ML19221B210

Reg Guide 10.3,Revision 1, Guide for Preparation of Applications for SNM Licenses of Less than Critical Mass Quantities

ML19221B210
Person / Time
Issue date:	04/30/1977
From:	NRC OFFICE OF STANDARDS DEVELOPMENT
To:
References
REGGD-10.003, NUDOCS 7907200044
Download: ML19221B210 (7)

Text

..

Revision 1

,/j g*

U.S. NUCLEAR REGULATORY COMMISSION April 1977

@ @N ' a f,%

i i REGREORY GUD DE 5

OFFICE OF STANDARDS DEVELOPMENT o

REGULATORY GUIDE 10.3 GUIDE FOR THE PREPARATION OF APPLICATIONS FOR SPECIAL NUCLEAR MATERIAL LICENSES OF LESS THAN CRITICAL MASS QUANTITIES

1. INTRODUCTION 10, Code of Federal Regulations. Speci. nuclear material, by definition in 10 CFR Part 70, means 1.1 Purpose of Guide r.lutonium, uranium-233, uranium enriched in the isotope 233 or in the isotope.

1 any other This guide describes the type of information material that the Commission _

mines to be needed to evaluate an application for a specinc special nuclear material or any ma...ial artificialk license for receipt, possession, use, and transfer of enriched by any of :he foregoing. In addition to 10 special nuclear material. It is intended for applicants CFR Part 70, the regulations pertaining to special requesting authorization to possess and use up to nuclear material licenses are found in 10 CFR Part 2,000 grams of plutonium, total, in the form of sealed 19, " Notices, Instructions, and Reports to Workers, plutonium-beryllium neutron sources, and an)

Inspections;" 10 CFR Part 20, " Standards for special nuclear material in quantities and forms not Protection Agamst Radiation;" 10 CFR Part 71, sufficient to form a critierJ mass. The latter quantities

" Packaging of Radioactise N1aterial for Transport are considered to be 350 grams of contained and Transportation of Radioactive N1aterial Under uranium-235, 200 grams of uranium-233,200 grams Certain Conditions;" and 10 CFR Part 170 " Fees for of plutomam (in any form other than plutoniura-Facilities and State-ials Licenses Under the Atomic beryllium neutron sources), or any combination of Energy Act of !954, as Amended.' The applicant them in accordance with the following formula:

should study carefully the regulations and this guide and should submit all information quested.

grams U-235 + ' grams U-233 + grams Pu 1

=

350 200 200 1.3 Items Requiring Separate Apr ications For each kind of special nuclear material, the appli-Activities that invohe the receipt, possession, use, cant should determine the ratio between the re-and transfer of special nud mateial in quantities cuested quantity of that special nuclear material and aad forms sufficient to forr.. a c itical mass are not the quantity specified above for the same kind of within the scope of this guide.

special nuclear material. The sum of such ratios for all kinds of special nuclear material in combination 1.4 As Low As is Reawnahh Achiciable ( AI AR A i should not exceed unity if this guide is applicable.

For example, the following in combination w ould not Paragraph 20.1(c) of 10 CFR Part 20 states that exceed the limitation of the formula:

. persons engaged in activities under licenses is-sued by the Nuclear Regula ry Commission pur-175 (grams contained U-235) suant to the Atomic Energy A.t af 1954, as amended, 350 and the Energy Reorgandation Act of 1974 should, 50 (grams U-233) + 50 (grams Pu) in addition to complying with tae requirements set A

g

+

forth in this rart, make every reasonable effort to 1

=

C 00

'00 maintain radiation exposaes, and releases of a

1.2 Applicable Regulations radioactive materials in effluents to unrestricted Special nuclear material licenses are issued pur-areas, as low as is reasonably achiesable "

g suant to Part 70,"Special Nuclear N1aterial," of Title Regulatory Guide 8.10, " Operating Philosophy for

.P USNRC REGULATG AY GUIDES v

nv-

!u-e 7 ~,.r.,,..,

<g-r w v"+-

e

' ~ r m,

.a.

