IR 05000024/2030007
| ML20247G528 | |
| Person / Time | |
|---|---|
| Site: | 05000024, 03001179 |
| Issue date: | 04/16/1998 |
| From: | Prange B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| References | |
| 50-02430-07, 50-2430-7, 572648, NUDOCS 9805200274 | |
| Download: ML20247G528 (79) | |
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NY FORM 374 PAGE 1 oF fl PAGEs u.s. NUCLEAR REGULATORY Commission Amendment No. 39 MATERIALS LICENSE hhb Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93438), and Title 10, Code of Federal Regulations, Chapter I, Parts 30,31,32,33,34,35,36,39,40, and 70, and in reliance on statements and j representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and
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transfer byproduct, source, and special nuclear material designated below; to use such material for the purpose (s) and at the place (s) l
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d signated below; to deliver or transfer such material to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, Es Emended, and is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effIct and to any conditions specified below. '
Licensee in accordance with letter dated April 14,1998 1. University of Alaska Fairbanks 3. License number 50-02430-07 is amended in Office of Sponsored Programs p p.M E jis entirety to resd as follows:
2. 306 Signers Hall p' 4. Expiratio' n date September 30,1999 Fairbanks, Alaska 99775
h 5. Docket No. 030-01179 Reference No. O 6. Byproduct, source, and/or specialD 7. Chemical and/or physical form 8. aximum amount that licensee may nuclear material ,4 /
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p6siiess at any one time under this license (
A. As specified in Sectio _n A.. Any) 'S' 4 A. (As specified in Section 33.100, Schedule A:of 10 t iy ',;'y h.-j g [R f 33.11(b) of 10 CFR 33 for a CFR 33 @ A,7 ,$. \ EType B Broad Scope
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.ficense B. Cobalt-60 Q t CB.G Sealed . Q source /
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g Bg 15 millicuries y Chem,ical andg(ICNkisotope rg ys ygj C. Americium-241 /)# C. Sealed sources (Troxler A' C. 10 millicuries 4 3220 series sources).
i.; , L y .)y y D. Americium-241 D. Sealed neutron sources D. Not to exceed 110 millicuries (Troxler Dwg. A-100608 per source and 310 Rev. A or Model Nos.104A millicuries total !
or 105A) {
E. Hydrogen-3 E. Foils contained in electron E. 400 millicuries capture detectors F. Nickel-63 F. Foils contained in electron F. 120 millicuries capture detectors j
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G. Cesium-137 G. Sealed source (Mount G. 5 millicuries l Sorpris Model GG375)
H. Sealed neutron sources H. 1 curie i
H. Americium-241 (Mount Sorpris Model NN976)
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NRC FORM 374A U.s. NUCLEAR REGULATORY Commission PAGE 2 of 8 PAGEs
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License Numtnr l 50-02430-07
! MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 030-01179 Amendment No. 39 l
l 6. Byproduct, source, and/or special 7. Chemical and/or physical form 8. Maximum amount that licensee may nuclear material possess at any one time under this license 1. Americium-241 1. Sealed neutron sources 1. 50 millicuries (Campbell Pacific Nuclear n._
CPN-131)I5 bK b r7; f J. Cesium-137 J. (Sealed source (Camptiell J. 10 millicuries
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K. Gold-198 .r e.
s 7 Pacific Nuclear K. Solid . 40 millicuries CPN-131){[
L. Cesium-137 C's L. Sealed source (Isotope h Not to exceed 30 millicuries hj Q3 roducts Laboratories,s(
P A per source and 60 millicuries
/ t s.M3. . :Model X HEG-137-30)/;/ botal g[-[.,'.'g,-
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M. Hydrogen-3 M. Anyl
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M. (,50 millicuries b.ib AIniyek ~ l QlSV J A.D' 2 N. Carbon-14 W .?<'/ N." 2.5 millicuries 9. Authorized use n Wc% 7 ,' / ,o
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Research and developm. aent as defin' in 10 CFR 30.411n vit ;and in viv(o' studies in plants and animals.
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\, QV B. For calibration of the licens(ee's-survey instrumerits'only., Q %L_f,3J?~he'
<g %~ 4 l C. For use in Troxler Model 3220 Series depth moisture content gauges to measure properties of soils or construction materials. '-
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D. For use in Troxler Model 1255 or 1257 depth moisture probe gauges to measure properties of soils or construction materials.
E. cnd F. For use in gas chromatography for sample analysis.
G. and H. For storage only.
l. cnd J. For use in Campbell Pacific Nuclear Model MC Series gauges to measure properties of soils or construction materials.
K. Research and development as defined in 10 CFR 30.4.
L. For calibration of the licensee's survey instruments and for physics laboratory demonstrations conducted in accordance with the protocol submitted on May 1,1994.
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l NRC FoR2 374A u.s. NUCLEAR REGULATORY CoMM!ssioN PAGE 3 of 8 PAGEs
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N Licensa Number l 50-02430-07 MATERIALS LICENSE Docket or Reference Number
! 030-01179 SUPPLEMENTARY SHEET Amendment No. 39 l
l l 9. Authorized use (Continued)
l l M. Injection of tritiated water (prior to December 31,1996) into 60 female northern fur seals (Callorhinus l urstnus) and into 60 pups on the Pribilof Islands. Collection of blood and milk samples containing tritium from northern fur seals.
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N. For plant uptake studies at the Toolik Lake Field Station conducted in accordance with the protocol l
submitted with letters dated r,Y *June 30,1997)ahd Abr~il'14,l.1998.k a
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g CONDITIONS '
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10.A.
v O Licensed material shall be used only at the licensee's facilities located at:
v) r ',,6, If , p.. s .
(i) the Universitfof Alaska, Fairbanks Campus, Fairbanks, Alaska
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(ii)
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the Institute'of. Marine Science Seward, Marine Center, Seward, Alaska O
l Anirpal Research St.kt[ iion,7 Mild$tDYankovich Road, F F-- h- [,I I
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! (iii) the Large "
! (iv) the Valdez Crs'ek $ Mine'$k S~r$$$ ^ /0 th
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agroximately 50 miles east Of Cantwell/ Alaska d b$h [dj! t fIhk k @
(v)
the Reindeer Research' Station,tCantwell,JAlaskh[(e Q B.
Y, W R [f$% n '
Licensed material describd in Items A., CQhr,ough
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r M. may F.,}and also beI.used anywhere in the State of Alaska and'at' temporary job sites of the license l Commission maintains jurisdictiori for r.egulating the us'e'of licensed material under the following
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l conditions: if 7[ Y i
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1. Specified approvalis given by the University of Alaska, Fairbanks, Alaska, Radiation l Safety Committee.
l l 2. The licensee obtains written permission to use radioactive material at the proposed site
! from the appropriate authorities (or persons) who maintain administrative control over the property.
3. For licensed material described in item M., the licensee must possess a " Permit to Take Marine Mammals" issued by the U.S. Department of Commerce.
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C. Licensed material described in item K. may also be used at the Valdez Creek Mine approximately 50 miles east of Cantwell, Alaska, for gold-198 sluice box studies.
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L NRC FoRC 374A u.s. NUCLEAR REGULATORY Commission PAGE 4 of G PAGEs t
License Number 50-02430-07 Docket or Reference Number MATERIALS LICENSE SUPPLEMENTARY SHEET 030-01179 i
j Amendment No. 39
10. (Continued) l D. Hydrogen 3 and carbon 14 may be used at the Large Animal Research Station, Fairbanks, Alaska, as described in the application dated March 15,1993 for studies of the metabolism and body processes of reindeer / caribou (Rangifer tarandus) and muskoxen (Ovibos moschatus).
E. Licensed material described in items b. and F may be used aboard the RN Alpha Helix. !
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j F. Licensed material described.in item N. may be used at the Toolik Lake Field Station as described in the letters dated June 30,s1997 and April 14,1998 for plant uptake studies.
11. A.
V *O Licensed material shall only be used by, or under the supervision of, individuals designated by the
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Radiation Safety Committee, Dr. Ted DeLaca, Chairperson - '>
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Licensed material listed in item MF(the norther fur se' al' studies) shall be used by, or under the supervision of, Dr.: Daniel P. C'o,sta ogich ! E. Goept.' {
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cense is Dr.tSJsan Henrichs. S 12. The Radiation* Safety4Officer fo[r this {4 - K.,_,4 y.5' f4,/ ,
13. This license does not authorize: disposal'of licensed ~ material at' sea / JC h deb ~b[I h I(: l
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14. A. Sealed sources and'detectorldells shal be tested {kfr otleaYage and/or contamination at intervals not to exceed 6 months or 5t,soch ohiie'r'interUals#3sTpecified iay the certificate of registration referred to in l 10 CFR 32.210.
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B. Notwithstanding Paragraph A of t.his.C,onditiop, sealed' sources designed to emit alpha particles shall be tested for leakage and/or contamination'at intervals not to exceed 3 months. i
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, C. In the absence of a certificate from a transferor indicating that a leak test has been made within l
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6 months prior to the transfer, a sealed source or detector cell received from another person shall not i be put into use until tested.
D. Each sealed source fabricated by the licensee shall be inspected and tested for construction defects, leakage, and contamination prior to any use or transfer as a sealed source.
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NRC FORM 374A u.s. NUCLEAR REGULATORY CoMMISsloN PAGE 5 of 8 PAGEs
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Ucense Number 50-02430-07
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MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 030-01179 Amendment No. 39 l i
14. (Continued)
E. Sealed sources need not be leak tested if-(i) they contain only hydrogen-3; or (ii) they contain only a radioactive gas; or g p"
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(iii) the half-life of the isotop,e is 30 days or less; or sj l
& TJ (iv) they contain not more than 100 microcuries of beta and/or gamma emitting material or not more
- than 10 microcuries of alpha emitting material; or
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(v) they are not designed to emit alpha particles, are in storage, and are not being used. However, j when they are removed from storage,for.use or transferred to another person, and have not i
been tested within the require'd.le'ak test in,terval, they shall be tested before use or transfer. No sealed source or detector, cell shall be stored for a period of more,.than 10 years without being
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tested for ** le'akage and/or'contaminatidnN'iW [J l F.
QQ y -.4 l- lp The leak test shall be capable of detecting the presence of 0,005 microcurie of radioactive material y
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l on the test sample [if the tist reve'als the presence,of 0.005 microcurie or more of removable contamination, a report shalf be filed hith theSS/NucleaFRegulatory" Commission in accordance with 10 CFR 30(b)(2),'and the'so'urce shall be'. removed immediately from service and l decontaminated, repaire'dfor dispose'd of Wi'cIordancEwith Co'mrnission regulations. The report l shall be filed within 5 days'of the date the le'ak' test result is kiiown with the U.S. Nuclear Regulatory Commission, Region IV,611 Ryan Plaza Drive, Suite 4,00, Arlington, Texas 76011, ATTN: Director, Division of Nuclear Materials Safety. The report shall specify the source involved, the test results, and corrective action taken.
G. Tests for leakage and/or contamination shall be performed by the licensee or by other persons specifically licensed by the Commission or an Agreement State to perform such services.
15. Maintenance, repair, cleaning, replacement, and disposal of foils contained in detector cells shall be performed only by the device manufacturer or other persons specifically authorized by the Commission or an Agreement State to perform such services.
16. A. Detector cells containing a titanium tritide foil or a scandium tritide foil shall only be used in conjunction with a properly operating temperature control mechanism which prevents the foil temperature from exceeding that specified by the manufacturer and approved by U.S. Nuclear J Regulatory Commission.
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s NRC FORM 374A u.s. NUCLEAR REGULATORY Commission PAGE 6 of 8 PAGEs
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License Number 50-02430-07 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 030-01179 Amendment No. 39 l
l 16. (Continued)
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B. When in use, detector cells containing a titanium tritide foil or a scandium tritide foil shall be vented to the outside, unless the cells are used in a mobile laboratory situation in the field.
17. Licensed material shall not be used in or on human beings.
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! that have been administered licensed 18. materials Experimental animals, shall not be or the used for hurfian products from experimental animals,1 f consumption.
e 19. The licensee shall not use, licensed materialin field applications where activity is released except as O
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provided in 57 FR 38885," Appendix A and Appendix B of the application' dated March 15,1993, or as l described in letters dated! June 21,- 1995, June 10,1996 (two. letters), ancfJune 11,1996, facsimile dated l June 18,1996, and letters dated ' June'30,s1997 and April.1V1998. ()
l 4 Yk Mnaterial //9 p 20.PartThe licensee is authorized to transport 71," Packaging and Transportation of Radi only in accordance_wiith S
licen)
the provisions sed)6 of 10 CFR ac
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21. Pursuant to 10 CFR 20.106(b)[andJ0$FR ,
20.302, thdJicensee is;a'uthor
! material by incineration provided the gaseous effluent from incineration does not exceed the limits l specified for air in Appendix B, TatMg0.CER Part 205%/f Y
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% h OIh,h% 44 22. Sealed sources or detector cells containing licen* sed)Tiaterial shall nobe opened or sourc from source holders by the licensee. Y Zb .1 > LM l 23. The licensee shall conduct a physical inventory e0ery 6 months to account for all sources and/or devices received and possessed under the license.
