ML20041A887

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Revised Application for Renewal of License SNM-910
ML20041A887
Person / Time
Site: 07000920
Issue date: 01/01/1982
From: Ryan R
RENSSELAER POLYTECHNIC INSTITUTE, TROY, NY
To:
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ML20041A886 List:
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20210, NUDOCS 8202220638
Download: ML20041A887 (25)


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.

SPECIAL fiUCLEAR MATERIALS REtiEWAL APPLICATI0ti Revised January 1, 1982 for the Department of fluclear Engineering Rensselaer Polytechnic Institute Troy, New York 12181

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by hj. u d([ [.\\ 'il. '

f Robert M. Ryan,'Qlrector Office of Radiation and tiuclear Safety 8202220638 820120 PDR ADOCK 07000920 C

PDR

1 TABLE OF CONTENTS Page INTRODUCTION....................................................................

2

1. STANDARD CONDITIONS AND SPECI AL AUTHORIZATIONS.............................. 2 1.1 Name....................................................................

2 1.2 Location................................................................

2 1.3 License Number.........................................................

2 1.4 Possession Limits.......................................................

2 1.5 Loca tion Whe re Ma teri al Wil l Be Used....................................

5 1.6 Definitions.............................................................

5 1.7 A u t h o r i z e d Ac t i v i t i e s...................................................

5-1.8 Exemptions and Special Authorizations...................................

5 2.

GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS..................... 6 2.1 S t a t eme n t o f S a f e ty.....................................................

7 2.2 Organizational Responsibili ties and Authority........................... 8 2.3 Sa fe ty Re v i ew Co mmi t t ee s................................................

10 2.4 Approval Authori ty for Personnel Sel ection..............................

12 2.5 Personnel Education and Experience Requirements.........................

12 2.6 Training................................................................

14 2.7 O pe ra t i n g P ro c ed u re s....................................................

16 2.8 A u d i t s a nd I n s pec ti o n s..................................................

17 2.9 Investigations and Reporting of Off-Normal Occurrences..................

18 2.10 Records.................................................................

18 3.

RADIATION PROTECTION..................................................... 19 3.1 Special Administrative Requirements.....................................

19 3.2 Technical Requirements..................................................

19 3.2.1 Access Control...................................................

19 3.2.2 Ventilation Requirements.........................................

23 3.2.3 Instrumenta tion (Survey and Counting Moni tors )...................

23 3.2.4 Internal Exposures...........................

24

g INTRODUCTION The following information is being supplied to support Rensselaer's application for renewal of its special nuclear materials license SNM910.

I. Standard Conditions and Special Authorization 1.1 Name Department of Nuclear Engineering Rensselaer Polytechnic Institute 1.2 Location (a) Troy, New York 12181 (b) \\!srious campus buildings containing laboratories are used.

These include, but are not limited to the follow-ing (see Figure 1) -

1.

Linear Accelerator Laboratory (63 and 64) 2.

Blaw Knox 1 (12) 3.

Cogswell Laboratory (31) 4.

Science Center (30) 5.

Walker Laboratory (10) 6.

West Hall (4) 1.3 License Number SNM-910 (Expiration date 3/31/79) l 1.4 Possession Limits l

The following is a listing of the isotope quantities and form of the special nuclear material requirements for both educational and research functions in the Department of Nuclear Engineering at Rensselaer Polytechnic Institute.

Table 1 indicates the poses-sion limits and is extracted from the existing license.

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12 c.

4 Table 1 SNM Possession Limits Isotope Form Quantity A. Uranium Enriched Foils 350 grams in the isotope U-235 B. (Incorporated into A. above)

C. Plutonium Encapsulated "Nd0ntSh$k39 Grams (Pu)

M-1149 96.39 M-89 14.86 M-90 14.83 ti-91 14.74 ti-96 2.12 M-97 2.14 MRC-N-SS-W-330 47.30 965-S-55 96.37 N320C29 29.77 N320030 29.77 N320C31 29.77 Total Pu 239 378.06 grams Pu -238 (Ident.#)

(Grams Pu)

MRC#41 0.21 Total Pu 238 0.21 grams D. Plutonium Encapsulated for the Nuclear Accident 3 grams Dosimeter E. Pu 239 Metal Discs 175 grams Total in any U 233 combination U 235 F. U 235 Metal encapsulated in 477 grams stainless steel G. Pu 239 Fuel coupons 750 grams Total U-233 Uncladded-sintered U-235 00 -Th02 pellets or sinter-2

-ed U07 - Th02 pellets in zircaToy cladded fuel rods.