, m

..r r,s

,.y y >=s j.I f I

d' lt P

900 r1*-

t 4. f rJ ' i08 Y,

t jt i rd*P g ffp j, se je',

• 4 i rf en I g

'q WiI-l nd t-),9

(

,I 5

W 'j e-

=#

U

$ l h

II (

J J.II# N

.pe e

>t r,,t..'

tes 4 eq ; l rsl i e

gen,'*j t t, p g

t e s, g iir crl 1

WW * ' '

b d 1

8.ie * #

nf+

gr u j i.,

?

.f' f

se*

.s q

fte J., e lem W, L 1 t ia.

pg

""'""d'"!

'd

%i

.,) e s e I py l

,.j+,

F e'

y

'83, f a sg e

p

, e C f vuY'.P*f t,ers jW.J J,M1

% f<w vos e-1%

QU -(D',

.6r e e f )yessj af dit r

p p

p

,_9

,j,,g

, j,

t v rr'Ir g

.g ngj ry,e jeg qrtg i'i {# #

, gor j reg y g4 jg y

g twNris gj gY P (

reteri'g 31(j e

6 6

0 t f I f

1 3

e il I F 4 6'f k s k-

,j,,'

q.,:

,i,gt,..

,c,

,=f ta v e+

• t wevy.til..r w. m oe e s e

e Yk s q. e e, c, ev.<,e< j 45 4 r emy :, o f J

qq.

g i

,y

,,ta.

..g

,, p, j e

,5 g g.,t t,,,evy n,r m9.

y

.tw.p,

y rme+% r *. e ea,

[, f 1'-

J I' t

f'

e..

Maintaining Occupational Radiation Expo 3ure As processing procedure to record the location, by Low As is Reasonably Achievable," prosides the licensee, of special nuclear material. This system uses N RC staff position on this important subject. License a three-letter Reporting Identification Sy mbol (RIS) apphcants should gise consideration to the ALAR A to identify licensees who must submit material philosophy, as described in Regulatory Guide 8.10. m transfer reports and periodic material status reports the desclopment of plans for w ork with licensed in accordance with M70 53. " Material Status radioactne materials.

Reports,' and 70.54. " Nuclear 51aterial Transfer Reports," of 10 CFR Pait 70. Applicants will be as-

2. LICENSE FEES signed an RIS and will be informed how it is to he used following issuance of the beense. Requirements An appheation fee n required for most types of for report, will be forwarded under separate coser heenset The appheant should refer to 5170.31, followine the issuance of either a license or an

" Schedule of Fees for Materials LicensesJ of 10 am endm'ent authorizing greater than 1 gram of Cl R Part 170 to detcrmme the amount of the fee that special nuclear material.

must accompany the appheation. Resiew of the ap-phcatien will not begin until the proper fee is recened No informa, ion concernmg criticahty prosisions 53 the NRC is required if no more than 450 grams of plutonium as plutonium-berylhum neutron sources are requested

3. FILING AN APPLICATION For quantities greater than 450 g;ams as neutron sources, no < oticality information is required A license app;ication for special nuclear material prosided adequate proccJures to ensure that no more shou!d be filed m letter form and should preside the than 450 grams will be used or stored at any smgle information specified in 470Z, " Contents of Ap-site are submitted piications, of 10 CFR Part 70. All items should be completed in sufficient detail for the NRC to deter-

4. CONTENTS OF AN APPLICATION mine that the apphcant's equipment. facdities, and radiation protection program are adegaate to protect health and mimr.ute danger to hfe and preperty.

4.1 Specification of Applicant Fach separate sheet or document submitted with The applicant corporation. institution, gos ernment the appheation sheuld be identified as to its purpose.

acenes. or other leeal er ta, -uld be spedfk,,3

~

u 0 e c.

response to an item of the regulation. radiation n'ame. street addresl of prmeipal of fice and the state safety instructions etc. Sesen copies of the applica-w here incorpcrated. Ans control or ow nership exer-tion should be completed. The original and fise cised over the applican't bs ans ahen, foreign cor-copies should be mailed to; Radioisotopes Licensing forcien gos erninent should be indicated 20 Branch, Dnision of Fuel ( scle and Material Safets.

t.

