Regulatory Guide 10.4

Guide for the Preparation of Applications for Licenses to Process Source Material

ML13350A215
Person / Time
Issue date:	07/30/1976
From:	NRC/OSD
To:
References
RG-10.004
Download: ML13350A215 (10)

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U.S. NUCLEAR REGULATORY COMMISSION July 1976 REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 10.4 GUIDE FOR THE PREPARATION OF APPLICATIONS FOR

LICENSES TO PROCESS SOURCE MATERIAL

1. INTRODUCTION hexafluoride production, are not within the scope of this guide.

1.1 Purpose of Guide

1.4 As Low As Is Reasonably Achievable (ALARA)

This ouide describes the information needed to evaluate an application for a specific license to process Paragraph 20.1(c) of 10 CFR Part.20 states that source materials. Examples of such processing activities "... persons cngak,:d in activities under licenses issued are manufacture of depleted uranium and thorium, by the Nuclear Regulatory Commssion pursuant to the magnesium alloy products; shaping, grinding, and Atomic Energy Act of l954."as:amn nded, and the polishing of lenses containing thorium: and the manurac- Energy Reorganization'Act of 1974 should, in addition ture and distribution of other products containing to complying with the i'equirenicnts set foiti in this source material. part,make every reasoriable effort to maintain radiation exposures,. and.,,. elescs-0f radioactive materials in

1.2 Applicable Regulations effluents to' unretricted areas, as low as is reasonably achievable* '.Regulatory Guide 8.10, "Operating Philo- The Commission's rules and regulations concerning sophy for Maintaining Occupational Radiation Ex- licensing of source material are contained in Title 10, ..posuraisAs LOW; As Is Reasonably Achievable," provides Code of Federal Regulations, Part 40, "Licensing of 'ih, NRC :staff position on this important subject.

Source Material." Source material means (1) uranium or 'ALacineniapplicants should give consideration to the thorium, or any Combination thereof, in any physical 6*i:',, ,1Ai. philosophy, as described in Regulatory Guide chemical form or (2) ores that contain by weight 1/20 of "'-8.10, in thie development of plans for work with licensed one percent (0.05%) or more of uranium, tltoriutný.or ,ý'radioactive inaterials.

any combination thereof. Source materit:dbes not'

include special nuclear material. OthetI, regulations 1.5 General Licens.e-.

pertaining to source material licenses are':found.li 10

CFR Part 19, "Notices, Instructions and'Rep&rts to Although this guide pertains to the filing of applica.

Workers, Inspections;" 10 CFR Part 20, "Standards for tions for specific licenses, the applicant should be aware Protection Against Radiation, 10 CFR Part 71, of the existence of general license

s. General licenses are

"Packaging of Radioacti airi for Transport and effective without the filing of an application or the Transportation of Radioac' 0"M.*"'i'al Under Certain issuance of specific documents. (Specific licenses require Conditions;" and 10-& rPaRt4,70, "Fees for Facilities filing of an application and the Issuance of licensing and Materials Licetes Un'Zr th; Atomic Energy Act of documents to specific persons.)

1954, as Amoddedi".=The ,4plicant should study care- fully the rsgula&d'o id this guide and submit all information tiusted. 1.5.1 General License to Receive Tide to Source

'" Material

1.3 Items Requirinrg Separate Applications A general license to receive title, only, to source Activities that are related to the reactor fuel cycle, material is provided by §40.2 1. 10 CFR Part 40. Under such as uranium and thorium milling and uranium this general license, materials may be owned without USNRC REGULATORY GUIDES Comments thould be $*en to the Sacetety at She Comm'rissin. U5 Nu.clear Regulatory Conimiton.m Washington. OC ',SW. Aglontion Docket~ing en~d Regulatory Guides Old $Stued to describe and make available go the Public 5,,,ics,Sectiou.

melthods acceptable I* She PdRCstaff Of im~~meniling *Pacific Petit at the Corymrossiones tegulat.ono. to delineate techniques used be the $left on tvli The gwidots#reissued in I%&following tonbroaddie'.oons

lang specific problems a or S'tulated accidenits, ofto provide guidance to appl.

drift Regulaetory Ouid*% are not subtiluest tot togulationt. and comnplianice I Pows# Reactors 6 Products wvivhtheme i not le4,.red Methods end soltuions different from those set out.in patriarch end Test Rsterlts 7 T.raep@tiot.iof the guiotdoe *,t be ACCeptable if they provide a basis tor the findings req.,isaolto Fueus and Material& Facilities 4 OeCUPSIAMIHal Ietth the issuance Ot ort-wntei* ofta oeitnit or license by SheCommnission 4 (uosil~nmontet end $,long 0 Antotoust Review Commiventsf arndsuiggeettlonsl ot ,improvements ,1nthet guidds ate, encouraged 5 MeAer,.41 slid Plant protection 10 General be to-sted, as appropriat

e. to accomimodate coin

'teitnos,,and guides -. ltInformatlion the monglo nd to ;calle" neRw Of .. Poioancoo However. comnments on Copies of published qurid*& may be obta~ined by writtent request &inidcatin~g this gude. .1 0ec..eed Ailh.,, about two months &flat its issuance, will be psi divsieonsldolited to the U.S Nucleet Regulatory Commission. Washinuton. D C

titularly utetutf in avlele~uai St.. need For en ejsiS,revition 26. AttentionS Director, Office of Standards Developmeft

regard to quantity but may not be physically possessed above do not meet the applicant's needs, an application or used in any manner. should be filed on Form NRC-2. All items of the applica- tion form should be completed In sufficient detail for