24. In addition to the possession limits in item 8, the licensee shall further restrict the possession of unsealed licensed material to quantities less than 10,000 times the applicable limits in Appendix B of 10 CFR Part 30 as specified in 10 CFR 30.35(d).
25. The licensee shall maintain records of information related to decommissioning at the Radiation Safety Office at the Fairbanks Campus, Fairbanks, Alaska as specified in 10 CFR 30.35(g) until this license is terminated by the Commission.
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o NRC FORM 374A U.s. NUCLEAR REGULATORY Commission PAGE 7 of 8 PAGEs l
I. Licens9 Numtor 1 50-02430-07 Docket or Reference Number MATERIALS LICENSE SUPPLEMENTARY SHEET 030-01179 l
l Amendment No. 39 26. The licensee is authorized to hold radioactive material with a physical half-life of less than 65 days for decay-in-storage before disposal in ordinary trash provided: l A. Radioactive waste to be disposed of in this manner shall be held for decay a minimum of 10 half-lives. ,
B.
nP RI n Before disposal as ordinary trashThyprod'uct material sh'all be surveyed at the container surface with
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the appropriate meter set on~ltd m6st sensitive scale an'd'with.no interposed shielding to determine I that its radioactivity cannol b'e' distinguished from backgroun'df All radiation labels shall be removed l or obliterated. Q*" "Q M $ !
27. Each portable nuclear ga,uge shall have a lock or outer locked container' designed to prevent unauthorized or accidental removal of trie se'aled source from its shielded, poi tion. Thelauge or its container must be en not under the direct surveillance ~of an authorized user.
locked when in M transport;storageQw{$;\
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'f ' i { k l 28. The licensee may remove the source rod from Troxler or Campbell Pacific Nuclear Company gauges for the purpose application of cleanirig,)15,1993:
dated March ':Cd4 maintenance,
- of r%> pair of th'e gauge (s)'in w,A5'
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NRC FORM 374A u.s. NUCLEAR REGULA7oRY CoMMISsloN PAGE 8 of 8 PAGEs License Number 50-02430-07 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 030-01179 Amendment No. 39 29. Except as specifically provided otherwise in this license, the licensee shall conduct its program in accordance with the statements, representations, and procedures contained in the documents, including any enclosures, listed below. The U.S. Nuclear Regulatory Commission's regulations shall govern unless the statements, representations, and procedures in the licensee's application and correspondence are more restrictive than the regulations.
n A. Application dated March 15,1993[,14 p* R 'e cJ (f ,,
B. Letter dated June 3,1993 (~,V L C. Letter dated August 16,,1993 ,)-
D. Letter dated Decembers12,1993 E. Letter dated December 29,1993 O
F. Letter dated Februar ,7,1,994 f- #j_
G. Letter dated February 18,1994N /,
H. Letter dated May 171994 Letter dated Septeniber 16,1994.1{,<
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/' O J. Letter dated September 19,1994 ( t K.
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Letter dated June 21,1995 h [Mb%h j .
Letter dated June *10,1996 igried by Daniel Costs and MichaelGoebel=
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M. Letter dated June 10,1996lsignedtiy Susan Henrichs' f/.f/
N. 1996 's'ig^n'e'd 'b O. Letter Facsimile dated June 11f[18,19969 dated Jun'e 4;y[Mich'ael Gosbel, without enclosure c% 'pl&y6 P. Letter dated June 30,\1997 4 /MN *' N Cf Q. Letter dated April 14,1998 m
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R. Facsimile dated April 16,1998 v $. -
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T l- Q -Q 'i FOR THE U.S. NUCLEAR REGULATORY COMMISSION Date APR 1 6 1998 gy gyrg. M,wg Materials Branch Region IV, WCFO j
Walnut Creek, California 94596
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'% UNITED STATES e k NUCLEAR REGULATORY COMMISSION e
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REGION IV
l D ! Walnut Creek Field Office
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\ ,,,p # Walnut Creek, California 94596-5368 1450 Maria Lane, Suite 3o0
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! April 16,1998 University of Alaska Fairbanks l Office of Sponsored Programs ATTN: Dr. Susan Henrichs-l Radiation Safety Officer l 306 Signers Hall l Fairbanks, Alaska 99775
L SUBJECT: LICENSE AMENDMENT 4 f
l Please find enclosed License No. 50-02430-07. You should review this license carefully and be j sure that you understand all conditions. If you have any questions, you may contact the l reviewer who signed your license at (92.5) 975-0250.
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l NRC expects licensees to conduct their programs with meticulous attention to detail and a high standard of compliance. Because of the serious consequences to employees and the public '
which can result from failure to comply with NRC requirements, you must conduct your program
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involving radioactive materials in accordance with the conditions of your NRC license, l representations made in your license application, and NRC regulations. In particular, note that j you must:
l l 1. Operate in accordance with NRC regulations 10 CFR Part 19, " Notices, Instructions and Reports to Workers: Inspection and Investigations," 10 CFR Part 20, " Standards for Protection Against Radiation," and other applicable regulations.
2. Possess radioactive material only in the quantity and form indicated in your license.
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r 3. Use radioactive material only for the purpose (s) indicated in your license.
I 4. Notify NRC in writing of any change in mailing address (no fee required if the location of l radioactive material remains the same).
5. Request and obtain written NRC consent before transferring your license or any right thereunder, either voluntarily or involuntarily, directly or indirectly, through transfer of control e jour license to any person or entity. A transfer of control of your license includes not only a total change of ownership, but also a change in the controlling interest in your company whether it is a corporation, partnership, or other entity, in addition, appropriate license amendments must be requested and obtained for any other planned changes in your facility or program that are contrary to your license or contrary to representations made in your license application, as well as supplemental correspondence thereto, which are incorporated into your license. A license fee may be charged for the amendments if you are not in a fee-exempt category.
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University of Alaska Fairbanks -2-6. Maintain in a single document decommissioning records that have been certified for completeness and accuracy listing all the following items applicable to the license:
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Onsite areas designated or formerly designated as restricted areas as defined in 10 CFR 20.3(a)(14) or 20.1003.
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Onsite areas, other than restricted areas, where radioactive materials in
, quantities greatcr than amounts listed in Appendix C to 10 CFR 20.1001-20.2401 l have been used, possessed, or stored.
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Onsite areas, other than restricted areas, where spills or other unusual
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occurrences involving the spread of contamination in and around the facility, equipment, or site have occurred that required reporting pursuant to 10 CFR 30.50(b)(1) or (b)(4), including areas where subsequent cleanup procedures have removed the contamination.
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Specific locations and radionuclides contents of previous and current burial areas l within the site, excluding radioactive material with half-lives of 10 days or less, l depleted uranium used only for shielding or as penetrators in unused munitions,
- or sealed sources authorized for use at temporary job sites.
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Location and description of all contaminated equipment involved in licensed operations that is to remain onsite after license termination.
7. Submit a complete renewal application with proper fee, or termination request at least 30 days before the expiration date on your license. You will receive a reminder notice approximately 90 days before the expiration date. Possession of radioactive material after your license expires is a violation of NRC regulations.
8. Request termination of your license if you plan to permanently discontinue activities involving radioactive material.
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University of Alaska Fairbanks -3 You will be periodically inspected by NRC. Failure to conduct your program in accordance with NRC regulations, license conditions, and representations made in your license application and supplemental correspondence with NRC will result in enforcement action against you. This could include issuance of a notice of violation; imposition of a civil penalty; or an order suspending, modifying, or revoking your license as specified in the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG 1600.
Thank you for your cooperation.
Sincerely,
% 2tt7. fr y e Beth Sr. Health Physicist (Licensing)
Materials Branch Docket: 030-01179 License: 50-02430-07 .
Control: 572648
Enclosures:
As stated
REGION hhh 1. APPLICATION ATTACHED Applicant / Licensee: ALASKA. UNIVERSITY OF FAIRBANKS Received Date: 980415 Ic W W ., . .s.,
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Docket No: 3001179 Control No. 572648
/-- a License No.. 50-02430-07 r.,
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Action Type: Amendment Lc ._ h /_ _ N 2-hut Check No.
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3. COMMENTS b
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Signed ,
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Date !/ 11 - lL - n v
} B.LICENSEFEEMANAGEMENTBRANCH(Checkwhenmilestoneh ntgedp 1. Fee Category and Amount: b h[ F i k' k'
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2. Correct Fee Paid Application may be processed for.-
Amendment i "Jh*/
Renewal License 3. OTHER Si ned ae _f4;[
y <v W tai > is a re saben it f r-ome<,dment Mat was& an vorse aYmtica wm ap j n- em n o. V72 5~n. sa a na ael tee sheet,
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O , O School of Fisheries and Ocean Sciences
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,,a UNIVERSITY OF At^Sx^ FAIRBANKS P.O. Box 757220 Fairbanks, Alaska 99775 7220 April 14,1998 Ms. Deth Prange US Nuclear Regulatory Commission Region IV, Walnut Creek Field OfTice 1450 Maria Lane Walnut Creek, CA 94596
Dear Ms. Prange:
Please find enclosed the revised application for experiments invohing release of small amounts of 14C, to be conducted during summer,1998, at the Toolik Lake Field Station of the University of Alaska Fairbanks. I request an amendment to NRC License #50-02430-07 (Reference #030-01179) to allow these experiments. Attached is a letter from Dr. Reeburgh which answers the questions that you raised in an earlier review of the application, and, for reference, the original application. Also attached are copies ofletters from the UAF Radiation Safety Committee, which approved the experiment last year contingent on review and approval by the North Slope Borough and the Bureau of Land Management, and from Dr. Bob White, Director of the Institute of Arctic Biology, who is the UAF administrator responsible for the Toolik Field Station; and a permit from the Bureau of Land Management. A copy of the permit from the Nonh Slope Borough will be arriving under separate cover from Dr.
Reeburgh.
Please also note that the persons who will be involved in the experiment have been approved as Authorized Users by the University of Alaska Fairbanks Radiation Safety Committee. These individuals include Dr. Knute Nadclhoffer, Dr. Loretta C. Johnson, Dr. William S. Reeburgh, and Ms. Jennifer King. Ms. Kama Thicler has been approved as a Supervised User.
I will try to contact you by phone on Friday morning. After that, until May 1, I will be at sea aboard the R/V Alpha Helix. I can be reached there by e-mail (fyhelix@uaf.edu), but there is a lag of several days in response as e-mail is read only twice a week due to the cost of the satell;te link. Most general questions about Toolik facilities, the UAF Radiation Safety Program, etc., can be answered by Dr. Don Schell, fTdms1@uaf.edu or (907) 474-7978. I will leave a copy of the application materials with him. I will return to i uirbanks 5/1, but leave again 5/5, retuming from that research cruise about 5/23. For very specific questions about the experiment, Dr.
Reeburgh can be reached at reebergh@uci.edu or (714) 824-2986.
Dr. Reeburgh needs to get the approva! by July to be able to conduct his experiment, because winter comes in August. June woc!d be better. Unfortunately, the BLM 245 O'Neill * Phone (907) 474-7824 * FAX (907) 474-7204 * Internet: fysfos@ aurora alaska.edu
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I permitting was very time-consuming, and I was at fault for a delay here as well. We would very much appreciate it if this application could be reviewed as soon as possible.
Sincerely,
.z-6 4rt,s 4/%
Susan M. Henrichs Radiation Safety Officer -
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INSTITUTE or AncTic Brot.cor PO Box 757000 f (907)474-7640 g Fairbanks. Alaske 99775-7000 U.S.A. FAX: (907) 474-6967 l
l July 22,1997 I
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Ms. Beth Parge j
U.S. Nuclear Regulatory Commission j
Region IV, Walnut Creek Field Office 1450 Maria Lane .
Walnut Creek, California 94596
Dear Ms. Parge:
I have reviewed the procedures proposed by Dr. Reeburgh and his collaborators for an outside, contained radioisotope study using C-14. I do not believe the study will constitute more than a minimal release of C-14 to the atmosphere through plant respiration. Therefore, the study could be conducted at the Toolik Field Station on a location that is under the management of the Institute of Arctic Biology. The study would need to be reviewed by the BLM, North Slope Borough and the NRC to meet
, our requirements for approval.