Office of Nuclear Material Safety and Safeguard's.

I.he prmeipal ofheials of the applicant corporation should be mdicated hs name, title. address. and

[. S; Nuclear Regulatory t ommission. W.ashington' citizenship. Indisiduals should he designated as the DL M One ceps of the apphcation. with all at-app nt dy

d. W u s e of & pa! nudear tachments. should he'retair.ed by the applicant, since material is lot connected with employ ment with a the beense will require, as a condition, that the corporation or other entity. If the appheant n an in-ljcensee f ollow the statements and representations set disidual, the indinJual should be specified bs full f orth m the appucation and any suppiement to i name, age, citizenship. and street addr ess. incl' ding u

state and zip code. The indnidual applicant should 3.1 Proprietary Information also irdicate three personal references identified by name, address, and citizenship.

The mformation reqmred in applications usually can ne Presented without.ne use of proprietary data.

% hen its use cannot be asoWed. the proprietary m-4 2 Specification of Actisities lo He Performed fo r m a t io n hould he separated f rom the rest of the apphcatior, and an appheation for withholding from The operations for w hich the special nuclear pubhc mspection should be made in accordance with material will be used and a general plan for carry me the requirements of d2 MO of 10 CFR Part 2. " Rules out the actaity should be described. This informanon of Practice '

hould be specified for each location where the spscial nuclear material will be used Each indisidua' operation should he described T he purpose of this 3.2 Safeguards and Criticality descriptne information is to enable the Comnussion to determme that the special nuclear material will be For heenses meluded in the scope of this guide, no used for activines pernutted under the Comnussion's safeguard information is required in an imtial ap-regulations and the Atomic Energy Act of 1954. as phcanon The Commission uses an electronie data amended.

156 236 10.3-2

4,3 Npecincation of Special Nuclear Tlaterial

1. The number, type, and length of remote handl-ing devices.

The special nuclear material requested should be identiGed by isotope; chemical or physical form; ac.

2. Storage containers and facihties Consideration tiuty in curies, millicuries, or microcuries; and mass

1. both shielding and security of materials should be in grams. Specification of isotope should include indiuted.

principal isotope and significant contaminants. Ma-

3. Containers, deuces, protectise clothing, aux-ior dose-contributmg contammants present or ex-iliary shieldmg, general laboratory equipment. Jr pected to build up are of particular interest. For ex-sampiing equipment, etc., actually employed in the a mple, the quantity ca plutomum-236 pre sent in daily use of material. Shielding and containment plutonium 236 should be specified prosision for loose materials designed to mimmize Possession limits requested should coser the total anticipated msentory, including stored materials and

4. Physical plant, laboratory, or working area w aste.

facilities A description of all fume hoods, glos e boxes, u a,te receptacles, special sinks, s en tila tion if the apphcation is for a sealed source or plated and cor tainment systems, efnuent filter systems, m-source, the special r,uclear material content and c lin; the design specifications and capabihties of manufacturer's name and model number of each these s ystems, should be meluded. All processing, 3ealed or plated source should be specified. If a sealed work, and change areas should be described Ap-source will be used m a desice(holder, gage, analyzer plications for chemical or physical processmg opera-etel, the manufseturer's name and model number of tions should include a description of the controls for the deuce should be identified Each sour e shou ld fire presention and the fi r e fig h tin g equipment bc keyed to the specine deuces used with it.

asailable. Sketches showmg laboratory or plant ar-rangements and the nature and use of areas aducent 4.4 Technical Qualifications of Personnel to areas in w hich special nuclear matenals will be processed should be submitted A resume of the training and experience of each

5. Radiation detection instruments to be used The person who will directly supersise the use of material manufacturer's name and model numbers, the or w dl have radiological safety recponsibilities should number of each tspe available, the is ne of radiation be submitted The resume should include the type of detected (alpha, beta, gamma, or neutron), the sen-traming (e g, on-the job or formal course work),

the location where the training was receised, and the sitiuty range (milbroentgens per hour, neutrons per second, or counts per minute), the wmdow tha.kness duration of the trainmg. Training should include sub-in mg/cmL and the type of use for each instrument ject., such as (1) prmeiples and practices of radiation should be specified. The type of use would noimally protection, Q radioactiuty measurements, standard-be monitoring, suneying. assaying, or measuring i/ation, and monimring techmques and instru-Instrument calibration prosisn'ns should be ments (3) mathematics and calculations basic to the described. State the frequency, and describe the l