1.S.2 General License for Possession of Small Quan- the NRC to determine that the applicant's equipment, tities facilities, and radiation protection program are adequate to protect health and ninimize danger to life and Section 40.22. 10 CFR Par, 40, provides a general property.

license for the use and transfer by certain persons for certain uses of up to 15 pounds of source material it Since the space provided un the application form is any one time provided that no more than 150 pounds of limited, the applicant should append additional sheets to source material arc received in any caletndar year. Note provide complete information. Each separate sheet or that the 15 pounds and 150 pounds of source material document submitted with the application should be refer to contained source material. For exdmple. 375 identified as to its purpose, e.g., response to an item of pounds of thorium-magnesium alloy containing 4% the application form, radtation safety instructions, etc.

thorium could be transferred and used at any one time under the general license. Five copies of the application should be completed.

The original and three copies should be mailed

1.5.3 General Licenses to Export to: Radioisotopes Licensing Branch, Division of Fuel Cycle and Material Safety, Office of Nuclear Material The export of source material in certain forms and Safety and Safeguards, U.S. Nuclear Regulatory Corn.

quantities is authorized by a number of general license mission, Washington, D.C. 20555. One copy should be provisions in §40.23. 10 CFR Part 40. If it is desired to retained by the applicant since the license will require, as export forms or quantities of source material that are a condition, that the institution follow the statements not provided for in the general licenses of §40.23, it will and representations set forth i. the application and any be necessary to file an application for a specific license supplement to it.

pursuant to § §40.31 and 40.33.

1.6 Exemptions 3.2 Proprietary Information Paragraphs 40.13(a) and (b) provide certain exemp- The applicant should not submit proprietary inform- tions from Commisson rules and regulations and ation unless it cannot be avoided in giving a complete requirements for licensing. If the concentration by description of the applicant's equipment, facilities, and weight of source material in the materials being radiation protection program. If the use of proprietary processed does not exceed 1/20th of one percent information cannot be avoided, the proprietary informa-

(0.05%) at any time during processing and use, such tion should be separated from the rest of the processing and use are cexempt from licensing. The application, and an application for withholding from receipt, possession, use, and transfer and the import of public inspection should be submitted in conformance

"unrefined and unprocessed" ore a:. also exempt from with the requirements of § 2.790 of 10 CFR Part 2.

licensing.

3.3 Environmental Information

2. LICENSE FEES

A formal environmental report is not specifically An application fee is required for most types of required for the type of activities included in the scope licenses. The applicant should refer to §170.31, of this document. However, the Commission has a

"Schedule of Fees for Materials Licenses," of 10 CFR responsibility to determine if the "conduct of any other Part 170 to determine the amount of the fee that must activity" will significantly affect the quality of the accompany the application. Review of the application environment when issuing new licenses or amendments and renewals of existing licenses. Certain large-scale will not begin until the proper fee is received by the NRC. processing operations and associated waste storage and disposal activities may require evaluation pursuant to 10

3. FILING AN APPLICATION CFR Part 51, "Licensing and Regulatory Policy and Procedures for Environmental Protection," unless the

3.1 Application Form NRC-2* information submitted clearly shows no significant impact on the environment from the proposed opera- When the exemptions or general licenses described tions. The information concerning effluents submitted to show lack of impact should cover all aspects of the operation and include the technical basis and rationale

"Form NRC-2 was fotmefly designated Form AEC.2. Existing copies of Form AEC-2 may still be used. See Appendix to this that support the evaluation of potential environmental guide. effects.

10.4.2

3.4 Safeguards materials in ambient air and water and in effluents by employing modern process. containment, and ventilation No safeguard information is required in an initial engineering to avoid unnecessary exposures. The limits application for licenses covered by this guide. in 10 CFR Part 20 are not to be considered as design limits. The analysis should include a narrative d',-:rip- The Commission uses an electronic data processing tion of the proposed possession and tise of sour:e procedure to record certain types of information materials from the time of receipt of raw materials to concerning source material. Tiis sytem uses a three- ultimate disposition of products and wastes. The letter Reporting Identification Symbol (RIS) to identify chemical and physical form. percent by weight. and total licensees who must submit material transfer reports and batch size for each step in a processing operation should periodic material status reports in accordance with be estimated. A sampling program may be required for