Sincerely Robert G. White Director cc Dr. Ted DeLaca Dr. William Reeburgh ,
Radiation Safety Committee, UAF l
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. United States Department of the Interior
.k BUREAU OF LAND MANAGEMENT Northern Distnct office 1150 University Avenue Fairbanks, Alaska 99709-3899 IN REPLY RElIR To:
F-92279 2920.06 (020)
CERTIFIED - RETURN RECEllT REQUESTED l Dr. William S. Reeburgh 15 FEB 1998 l Department of Earth System Science University of California,Irvine 205 Physical Sciences Research Facility Irvine, California 92697-3100
Dear Dr. Reeburgh:
- Enclosed is your countersigned copy of permit F-92279 which authorizes your research site at I the Toolik Lake Field Station. It is important that you coordinate the actual site location with Mike Ables at the Institute of Arctic Biology.
Please be aware that only the activities authorized by this permit are those outlined in Exhibit A of the enclosed permit. Any deviations, additions, or changes in use must be pre-approved in
! writing by the Authorized Officer.
If you have questions or need clarification on anything please contact me at (907) 474-2310, Toll Free at 800-437-7021, or via e-mail at psalvato@ak.blm. gov.
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Sincerely,
/s/ Paul J. Salvatt.r.
Paul J. Salvatore
! Realty Specialist Dalton Management Unit Enclosure cc: Mike Ables UAF/IAB Susan Henrichs UAF l.
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PERMIT
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Permi:sion is hereby granted to William S. Reeburgh Permit Number Of Department of Earth System Science, University of California, Irvine F-92279 to use the following-described lands:
TOWNSHIP RANGE SECTION SUBDIVISION 9 south 11 east 29 metes and bounds Meridian: Umiat State: Alaska County: N/A Acres 0.01 l foi the purpose of see Exhibit A
! and subject to the following conditions :
l l 1. This permit is issued for the period specified below. It is revocable at the 9. Permittee shall pay the authorized officer, in advance, the lump sum of $ - -
discretion of the authonzed officer of the Bureau of Land Management, at any --- for the period of use authorized by this permit or $ 100.00, annually, as time upon notice, This permit is subject to valid adverse claims heretofore or rental or such other sum as may be required if a rental adjustment is made.
i hereafter acquired.
j 2. This permit is subject to all applicable provisions of the regulations (43 10. Use or occupancy of land under this permit shall commence within ---
l CFR 2920) which are made a part hereof. months from date hereof and shall be exercised at least ---- days each year.
l 3. This permit may not be assigned without prior approval of the authorized i 1 Permittee shall take all reasonable precautions to prevent and suppress I officer of the Bureau of Land Management. forest, brush, and grass fires and prevent pollution of waters on or in the l vicinity of the lands.
t 4. Permittee shall not enclose roads or trails commonly in public use. 12. Permittee shall not cut any timber on the lands or remove other resources from the land without prior written permission from the authorized officer.
Such permission may be conditioned by a requirement to pay fair market value for the timber or other resources.
t 5. Authorized representatives of the Department of the Interior, other Federal 13. Permittee agrees to have the serial number of this permit marked or i agencies, and State and local law officials shall at all times have the right to painted on each advertising display or other facility erected or maintained
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enter the premises on official business. under the authonty of such permit.
l 6. Permittee shall pay the United States for any damage to its property 14. His permit is subject to the provisions of Executive Order No.11246 of l resulting from the use. September 24,1965, as amended, which sets forth the Equal Opportunity I clauses. A copy of this order may be obtained from the signing officer.
, 7 Permittee shall notify the authorized officer of address change immediately. 15. Permittee acknowledges, by signing below, that he/she knows,
! understands and accepts the terms and conditions under which this permit is issued.
8. Permittee shall observe all Federal State, and local laws and regulations 16. Special con.fitions (attach additional sheets, if necessary)
l l applicable to the premises and to erection or maintenance of signs or See Exhibit 11
, advertising displays including the regulations for the protection of game birds and game animals, and shall keep the premises in a neat, orderly, and sanitary condition.
Permit issued for period
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(Perrmttee) V\
! From January 1.1998 d > / A# f I
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[CR Dalten Team Representative (Authorized Officer) /
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To December 31.1999 (Title) (Date)
- INSTRUCTIONS I 1. Submit, m dupheate, to any local office of the Bureau of Land Management havingjunsdiction of the lands.
l 2. Applications for land Use Permits will not be accepted unless a nouficauon of the availability of the land for non-BL.M use (Notice of Realty Acuon) has been published in I the Federal Register and for 3 weeks thereafter in a newspaper of general circulanon. This provision does not apply in those situauons where the publicauon of a tNotice of Realty Action) has been waived by the authorized officer.
i 3. If the annual rental exceeds $250 dollars per year; costs of processing the application must be paid by the applicant in advance.
4. The authonzed otficer may require addinonal informanon to process an application. Processing will be deferred until the required information is furnished by the apphcant.
The Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq ) requires us to mform you that:
Information is needed to process applicauon for land use authorizauons, pursuant to 43 Cf~R Secuan 29 0. Informanon shows if the applicant and proposed use meet the requirements of 43 CFR Section 2920.l. Applicant must respond before he/she can be granted an authonzauon to use public lands.
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O j Figure 1 Labeline / Sampline Chamber Schematic Plexiglas Flux Chamber 12" diameter by 18" tall All fittings penetrating i BucketInterior chamber have O-ring Q seals Mounting tlange for LICOR CO2Sensor Chamber - Bucket adapter, side (left) and top view (right). Welded stainless steel construction. Inner two rings form a 1.5" deep channel, which is filled with water for an airtight seal with the Plexiglas chamber between the 5 gallon bucket for containing soil core with plants.
Adapter flange fits snugly against sides of bucket. Water table provides airtight seal on flange. For experiments with low water level, closed-cell foam gasket on bottom of adapter seals with bucket lip.
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l Figure 2 Experimental Area Schematic Side View
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[ Stock tanks containing experimental buckets on table. Cooling water
___ from Toolik is pumped into stock tanks and drains back into lake.
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Hardware cloth perimeter to prevent Imp tmeable membrane covering ground squirrel access. Buried or timber or gravel dike framework, stapled to timber membrane framework. Bird-proof netting on top and above hardware cloth.
Top View
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Locking l l- Gate OOO 000 000 000 l
Timber framework for liner inside fenced perimeter.
Table with stock tanks containing experimental buckets.
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l i l L ___________________
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Exhibit B Pulse Labeling F-92279 l Additional Terms and Conditions l
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- This permit shall be contingent upon approval from the Nuclear Regulatory Commission and the
! University of Alaska-Fairbanks / Institute of Arctic Biology. The permit may be terminated if either of these parties fail to give their concurrence for the operation.
All structures will be painted so as to blend into the natural environment. All colors are to be pre approved by the Authorized Officer of BLM.
Precise geographic positions of all research sites associated with this authorization shall be submitted to the Authorized Officer. These locations can be noted by either Latitude and Longitude or Universal Transverse Mercator coordinates.
A summary of the previous field seasons activities shall be submitted to the Authorized Officer by December 31" of each year during the authorized period. The summary shall include the approximate number of times the site was visited, by how many people, and at what time periods. This summary shall also include any changes to the type of collection taking place and any proposed site additions.
A copy of all data acquired will be submitted to the Authorized Officer upon Permit expiration or 1enewal.
All operations must not impede rural residents from pursuing their traditional subsistence activities (ANILCA, PL 96-487).
Protection of Survey Monuments. The Holder shall protect all survey monuraents. Survey monuments include, but are not limited to, General Land Office and Bureau of Land Management Cadastral Survey Corners, reference corners, witness points, U.S. Coast and Geodetic benchmarks and triangulation stations, military control monuments, and recognizable civil (both public and private) survey monuments. In the event of obliteration or disturbance of any of the above, the Holder shall immediately report the incident, in writing, to the Authorized Officer and the respective installing agency, if known. Where General Land Office or Bureau of Land Management right-of-way monuments or references are obliterated during operations, the Holder shall secure the services of a registered land surveyor or a Bureau Cadastral surveyor to restore the disturbed monuments and references using surveying procedures found in the Manua.J of Surveyina Instmetions for the Survey of Public Lands of the United States, latest edition. If the Bureau Cadastral surveyors or other Federal surveyors are used to restore the disturbed survey monuments, the Holder shall be responsible for survey costs.
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Research General Stipulations Pulse labeling F-92279 All operations will be conducted in such a manner as not to cause damage or disturbance to any fish or wildlife and subsistence resources.
Holder shall prohibit the feeding of wildlife. Garbage or other potentially edible items which would attract wildlife shall be kept in covered containers while awaiting incineration.
All operations shall be conducted with due regard for good resource management and in such a manner as not to block any stream, or drainage system, or change the character or course of a stream, or cause the pollution or siltation of any stream or lake.
All activities shall be conducted so as to avoid or minimize disturbance to vegetation.
Cultural and Paleontological Resources. Any cultural or Paleontological resource (historic or prehistoric site or object) discovered by the holder, or any person working on his behalf, on ,
public or Federal land shall be immediately reponed to the authorized officer. Holder shall i
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suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the AO. An evaluation of the discovery will be made by the AO to determine appropriate actions to prevent the loss of significant cultural or scientific values. The Holder will be responsible for the cost of evaluation and any decision as to the proper mitigation measures will be made by the AO after consulting with the Holder.
All solid wastes shall be removed from the public lands to Alaska State DEC approved solid waste disposal facilit ies. Solid waste combustibles may be incir.erated. All non-combustible solid waste, including ash from incineration and fuel drums, shall be removed for approved disposal. There will be no burial of garbage or human wastes.
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O u F-92279 lh"tLd}LOS Pulse Labeh*ng at the o Deadhorse ooy Toolik Lake Field Station Pump Station 10 i
Mile 284.5 of the Dalton Highway
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BEAUFORT a.,conero;tn coue l Pump Station 40t i CHUKCHI BAR, tow SEA -
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JUNEAU 0 GULF OF ALASKA CDIAK ISLAND o 150 300 l i KitovdERS P. J. SALV4 TORE _
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O O UNIVERSITY OF CALIFORNIA,IRVINE alRKHEY * DAVI5 * RVDE * ID$ AN(iEGAS * RNHtSIDE * SAN DS000 * SAN HtANClKD sal (IA BARBARA * SANTA 0tOZ EARTH SYSTEM SCIENCE IRvlNE.CAlllORNIA 92697-3100 William s. Rechurgh 205 PilYSICAL SCIENCES RESEARCll FACIIIrY PIK)NE: 014) 8.'4-2986 FAX:0 14) 824-3256 Internet: REEBURGil@uci.edu February 9,1998 Prof. Susan Henrichs UAF Radiation Safety Officer I Institute of Marine Science University of Alaska Fairbanks Fairbanks, AK 99775-1080 Dear Susan.
Enclosed please find Authorized User Applications for Knute Nadelhoffer, Lomtta Johnson, and Kama Thieler. All am associated with the pulse labelling study we am proposing at Toolik Lake Station. This experiment was done in a growth chamber at MBL during Fall,1997, and all worked closely with George Kling during the experiment. The Nadelhoffer and Johnson applications am accompanied by letters from Andy Mattox, the MBL RSO.
We would like to include Nadelhoffer, Johnson, and Thieler in the NRC application at
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[/[h whatever user level the UAF Radiation Safety Committee considers appropriate. leanne Jablonski is no longer with the project, so she should not be included.
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I am FedExing a signed BLM permit application with a check for one year's rent to Paul g, i Salvatore today. I have asked him to mail you a copy of the completed permit to avoid a round of v i
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mail to California. I will call after you have returned from the Ocean Sciences Meeting and we can go through a check list for the NRC permit application. I think you have all of the pieces except l
- the BLM permit and the enclosed modifications to the Authorized User list.
l Best Regards,
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William S. Reeburgh I
Professor l
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Responses to Beth Prange, NRC 1. Th.4 letter from Dr. White will be supplied.
2. The Toolik Lake Field station and ajoining area is situated on Federal lands.
The Toolik Lake Field Station site is leased by the University of Alaska ;
Fairbanks through the Bureau of Land Management. Alllands in the Toolik l Lake Field Station area lie within the boundaries of the North Slope Borough.
We supplied the North Slope Borough Planning Department with a description of our experiment as the materials submitted to the UAF Radiation Safety Committee prior to submission of the application to NRC Walnut Creek.
We have since been advised that we should apply for a Development Permit and are doing so now. ;
i Contact: Mr. Jon Dunham l l
l Planning Department North Slope Borough
%s perodf- b S l P.O. Box 69 McW b-em Iscudl #
l Barrow, AK 99723 lwd M hPPb #g gI l l
Tel: 907-852-0440 @, (he beg h . j Fax: 907-852-5991 v/ .