• use and measurement of radioactisits, and (4) bioloeical effects of radiation. The description of the methods and procedures for cahbration of sursey actuai use of radioactise materials or equnalent ex.

and monitoring instruments, as well as any other m-perience should melude the specific isotopes handled, struments and systems used in the radiation protec-the maumum quantities of materials handled, where tion program, such as measurmg instruments used to the esperwnee was cained, the duration of ex.

assay sealed 60urce leak-test samples. contammation perience, and the ty p'e of use. The qualiEcations.

samples (e g., air samples, surface smear-test sam-traming, and experience should be commensurate ples), and bioassay samples (see Item 4 6 3 3) wit'i the proposed use of the material requested in the An adequate cahbration of survey instruments ;

apphcation usually cannot be performed with built-m check sources. Electrome calibrations that do not msohe a 4,5 De,criptior of Equipment, Facilities. and source of radiation are also not adequate to deter-imtrumentation mme the proper f unctioning and response of all com-ponents of an instrument j

The equipment, facihties, and radiationdetection Wily or other frequent checks of sursey mstro i instr amentation for each site of use should be ments should be supplemented escry 6 months with a described in detail. The proposed equipment and two-point cabbration on each scale of each mstru '

facihties for each act uty must be adequate to protect health and mimmize danger to life and property. In ment with the two points separated by at least 50 ; of I the scale. Surves instruments should also be describing asailable e luipment and facihtics, the fol-cahbrated followide repair. A sursey instrument may l lowing types of mfor n "

should be mch ded _,

m appropriate:

• i mes me s Aura 1e enes fre crew we 10.3-3 u-

he considered properly cahbrated when the instru-

d. Step-by-step calibration procedures anJ. if I

,i ment readmps are within il07 of the calculated or appropriate, associated radiation safety procedures, know n salues for each point checked. Readings and withm ? 207 are considered acceptable if a calibra-l tmn thart or graph is prepared and attached to the in-

e. The name and pertinen. experience of each i

strument person w ho w di perform the instrument calibrations.

If the applicant proposes to eahbrate his sursey 4.6 Proposed Procedures To Protut llealth and detailed description of planned N1inimiie I) anger i n s t r u m e n t s.

a cahbration proecdurcs should be submitted The description of cahbration procedures should include.

Procedures should be estabbshed to ensure com-as a mimmum:

phang with prousions of 10 CFR Part 19. " Notices.

Instructions, and Reports to Workers; inspections, a The manufacturer and model number of and 10 CFR Part 20. " Standards for Protection j each radiation source to be used, A pin,st Radiationf The procedures should be specific for the actiuties for u hich a heense is sought.

b. The nuclide anj quantity of radioactise Depending on the types and quantities of materiah material contamed in ach source, and the. cope of use, the following information should be submitted:

e. The accuracy 01 each source. The traceability of the source to a pre ary standard 4.6.1 Specification of Radiation Sa fe t y Respon-should be prosided.

sibilities and I)uties d 1 he step-by-step procedures, includmg as-The responsibihties and duties e management, r

sociated radiation safety procedures, and any radiation safety committees, radiation saf ety of-Ocers, and users should be cleark estabhshed In-

e. The name and pertinent experience of each disiduals havmg radiation safety responsibilities

~

person w ho will perform the calibrations.

should be identified by name, and pertinent training and experience should be described (see Section 4 4)

If the appheant intends to contract out the Assignment of duties should coser all aspects of the eahbration of sursey instruments, the name. address, radiation safety progiam.

and license number of the cahbration firm should be specified together with the frequency of calibration.