§40.64. 10 CFR Part 40. Applicants will be assigned a raw materials and when changing or initiating !,ew Reporting Identification Symbol and will be informed procedures to determine concentrations and quantities how it is to be used following issuance of the license. of source materials at each stage of a process. Each stacze This information will be forwarded under separate cover of a process should be con.i~dered in evaluating potential fullinwing issuance of a license or license amendment hazards. For example. the processing of uranium may authorizing greater than 1,000 kilograms of source produce dust in the processing rea., release radon material, daughter products. result in loose contamination iroin spills during transfers, and result in releases of dusts to

4. CONTENTS OF AN APPLICATION the environment from ventilatii system exhausts.

'

Many itenis on Form NRC-2 are self-explanatory. The Written radiation safety procedures and instructions following comments apply to the indicated items on covering all operations should be submitted. These Form NRC.2. should cover potential external radiation exposures to personnel; the possible production of gas. vapor. dust. or Item 4. Each site of use or storage should be given. other airborne radioactivity: generation of liquids Each site should be identified by street address. city, and containing suspended or dissolved materials: and the state. generation of solids as fines, scrap, slav. etc.. according to the process involved.

Item 7. A brief narrative description of services or products in which the source material will be used Item 10. A description of the training and experience should be submitted. of each person who will directly supervise the use of imaterial or who will have responsibilities for radiological Item 8. The physical form specification (Item 8(c)) or uranium chemical safety should be submitted.

should include percent by weight of source material.

This is necessary to determine the amount of source The description should include the type (on-the.job material to be covered by the license. For example, or formal course work). location, duration, and nature

2.000 pounds of monazite ore containing 5% natural (subject. depth, scope. etc.) of the training. Training thorium would contain 0.05 x 2,000 = 100 pounds of should cover (a) principles and practices of radiation source material. In this case, "5%- should be entered in protection. (b) radioactivity measurements, stanu'ardiza- Item 8(c) and "100 pounds" in 8(d). Percent specifica. tion. and monitoring techniques and instruments. (c)

tions may be given as a range. but the "Maximum mathematics and calculations basic to the use and Amount" (Item 8(d)) should be based on the upper measurement of radioactivity, (d) biological effects of limit. The maximum total quantity to be on hand (item radiation, and (c) principles and practices of protection

8(e)) should include all source materials, i.e., raw against the chemical toxicity of source materials.

materials, materials in process and storage, scrap materi- als, and wastes. The possession limit requested should be The description of the personal use of radioactive commensurate with the applicant's needs and facilities materials or equivalent experience should include the for safe handling and disposal. specific isotopes handled, the quantities of materials handled, the chemical and physical form of materials Item 9. An evaluation of the potential external and handled, where rthe experience was gained, the duration Internal radiation and uranium chemical* hazards to of experience, and the type of use. Personnel qualifica- workers and the public should be submitted. Applicants tions should be commensurate with the use of the are expected to utilize all practicable means for reducing materials as proposed in the application.

radiation levels and concentrations of radioactive Item 11. The equipment, facilities, and instrument:a- tion for each site of use soiould be described in detail.

• For soluble mixtures of U 238, U.234. and U-235 in air, chemical toxicity may be the limiting factor. See Footnote 3 to The proposed equipment and facilities for each opera- Appendix B. 10 CFR Part 20. tion must be adequate to protect health and minimize

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3.4 Safeguards materials in arbient air and water and in effluents by employing modern process. containment, and ventilatton No safeguard information is required in an initial engineering to avoid unnecessary exposures. Tihe limits application for licenses covered by this guide. in 10 CFR Part 20 arc not to be considered as desipi limits. The analysis should include a narrative d'.,crip- The Comnmission uses an electronic data processing tion of the proposed possession and use of sourxe procedure to record certain types of information materials from the time of receipt of raw mnateriab, to concerning source material. This sytem uses a three. ultimate disposition of products and waste-. The letter Reporting Identification Symbol (RIS) to identify chemical arid physical form. percent by weight. arid total licensees who must submit material transfer reports and batch size for each step in a processing operation should periodic material status reports in accordance with be estimated. A sampling program may be required for

§40.64, 10 CFR Part 40. Applicants will be assigned a raw materials and when changing or initiating new Reporting Identification Symbol and will be informed procedures to determine concentrations and quantitics how it is to be used followving issuance of the license. of source materials at each stage of a process. Each stage This information will be forwardc-d under separate cover of a process should be con.idered in evaluating potential following issuance of a license or license amendment hazards. For example. the processing of uranium may authorizing greater than 1,000 kilograms of source produce dust in the processing area, release radon material. daughter products, result in loose contamination trotm spills during transfers, and result in releases of dusts to

4. CONTENTS OF AN APPLICATION the environment from ventilatiL i system exhausts.

Many items on Form NRC.2 are self.explanatory. The Written radiation safety procedures and instructions following comments apply to the indicated items on covering all operations should be submitted. These Form NRC.2. should cover potential external radiation exposures to personnel; the possible production of gas. vapor. dust. or Item 4. Each site of use or storage should be given. other airborne radioactivity: generation of liquids Each site should be identified by street address, city, and containing suspended or dissolved materials: and th'>

state. generation of solids as fines. scrap. slag. etc.. according to the process involved.