[

g 1.5 Location Where Materials will be Used (a) Linear Accelerator Laboratory All Special Nuclear Materials (b) Blaw Knox I Plutonium Beryllium Neutron Sources (c) Cogswell Laboratory Plutonium Beryllium Neutron Sources (d) Science Center Plutonium Beryllium Neutron Sources (e) Walker Laboratory Plutonium Beryllium Neutron Sources (f) West Hall Uranium.& Plutonium Calibration Sources 1.6 Defintiions Definitions are as provided in ANSI N1.1-1976 and/or the Code of Federal Regulations Title 10.

l 1.7 Authorized Activities The Licensees activities are confined to using the special nuclear materials in educational research and development activi-ties at the Linear Accelerator Laboratory. At all other build-ings on campus the activities at present are associated with the use of the neutron radiations from the Pu Be neutron sources in various educational and research laboratory measurements.

l.8 Exemptions and Special Authorizations 1.

An exemption to the requirements of 10CFR70.24 is requested based on the fact that there is no area (room) where the possession limits at Rensselaer Polytechnic Institute

6 exceeds 700 grams of U 235, 520 grams of U 233 or 450 grams of Pu 239, or any combination of these special nuclear ma-terials wnose fractional inventories related to the above quantities is equal to or greater than 1. (e.g.

gram U 235, gram U 233 grams Pu 239 g 1 )

700 520 450 2.

An exemption from the licensing fees stated in 10CFR120.ll (a)(4) is requested based on tne fact that all work in-volved in the use of the special nuclear material is for educational and research related purposes.

2.1 Statement of Safety Policy 1.

Safety Policy

  • It is the policy of Rensselaer Polytechnic Institute to provide a safe and healthy environment for its students, faculty, staff and visitors I believe that the elimination of accidents that injure personnel and result in losses of property and equipment is everyone's responsibility.

Each person using the equip-ment and facilities of the Institute is expected to follow the procedures outlined in this manual, to supplement these procedures when necessary, to report all accidents promptly, and to bring to the attention of supervisors and faculty members any unsafe conditions or practices.

It is only through the dedicated efforts of everyone that accidents and injuries can be prevented and a safe healthy environment created for all to enjoy.

2.

Statement of ALARA

(

The radiation dose received by any person from external or t

internal exposure to ionizing radiation in a radiation in-l stallation (a controlled area in which radioactive material or machines generating ionizing radiation or both are used) must be held to the lowest possible value consistent with effective use of the installation and must never exceed the legally maximum permissible value.

Every effort should be made to avoid contamination of work areas, and, in any case, release of airborne or waterborne radioactivity must never exceed legal limits and every effort should be made to avoid accidental releases.

Disposal of all radioactive

  • George Low, President i
    • Rensselaer's Radiation Safety Regulations & Procedures

8 waste must be in accordance with procedures.

The radiation dose received by any person from external or internal exposure to ionizing radiation in a non-controlled area must be held as close to natural background levels as possible and must never exceed the legal maximum pennissible level.

Legal maximum permissible dose levels are those specified in the current edition of the New York State Department of Health Sanitary Code, Chapter I, Part 16, " Ionizing Radiation" and in Title 10, Part 20, of the Code of Federal Regulations (10 CFR 20).

2.2 Organizational Responsibility and Authority 1.

Administration The Institute's radiation safety p;Pgnm is within the province of the Office of the Provost

,d is administered by the Vice Provost, Academic Affairs, through the Office of Radiation and Nuclear Safety.

In addition, there is a Radia-tion and Nuclear Safety Committee which reports to the Vice Provost. A Personnel Directory is given in Table 2.

(An independent Nuclear Safety Review Board, which also reports to the Vice Provost, is specifically responsible for nu-clear safety at the Institute's Critical Facility in Schen-ectady, New York, NRC License CX-22).

The following chart shows the current organization of the Institute's radiation safety program.

