ML20035B017
| ML20035B017 | |
| Person / Time | |
|---|---|
| Site: | 07000113 |
| Issue date: | 03/22/1993 |
| From: | Shirley D PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9303310004 | |
| Download: ML20035B017 (10) | |
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. PENNSTATE mmm no-con 3 Dasid A. Shirley The Pennsyhania State Univerwty Senior Vice heud:nt for Research 114 Kern Graduatt Buih!injr and Dean of the Graduate Schmi Unisersity Park 1% lf@2-339b 22 Mar 93 U. S. Nuclear Regulatory Commission, Region I Nuclear Material Safety Section B 475 Allendale Road King of Prussia, PA 19406 i
License: SNM-95 Gentlemen:
Docket No: 70-113 The Pennsylvania State University requests the following changes to special nuclear material license SNM-95. This license is currently under NRC review for renewal. The changes are the.
result of discussions with NRC representatives from Region I and headquarters during and subsequent to an inspection of the license in October 1992.
- 1. Section 22, Source Material, of the Rules and Procedures for the Use of Radioactive t
Material at the Pennsylvania State University has been revised. The major change is a requirement that source material acquired under a general license is subject to radiological control procedures similar to those used by the University for byproduct material. This includes controls on the purchase, inventory, and disposal of all source material.
Approval of the University Isotopes Committee will be required for use of greater than I gram of thorium or class Y uranium and 100 grams of class D or W uranium. These values have been set to limit the committed effective dose equivalent to less than 100 mrem for persons using this amount of material without radiological controls. The limits are based on resuspension of surface contamination and aerosols produced during typical laboratory procedures.
- 2. Two items have been deleted from Section 21, Special Nuclear Material, of the Rules and Procedures for the Use of Radioactive Material at the Pennsylvania State University.
The material balance area at the Beaver Campus has been deleted from section 21.4..The 2"Pu-Be source that was at that location was transferred to University Park and there are no plans for further use of SNM at the Beaver Campus. Section 21.11, a requirement for an annual internal audit, has also been deleted. The inventory of SNM at the University is now below the level at which an audit is required. The University will probably continue to perform the audit, but we do not wish to have it as a license requirement.
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- 3. The addition.to the license of 10 kilograms of source material in any physical or chemical form is also requested. After the NRC inspection of license SNM-95 in October 1992 the Health Physics Office conducted an' inventory of the source material at the University that had been acquired under the general license over many years. That inventory now stands at about 15 pounds and it is likely that more material will be located as additional laboratories are checked. It has been the opinion of the University that there is no possession limit for source material acquired under the general license.
However, some NRC representatives have indicated that no more than 15 pounds of l
general license source material may be possessed at one time. The University requested t
a written interpretation of this matter in a letter to Region I on 4 Dec 92. A reply has not yet been received. If the official interpretation is an inventory limit of 15 pounds, f
the University may need to transfer some material acquired under the general license to SNM-95 until the excess material can be disposed.
Copies of the revised Section 21 and Section 22 are enclosed. Please contact the University l
Health Physicist, Rodger W. Granlund at 228 Academic Projects lluilding,814 865-3459 if you l
need additional information about the above.
i The University is exempt from license renewal or amendment fees under 10CFR170.ll(a)(4).
i Sincerely,
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David A. Shirley 4
Senior Vice President for Research and Dean of the Graduate School enc.
l cc; Mark Klasky Univenity Isotopes Committee t
lorraine Mulfinger l
Rodger W. Granlund j
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i 1.
i SECTION 21 I
i SPECIAL NUCLEAR MATERIAL CONTROL PROCEDURES 21.1 This section describes the procedures for the control of special nuclear material. The i
procedures are designed to provide a record of the receipt, use, disposal or transfer of special i
nuclear material (.SNM) and to detect the loss, theft or unauthorized use of such material. Terms i
and abbreviations used in this procedure are defined as follows:
a) Item Control Area (ICA) an identifiable physical area where the control of SNM into or out of the area is by item identity and count for previously determined SNM r
quantities, the validity of which shall be assured by the use of tamper-safe seals unless the items are sealed sources.
b) Material Balance: a determination of inventory difference (ID) made by subtracting ending inventory (EI) plus removals (R) from the beginning inventory (BI) plus additions to inventory (A).
