Specific Guidance About Fixed Gauae Licenses." 8-3 Item No. and Title 10.3 Radiation Safety Program -Material Receipt and Accountability Suggested Response Physical inventories will be conducted every 6 months or at other intervals approved by the NRC to account for all sealed sources and devices received and possessed under the license. AND We will develop, implement, and maintain procedures for ensuring accountability of licensed materials at all times. 10.4 Radiation We will maintain, for inspection by the NRC, Safety Program -documentation demonstrating that unmonitored Occupational Dose individuals are not likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502(a).
OR We will provide and require the use of individual monitoring devices (dosimetry).
All personnel dosimeters that require processing to determine the radiation dose will be processed and evaluated by a NVLAP-aooroved processor.
Yes D D D Alternative Procedures Attached D LJ 10.5 Radiation Safety Program -Public Dose The applicant is not required to submit a response to the public dose section in a license application.
This matter will be examined during NRC insoections.
Need not be submitted with application.
10.6 Radiation Safety Program -Operating, Emergency, and Security Procedures If the gauge meets one or more of the safety conditions specified in the "Discussion" part of Section 8.10.6, "Operating, Emergency, and Security Procedures," in NUREG-1556, Volume 4, Revision 1, "Consolidated Guidance About Materials Licenses:
Program-Specific Guidance About Fixed Gauge Licenses," state the following:
Operating, emergency, and security procedures will be developed, implemented, maintained, and distributed and will meet the criteria in Section 8.10.6, "Operating, Emergency, and Security Procedures," in NUREG-1556, Volume 4, Revision 1. OR LJ If each gauge requested does not meet any of the D safety conditions specified in the "Discussion" part Procedures of Section 8.10.6, "Operating, Emergency, and Attached Security Procedures," in NUREG-1556, Volume 4, Revision 1, provide your operating, emergency, security, and lock-out (if aoolicable) procedures.
B-4 LJ Cender, Laura From: Sent: To:
Subject:
Attachments:
Hello Frederick, (ender, Laura Monday, May 14, 2018 11:34 AM 'Frederick Hommel' NRC License No. 21-32044-01 License Renewal -Conversation Record Conversation Record to St. Marys Cement U.S. LLC 5.14.2018.pdf; Application Items 10.2 & 10.6.pdf Thank you for taking time out of your day to discuss your pending NRC license renewal. As we discussed, attached is a record of our conversation.
Please let me know if you have any questions or concerns about what is described in the record. Additionally, attached is a partial copy of the NU REG 1556 Vol. 4 Rev. 1 Appendix B Licensing Application for your use regarding application Items 10.2 and 10.6. Please feel free to contact me at 630-829-9712 if you have any questions.
Thank you, Laura Laura (ender U.S. Nuclear Regulatory Commission Materials Licensing Branch E-mail: Laura.Cender@nrc.gov Phone: (630) 829-9712 Fax: 630-515-1078 1