Itcn 7. A brief narrative description of services or products in which the source material will be used Item 10. A description of the training and experience should be submitted. of each person who will directly supervise the use of ntaterial or who will have responsibilities for radiological Item 8. The physical form specification (Item 8(c)) or uranium chenical safety should be submitted.

should include percent by weight of source material.

This is necessary to determine the amount of source The description should include the type (on-the-job or formal course work), location, duration. and nature material to be covered by the license. For example,

2.000 pounds of monazite ore containing 57e natural (subject, depth, scope. etc.) of the training. Training thorium would contain 0.05 x 2,000 = 100 pounds of should cover (a) principles and practices of radiation source material. In this case, "5%" should be entered in protection, (b) radioactivity niasurencents. standardiza- Item 8(c) and "100 pounds" in 8(d). Percent specifica. tion, and monitoring techniques and instruments. (c)

tions may be given as a range. but the "Maximum mathematics and calculations basic to the use and Amount" (Item 8(d)) should be based on the upper measurement of radioactivity. (d) biological effects of limit. The maximum total quantity to be on hand (Item radiation, and (e) principles and practices of protection

8(e)) should include all source materials, i.e., raw against the chemical toxicity of source materials.

materials, materials in process and storage, scrap materi- The description of the personal use of radioactive als, and wastes. The possession limit requested should be commensurate with the applicant's needs and facilities materials or equivalent experience should include the for safe handling and disposal. specific isotopes handled, the quantities of materials handled, the chemical and physical form of materials handled, where the experience was gained, the duration Item 9. An evaluation of the potential external and of experience, and the type of use. Personnel qualifica- intemal radiation and uranium chemical$ hazards to workers and the public should be submitted. Applicants tions should be commensurate with the use of the materials as proposed in the application.

are expected to utilize all practicable means for reducing radiation levels and concentrations of radioactive Item 11. The equipment. facilities, and instrumenta- tion for each site of use should be described in detail.

• For sluble mixtures of U 238, U-234, and U-235 in air The proposed equipment and facilities for each opera- chemical toxicity may be the limriting factor. See Footnote 3 to Appendix B. 10 CFR Part 20. tion must be adequate to protect health and minimime

10.4-3

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danger to life and property. In describing equipment and of 10 CFR Part 20.0 Specification of a respiratory facilities, the following information should be included: protection program should include the following information:

a. Description of site. A description of the area surrounding each facility should be submitted estab. (I) A written management policy statement.

lishing distances to, and the use of, neighboring buildings Subjects to be covered by the policy statement include and facilities. A general site description should include the ;tse of practicable engineering controls instead of storage, processing, and waste holding areas. Restricted respirt.'ors; the use of respirators in routine, nonroutine, areas and methods for controlling access to such areas and emergency situations: and limits on periods of should be described. Diagrams of the plant layout respirator use and relief from respirator use.

depicting process areas, storage areas, laboratories, clothing change areas, offices, etc.. should be submitted. (2) Specification of respiratory equipment and Explanatory sketches, drawings, and process flow rationale for selection. Equipment approved under diagrams should be appended to the application, as appropriate approval schedules in 30 CFR Part I I of the appropriate. U.S. Bureau of Mines - National Institute for Occupa.

tional Safety and Health (NIOSH) should be used.

b. Description of storage facilities. Consideration of shielding, containment, and security of material should (3) Written operating procedures to cover training be included. of personnel and fitting, use, testing, cleaning, dczontamination, inspection, repair, and storage of c. Description of general safety equipment. A respiratory protection equipment.

description of protective clothing, general and personal air sampling equipment, fume hoods, waste receptacles, (4) A description of the air sampling program.

auxiliary shielding, "veste holding tanks, firefighting and fire prevention equipment, vacuum systems, safety (5) A description, of the bioassay program to showers, and any other equipment that would contrib. monitor effectiveness of the respiratory protection ute to safe- use of materials should be described as program.

i appropriate.

(6) A descriptiori of the medical evaluation d. Description of ventilation and containment program. Workers should be evaluated by competent systems, filters, dust collection devices, scrubbers. and medical personnel to ensure that they are physically and discharge stacks and vents. Ventilation and containment mentally able to wear respirators. These evaluations equipment should be described as it relates to the phase should be part of the employee's periodic physical or type, of processing of source material involved. examination.

Criteria and procedures for evaluating the performance of the equipment should be specified.

f. Description of the radiation detection instruments to be used.

e. Description of respiratory protection program.