ID = (BI + A) - (El + R).
c) Material Balance Area (MBA): an identifiable physical area for the physical and administrative control of SNM such that the quantity of SNM moved into or out of the MBA is represented by a measured value.
d) Material Balance Area Controller (MBA Controller): the individual with the responsibility for maintaining the inventory and control of allitems within a given MBA.
e) Nuclear Materials (NM): all materials designated as nuclear materials by the Secretary of the Department of Energy. Presently, these materials are: depleted uranium, normal uranium, enriched uranium, uranium 233, americium-241, americium-243, curium, berkelium, californium, plutonium 238-242, lithium-6, neptunium-237, deuterium, and thorium.
f) NMMSS: Nuclear Materiais Management and Safeguards System.
g) Nuclear Material Representative (NM Rep): the person responsible for nuclear materials reporting and data submission to the NMMSS.
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SECTION 21 h) Special Nuclear Material (SNM): plutonium, uranium 233, uranium enriched in the isotope 233 or the isotope 235, or any material artificially enriched in the foregoing but does not include source material.
21.2 Orders for SNM are to be processed in the same manner as orders for other radioactive material (see section 16). All shipments of radioactive material and SNM for the University Park Campus are to be delivered to the Health Physics Office. Prior arrangements should be made with the Health Physics Office for the receipt of material at other campuses to insure that the package is properly checked. ' Arrangements may also be made with the Health Physics Office to receive material at other locations on the University Park campus or by persons other than the health physics staff when necessary. The persons accepting delivery of a package shall inspect it for damage and check the serial numbers of security seals against the shipping orders.
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Any damage to the package or missing or damaged seals should be noted on the shipping orders.
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If a person other than a representative of the Health Physics Office is accepting the shipment, the Health Physics Office shall be notified immediately of any damage to the package or seals.
l The exterior or the package should be checked according to section 17. Packages are to be i
opened by or under the supervision of a health physics staff member unless prior arrangements have been made with the Health Physics Office for someone else to do this. A physical inventory of the material is to made at the same time and the inventory form completed (form HP-30 or HP-30S) for material licensed under one of the byproduct material, SNM or source material licenses. Upon completion of the procedures for receipt of the material the package will be delivered to the authorized user at the appropriate MBA.
21.3 Special nuclear material is to be stored and used according to the authorization issued by the UIC or according to the reactor operating license, for material included within that license.
Material may not be transferred between MBA's or from one user to another until authorization to do so has been received from the UIC, except for material under the reactor license. Unsealed I
SNM in quantities greater than 10 grams is to be stored in a secure area with some form of tamper-safe security seal and access should be restricted to those persons named on the UIC 21-2 o
SECTION 21 l
i authorization for the material or under the reactor license. Irradiated materials which require
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storage in the reactor pool or in a shielded enclosure are exempt from the requirement for 1
tamper-safe seals. One person is to be designated the MBA Controller for each MBA. That i
person is responsible for maintaining an inventory of SNM in the MBA and for keeping a record of any transfers or loss of material. Persons authorized to use SNM within a MBA are responsible for notifying the MBA Controller of any removals, additions,' transfers or losses of l
SNM.
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21.4 The UIC shall identify the boundaries of Material Balance Areas and item Control Areas l
r and shall designated the MBA Controllers for each area. The current Material Balance Areas are listed below. There are no item Control Areas.
_ CODE LOCATION MBA CONTROLI.ER j
M BA-1 University Park Campus Operations and Training Manager, Breazeale Nuclear Reactor l
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21.5 Transfers include receipts, shipments to other licensees, movement between MBA's, and I
transfers between authorized users. New material will be assigned to a MBA and an a ithorized user upon receipt. Any subsequent change in MBA requires completion of the Special Nuclear Material Transfer Form, HP-40. This from is to be completed by the perscm initiating the
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transfer and signed by the authorized user (s), the MBA Controller (s) and a representative of the
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s Health Physics Office. Copies of the completed from are to be distributed to each of the above i
i named individuals and the NM Rep.