4.6.2 Personnel Alonitoring T he appheant should contact the firm that will per-

1. Personnel monitormg equipment (film badge, f orm the cahbration, to determine if information T LD, dosimeters) shot ld be specified, including the encerning calibration procedures has been filed with ty pe of radiation monitored (beta, ga m ma, or i the Ommission. If mformation concerning cahbra-neutron), the frequency of esaluation, and the ty pe of tion pri edures has not been filed, it should be ob-ser. ices to be obtained from a commercial suppher.

tained and submitted This specification should include w hether the m initoring is to esaluate w hole body or extremity ev Quantita ise measurme nstruments used to posure. If dosimeters are to be used, the type, range, monitor the idequacy of' containment and con.

frequency of reading, and maintenance and cahb.a-tammation control such as those used for measuring tion prousions should be specified leak-test,

,or, efDuen t, bioassay, work area, and

2. If no personnel monitoring is specified, the equipment contamination s..mples should usually be applicant should submit an evaluation of expected cabbrated prior to each use. The procedures and fre-exposures from the proposed use. This evaluation l quency for calibration of such instruments should be should demonstrate that no indisidual is hkeh to

- subnutted and should include:

~

receise a dose in any calendar quarter in excess of 0.31 rems to the w hole body, blood-forming organs.

a.

The name of the manufacturer and model lens of the eye, or gonads; 4 69 rems to extremities number of each of the standards to be used, (hands, forearms, feet, or anklest or 1.XX rems to the skin of the whole body from all sources and types of

b. The nuchde and quantity of radioactise occupational exposuret materi.;i contained in each of the standard sources,

c. A statement of the accuracy of each of the

3. For processing operations w here a potential standard sources The source accuracy should be, as a for internal deposition of radioacthe material eusts.

mimmum,157 of the stated s alue and traceable to a a bioassay program may be required. Regulatory primary standard, such as that mamtained by the Guide 8.11.

' A pplica tions of fhoassay for National Bureau of Standards.

Uranium." deah with depleted, natural, and enriched 10.3 4 156 238

uramum. but the general requirements and methods protectn e clothing. equipment, or tools required dur-are appheable for a special nuclear material bioassay ing processing should be described. Surface con-program.

tamination esaluation shou!J include unrestricted areas such as lunch rooms, offices. etc. The sursey 4f.3 Radiation Sursey Program program to momtor cleanup efforts for work areas where dust or loose materials are produced or spread i A surs ey is denned as an esaluation of the should be described. Reasonable efforts should be radiation hazards incident to production, use, made to remose all residual contamination. Accep-release, disposal, or presence of radioactne materials.

table hmits of 6xed and removable contamination for When appropriate, such esaluation includes a facihties in restricted areas should be set.

physical sursey of the location of materials and equipment and measurements of lesels of radiation or concentrations of radioactise material present in

4. Acceptable limits of find and removable con-air, water, or other materials and on surfaces. The tamination for facilities and equipment in on-types, methods, and frequency of surseys should be restricted areas and for release for unrestricted use specined according to the nature and complexity of should be set. For example, after reasonable effort to the special nuclear material program.

remos e all residual contamination, if maumum alpha levels are 300 dpm'/100 cm or less and the 2

2 For operations mvolung only sealed sources, aserage is 100 dpm/100 cm or les< unrestricted use 2

a sursey program should include evaluation and/

is permissible. provided that remosable a!pha con-or measurement of gamma and neutron radiation tamination does not exceed 20 dpm/100 cmt These les eis for storage and use conGgurations. When guidehnes apply to all spe:ial nuclear material except sources are used in desices basing "on" and "off' mixtures of the naturally occurrmg isotopes of positions, both positions should be evaluated at the uranium (U-234, U-235, U-238) for which the lesels time of mstallation. Supplemental surseys should be may be a factor of 5 higher.

I performed following any changes in operation.

~

shielding, us. or iocation of the desice.