Applicants are expected to consider means for reducing concentrations of airborne radioactive materials by (1) The manufacturer's name, Instrument model employing modern process, containment, and ventilation number, the number available, the type of radiation engineering controls whenever possible. The use of detected (alpha, beta, or gamma), the range (milliroent.

gens/hour, or counts/minute), the window thickness in respiratory equipment will not be considered an adequate substitute for a well.planned safety program mg/cm 2 , and type of use should be specified for each for reduction of potential airborne contamination. instrument. The type of use would normally be Section 20.103, 10 CFR Part 20, currently requires monitoring, surveying, assaying, or measuring.

applicants to obtain specific approval before making allowance for the protection afforded by use of respira. (2) The frequency and methods of calibration of tory protective devices. However, Commission require- instruments should be described, Daily or more frequent ments concerning respirators and associated protection operational checks of survey instruments should be factors are not meant to discourage their use as an additional precaution in routine operations, In *A notice of proposed amendments to §20.103, 10 CFR Part emergency situations, or in cases where protection from 20, was published for public comment on August 21. 1974 (39 respiratory hazards other than airborne radioactive FR 30164). Guidance as to acceptable methods of implement.

material is needed. 4% the proposed rule changes, such as protection factors and references to acceptable equipment, would be set out in a regulatory guide, and related technical Information would be provided in an associated manual. The regulatory guide and the A formal respiratory protection program may be manual will be issued following the adoption of the proposed established and approved pursuant to Section 20.103(c) amendments to § 20.103.

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supplemented periodically by a complete calibration of Item 12(c).

all ranges of each instrument. If survey instruments will not be returned to the manufacti-'- Fr calibration, a a. Radiation Survey Progra

m. A survey means an

0 detailed de;cription of planned calibr-tion procedures evaluation of the radiation hazards incident to produc- should be submitted. The description should include tion, use. release, disposal, or presence of radioactive standard sources to be used, facilities to be used, materials under a specific set of conditions. When pertinent experience of each individual who will perform appropriate, such evaluation in:ludes a physical sarvey the calibrations, and procedures to ensure safe and of 'he location of materials and equipment and measure- accurate calibrations. ments of levels cf radiation or concentrations of materials present.

g. Description of personnel monitoring equipment.

The type of equipment (film badges, TLD. pocket A more extensive survey program may be needed for dosimeters) to be used, the f-equency of evaluation, and evaluation and verification of potential hazards whether the devices are used to evaluate whole body or associated with pilot studies and initial phases of a full- extremity exposure should be specified. A description of scale produat',n ,.peration than is needed for day.to-day methods of calibrating and processing monitoring equip- operations within an established program. Provisions for ment or specification of the type of services to be evaluation ,,f all changes in operations should be made.

obtained from a commercial supplier should be submitted. The proposeJ survey program should he designed to monitor t!he adequacy of containment and control provi- sions for radiological safety purposes. The areas of Item 12 Radiological and uranium chremicall safety primary concern for source material operations are air procedures should be developed regarding all aspects of sampling, monitoring releases to unrestricted areas.

the radiation and uranium chemical safety program. surveying for personnel contamination, and surveying to These procedures should be established to ensure evaluate surface contamination. Gamma surveys of compliance with the provisions of 10 CFR i.'t, 19. processing and storage areas may be required for opera-

"Notices, Instructions and Reports to Workers; tions involving concentrated or pure source materials.

Inspections," and 10 CFR Part 20, "Standards for The types, methods, and frequency of surveys should be Protection Against Radiation." The procedures should described in detail as they relate to the type of progr:rm be specific to the activities for which a license is sough: involved.

and should cover all external and internal radiation hazards associated with these activities at all locations of (1) The survey program for evaluation of alpha use. contamination of personnel and plant surfaces should include provisions for monitoring protective clothing, hands, and feet of workers leaving restricted areas before Item 12[a). Safet, features and procedures. Safety breaks and at the end of shifts. Surveys of gloves and and fire prevention aipects of the program such as other protective clothing, equipment, or toots required storage of flammable or caustic reagents apart from during processing should be described.

source materials, temperature controls on dryers, or use of inert atmospheres in thorium-magnesium machining The survey program associated with cleanup should be described. efforts where dust or loose materials may be involved should be described. Reasonable efforts should be made Item 12(b). Emergency and decontamination to remove all residual contamination.

procedures. A copy of emergency procedures to be posted in all laboratory or work areas where radioactive Surface contamination evaluation should include materials are used should be submitted. These instruc- unrestricted areas such as lunch rooms, offices. etc.

tions should describe immediate action to be taken in Acceptable limits of fixed and removable contamination for facilities and equipment should be established and case of an emergency in order to prevent release of submitted.

radioactive material or further contamination of work areas and personnel. Examples of emergency procedures are turning off the ventilation systems, evacuation of the (2) Acceptable limits of fixed and removable area, re-entry, procedures for containment of spills, etc. contamination for fa:iities and equipment to be released for unrestricted use should also be established The instructions should specifically state the names and telephone numbers of responsible persons to be notified.

and submitted. For example, if, after reasonable efforts to remove all residual contamination, maximum alpha readings are 3,000 dpm/100 cm2 or less and the average is 1,000 dpm/100 cm 2 , unrestricted use is permissible

• For gluble mixtures of U.238. U-234, and U-235 in air, provided that removable alpha contamination does not chemical toxicity may be the limiting factor. See Footnote 3 to exceed 200 dpm/100 cm2 . These guidelines apply to Appendix B, IOCFR Put 20.