I 21.6 Transfers of SNM between different NRC licensees may require completion of DOE /NRC Form 741, the Nuclear Material Transaction Report. Transfers of certain other nuclear materials that are DOE owned, including deuterium, normal and depleted uranium, californium and enriched lithium may also require completion of DOE /NRC Form 741. This form is to be
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t prepared and signed by the NM Rep. Current regulations require that a licensee supplying j
nuclear materials prepare and dispatch DOE /NRC Form 741 no later than one working day j
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SECTION 21 following shipment of the material. A licensee receiving Nuclear Materials is permitted 10 calendar days after arrival of the material in which to document its receipt by completion of the receiver's section of the form. Individuals supplying materials covered by these reporting requirements to other licensees and those receiving such materials from other licensees are responsible for providing the NM Rep with the information necessary to complete and submit DOE /NRC Form 741 within the specified time limits. Distribution of this form is to be made in accordance with instructions contained in NUREG/BR-006 or DOE Notice 5633 for privately-owned and DOE-owned nuclear materials, respectively.
21.7 A physical inventory shall be conducted of the SNM in each MBA at intervals not to exceed 12 months. The inventory shall be initiated by the Health Physics Office and shall be conducted by at least two individuals, including the MBA Controller or his designate and a member of the Health Physics staff. The inventory shall consist of a visual examination and the actual measurement of quantities of unsealed SNM.
Material which has been previously measured and continuously maintained under tamper-safe seal need not be remeasured unless the seal has been broken or damaged. Material which has been irradiated and requires shielded storage or containment because of the radiation or contamination hazard need not be visually inspected or measured, but the presence of the storage container or irradiation vessel must be verified. Each item or container of SNM, except fuel elements in the pool, shall be identified by a tag which indicates that the item is SNM and includes the item description, isotope, quantity, inventory number, authorized user, license number, date and initials of the person completing the tag. The tag should be attached directly to the item or item container.
21.8 Tamper-safe seals are to be applied immediately upon completion of the operations which l'
establish the SNM content of an item. Serial numbers of seals are to be recorded and checked at the next inventory or when the container is next opened. More than one individually packaged item may be stored in a container such as a metal box or vault under the same seal. Seals are to be stored in a locked container accessible to only the MBA Controller and/or the University Health Physicist. The selection and use of security seals should follow the recommendation in 21-4
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SECTION 21.
i NRC Regulatory Guides 5.10 and 5.15. It is recommended that small items of unsealed SNM i
be kept in transparent containers with the gross weight and net weight recorded in the inventory so that the material can be visually checked and the amount readily determined by weighing the l
container, if necessary.
21.9 Sealed sources of SNM, such as fuel elements, fission counters and neutron sources, need j
not be assayed, but serial numbers or other identification should be checked. When the number.
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of similar items exceeds 25 a random sampling of at least 10% of the items (but not less than
- 10) may be made to check identifying numbers.
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21.10 The inventory information shall be recorded on a written form and signed and dated by the persons conducting the inventory. The same form may not be used for more than one day or for more than one MBA. Copies of the inventory form shall be distributed to the MBA l
Controller, NM Rep and the Health Physics Office. The physical inventory shall be compared -
l with the inventory record and documented by the MBA Controller.
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21.11 Deleted 22 Mar 93 21.12 The University is required to submit semiannual material balance reports covering DOE-owned SNM as well as privately-owned SNM to the Nuclear Materials Management Safety and
.f Security organization at Oak Ridge, TN within 30 days following the end of the period covemd
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by the reports (31 March and 30 September). These reports shall be prepared, signed and submitted by the NM Rep or his designate with copies to the Senior Vice President for Research and Dean of the Graduate School and to the llealth Physics Office. Each MBA Controller is l
responsible for providing the NM Rep with a material balance for the SNM in his area as of the I
above dates in sufficient time for the preparation and submission of these reports. Fission and l
transmutation losses in reactor fuel shall be calculated as described below.
i a) The Burn-Up Log, which is kept by the Breazeale Nuclear Reactor, contams i
the power level and duration of each reactor run on a daily basis. The number j
of kilowatt hours of operation for each month are totaled from the daily data. A l
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SECTION 21 cumulative total of all kilowatt hours to date is also kept on a monthly basis in the Burn-Up log.
b) Compute total burn-up (B) by multiplying the kWh for each month and the total to date by 4.32 x 10' grams burn-up/kWh.