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i Following submission of the NRC application, the Toolik Lake Field Station l management requested that we apply for a permit from the Bureau of Land Management. The proposed pulse labeling experiment was viewed as a large 4 enough departure from previous work with radioisotopes to warrant review by the Federal agency responsible for the land on which the station is sited, BLM. j This application was submitted on July 7,1997, and is presently under staff review by the Fairbanks BLM office.
Contact: Mr. Paul Salvatore, Realty Specialist l
Dalton Management Unit $ is perr d.
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Bureau of Land Management ;ms gm issu<d 1150 University Avenue cLtd i
Fairbanks, AK 99709-3844 O I"
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l Tel: 907-474-2310 in W Pa cb *$g 6
! 3. The RSC approvals are attached L
4. Figure 1 shows the experimental arrangement. The chambers are arranged
- so that their bases rest inside a water-filled channel that is part of a welded i stainless steel chamber-bucket adapter plate. The experiments on wet meadow l tundra will be conducted in buckets containing water. The buckets will be filled with a soil core containing plants. The flange on the chamber-bucket adapter
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extends below the water level in the bucket. With this arrangement, two water seals (channel and bucket) provide airtightness.
The experiments with tussock tundra will again involve soil cores containing plants, but will have lowered water tables. A closed-cell foam gasket attached to the bottom side of the collar-bucket adapter provides an air-tight seal with the bucket lip . Duct tape will be used to provide mechanical strength.
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Dr 'r frv- Ra i Wf mve(br tm) Milh g W % W6&l+ - he .au , lea-9d l Note that with this experimental layout, vacuum or pressure testing of the l chambers for leaks is not possible. The chambers are maintained at
! atmospheric pressure. They are fabricated from plexiglas and the tops are j solvent-glued. All ports and penetrations of the chamber wall have o-ring seals,
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so there are no mechanical leaks. ;
Some of the labelled CO2 introduced to the chamber for labelling will equilibrate with the water in the channel of the bucket-chamber adapter. We intend to use distilled water to fill this channel, and following labeling allow this i
' dissolved CO to evade to the atmosphere. Dr. Reelon3h , in a&f rhevy Wi ll cterrikj thi s wMer io Ilmi+ 141e chssolutum of co., -frew YM
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5. We are collecting samples for measurement of soil background ch7t#M g concentrations in the area used for the experimental setup. SWT -
6. A copy of the Toolik Lake Field Station handbook is attached. There are residential quarters at the Toolik Field Station as well as secure (locked) space for storage of the licensed material. Ampoules containing the 14C (as Na2CO) 3 will be prepared in Fairbanks. All transfers will be under the supervision of the University of Alaska RSO.
l 7. The H-3 referenced by George Kling is part of a different experiment. This
experiment involves no environmental releases and has been previously
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authorized by the UAF RSC.
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8. Figure 2 is a schematic of the experimental area. A map is attached to show the location of the proposed experimental area within the Toolik Lake Field l Station. The experimental area will consist of a secure fenced area enclosing a
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timber or soil dike lined with an impermeable membrane. As indicated in our original request, our plans are to conduct this experiment in 5 gallon plastic buckets. In order for this experiment to be realistic and meaningful, it will be '
necessary to maintain the roots at temperatures below air temperature. We >
plan to locate the experimental area near Toolik Lake so that water can be j pumped from the lake to maintain the buckets at a lower than ambient
, temperature. This will be accomplished by placng the buckets in 50 gallon l Rubbermaid stock tanks. These stock tanks will be equipped with overflow
! drains so that the cooling water cannot reach the tops of the buckets and flood them.
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To prevent soil contamination, a vinyl-coated cloth liner (same material as used to line fuel storage tank sites) will be placed on the ground. A layer of a geotextile will be placed below the vinyl-coated cloth membrane to prevent punctures on sharp rocks. The membrane liner will accumulate rainwater and
, provide protection from overflows. The contents of the membrane liner will be l assayed for radioactivity before being removed periodically.
The entire experimental area will be enclosed in a commercially available dog kennel. These have chain link panels as well as a lockable gateway. A skirt of 1/2" mesh hardware cloth will be buried around the perimeter of the kennel or stapled to the timbers used to provide the water-impermeable barrier.
The hardware cloth will extend to a height of about 4 feet. This provision will prevent access to the experimental area by arctic ground squirrels, which are
- common in the camp area. The area above the hardware cloth, as well as the
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top of the enclosure, will be covered with chicken wire or a smaller gauge bird mesh to prevent access by birds.
Appropriate signs will on permanent display at the experimental area. In particular, a " Caution Radioactive Materials" sign, a list of investigators associated with the experiment and their locations in camp, addresses and telephone numbers of the UAF RSO and Safety Officer. A NRC-3 form and notice of the location of documents regarding the NRC license will also be
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posted on the experimental area.
Prior to starting the experiment, an "all-hands" orientation meeting will be I conducted at the Toolik Lake Field Station. This will be repeated as new camp personnel arrive. The orientation will describe the experiment and outline the rules and precautions associated with the permit.
As indicated in Figure 1, this experiment is to be conducted in watertight 5 i gallon plastic buckets. No liquid or solid material can leak from the buckets, 1 and our only anticipated environmental releases will be small quantities of 14CO2 and 14CH4t o the atmosphere, where it can be diluted to low levels. One possible way for labelled material to be lost from the buckets is by overflow during rainstorms. The impermeable liner will capture this material, but our intention is to cover the experimental cage with tarps during rainstorms to prevent bucket overflow. The camp operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, so we will arrange as part of the orientation to have persons responsible for the experiment wakened during rainstorms.
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Figura 1
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Labeling / Sampling Chamber Schematic
Plexiglas Flux Chamber 12" diam. x 18" tall All fittings penetrating chamber have 0-ring seals i
g Mounting flange for LICOR CO2 Sensor Bucket I I interior m m Chamber Bucket adapter, side (left) and top view (right). Welded stainless steel construction.
Inner two rings form a 1.5" deep channel, which is filled with water for an alttight seal with the plexiglas chamber.between the 5 gallon plastic bucket for containing soil core with plants. Adapter flange fits snugly against sides of bucket. Water table provides airtight seal on flange. For experiments with low water level, closed-cell foamgasket on bottomof adapter seals with bucket lip i
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Figure 2 Experimental Area Schematic Side View
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Stock tanks containing experimental buckets en table. Cooling water from Toolik is pumped into stock tanks and drains back into lake
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Hardware cloth perimeter to prevent ground impermeable membrane covering squirrel access. Buried or stapled to timber timber or gravel dike framework membrane framework. Bird-proof netting on top and above hardware j cloth 1
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Top View Locking gate
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I Timber framework for liner inside fenced perimeter Table with stock tanks containing experimental buckets l
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office of Arctic Research 301 Signers' Hall Phone (907) 474 7314
""**" Fax (907) 474 7225 Uxiveasirv or Atasx^ 7^ina^"xs .
l Fatrbanks. Alaska 99775-7560 June 30,1997 l
l Ms. Beth Parge l
U.S. Nuclear Regulatory Commission
! Reg!- IV, Walnut Creek Field Office
,
1430 tria Lane l Walnut Creek, California 94596
Dear Ms Prange:
Enclosed is the experimental protocol for some research at the Toolik lake field research Site that could result in the release of "co. We are requesting 2 your review and approval of this application.
Theexperimental for UAF Radiation release Safety of "coCommittee met on June 9 to discuss an application
l Reeburgh (U.C. Irvine) and his collaborators.at the Toolik Lake site by Dr. William This application and protocol
- was reviewed and approved by Dr. Susan Henrichs (UAF Radiation Safety Officer (RSO)) prior to her departure to a scientific expedition. The Committee, which consisted of Drs. Ted DeLaca, Robert White, Donald Schell and William Krause, considered the application and Dr. Henrich's analysis !
and approval with Dr. Reeburgh. ,
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While we agreed with the recommendation to approve the application, there was considerable discussion regarding the necessity and importance to discuss t
the experiment with representatives of the North Slope Borough (NSB)
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I pursuant to the spirit of the National Science Foundation's ethics in research statement.
We recommended that those discussions occur prior to any official application to the Nuclear Regulatory Commission (NRC), Toolik Field Station (TFS), or the Bureau of Land Management (all of which must occur prior to conduction of the experiment).
The investigator has subsequently discussed this matter with Dr. Richard
.
Glenn -(NSB representative and member of the U.S. Arctic Research Commission) and received his acknowledgment of the proposed experiment and his encouragement to proceed.
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June 30,1997 Ms. Beth Parge U.S. Nuclear Regulatory Co;nmission i The investigator, along with the other spokespeople for the Toclik Lake site have agreed to keep the NSB informed of the experiments conducted at the '
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TFS and schedules. adjacent regions, and their results through established practice and The UAF Radiation Safety Committee, therefore, has no difficulty in approving this application and requests an amendment to UAF's NRC Materials field release.License #50-02430-07, Docket #030-01179 to permit the requested Thank you for your consideration in this matter.
Sincerely,
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i T . DeLaca, Director Chair, UAF Radiation Safety Committee
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Application for release authorization from Dr. Reeburgh 1 Evaluation and approval from Dr. Henrichs (UAF - RSO)
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William Reeburgh, University of California, Irvine Don Schell, University of Alaska Fairbanks Robert White, University of Alaska Fairbanks Bill Krause, University of Alaska Fairbanks
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P.O. Box 7s7220 Fairbanks. Alaska 99775 7220 RECEIVED MEMORANDUM To: UAF Radiation Safety Committee JUN 101997 Dr. Ted DeLaca (Chair)
Dr. Don Schell OFFICE OF ARCTIC RESEARCH Dr. Robert White Mr. Bill Krause *
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f From: Dr. Susan Henrichs Radiation Safety Officer .[' po' Ol * '
Date: June 5,1997 Subject: Experimental Release of I4 CO2at Toolik Lake field research site
. Attached you will fmd a letter from Dr. William S. Reeburgh requesting, on behalf research Lgroup, permission to release a small amount of radioactivity in the at the Toolik ake field research site. I have reviewed this request, and find that the proposed release is limited to small amounts ofgaseous radioactivity which wil diluted in the atmosphere to background levels. All other radioactive materials will b removed from the site at the close of the experiment. Thus, the experiment poses n significant risk to the personnel at the site, nor to the general public. Further, the us radioisotopes and the small experimental release are essential to meeting the resea goals of the project. On that basis, I recommedd that this request be approved UAF Radiation Safety Committee, under the following conditions, which are the UAF Radiation Safety Program and the Nuclear Regulatory Commission .
below should be followed in order, 1. The field site use of radioisotopes and the environmental release must be reviewed approved in writing by the individual administratively responsible for the site, in this case the Director of the Institute of Arctic Biology, Dr. Robert White.
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2. All persons mentioned as being in charge of the experiment in Dr. Reeburgh's must be approved as UAF Authorized Users by the Radiation Safety committee. On those persons must be on site at all times during the experiment.
3. The field experimental release must be approved by the UAF Radiation Safe Committee in writing.
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l 4. Dr. Reeburgh's letter, with Dr. White's approval memo, this (RSO) memo, and a c l
letter from the Radiation Safety Committee, which lists the Authorized Users this project and stating the RSC's approval of Dr. Reeburgh's request, must be se Nuclear Regulatory Commission. The letter should request an amendment to UAF Materials License #50-02430-07, Docket # 030-01179 to permit this field release. Th address is:
Ms. Beth Prange or Mr. James Montgomery U.S. Nuclear Regulatory Commission Region IV, Walnut Creek Field Office 1450 Maria Lane Walnut Creek, CA 94596 The phone number there is (510) 975-0250. The fax # is (510) 975-0381. To e this you might want to contact them to get advice on any other information they require.
Unfortunately, I will be unavailable from June 9 to June 28 because I will be at sea a the R4'Wecoma. In my absence, Dr. Schell will handle techr.ical questions relative t application. Dr. DeLaca, as chair of the Radiation Safety Committee, has final a authority for UAF on this request, and he should sign the Amendment request to the l
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MEMORANDUM To:
Dr. Susan M. Henrichs Radiation Safety Officer. University of Alaska Fairbanks From: W. S. Reeburgh W Ib.