10.4-5

natural thorium. For natural and depleted uranium, the of the package, notification of the shipper and the levels may be a factor of 5 higher. Commission is required by §20.205, 10 CFR Part 20.

(3) A description of an air sampling program f. Procedures for training personnel. A description of should define the areas where samples will be taken, the the training programs for all personnel who arc involved frequency of sampling, and appropriate spatial relation- in or associated with the use of materials should be ship between sampling locations and workers' breathing submitted. The description should include the form of Lones. The type (gross alpha, fluorimetric, etc.), justifi- training (formal course work, lectures, on-the-job cation for, and sensitivity of assays that will be instruction, written instruction, or manuals), duration of performed to evaluate air samples should be described. training, retraining provisions, and the subject matter to The methods used to relate sample results to actual be included. Copies of training procedures and manuals personnel exposure should be described. If air sampling should be submitted.

instruments %%illnot be returned to the manufacturer for calibration, the methods, frequency, and standards used Itent 13. The description of the waste disposal for calibration should be specified. program should specify the quantities and types of radioactive waste products generated by all phases of

(4) The effluent monitoring program for releases operation. Consideration should be given to the disposal to unrestricted areas should encompass all airborne and of contaminated equipment such as filters, tools, process liquid releases. Calculational evaluations should be equipment. scrap, fines, and any wastes generated from supplemented by stack monitoring, waste stream molding, grinding, or machining operations. Airborne monitoring, water sampling, or other environmental wastes released from processing facilities, ventilation m-,nitoring as appropriat, for the planned and potential systems, or dust collection systems, and liquids and releases of radioactive materials. solids from chemical processing and melting should be considered where such processes are involved.

b. Specification of radiation safety responsibilities and duties. The responsibilities and duties of manage- Wastes generated ps a result of operations involving ment, any radiation safety committees, radiation safety source materials should be disposed of in a safe manner.

officers, and use of consultants should be established Sections 20.301 through 20.305, 10 CFR Part 20, deal and clearly described. Individuals having radiation safety with waste disposal. The applicant should specifically responsibilities should be identified by name and each describe waste disposal methods and procedures.

individual's pertinent training and experience described.

Assignment of duties should cover all aspects of the Wastes which are soluble or readily dispersible in radiation safety program. water may be disposed of in the sanitary sewer system subject to the concentration and the daily, monthly, and c. Bioassay program. Regulatory Guide 8.11, annual limits specified in § 20.303, 10 CFR Part 20. For

"Applications of Bioassay for Uranium." outlines the example, up to one millicurie of natural uranium may be information to be submitted concerning a bioassay disposed of daily provided the concentration in sewage program. Regulatory Guide 8.11 specifically deals with does not exceed 1 x 10-3 microcuries/ml when diluted depleted, natural, and enriched uranium; however, some by the licensee's average daily quantity of sewage. Sewer of the methods and concepts are applicable to thorium. disposal of radioactive materials by a licensee Is limited to a total of one curie/year and average monthly d. Records management. Provisions for keeping and concentrations not exceeding restricted area water reviewing records of surveys, material inventories, concentrations.

personnel exposures, and receipt, use, and disposal of materials should be described. Wastes may be buried in soil. Such burials are subject to the four-foot depth. six-foot separation, and

12-per-year limitations of §20.304, 10 CFR Part 20.

e. Materials control provisions. Procedures for The quantity per burial is limited to 100 rnmllicuries for ordering materials, for notification of responsible source materials (330 pounds of natural uranium).

persons upon receipt, and for safely opening packages should be submitted. Section 20.205, 10 CFR Part 20, The most commonly used method of disposal is requires monitoring of certain packages upon receipt transfer to a commercial firm licensed to accept such depending on the quantity of contained material and Its wastes. Lists of such firms are available from the form. Monitoring of external package surfaces for Commission upon request. In dealing with such firms, contamination is required upon receipt of packages prior contact is recommended to determine specific containing more than I millicurie of source materials services provided.

(greater than 3.3 pounds of natural uranium). If removable contamination in excess of 0.01 If other methods of disposal are requested, the microcuries/l00 cm2 is found on the external surfaces information specified in §20.302. 10 CFR Part 20,

10.4-6

should be submittcd. The information should include radioactive materials from the products and the basis for the quantities and kind of materials, levels of radio- these estimates.

activity, a description of the manner and conditions of disposal, and evaluation of environmental effects, and 5. AMENDMENTS TO LICENSES

control procedures.