5. A survey program for pilot studies and initial

3. For operations involsing materials in forms phases of a full-scale production operation needed other than as sealed sources, the sursey program for esaluatirg and serifying acteal hazards may be should also be designed to monitor the adequacy of more extensne than the survey Frogram that may be cont unment and contamination control. The appropriate for the day-to-day program. Prosisions program should include air sampling. bioassays, for the evaluation of all changes in operation should monitormg effluent releases, and surseys to esaluate be made.

alpha contamination of personnel aork areas, and

'*"I*'"'

4.6.4 Waste Dispmal

a. The specification of an air sampUng

1. Wastes generated as a result of operations in-program should include the areas where samples will solsing special nuclear m aterial need to be disposed be taken, the frequency of sampling, the relationship of in a safe manner. Suc'i w astes may mclude items to the processing or maintenance phase, and orienta-such as contaminated toals, glos es, clothing. absor-tion of sampler with respect to workers' breathmg hent materials, filters, resin columns, decontamina-The type of assays that will be performed to tion solutions, or proce< s w astes (see M20.301-20.305.

f o nes.

evaluate air samples and the methods used to relate which deal with waste Jisposal, of 10 CFR Par results to actual personnel exposares should be described 1 Wastes that are soluble or readils dis

,.nle in water may be disposed of sia the samtary sewer

b. The effluen t monitoring program for svstem su biect to the concentration and dails,

releases to unrestricted areas should encompast all monthly, and annu il hmits specified in 420.303 of 10 airborne and hquid re! eases. Calculational esalua-CFR Part 20. For example, up to 0.1 microcurie of tions should be supplemented by stack monitoring uranium-233 may be disposed of daily, prouded the appropriate for the planned and potential releases-contentration in sewage released does not eueed 4 x 10" microcuric/rulhhter when diluted by the aserage c The sursey progiam for esaluating alpha daily quantity of sewage Releases to sewage of all contaminat.on of personnel and plant surfaces radioactne maxrials by a licensee are hmited to one should include prosiuons for monitormg protectne curie / year and aserage monthly concentrations not 3

clothmg, hands, and feet of w orkers leavmg restricted exceeding restr eted area water concentrations.

areas before breaks and at the end of shifts. balua-tion (alpha and 'or camma lesels) of gloses or other

. % as u ns pe,

e. nm o as per me 156 239 i0a.,

3. Burial m soil is another method of waste dis-4.6.7 Scaled-Source 1.cak-Testing Prmisions posal.' Such burials are subject to the 4-foot depth.

6-foot separation, and 12 / year hmitations of CO.304

1. Plutonium-beryllium sealed neutron sources of 10 CFR Part 20 The quantity per burialis hmited and cer'ain plutonium gamma sources are required to 10 microcuries for special nuclear material, by beense condition to be tested for leakage and con-tamination at intersals not to cueed 6 months.

4 The most commonly used method of disposal Sealed sources desieneo a s alpha sources and other transfer to a commercial firm licensed to accept plutomum sources must be tested at mtersals not to is such wastes. Lists of such tirms are as ailable from the exceed 3 months.When the suppher does not certily Commission upon req u est. In Jealing with such that such tests base been performed within the ap-firm s, prior contact is recommended to determine propriate inters al. the sources are not to be used until specific seruces prosided.

leak tested. The test should be capable of detectmg the presence of 0 005 microcurie of alpha contamma-5 Other methods of disposal may be considered tion on the test sample. The test sample should be and justilled on a case-by-case basis. The ir. formation taken from the source or from appropriate accessible specified in CO 302 of 10 CFR Part 20 shouH be sub-surfaces of :he deuce in which the sealed source is mn ed to support a request for any altermin e permanemly mounted or stored w here contamination met hods at disposal. I hn inf ormatioa should melude could appt it if the source were defectise. Records of the quantities and kinds of materials. the lesels of leak-test results are iequired by beense condition to radioact n it. a description of the manner and condi-be mamtamed for mspection by the Commission tions or dnposal, an evaluation of enuronmental Any leaking sources must be withdraw n from use.

considerations, and the control procedures Prosision for decontanmation, repair, or disposal should be made.