Co-investigator. Pse Labeling Pr 'ect Date: June 5,1997 Subject:
Request for Environmental Release Authorization Carbon Cycling in Tundra at Toolik Lake Field Station: 2 A 14CO Pulse Labeling Study on Contained Plant-Soil Systems Overview:
We request permission to perform a pulse labeling experiment at the Toolik Fiel Station during the summers of 1997.1998, and 1999. The study involves la soil systems by photosynthetic uptake 2 of 14CO , and following distribution oflabele carbon, and finally, respiratory losses as carbon dioxide study has been designed to allow several investigators to efficiently utilize a minim number oflabeled systems to study a range of problems that can only be address field study. The study involves minor gas phase environmental releases as deta The experiments proposed for 1997 and 1998 will be conducted in 5 gallon .
buckets. Using data accumulated during the 1997 field work, we anticipat modification to this request in 1998 to label specific sites in the Toolik Lake L Ecological shading, Research and warming. area that have been amended by long and short term fertili
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Introduction and Methods:
The specific applications include standard 14C radiotracer methodologies to plant photosynthesis, subsequent translocation of radio 2 plant during plant growth and respiration, and their ultimate transfer to the soil, so solutions and respired gases as the labelled roots die and decompose. These sta This methodology has been widely used in a number o .
decades in order to trace the flow of carbon through ecosystems (Caldwel 1974; 1992). Dahlman and Kucera,1968: Milchunas et al.,1985, Milchunas and Lauenro ,
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The 14C labeling method involves temporarily enclosing plant-soil cores in translucent, gas-tight chambers, labeling the2,headspace withn 14CO and allow time (2-3 hr) for the plants to photosynthetically assimilate the 14CO 2. We will follow the 14C label with frequent measurements for about one month in the su mmer 1997 as the label moves into aboveground biomass (leaves), belowground biomass (roots, unde stems, and microbial biomass, and ultimately, humus), into the soil solution as dissol organic carbon (DOC), dissolved inorganic carbon (DIC = CO ), and dissolved C
into the atmosphere2 (as CO 4 and CH ). This approach will allow us to measure C
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and atmospheric pools, and rates of soil C tumover. ..
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and belowground plant tissues) will be shipped to investigator's home laboratories f further analysis following the field season.
There are few altemative non-tracer methodologies that permit quantification o carbon transfer from plants to soils and the atmosphere. Because C cycling with ecosystem is dynamic, i.e. carbon is continually being transferred from one pool to (e.g. plants to soils), it is very difficult to measure C transfer rates er without using approach. We propose to use 2 14CO instead of the stable isotope 13CO because of the
greater sensitivity of 14C methods. In 2fact.13CO cannot be used effectively because problems associated with detecting small changes in 13C relative to large back C contains -1.1 % 13C vs. ~ 10-10% 14C. Further, the sample preparation ai costs for use of 13C would make an experiment of this scope impractical.
This request for the use of 14C will result in small. incidental2 releases of 14CO the atmosphere over approximately a two week period for each labeling .
event The proposed study will result in a maximum total incidental release of 1.2 mci of radioacti gases over this two week period. The 2 14CO that is released from plant respiration as a result of our labeling will be quickly diluted as it enters the atmosphere (see calculati below). The concentration 2 of 14CO in this effluent will fall well below the an concentration for 14CO2 effluent of 3 x104 level produced naturally in the atmosphere and The pulse labeling approach outlined here provides the safest and most realistic a
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and still poses no safety risk.of quantifying carbon flow with minimal dismp Experimental Details:
Physical Setting:
The buckets will be located in a fenced area of about 10x10 m at th Station. The area will be posted and accessible only to authorized users associated l
t experimental site. Labeled solid and liquid phases will be ;
Labeled plants and soils remaining after the experiment. as well as associated i waste, will be transported to the University of Alaska Fairbanks in accordance with DOT 1 and NRC regulations for incineration or shipment to the low level waste disposal s t Hanford, WA. A post-season survey of the site will be conducted to insure that the clean.
Authorized Users: !
Authorized users associated with this project are:An authorized user w California. Irvine), George W. Kling (Michigan State University), Leanne Jablo (Marine Biological Laboratory), and Jennifer Y. King (University of California. Irv Expected Environmental Release:
l We will use 14CO 2 with a specific activity of 75 MBq/gC. Based on our earlier carbon flux studies, we assume an uptake rate of 50 mg C over the 2 hrlabelling Therefore, each plant-soil system should contain 3.75 MBq oflabeled carbon. W labeling a maximum of 24 buckets in 1997. Thus the total amount of radioactivity MBq. The 14CO will be quickly incorporated into the plants and a fraction will be later
respired by the plants. Based on many physiological studies and some of our own L_________-_______________.
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measurements 2of2 CO respiration. we estimate that about 50% of this 14C will be respire by the plants as CO and CH4 in the first two weeks: the rest (45 Mbq) will be in into plant tissue (or into other pools in the plant-soil system e.g., microbes, dissolved constituents. etc). About 3% of the gaseous effluent will be 14CH4 (Minoda and Kimura 1994, Minoda et al.,1996).
Converting to curies, we anticipate releasing a total of 1.2 microcuries or 1.2 millicuries over the two week period of peak plant respiration losses. or roughly 0.0 millicuries per day. This 0.085 millicuries will be quickly diluted in the air column over t roughly 10 m x 10 m occupied by the 24 buckets. Therefore, with an air column 20 m high over a 100 m2 area, we have about 85 microcuries in 2000 m3of air or a 14CO
effluent concentration of 4.25 x10 8 14 day period, we estimate releases to be 5.95 x 10 7microcuries/ml air on a pe microcuries/mi air. The NRC regulatory limit for the average annual radioactivity in effluent2 14CO is 3 x 10-7 microcuries/ml.
References:
Coleman.
Diego. D. C. and B. Fry (1991) Carbon Isotope Techniques. Academic Press, San Caldwell. M. and L. B. Camp t 1974) Belowground productivity of two cool desert communities. Oecologia 17: 123-130.
Dahlman. R. and C. L. Kucera (1968) Tagging native grassland vegetation with carbon-14. Ecology 49(6): 1199-1203.
Eisenbud. M.1981.
Health Physics 40:429-437. The status of radioactive waste management: Needs for reassessm Milchunas. D. G. and W. K. Lauenroth (1992). Carbon dynamics and estimates of primary production by harvest,14C dilution, and 14C turnover. Ecology 73(2):593-607.
Milchunas. D. G., W. K. Lauenroth J. S. Singh, C. V. Cole, and H. W. Hunt (1985)
Root tumover and production by 14C dilution:
plants. Plant and Soil 88:353-365. implications of carbon partitioning in Minoda. T., M. Kimura and E. Wada (1996) Phoptosynthates as the dominant surces of
CH4 and CO in soil water and CH4 emitted to the atmosphere from paddy fields. J.
Geophys. Res.101(D15) 2109l-21097.
Minoda, T and M. Kimura (1994) Contribution of photosynthesized carbon to the methane emitted from paddy fields. Geophys. Res. Lett. 21(19) 2007-2110.
Pearcy, W., J. Ehleringer, H. A. Mooney, and PW Rundel (eds). (1991) Plant Physiological Ecology-Field Methods and Instrumentation Chapman and Hall, NY.
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RS.11.12.AND 133.
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DEPARTMENT OF EARTII SYSTEM SCIENCE UNIVERSITY OF CALIFORNIA IRVINE, CA 92697-3100
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Facsimile Cover Sheet (714) 824-8794 Telephone (714) 824-3256 FAX UCI's new area code is 949 effective April 18. 1998 Dcte: A-lI- 9 F Number of Pages Sent: M (including cover sheet)
Sent Te: 40 emo J
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FAX Number: _
9 LT 'l~lf 038f Telephone No.: 875 ' 't'7 f - og ro From: _
N 6- 4chvg k __
Telephone No.. 7 I4 - 82 4- E4 86 Message:
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NCILTH $1AM3E BOROUGH PLANNING DEPARTMENT
'O. Box 69 ~
Carrow, Alaska 99723 J ~,,,,J. ,,,,,
Phone: 907-852-2611 907-852-0320 Ka n Burnell, Director !
Fax: 907-8524322 l -
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August 28,1997 ep. wa M9 Wilham S. Reeburgh Univenity ofCalifornia-hvine 205 Phys.,al Sciences Research Facihty Irvine, CA 92697-3100 Rc; NSB 98-006 Devdopment Pannt, T9S, R11E Section 29, Umist Meridian (foolik Fick!
Station), Transportation Corndor District DearReeburgh.
We have completed our review your request to conduct a CO2 pulse labeling expenment during the summer of 1998 at Toolik Fickt Station! This experiment will study the photosynthetic uptake of
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Carbon Dmxide by tmxha' plant-soil systems by using trace amounts'of a radio-active isotope of Carbon (C14),.in tlie form of pulse' labeling., ' The expenment will be conducted..od tundm plant-soit v systems, conk in'.larke.plastxi: buckets with'I,singleistortierm,' addition'of pulse labeled C14 to measu're the phot 6s nthetic uptake ofCO2 by the plants above and below~the arface ofthe' soil. As a result of this expemnent, there will be relmses of Cl4 in the form of Carbon Dioxide and Methane into the air which will be quickly diluted into the bmipuerxl atmosphere and is within safety limits set by the Nuclear Regulatory Commission (NRC).
We have determined tint your proposal is consistent with Title 19 provided that you comply with the following conditions:
PROJECT SPECIFIC STIPULATIONS 1. There shall be m:ondary containment provided around the experimental pkts dcient to contam any material that may leak or spill from the plastic buckets. Any soil material containing introduced anxmats of C14 shall be disposed of by a method approval by the NRC. NSBMC 1970.050(I)(3)
GENERAL STIPULATIONS . ,
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. .- ..p b . Allh. h.oda hazardous nuieirial,.,spillsfsNbe'nported im,Enhateiy,'to,'the Penmttin'g ,
'and Zoning Didsion,','at ~(907); 8524140'or f' at,to;(907); 852-5,991as. lwell lis to 'the , ' ,
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' NSB/OSEA MT6at '(907)lR52-0390/ fax!(907) 852-0327. A 'sufIicient innount of "
absorbent materials shall be on harid at aN times in'tidevent'6f any fud, oil l or chemical o spills. Spills shall be cleaned up'as'soon as possible. Secondary containment shall be
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provided aroumi all fuel storage MW capable of handling 110% of the volume of the V largest containct. NSBMC 19.70.050(I)(3)
2. The Lami Management M==ierrator may require that her mMad representative be oswite dunng any opershons cdW under this permit. NSBMC 19.30.100 .
3. Within the contraints of federal, state and local law, the pennittee and its agents are encouraged, tirough a voluntary .Lm.0ve action program, to hire and train rendents of the North Slope Borough. In order to comply with this stipulation the pamittee and its agents shall emnact the Mayor or City Manager and the village wipui.Gon of any village most affected by this permit. In this case contact the village of Anaktuvuk Pass at (907)
661-3612 ami Nunamuit Corporation at (907) 661-3026 to determine if there are quahfied people available or people who could be employed for on4hejob training. NSBMC 19.70.030 4. All state and faleval permit conditions applicable to this dr-W are Iru.yvi.i i . . .
herein by reference, and may be enforced at the ophon of the Borough. This provision in no way attempts to impart to the Borough any powers not granted or reserved to h under state or federal law. within its authority, by operation of this provision, the Borough has the ophon of eA4 say -ans imposed by otler i .mius authorities, includmg condetions imposed by such authorities to address issues not raised by prior Borough review 16 U.S.C.1451, if C.F.R. Ch. IX Part 923, AS 46.40,6AAC 50 V
5. This pernut automatically expires within twelve months of this approval Failure to comply with the corxhhons of this permit could resuk in immediate revocation of this permit.
NSBMC 1930.070 6. The permittee shall inform and ermre w.As with these stipulations by its agents and employees. This peamit shall be posted in a conspimous place for these indmduals to see.
NSBMC 1930.100 Our review of your application, received _ July 24,1997 was conducted in m% with _
NSBMC, Title 19. 'Be purpose ofour review is to enare that your project achieves the goals and objectrves, and implements the pobcies, of the Borough Comprehensive Plan; to ensure that the future growth and dedsp..we of the Borough is in accord with the values ofits r-=id-atr to idertify and semre, for present and future residents, the beneficial impacts of development; to identify and avoid, =idra, or prohibit the negative impacts of development, and to ensure that future development is of the proper type, design and locahon, and is saved by a proper range of public services and facihties.
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APR-16-BO 10:02 FROM Earth System Science ID:7140243258 PACE 4/O
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Cunr=*e or quetions should be sent to Jon Dunham, Permitting & Zoning Manager at the V
address above or by trJephone at (907)852-0440/1 800.4784(o5.
sincerely,
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Karen Bumell, Land Management Admmistrator m NulPiarsma Crrrunmum Charles DR Brewer, Dra*r, NSB Wddlife Dan Ibarnburgh, NSB Adas A Firumre.OSFA Domen:Imrge, NSH CommurntyPleaner, Plannmg Arkne Thturm NSB Canmunity Fisme:/ Ache CIP,Plaun:r:g Arlene Gkon, Acting IHIf Lissa Ospr,Mamaing DorotbyIkgam/Riley14xry, NSB Valbge Oxudinnears, Annktavuk Pass CuydAnaktumk Pass _ _, ..