Licensees are required to conduct their programs in Any long-range disposal plans for large volumes of accordance with statements, rcprescntationis, and low concentration source material waste should be procedures contained in the licenso application and described. Applications for processing operations, such supportive documents. The license must therefore b.

as rare earth extraction, that generate large volumes of aniended if the licensee plans to make any changes in wastes should include detailed specific plans for ultimate facilities, equipment (including monitoring and survey disposal of such materials. instruments), procedures, personnel, or source material to be used.

When such wastes are to be held for significant periods of time on site in basins, etc., adequate provi- Applications for license amendments may be filed sions for containment, security, and long-term control either on the application form or in letter form. The should be made. Plans for any interim type of storage application should identify the license by number and should be described in detail. should clearly describe the exact nature of the changes.

additions, or deletions. References to previously submitted information and documents should be clear Ihem 14. If distribution of products containing and specific and should identify the pertinent informa- source material is planned, the detailed description of tion by date, page, and paragraph.

the products outlined in Item 14 of the application Form NRC-2 should be supplemented, as appropriate,

6. RENEWAL OF A LICENSE

with the following:

An application for renewal of a license should be filed a. A description of the quality assurance program, at least 30 days prior to the expiration date. This will including process control measures, sampling plans, ensure that the license does not expire until final action product examination and testing, acceptance criteria. on the application has been taken by the NRC as and testing and examination of prototype or production provided for in paragraph 40.43(b) of 10 CFR Part 40.

products, which establishes that the products will consistently have the radiation safety characteristics Renewal applications should be filed on the Form described to the Commission and that these charac- NRC-2, appropriately supplemented, and should contain teristics will not be significantly degraded over the complete and up-to-date information about the expected lifetime of each product. applicant's current program.

b. If appropriate, a description of labeling, including In order to facilitate the review process, the applica- label materials, content, location on the product, and tion for renewal should be submitted without reference method of attachment. to previously submitted documents and information. If such references cannot be avoided, they should be clear c. Estimates of radiation doses to users of the and specific and should identify the pertinent informa- products and others who 'may be exposed to radiation or tion by date, page. and paragraph.

10.4-7

APPENDIX

fORM CC-2 FORM APPROVED

(- OUREAU OF BUDOET NO 3-Ao002 UNITED STATES ATOMIC ENERGY COMMISSION

APPLICATION FOR SOURCE MATERIAL LICENSE

Pursuant to the regulations in Title 10, Code ot Federal Regulations, Chapter 1, Part 40, application is hereby made for a license to receive, possess, use, transfer, deliver or import into the United States, source material for the activity or activities described.

1. tCAch o*4) 2. N1AME OF APPLICANT

0 (a) New license C (b) Amendment to License No. 3. PRINCIPAL auSINES.S ADODESIS

3 (c) Renewal of License No.

O (d) Previous License No.

4 STATE THE ADDRESSIES) AT WHICH SOURCE MATERIAL WILL oB POSSESSED OR USED

5 BUSINESS OR OCCUPATION (1&. IF APP.ICANT IS AN INDIVIDUAL. STATE (b) AGE

CITIsrs I

7 DESCRIBE PUIRPOS.* FOR WHICH SOURCE MATERIAL WILL BEr USED

0 %TATE THE TYPE OR TYPES. CHEMICAL FORM OR FORMS. AND QUANTITIES OF SOURCE MATERIAL YOU PROPOSE TO 1RE1CCIVE.

POSSESS. USC. OR TRANSFER UNDER THE LICENSE

(a) TYPE (b) CHEMICAL FORM (c) PHYSICAL FORM (Includin (cd) MAXIMUM AMOUNT AT

% U or Th.) ANY ONE TIME (in pounds)

NATUHAL URANIUM

URANIUM DEPLETID IN

THE U-235 ISOTOPE

THORIUM tIsOrOPLi (a) MAXIMUM TOTAL QUANTITY OFr 6OUV4CE MATERIAL YOU WILL. HAVE ON HAND AT ANY TIME (.inpou~d.1

9 DESCRIBE THE CHEMICAL. PHYSICAL. METALLURGICAL. OR NUCLEAR PROCESS OR PROCCISES IN WHICH THE SOURCE MATIERIAL.WILL

BE USED. I NOICATING THE MAXIMUM AMOUNT OF SOURCE MATERIAL INVOLVED IN EACH PROCESS AT ANY ONE TIME. AND PROVIDING

A THOROUGH EVALUATION Or THE POTENTIAL RADIATION HAZARDS ASSOCIATED WITH EACH STEP OF THOSE PROCESSES.

10 OISCRcIIUE THE MINIMUM TECHNICAL OUALIFICATIONS INCLUDING TRAINING AND 1EXPERIENCE THAT WILL BE RECUIRO OC" AP-

PLICANT'S SUPERVISORY PERSONNEL INCLUDING PERSON RESPONSIBLE FOR RADIATION SAFcTy PROGRAM (OR OF APPLICANT IF

APPLICANT IS AN INDIVIDUAL).