6. T h e applicant should specifica:b mdaate how w astes will be disposed of.

1 If the appheant desires to perform his ow n leak tests, the followmg information should be sub-4A5 Record Management mitted 1 Qua anons of penonnel w ho will per-Fros nian for keermg and reuewing records of form the leak test.

su rx cy s; ms entories; personnel exposures; receipt, use, and dnposal of materials; ete should be described

b. Safets Persons responsible for keepmg and res iew ing the test'

' procedures to be followed dur ng records should be identified

c. Test procedures and materials or commer-4A6 Material Control Prmisions cial kit to be used, and Procedures for ordering materials, receising

d. Ty pe, man u fact u rer's name, and model materials, notifying responsible persons upon receipt ~

number of the instrument to be used for assas of test and openmg packages should be mdicated. Section

~

samples 20205 of 10 CFR Part 20 requires monitoring of cer-t un packages upon receipt, depending on the quan-4.M General Safety Instructions tu) of radioactne material contamed ano its form.

Packages containing less than 10 microcuries of A copy of the eneral radiation safety mstrue i plutonium,100 microcuries of uranium-233. or I mil-tions to be followed by laboratory or field personnel heurie of uranium-235 are exempt from monitoring.

w hue working with r idioactise material should be Morntormg of external surfaces n required if these submitted.

quantities are exceeded. If removable contammation h9 Emergency and Decontamination Procedures in excess of 0 01 microcurie!100 cm; is found on the external surface of ti e outer container. notification of A cop's of emerger - procedures to be po'ted m the shipper and the Commission is required.

all laboratory or work vos w here radioactn e Packages contaming sealed sources are exempt from materials are'used should be subnutted. These in-surface momtoring requirements as "special formf structions should describe immediate action to be Monitarmg of external radiation lesels is also re-taken in case of an emergency in order to present quired for certain quantities.

re; ease of radioactise material or further contamma-tion of work areas and personnel Examples of ne ( ernmnon n w,arir, ame,amems ir in ( i R nn :n emergency procedures are turnmg off the untilation 6 ~ JJ rrohN ihe J.sres a a iramrare tiemens M s stems, es acuation of the area. reentrs, proce<Jures i k Ne$s$n r$l e b'Ns]

for containment of spills, etc. The instructions should

~

u o

s ru n s-,

n rra v e % uhm 5 scars aher specifically state the names and telephone numbers of cere

~

s responsible persons 'o be notilled 156 240 io n

4.6.10 Procedures for Training Personnel References to preuously submitted information and documents should be clear and specific and should sonne \\ description of the trainmg program for all per-identify the pertment informatinn by date. page and l w ha are insolsed in or associated with the use paragranh.

of material should he submitted The description should include the form of training (e g, formal

6. RENEWAL OF A LICENSE course w ork, lectures, on-thegob instructions. and An appheation for renewal of a heense should he w ritten instructions or manuals). the duration of filed at least 30 day s prior to the expiration datt. I his traming. retraining prousions. and the subject matter will ensure that the hcense does not expire,ntil final to be ir.cluded action on the appheation has been taken by the NRC

5. AMENDMENTS TO A LICENSE as prouded for in paragraph 70.33(b) of 10 CI R Part

U.

1.icensees are required to conduct their programs m accordance w: h statements, representations. and Renewal appheations should be filed in :he san.c procedures coi med in the license apphqation and manner as the or%nal application..ippropriately support a e documents The beense must therefore supplemented, and should cont.un complete nd up-he amended if the hcensee plans to make any changes t o-d a t e inf ormation about the appheant

<urrent m facihties, equipment (includmg monitoring and program.

sur.cy i n s t ru men t s ). procedures, personnel, or specul nuclear material to be used.

In order to facihtate the reuew process. the ap-pheation for renewal should be submitted without

\\pphcations for heense amendments may be filc j reference to presiously submitted documents and in-m letter form The application should ilentity the formation. If such references cannot he asoided, they bcense bs number and should clearly describe the ex.

should be clear and specific and should identif y the et nature of the changes, additions. or deletiens.

pertment information by date. page. and paragraph 9

O 10.3 7

=*

UN>TE D ST ATES NUCc( AR REGULATORY COMWSSION

• As mv oT Os. o. c. 20sss

/,

OF F ICI AL BU$6 NESS PE N ALTY F OH PRiv ATE U$E, $300 g gm k

O (Se 242