B (grams) = 4.32 x 10' x kWh.
c) Compute the grams of uranium lost (U) by multiplying the burn-up, B, by 1.077.
U (grams) = 1.077 x B d) Compute the grams of uranium-235 lost (U-235,) by multiplying the burn-up, B. by 1.192.
U-235, (grams) = 1.192 x B c) The burn-up data must be reported in a timely fashion to the NM Rep so that the NRC/ DOE 741 form required to account for the burn-up may be submitted to the NMSSS within the required time period.
21.13 A Nuclear Material Transaction Report form (DOE /NRC 741) must be submitted for each reporting pericx! in which an onsite gain or loss of nuclear material occurred because of burn-up, decay (transmutation). production or measured discard.
Revised 22 Mar 93
..ms sem,,
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i SECTION 22 SOURCE MATERIAL l
22.1 Source material is defined in 10CFR40.4 as uranium and/or thorium in any physical or chemical form, or ores which contain 0.05% or more by weight of uranium and/or thorium. It does not include special nuclear material (plutonium or uranium enriched in the isotope 233 or 235) but does include depleted uranium. The amount of source material referred to in this section is the amount of uranium or thorium, not the amount of a compound or mixture.
I 22.2 The University has a specific license to possess and use a large quantity of uranium in a subcritical graphite pile. Small quantities of source material for laboratory use may be obtained under a general license (10CFR40.22). This allows the University to use and transfer up to 15 pounds of source material at one time. The University may not receive l
more than 150 pounds of source material in one year under the general license. Because I
the University has a specific license for uranium for the subcritical pile, it is not exempt from the requirements of 10CFR19,10CFR20, or 10CFR21 for source material acquired i
under the general license. Therefore, all purchases and transfers of source material must
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be made through the Health Physics Office, using the same procedures as for licensed byproduct material. The Health Physics Office will keep an inventory record of source material acquired under either a specific or a general license. However, this section of l
the University rules and the inventory requirements do not apply to mineral specimens.
i or unimpodant quantities of source material as listed in 10CFR40.13.
22.3 Even though small quantities of source material may be obtained under a general license, there may be some hazard in using the material or the device containing the material.
Use or storage of more than the following quantities of source material in one laboratory j
i requires an authorization from the University Isotopes Committee.
SOURCE MATERIAL GRAMS CLASS Y' URANIUM AND ALL THORIUM 1
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CLASS D' AND CLASS W" URANIUM 100
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SECTION 22 Source material should not be stored in offices, desks, or other areas where it is in close proximity to personnel for long periods of time, because of the elevated radiation levels.
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The 11ealth Physics Office will arrange for storage or disposal of source materials that are not in use.
I 22.4 Tne licalth Physics Office should be consulted before using source material in such a way that airborne contamination could be produced. Some examples of such uses are l
I machining uranium or thorium metal or alloys, opening vacuum tubes or thoriated lamps, making refractory materials from thorium oxide, or grinding thorium glass. Users should be aware that uranium and thorium are pyrophoric and metal chips or powder can ignite in air producing airborne contamination and creating a fire hazard. The Health Physics Office will evaluate proposed uses of source material, provide monitoring, and assist with the necessary radiological controls.
22.5 Waste containing source material must be transferred to the ficalth Physics Office for disposal in the same manner as licensed byproduct material.
22.6 The irradiation of source material in the Penn State Breazeale Reactor can produce fission i
products and transuranic elements. These materials can be very hazardous and may not i
be covered by existing licenses. Therefore, experimenters proposing to irradiate source material should discuss the project well in advance with the Health Physics Office and i
the Breazeale Nuclear Reactor staffs. Samples of soil, rock, sediments, etc. may contain i
enough uranium or thorium to present problems, if irradiated, even though the material is not classified as source material.
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I Revised 22 Mar 93 i
- t'I f WTP.fVF m0 22-2 OFFICIAL RECORD COPY i
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