Nancy Welch, ADNR,Fairbanks AlOu, ADFAG,Farteks Patrik Scnisa,USF&WS,Fairtsoks OhDDGC, Ardurage Wdliato "IW MGe,AIEC,Fairbanks Tary Cepenter. US. WOE ;
Deer.Ritdde, Ardie ArniMgr,DLM Fdes v
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- Attach to thiJs Application the fpilowing
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General Vicinity Map ( j'
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specific . . Location- Map, including nearby
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development and natural features. existing Design Plans--plot profilan, as appropriate. plan, elevations, ccess sections,
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supplemental etc., as n*=ded. Information-aerial photographs, studies, I BTNTNT OF ME ENOWLEDGE.CERTIFt TERT THE FM*mrte 15 TROF. AMD Nw*Er" TO THE BFAT
\A) M s' ,. - 44, Authorized Signature 3 7 ~l.-3 ' Q l \.Al i { { s*wm 5. ce h uq k gte '
Name 14.desse i
, _ _ _ _ . . . . .. 1 Title -
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FEE PAID: i Special Pl==ing m==insion Meeting $5,000.00
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_ Development Permit, $200.00
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_ Conditional Developteent $1,000.00
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prernIows
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,_ use permit Approved: This v preposed development.
substantially complies with the Ma#er Plan, and a use pc.rmit is issued, conditioned on compliance with all relevant Manter Plan conditions, lease stipulations, and thereunder. of state and federal law and perrits served provisions (see accompanying letter).
.J Developannt Peemit Approved: The proposed development meets all applicable aandatory Poljeias, represents the Developer's best efforts to impisment. all relevant best
efforts and minimization policies, and, as long as any i conditions set forth in the acessaenyi.ng letter are complied with, will represent a net public benefit. (see amanying letter) . .
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. Permit seated. (see accompanying letter). .
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Data
, Land Management Adminiekstor ~
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If you wish to appeal this decision, you must suhait written notice to the secretary regularly scheduled of meeting the Planning ccanaission pt.ior to the next j stating the policy or policies in question and the reasons you, believe the decision is incorrecta V .
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g Name og William S. Reeburgh ,
July 22,\>!9,911 errt Applicant-l Earth System deleira Date '
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Address of Univ. of California, Irvine 'MEi '
Applicant Irvine, CA 92697-3100 State I.D
_ Phone. No.7f4y s- ao o
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Name of Contact Par *:en William S. Reeburgh Locatiert: 2-~ E
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T 95 N R llE W Sec._29 Project Na:nn- Pulse Labeling IEIat EMTtdian Unitized Field Name:
Proposed Development Construct temporary-enclerure * h 1ik Field Station to concuer pui.,-; laLc1Ing apc . mt e = + ima rh-' '
_ soil-plant systems
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Purpose of Development Conduct pulse labeling experiment - scientific research Proposed.
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6/98 Depected 6/00 start-Up Date- , comp 1ntion Date
.V Pill / Dredges yeg_ _,._ no_3_ _ T-sporary
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Acreage Involvect Amount (pad). water Uses Toolik LaT&~' * no cy Sources (road)__ ~y c Access (other)_ cy Ma v4 == Withdrawal _ M' 9eD cay
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X 8ansitiva Habitat Invt,19eth Noise / vibration:yes4 no Floodplain-Amounte i shoreline
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Um-* AusuFawas P.O. Box 757220 Fairtianks Alaska 99775 7220 April 14,1998 Ms. Beth Frange US Nuclear Regulatory Commission Region IV, Walnut Creek Field Office 1450 Maria Lane Walnut Creek, CA 94596
Dear Ms. P1ange:
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Please find enclosed the revised application for experiments involving release of small amounts of14 C, to be conducted during summer,1998, at the Toolik Lake Field Station of the University ofAlaska Fairbanks. I request an amendment to NRC License #50-02430-07 (Reference #030-01179) to allow these experiments. Attached is a letter from Dr. Reeburgh which answers the questions that you raised in an earlier review of the application, and, for referen'.e, the original application. Also attached are copies ofletters from the UAF Radiation Safety Committee, which approved the experiment last year contingent on review and approval by the North Slope Borough and the Bureau ofLand Management, and from Dr. Bob White, Director of the Institute of Arctic Biology, who is the UAF administrator responsible for the Toolik Field Station; and a permit from the Bureau ofLand Management. A copy of the permit from the North Slope Borough will be aniving under separate cover from Dr.
Reeburgh.
Please also note that the persons who will be involved in the experiment have been approved as Authorized Users by the University of Alaska Fairbanks Radiation Safety Committee. These individuals include Dr. Knute Nade! hoffer, Dr. Loretta C. Johnson, Dr. William S. Reeburgh, and Ms. Jennifer King. Ms. Kama Thieler has been approved as a Supervised User.
I will try to contact you by phone on Friday morning. After that, until May 1, I will be at sea abo::rd the R/V Alpha Helix. I can be reached there by e-mail (fyhelix@uaf edu), but there is a lag of several days in response as e-mail is read only twice a week due to the cost of the satellite link. Most general questions about Toolik facilities, the UAF Radiation Safety Program, etc., can be answered by Dr. Don Schell, ffdms1@uaf.edu or (907) 474-7978. I will leave a copy of the application materials with him. I will return to Fairbanks 5/1, but leave again 5/5, returning from that research cruise about 5/23. For very specific questions about the experiment, Dr.
Reeburgh can be reached at reeburgh@uci.edu or (714) 824-2986.
Dr. Reeburgh needs to get the approval by July to be able to conduct his experiment, because winter comes in August. June would be better. Unfortunately, the BLM 245 OMil * Phone (907) 474-7824 * FAX (907) 474-7204 = Internet: fystos@ aurora. alaska edu
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permitting was very time-consuming, and I was at fault for a delay here as well. We would very much appreciate it if this application could be reviewed as soon as possible.
Sincerely, s M I Susan M. H chs Radiation Safety Officer
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/$ PO Box 757000 (9071 474-7640 Fairbanks. Naska 99775 7000 V 5.A. FAX: (907) 474 6967 7 ALA July 22,1997 Ms. Beth Parge , __.
U.S. Nuclear Regulatory Commission ,
Region IV, Walnut Creek Field Office 1450 Maria Lane *
Walnut Creek, California 94596
Dear Ms. Parge:
I have reviewed the procedures proposed by Dr. Reeburgh and his collaborators for an outside, contained radioisotope study using C-14. I do not believe the study will constitute more than a minimal release of C-14 to the atmosphere through plant respiration. Therefore, the study could be conducted at the Toolik Field Station on a location that is under the management of the Institute of Arctic Biology. The study would need to be reviewed by the BLM, North Slope Borough and the NRC to meet
, our requirements for approval.
Sincerely Robert G.. White Director ec Dr. Ted DeLaca Dr. William Reeburgh Radiation Safety Committer. UAF l
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g United States Department of the Interior BUREAU OF LAND MANAGEMENT Nonkrn Disuict oface 1150 Universtry Avenue Fa42nks, Alaska 99709 3899 IN REPLY REFTR To:
F-92279 2020.06 (020)
CERTIFIED - RETURN RECEIPT REQUESTED Dr. William S Reeburgh 13 FEB 1998 Department of Earth System Science University of California,Irvine 205 Physical Sciences Research Facility Irvine, Califomia 92697-3100
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Dear Dr. Reeburgh Enclosed is your countersigned copy of permit F-92279 which authorizes your research site at the Toolik Lake Field Station. It is important that you coordinate the actual site location with Mike Ables at the Institute of Arctic Biology.
Please be aware that only the activities authorized by this permit are those outlined in Exhibit A of the enclosed permit. Any deviations, additions, or changes in use must be pre approved in writing by the Authorized Officer.
If you have questions or need clarification on anything please contact me at (907) 474_2310, Toll Free at 800-437-7021, or via e-mail at psalvaro@ak.bim. gov.
Sincerely, i
Is/ PaulJ. Salvator.
Paul J. Salvatore Realty Specialist ,
Dalton Management Unit J Enclosure cc: Mike Ables UAF/IAB Susan Henrichs UAF t
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l~ , . s PERMIT ,
' Permit Number Trmitsion is hereby granted to William S. Reiburgh Department of Earth System Science, University of Califomia. Irvinn r-92279 of to tase the following-described lands:
FANGE SECTION SI'BDIVISION TOWNSHIP ._
9 south 11 east 29 metes and bounds State: Alaska County: N/A Acres 0.01 Meridian: Umlat for the purpose of s . a:xhibit A and subject to the following conditions :
9. Permittee, shall pay the authorized officer. in advance the lump sum cf $ ...
1. This permit is issued for the period spectfled below. It is revocable at the discretion of the sulhorized omeer of the Bureau of Land Management. at any - for the period of use authorized by this permit or 3100.00, annually, as tental or such other sum as may be required if a rental adjustment is made, dme upon nodce. This permit is subject to valid adverse claims heretofore or hercafter tequired.
10. Use or occupancy of land under this permit shall commence within -
2.This permit is subject to all applicable provisions of the regulations (43 months from date hereof and shallbe exercised at least - days each year.
CFR 2920) which are rnade a part hereof.
11. Permittee shall take all reasonable precautions to prevent and suppress 3.nis permit may not be assigned without prior approval of the authonzed
. forest. brush,and grass fires and prevent pollution of waters.on or in_the. _
offlect of the Bureau of Land Management. . . _ _ _ .
vicinity of the lands.
12. Permittee shall not cut any timber on the lands or remove other resources 4. Parmittee shall not enclose roads or trails commonly in public use.
from the land without prior written permission from the authorized offlect.
Such permission may be conditioned by a requirement to pay fair market value for the tirnber or other resources.
13. Permittee agrees to have the senal number of this permit marked or 5. Authorized representatives of the Department of theInterior, other Federal painted on cach advertising display or other facility erected or maintained agencies, and State and locallaw officials shall at all times have the right to under the authority of such permit.
! en:cr the premises on official business.
14. Dis permit is subject to the provisions of Execudve Order No. !!246 of 6. Permittce shall pay the United States for any damage to its property September 24.1965, as amended which sets forth the Equal Opportunity resulting fromthe use.
clauses. A copy of this order may be obtained from the signing officer.
15. Permittee acknowledges. by signing below, that he/she knows, 7. Permittee shall notify the authorized offlect of address change immediately.
understands and accep s the terms and condidons under which this permit is issued.
16. Special conditions (attach additional sheets if necessary)
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8. Permittee shall observe all Federal. State. and local laws and regulatins l applicabic to the premises and to crection or maintenance of signs or See Exhibit B advertising displays including the regulations for the protection of game birds and game animala. and shall keep the premises in a neat, orderly, and sanitary condition.
Pernstissued for period
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From h. m 1.1998 - M /
l.- (Authoffred Officer) /
To D=eamher 11.1999 _
j0og alton Tcam Rs= dve (Date)
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INSTRUCTIONS 1. Submit.in duplicate so any local office of the sureau of Land Manegement havingjurisdiction of the landt.
2. Applicadons for Land Use Permits will not be accepted unless a nouncadon of the availabilky of the land for non BLM use (No the Federal Regtsier and for 3 weeks therenner I . a newspaper of gerwral circulation. This provision does not apply in them situations wher Realty Action) has been waived by the authorised officer.
3. If the annual rental enceeds $250 dolbrs per year: costs of processing the applicadon must be paid by the applicant in advance.
4. De authorized officer may require additionalinformation to proecss an applicatio#L Processing will be deferred until the required Information The Paperwork Redvedon Act of 198o M411.5 C.3501 et seq.) requires us to inform you thac Inforenadon is needed to process applicauon fos land ow authorizadons. pursuant to 43 CFR Section 2910. Information shows if the applicant and p epos requirements of 43 CFR Section 2920.t. Applicant mrr respond before he/she can be grafited an authorization to use public lands.
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D Figure 1 Labeling / Samoline Chamber Schematic Plexiglas Flux Chamber 12" diameter by 18" tall
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LICOR CO 2Sensor
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Chamber - Bucket adapter, side (left) and top view (right). Welded stainless steel construction. Inner two rings form a 1.5" deep channel, whjch is filled with water for an ainight seal with the Plexiglas chamber between the 5 gallon bucket for containing soil core with plants.
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Adapter flange fits snugly against sides of bucket. Water
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with low water level, closed-cell foam gasket on bottom i. of adapter seals with bucket lip.
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Figure 2 Experimental Area Schematic Side View l
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Hardware cloth perimeter to prevent Impermenole membrane covering
ground squirrel access. Buried of timber or gravel dike framework.
stapled to timber membrane .
framework. Bird-proof netting on top and above hardware cloth.