1l OfSCRIBE THE LOUIPMENT AND FACILITIES WHICH WILL 0E USED TO PROTECT HEALTH AND MINIMIZe OANGEIR TO LIFE OR PROPERTY

AND RDELAfE 1 HE kjU.E OF THEN LOUIPM ENT ANOFACILITIES TOTHE OPERATIONS LISTEo IN ITEJM gINCLUODE(a)RAOIATtONPDETECTION

AND RELA T ED INTF1UMENTS including (*,m badgln. dosdmctIn counters, lit sampling. and other survey equtpmrriwtsoappeovelate. The d,.etiptlon o1 tiC,* ftln* IA)lI Icilu*.lt the Inttrumnet characteristic* ouch as type of radiation detectd. window Ihicbnfst, and the rgnsr(e) of each in.

rtadltl-fi ICIftI~tPIt If~c stUwme4flt).

(6) METHOD. *FREQUENCY. AND STANDARDS USED IN CALIBRATING INSTRUMENTS LISTED IN (W) ABOVE. INCLUDING AIR SAMPLINGI

EQUIPMENT (for fim badges. sprtrfy method of casltahl and processing or amem guppli*i).

10.4.8

APPENDIX-Continued Page 2

1I(c). VENTILATION ECQUIPMENT WHICH WILL BE U!;rD IN OPERATIONS WHICH PRoDUCc DUo?. rumes. MI*S. OR GA5C:E. INCLUDING

PLAN VIEW SHOWIN4G TYPE AND LOCATIONOF HOOD0 ANDr ILTCES.MINIMUM VELOCITIES MAINTAINCOAT H10 OPLSNI.G AND PRO.

CEOURES FO)l TESTING SUCH EQUIPMENT

It. DESCRIBE PROPOSED PROCEDURES TO PROTECT HECALTH AND MINIMIZC DANGER TO LI4E A^NO PROPERTY AND RELATE I*"ENE PRO.

CEDURES TO THE OPERATIONS LISTED IN ITEM 9ý INCLUDE (e) SAFrTY FEATURES AND P4OCCDURnEs TU AVOID NONNUCLLA" AC"I.

CENTS, SUCH AS FIRE. EXPLOSION. ETC , IN sOURCC MATERIAL STORAGE AND PsG'oCcSsaG AMFAI,

4b) EMERGENCY tb)n ~

--, -V"N

-MREC

HLLV NTO

r~5.l*CLLL JML-

ACCIDENTý!""'C" MIGHT INVOLVE SOURCE MATERIAL

H

() DETAILED DESCRIPTION OF RAOIAl ION SURVrEY PROGRAM AND PROCEDURES.

1I. WASTE PRODUCTS: If none will be gellerelted. state "'None" opposite (a). below. It waste products will be dener.

ated. check here 0 and esplain on a supplemental sheet:

(a) Quantity and type or radioactive waste that will be generated.

(b) Detailed procedures for waste disposal.

I&.IF PRODUCTS FOR DISTRIBUTION TO THE GENERAL PUBLIC UNDER AN EXEMPTION CONTAINED IN

10 CFR 40 ARE TO BE MANUFACTURED, USE A SUPPLEMENTAL SHEET TO FURNISH A DETAILED

DESCRIPTION OF THE PRODUCT. INCLUDING:

(a) PERCENT SOURCE MATERIAL IN THE PRODUCT AND ITS LOCATION IN THE PRODUCT.

(b) PHYSICAL DESCRIPTION OF THE PRODUCT INCLUDING CHARACTERISTICS. IF ANY. THAT WILL

PREVENT INHALATION OR INGESTION OF SOURCE MATERIAL THAT MIGHT BE SEPARATED

FROM THE PRODUCT.

(c) BETA AND BETA PLUS GAMMA RADIATION LEVELS (Specify instrument used. date of calibrationand calibration technique used) AT THI SURFACE OF THE PRODUCT AND AT 12 INCHES.

(d) METHOD OF ASSURING THAT SOURCE MATERIAL CANNOT BE DISASSOCIATED FROM THE MAN.

UFACTURED PRODUCT.

CERTIFICATE

(This item must be completed by applicant)

is. The applicant,and any official executing this certificate on behalf of the applicant named in Item 2, certify that this applicationis preparedin conformity with Title 10, Code of Federal Regulations, Part 40, and that all information contained herein, including any supplements attachedhereto, is true and correct to the beat of our knowledge and belief.

lApph~eant na~med In haem 3)

Dated BY:

APrent of type name under u'ans lueir)

,Tart ut ..- II'Iwng 0MCe', .) ther,,ed' atoanE behalf of AhcapplwatsC

WAItNlN.%(: 1.11 Jue'*V. 1918;t "1 Six(. 749; makmh II.S.I. Sreclioti 1001. Art iruni tshaefrnmineal Ouinje to MakP a Will(Ully UNA' ,IaC S

meni or rt'plrr~t~snticin lo an) departmenl torallene of the' Unlied Slhiell 9410 anY Muller within Its JurisdIction.

it u's ovwma4l mIft pU Inoaal@

10.4.9