Top View
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OOO 000 000 000 l I Timber framework for liner inside fenced perimeter.
Table with stock tanks containing experimental buckets.
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Exhibit B l l
Pulse Labeling F 92279 Additional Terms and Conditions
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This permit shall be contingent upon approval from the Nuclear Regulatory Commission and the University of Alaska Fairbanks / Institute of Arctic Biology. The permit ciay be terminated if i either of these parties fail to give their concurrence for the operation. l All structures will be painted so as to blend into the natural environment. All colors are to be pre approved by the Authorized Officer of BLM.
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Precise geographic positions of all research sites associated with this authorization shall be -- - -
submitted to the Authorized Officer. These locations can be noted by either Latitude and Longitude or Universal Transverse Mercator coordinates.
A summary of the previous field seasons activities shall be submitted to the Authorized Officer by December 31" of each year during the authodzed period. The summary shall include the approximate number of times the site was visited, by how many people, and at what time '
periods. This summary shall also include any changes to the type of collection taking place and any proposed site additions. 4 A copy of all data acquired will be submitted to the Authorized Officer upon Permit expiration or ,
renewal.
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All operations must not impede rural residents from pursuing their traditional subsistence activities (ANILCA, PL 96-487).
Protection of Survey Monuments. The Holder shall protect all survey monuments. Survey monuments include, but are not limited to, General Land Office and Bureau of Land Management Cadastral Survey Corners, reference corners, witness points, U.S. Coast and Geodetic benchmarks and triangulation stations, military control monuments, and recognizable civil (both public and private) survey monuments. In the event of obliteration or disturbance of any of the above, the Holder shall immediately report the incident, in writing, to the Authorized Officer and the respective installing agency,if known. Where General Land Office or Bureau of Land Management right-of-way monuments or references are obliterated during operations, the Holder shall secure the services of a registered land surveyor or a Bureau Cadastral surveyor to restore the disturbed monuments and references using surveying procedures found in the Mattual of Surveyinc Instructions for the Survey of Public Lands of the United States. latest edition. If the Bureau Cadastral surveyors or other Federal surveyors are used to restore the disturbed survey monuments, the Holder shall be responsible for survey costs.
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Research General Stloulations
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Pulse labeling l F-92279 l All operations will be conducted in such a manner as not to cause damage or disturbance to any fish or wildlife and subsistence resources.
Holder shall prohibit the feeding of wildlife. Garbage or other potentially edible items which would attract wildlife shall be kept in covered contamers while awaiting incineration.
All operations shall be conducted with due regard for good resource management and in such a manner as not to block any stream, or drainage system, or change the character or course of a stream, or cause the pollution or siltation of any stream orlake.
All activities shall be conducted so as to avoid or ndnimize disturbance to vegetation.
Lultural and Paleontological Resources. Any cultural or Paleontological resource (historic or prehistoric site or object) discovered by the holder, or any person working on his behalf, on public or Federal land shall be immediately reported to the authorized officer. Holder shall suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the AO. An evaluation of the discovery will be made by the AO to determine appropriate actions to prevent the loss of significant cultural or scientific values. The Holder will be responsible for the cost of evaluation and any decision as to the proper mitigation measures will be made by the AO after consulting with the Holder.
All solid wastes shall be removed from the public lands to Alaska State DEC approved solid waste disposal facilit ies. Solid waste combustibles may be incinerated. All nr>n-combustible solid waste, including ash from incineration and fuel drums, shall be removed for approved disposal. There will be no burial of garbage or human wastes.
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( F-92279 Pulse Labeling at the .
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Icolik Lake F.ield Station
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Q\ Pump Station 6 h q# Livengood 0 -- _N V " JUNEAU 0 GULF OF ALASKA V KODIAK ISLAND 0 150 300 KILOMEl(P,5 P J. Sat L Vat TO R t
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UNIVERSHY OF CALIFORNIA,IRVINE senxazy . pays . pyn . tosecuus . ameure sapuoo . samect:0 . SWAOME
) sensesMA EART11 sYsTDI SCIENCE IRVINP. CALIMRNIA 91677-3100 Wanam S. Rubr.nh 205 PHYSICAL SCIENCES RTSEARCII FACnJIT PHONEr (7ta) s24-2986 FAXt Gld) 524 3256 Imersee REEBt'RGHeud.edu February 9,1998 ,
l Prof. Susan Henrichs UAF Radiadon Safety Officer Institute of Marine Science
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University of Alaska Fairbanks ;
Fairbanks, AK 99775-1080 1
Dear Susan,
Enclosed le and Kama Thiefer.ase find Authorized All are associated User with the pulse Applications labelling study we for Knute Nadelhoffer, are proposing at Toolik Loretta Johnson Lake Station. This experiment was done in a gmwth chamber at MBL during Fall,1997, and all ,d h
worked closely with George Kling during the experiment. The Nadelhoffer and Johnson i applications am accompanied by letters from Andy Mattox, the MBL RSO.
[P We would like to include Nadelhoffer, Johnson, and 'Ihieler in the NRC application at whatever user level the UAF Radiation Safety Committee considers appropriate. Leanne Jablonski b,*
is no longer with the project, so she should not be included.
I am FedExing a signed BLM permit application with a check for one year's rent to Paul L Salvatore today. I have asked him to mail you a copy of the completed permit to avoid a round of 7 mail to California. I will call afteryou have retumed fmm the Ocean Sciences Meeting and we can go through a check list for the NRC permit application. I think you have all of the pieces except the BLM permit and the enclosed modifications to the Authorized User list.
Best Regards, William S. Reeburgh Professor
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Responses to Beth Prange, NRC 1. The letter from Dr. White will be supplied.
2. The Toolik Lake Field station and ajoining area is situated on Federal lands.
The Toolik Lake Field Station site is leased by tne University of Alaska Fairbanks through the Bureau of Land Management. All lands in the Toolik Lake Field Station area lie within the boundaries of the North Slope Borough.
We supplied the North Slope Borough Planning Department with a description of our experiment as the materials submitted to the UAF Radiation Safety Committee prior to submission of the application to NRC Walnut Creek.
We have since been advised that we should apply for a Development Permit and are doing so now.
Contact: Mr. Jon Dunham Planning Department ~{his per M bOS North Slope Borough ytgnr Ip.4p;n. fssu<d #
P.O. Box 69 - -- -- -
Barrow, AK 99723 INi 'llMMFg g '
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Tel: 907-852-0440 @, (bee b<.tr3 h-Fax: 907-852-5991 Following submission of the NRC applic ttion, the Toolik Lake Field Station management requested that we apply for a permh from the Bureau of Land Management. The proposed pulse labeling experiment was viewed as a large enough departure from previous work with radioisotopes to warrant review by the Federal agency responsible for the land on which the station is sited, BLM.
This application was submitted on July 7,1997, and is presently under staff review by the Fairbanks BLM office.
Contact: Mr. Paul Salvatore, Realty Specialist Dalton Management Unit Thiis p ur d.
Bureau of Land Management g m issu<d 1150 University Avenue 441g 15 I.H gigogd
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Fairbanks, AK 99709-3844 Tel: 907-474-2310 in M Pd M9 g 3. The RSC approvals are attached 4. Figure 1 shows the experimental arrangement. The chambers are arranged so that their bases rest inside a water-filled channel that is part of a welded stainless steel chamber-bucket adapter plate. The experiments on wet meadow tundra will be conducted in buckets containing water. The buckets will be filled with a soil core containing plants, The flange on the chamber-bucket adapter extends below the water level in the bucket. With this arrangement, two water seals (channel and bucket) provide alttightness.
The experiments with tussock tundra will again involve soil cores containing plants, but will have lowered water tables. A closed-cell foam gasket attached to the bottom side of the collar-bucket adapter provides an alr-tight seal with the bucket lip . Duct tape will be used to provide mechanical strength.
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[ br. Ceeburgh Will check. Me cA2m6.rs fw- Rab
[. g m vestm3 + Mh g W M4 vvcttzm 64.fue au ,
Y Note that with this experimental layout, vacuum or pressure testing of the chambers for leaks is hot possible. The chambers are maintained at
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atmospheric pressure. They are fabricated from plexiglas and the tops are
! solvent-glued. All ports and penetrations of the chamber wall have o-ring seals, I
so there are no mechanical leaks.
Some of the labelled CO2 introduced to the chamber for labelling will equilibrate with the water in the channel of the bucket-chamber adapter. We intend to use distilled water to fill this channel, and following labeling allow this
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dissolved CO to evade to the atmosphere. Dr. Reeburgh; in c:tdddrevr, M
, vvi ll AcAddj -t%s wotk'r +o ilm.+ Mic c45ssolufraw of co g Orwt l
5. We are collecting samples for measurement of soil background chan1 * L _,/
concentrations in the area used for the experimental setup. 6*W -
6. A copy of the Toolik Lake Field Station handbook is attached. There are residential quarters at the Toolik Field Station as well as secure (locked) space
for storage of the licensed material. Ampoules containing the 14C (as Na2CO3)
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will be prepared in Falrbanks. - All transfers will be under the supervision of the University of Alaska RSO.
7. The H-3 referenced by George Kling is part of a different experiment. This i experiment involves no environmental releases and has been previously l
authorized by the UAF RSC.
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l 8. Figure 2 is a schematic of the experimental area. A map is attached to show
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the location of the proposed experimental area within the Toolik Lake Field l
Station. The experimental area will consist of a secure fenced area enclosing a l timber or soil dike lined with an impermeable membrane. As indicated in our original request, our plans are to conduct this experiment in 5 gallon plastic
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buckets in order for this experiment to be realistic and meaningful, it will be l
necessary to maintain the roots at temperatures below air temperature. We l
plan to locate the experimental area near Toolik Lake so that water can be l pumped from the lake to maintain the buckets at a lower than ambient
, temperature. This will be accomplished by plaeng the buckets in 50 gallon l
Rubbermaid stock tanks. These stock tanks will be equipped with overflow i drains so that the cooling water cannot reach the tops of the buckets and flood them.
To prevent soll contamination, a vinyl-coated cloth liner (same material as
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used to line fuel storage tank sites) will be placed on the ground. A layer of a
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geotextile will be placed below the vinyl-coated cloth membrane to prevent l punctures on sharp rocks. The membrane liner will accumulate rainwater and
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provide protection from overflows. The contents of the membrane liner will be assayed for radioactivity before being removed periodically.
The entire experimental area will be enclosed in a commercially available dog kennel. These have chain link panels as well as a lockable gateway. A '
skirt of 1/2" mesh hardware cloth will be buried around the perimeter of the kennel or stapled to the timbers used to provide the water-impermeable barrier.
The hardware cloth will extend to a height of about 4 feet. This provision will prevent access to the experimental area by arctic ground squirrels, which are
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common in the camp area. The area above the hardware cloth, as well as the
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top of the enclosure, will be covered with chicken wire or a smaller gauge bird mesh to prevent access by birds.
Appropriate signs will on permanent disp lay at the experimental area. In i particular, a " Caution Radioactive Materials' sign, a list of investigators ;
associated with the experiment and their locations in camp, addresses and telephone numbers of the UAF RSO and Safety Officer. A NRC-3 form and I
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notice of the location of documents regarding the NRC license will also be I
posted on the experimental area.
Pdor to starting the experiment, an "all-hands" orientation meeting will be l
conducted at the Toolik Lake Field Station. This will be repeated as new camp personnel arrive. The orientation will describe the expedment and outline the rules and precautions associated with the permit.
- As indicated in Figure 1, this experiment is to be conducted in watertight 5 ;
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gallon plastic buckets. No liquid or solid material can leak from the buckets, l
and our only anticipated environmental releases will be small quantitles of ,
14CO2 and 14CH4 to the atmosphere, where it can be diluted to low levels. One i possible way for labelled material to be lost from the buckets is by overflow during rainstorms. The impermeable liner will capture this material, but our intention is to cover the experimental cage with tarps during rainstorms to i
prevent bucket overflow. The camp operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, so we will arrange
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as part of the orientation to have persons responsible for the experiment wakened during rainstorms.
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Figura 1 Labeling /S::mpling Chimber Schtmitic Plexiglas Flux Chamber 12" diam. x 18' tall All fittings penetrating chamber have 0-ring seals Mounting flange for LICOR CO2 Sensor l g g
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Bucket l l Interior m P
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Chamber Bucket adapter, side (left and top view (right). Welded stainless steel) construction.
Inner two rings form a 1.5" deep channel, which is filled with water for an atrtight seat with the plexiglas chamber.between the 5 gallon plastic bucket for containing soil core with plants Adapter flange fits snugly against sides of bucket. Water table provides airtight seal on flange. For experiments with low water level, closed-cell foamgasket on bottomof adapter seals with bucket lip
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. Figura 2 Experimental Area Schematic I l
Side View f
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{ a,k Stock tanks containing experimental buckets on table. Cooling water from Toolik is pumped into stock tanks and drains back into take
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Hardware cloth perimeter to prevent ground impermeable membrane covering
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squirral access. Buried or stapled to timber timber or graveldike framework membrane framework. Bird. proof netting on top and above hardware cloth Top View .
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l Locking pate i
888 888 l
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Timber framework for liner inside fenced perimeter Table with stock tanks containing experimental buckets
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- Usivasin or Ausu F^iums ,
SCHOOL OF FISHERIES AND OCEAN SCIENCES 245 O'Neill Bt'ilding * P.O. Box 757220 - Fairbanks, AK 99775-7220 FAX: 907-474-7204 VOICE: 907-474 7824 FAX INTEFINET: fysfos @ uaf.edu To: I r'7//7/f#1 b Fax #: 8/ 97 Og From: 7/ A4 /7 f Date: / i[ Time: AACO Hard cop; o fo ow?: YES NO # of pages (inc. caver): [
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omee of Arcue Research 308 signers Hall P.o. Sc.: r57560 gpg 9 'gg I 8
Fairtmnks. Naska 99775 7560 June 30,1997 Ms. Beth Parge U.S. Nuclear Regulatory Commission ~ ,,
Region IV, Walnut Creek Field Office 1450 Maria Lane Walnut Creek, California 94596
Dear Ms Frange:
field research Site that could result in the release of "c your review and approval of this application. 2. We are requesting for experimental release of "co, at the Toolik Lak Reeburgh (U.C. Irvine) and his collaborators. .
This application and protocol Officer (RSO)) prior to herwas reviewed and approved by Dr. Susan departure to a scientific expedition. The Committee, which consisted of Drs. Ted DeLaca, Robert White, Donald and approval with Dr. Reeburgh.and William Krause, considere
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While we agreed with the recommendation to approve the application, t was considerable discussion regarding the necessity and importance to discus the experiment with representatives of the North Slope Borough (NSB)f pursuant to the spirit of the National Science Foundation's ethics in research statement. i offidal applicat!on to the Nuclear Regulatory Commiss Field Station (TFS), or the Bureau of Land Management (all of which must occur prior to conduction of the experiment).
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Glenn (NSB representative and member of theThe investig U.S. Arctic Research and his encouragement to proceed. Commission) and received i
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l Pap 2 June 30,1997 Ms. Beth Parge U.S. Nuclear Regulatory Commission have agreed to keep the NSB informed of the TFS and schedules. adjacent regions, and their results through established pr
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De UAF Radiation Safety Committee, approving this application and requests an amendmenttherefore, has no diffic Materials License #50 02430-07, to UAF's NRC field release. Docket #030-01179 to permit the requested Dank you for your consideration in this matter.
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Sincerely,
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.e DeLac , Irector
l Chair, UAF Radiation Safety Committee
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Attachments: (2)
Application for release authorization from Dr. Reeburgh Evaluation and approval from Dr. Henrichs (UAF - RSO)
cc William Heeburgh, University of California, Irvine Don Schell, University of Alaska Fairbanks Robert White, University of Alaska Fairbanks Bill Krause, University of Alaska Fairbanks l c-a
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P.O. Box 757220 FairDanks. Alaska 9977s 7220 MEMORANDUM To. UAF Radiation Safety Committee Dr. Ted DeLaca (Chair) JUN1 0 1997 Dr. Don Schell Dr. Robert White. OFFICEOFARCTICRESEARCH Mr. BillKrause '
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From: Dr. Susan Henrichs .
Radiation Safety Officerv' .
Date: June 5,1997 Subject: Experimental Release of34 CO2 at Toolik Lake field research site Attached you will find a letter from Dr. William, onS.behalfof Reeburgh a requesting researchL group, permission to release a small amount of radioactivit at the Toolik ake field research site. I have reviewed this request, and find tha proposed release is limited to small amounts ofgaseous radioac
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diluted in the atmosphere to background levels.a will Allbeother radioactive m l removed from the site at the close of the experiment. no Thus, the experi significant risk to the personnel at the site, nor toe use .
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theof general public F i radioisotopes and the small experimental releaseearch are essential to mee goals of the project. On that basis, I recommerid that this request UAF Radiation Safety Committee, under the following ,
e y condition the UAF Radiation Safety Program and the Nuclear Regulstory Commis i s on. The steps below should be followedin order.
1. The field site use ofradioisotopes and the emironmental v ewed and release mus approved in writing by the individual administratively responsible , case for the sit t
the Director of the Institute of Arctic Biology, Dr. Robert White.
2a5 o'Neiil e Mene (907) 474 7824 * r AX (907} 474-7PO4 * Intemet, fystos@ aurora sw6. -4
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2. All persons mentioned as being in charge ofthe experiment in Dr Re b
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e urgh'sletter must be appmved as UAF Authorized Users by the Radiation Safety c . One of those persons must be on site at all times during the experiment
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3. The field experimental release must be approved by the UA Committeein writing.
4. Dr. Reeburgh's letter, with Dr. White's approval
, memo this (RSO)
memo, and a cover letter fmm the Radiation Safety Committee, which lists the Authorize pproved for this project and stating the RSC's approval of, must Dr.beReeburgh's sent to the request Nuclear Regulatory Commission. The letter should request an Materials License #50-02430-07, Docket # 030-01179 address is: .
e to permit th{
I Ms. Beth Prange or Mr. James Montgomery U.S. Nuclear Regulatory Commission Region IV, Walnut Creek Field Office 1450 Maria Lane Walnut Creek, CA 94596 The phone number there is (510) 975-0250.
The fax # is (510) 975-0381. To expedite this you might want to contact them to get advice on iequire.
onthey any other informati would Unfortunately, I will be unavailable from June.9 to June oard 28 because I w the R/V Wecoma. In my absence, Dr. Schell ewill handle technical qu sti ons relative to this application. Dr. DeLaca, as chair of the Radiation Safety Committej authority for UAF on this request, and he should sign the Amendment r ,
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MEMORANDUM To:
l Dr. Susan M. Henrichs l
Radiation Safety Officer. University of Alaska Fairbanks From:
W. S. Reeburgh O lb
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Co-investigator, fuhe Labeling Pr 'ect Date: June 5,1997 Subject:
Request for Environmental Release Authorization Labeling Study on Contained Plant Soil SystemsC 2 Overview-i Station during the summers of 1997,1998, and
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soil systems by photosynthetic uptake of IdCO , and ant-2 following distnbu carbon into above and belowground plant biomass,c microbial bio carbon. and fmally, respiratory losses as carbon dioxide and methane
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study has been designed to allow several investigators to efficiently uti
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number field study oflabeled systems to study a range of problems that can only !
- Ihe expen,. The study involves nunor gas phase environmental releases .
ments proposed for 1997 and 1998 will be conducted in 5 gallon poly)
buckets. Using data accumulated during the 1997 field work, w ,
modification to this request in 1998 to label specific rites in the Toolik Ecological shading, Research and warming. area that have been amended by long and short ,
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introduction and Methods:
a one-time incorporation (pulse-labeling)
plant photosynthesis, subsequent translocation of radiolabeled C ass 2 of IdC
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plant during plant growth and respiration, and their ultimate transfer to solutions and irspired gases as the labelled mots die and decompose. ,
This methodology has been widely used in a num . .
decades in order to trace the flow 'of carbon through mp, ecosystems (Cald 1974; Dahlman and Kucera,1968; Milchunas et al.,1985, 1992). roth, Milchunas and translucent, gas tight chambers, labeling 2, ng sufficient the heads time (2-3 hr) for the plants to photosynthetically assirnilate the idCO 14C label with frequent measurements for about one 2. We will follow month i the moves into aboveground biomass (leaves), belowground biomass (roots stems, and microbial biomass, and ultimately, humus), into the soil solution organic carbon (DOC), dissolved inorganic 2 carbon DIC = CO ), and diss into the atmosphere 2 (as CO and Clk). This approa(ch will allow us to me
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and atmospheric pools, and rates of soil C tumove ..
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and belowground plant tissues) will be shi further analysis following the field season.pped toinvestigator's home laboratories for carbon transfer from plants to soils and the atmos n the ecosystem (e.g. plants toissoils),
dynanuc H is i.e.
verycarbon difficultis tocontinua!!y measure C being transfer transferred another rate wi h from s t out using a tracer approach. We propow to use idCO instead of
2 the stable e isotope 13CO greater sensitivity of I'C methods. In fact.13CO cannot be used effecti
problems associated with detecting small changes o in 13C relat C contains -1.1% 13C vs. -10 30% IdC. Further, cal the sample p costs for use of 83C would make an experiment of this scope impractical
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the atmosphere over approximately a two week period e ng event. De
gases over this two week period. He idCO that i
result of our labeling will be quickly diluted as it entersonsathe atmosphere below). The concentration of 14COz inu this concentration for IdCO 2 effluent of 3 x10 7 averageeffluent will level produced naturally in He pulse labeling approach outlined here provides the safest and m the atmosphere
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of quantifying carbon flow with minimal dismption to and still poses no safety risk.
ns the experime Experimental Details:
Physical Setting:
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Station. The sea will be posted and accessible only this project. We plan an on-site orientation and training session to insure ex security of the rimental site. Labeled solid and liquid phases will be contained withi led plants and soils remaining after the experiment. as well as as .
and NRC regulations for incineration or shipment to Hanford, WA. A post season survey of the site will be clean. conducted to insu e site is Authorized Users:
Authorized users associated with thisAn authorized user will be on sita at all .
California, Irvine), George W. Kling (profet are:
Michigan State University), Leanne JablonskiWil (Marine Biological Laboratory), and Jennifer Y. King (University of Calif omia, Irvine).
Expected EnvironmentalRelease:
We will use 2IdCO with a specific activity of 75 MBq/gC. Based on our e carbon flux studies. we assume an uptake rate of 50 Therefore, each plant-soil system should contain 3.75 MBq.
mgoflabeled C over the 2 carbo
. We propose labeling a maximum of 24 buckets in 1997. Thus the total amount o MBq. The 14CO will be quickly incorporated into theis plants 2 90 and a fractio respired by the plants. Based on many physiological studies and some of our l
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measurements2 of CO respiration. we estimate the about 50% of this IT will be respir by the plants as CO and CE in the first two weeks: the rest (45 Mbq) will be i into plant tissue (or into other pools in the plant-soil system e.g., microbes, dissolved constituents.
1994. Minoda etetc). About 3% of the gaseous effluent will be ITE (Minoda and Kimura al.,1996).
Converting to curies, we anticipate releasing a total of 1.2 microcuries or 1.2 millicuries over the two week period of peak plant respiration losses, or roughly 0.0 millicuries per day. This 0.085 millicuries will be quickly diluted in the air column ove roughly high over a10 mm2 100 x 10 m occupied by the 24 buckets. Therefore. with an air column 20 m area we have about 85 microcuries in 2000 m3 of 2air or a 14CO effluent concentration of 4.25 x10 8 14 day period, we estimate releases to be 5.95 x 10-7microcuries/ml air on a pe microcuries/ml air. The NRC regulatory limit for the average annual radioactivity in effluent 14CO is 3 x 10-7 ,
microcuries/ml. 2
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References:
Coleman.
Diego. D. C. and B. Fry (1991) Carbon isotope Techniques. Academic Press, San Caldwell. M. and L. B. Camp (1974) Belowground productivity of two cool desert communities. Oecologia 17: 123-130.
Dahlman.
14. EcologyR. and49(6):C. L. Kucera (1968) Tagging native grassland vegetation with carbon 1199-1203.
Eisenbud M.1981.
Health Physics The status of radioactive waste management: Needs for reassess 40:429-437, Mitchunas. D. G. and W. K. Lauenroth (1992). Carbon dynamics and estimates of primary production by harvest. l'C dilution, and IT turnover. Ecology 73(2):593-607.
Milchunas. D. G., W. K. Lauenroth, J. S. Singh. C. V. Cole, and H. W. Hunt (1985)
Root Plant plants. turnover and Soi! and production by l'C dilution: implications of carbon partitioning 88:353-365.
Minoda. T., M. Kimura and E. Wada (1996) Phoptosynthates as the dominant surces of
CW and CO in soil water and CH4 emitted to the atmosphere from paddy fields. J.
Geophys. Res.101(D15) 21091-21097.
Minoda. T and M. Kimura (1994) Contribution of photosynthesized carbon to the methane emitted from paddy fields. Geophys. Res. Lett. 21(19) 2007-2110.
Pearcy. W.. J. Ehleringer. H. A. Mooney, and PW Rundel (eds). (1991) Plant Physiological Ecology-Field Methods and Instmmentation Chapman and Hall. NY.
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