9 Provost l

1 Radiation and

! Vice Prevost Deans of Schools Nuclear Safety

[

l Committee Director of Chairmen of Departments Radiation and or Nuclear Safety Directors of Centers Supervisors of Ibadia.

tion Installations I

f 1

USERS i

(a) Office of Radiation and Nuclear Safety The Office of Radiation and Nuclear Safety was established to facilitate inplementation of Institute policy and proced-ures on radiation safety.

It is staffed by a Director of Radiation and Nuclear Safety and an Assistant Director.

The Office has instrumentation for surveillance of sources of ionizing radiation and provides a periodic survey service for the Institute radiation installations.

The Director of the Radiation and Nuclear Safety Office is an individual engaged in the study of problems and prac-tices of providing radiation protection, lie is concerned with an understanding of the mechanics of radiation damage; with development and implementation of methods and pro-cedures necessary to evaluate radiation hazards; and with providing protection to man and his environment from un-warranted radiation exposures.

10 lie has the authority to stop an operation of any kind if a radiation hazard to personnel exists, if Institute property is endangered, or neglect of Institute policies is observed.

He is an ex officio member of the Radiation and Nuclear Safety Committee and the Nuclear Safety Review Board.

2.3 Radiation and Nuclear Safety Committee The Radiation and Nuclear Safety Committee is appointed by and reports to the Provost (or tiis designated representative). Pembers must have experience in the use of radiation and in some aspect of radiation safety.

The Director of Radiation and Nuclear Safety is an ex officio member of the Committee.

The Chairman is appointed by the Provost (or his designated represen-tative). The Chairman's responsibilities include:

(1) Calling meetings of the Committee (2) Making recommendations to the Provost concerning the size and composition of the Committee (3) Preparing reports of Committee activities for the Provost Upon recommendation of the Chairman and approval of the i rovost, the Committee may seek the advice of a consultant having special exper-tise in some aspect of radiation safety.

(a) Responsibilities The Committee is charged with:

(1) Setting Institute policies for radiation and nuclear safety.

(2) Giving such advice and assistance may be request-ed by the Director of Radiation and Nuclear Safety.

11 (3) Giving approval to reactivate an operation involving radiation if such an operation has been stopped by the Director of Radiation and Nuclear Safety.

(4) Evaluating the Institute's overall radiation safety program and the effectiveness of the administration of this program and making a brief written annual report to the Provost.

(b) Meetings The Committee meets at least bi-monthly during the aca-demic year. Meetings may be called at any time during the calendar year whenever matters of urgency arise, as deter-mined by the Provost, the Chairman or the Director of Radia-tion and Nuclear Safety.

Guests may attend meetings at the invitation of the Chairman.

In the event that meetings are held in the absence of the appointed Chairman, a Chairman pro tem is appointed by the Provost.

The Committee holds some of its meetings at Institute radia-tion facilities for the purpose of inspecting the facilities and providing the members with a first-hand knowledge of each facility. The Committee attempts to visit each facility at least once a year.

Minutes of meetings are distributed to the members, the Provost (or his designated representative), the Assistant Director of Radiation and Nuclear Safety, and to the Chairman of the Nuclear Safety Review Board.

i

12 2.4 Approval Authority for Personnel Selection 1.

The appointments to Rensselaer's Radiation and f;uclear Safety Committee is made in the Office of the Provost and is performed at present by the Vice Provost, Dr. Gary Judd.

2.5 Personnel Education and Experience The following are minimum requirements for the Director and Assistant to the Director of the Office of Radiation and Nuclear Safety:

1.

Director (a) Education

- BS degree in engineering or science (b)

Experience - 5 years supervisory in Health Physics preferably at a University (c) Preferable certification by the American Board of 11ealth Physics 2.

Assistant to the Director (a)

Education - Associates degree in science or certified x-ray technologist (b)

Experience - 2 years experience with handling of radioactive materials or operation of radiation producing machines 3.

f1 embers of the Radiation and Nuclear Safety Committee (a) Education - The members of this Committee full time are faculty or staff at Rensselaer who have had at least 2 years experience in the use of sources of radiation and radioactive materials and in some aspect of radiation safety as deemed appropriate by the Provost.

~

13 Table 2 Personnel Directory Radiation and Nuclear Safety 1.

Office of Radiation and Nuclear Safety Director Extension Location Robert M. Ryan 6409 LINAC Assistant Director Fred J. Mastrianni 6409 LINAC 2.

Radiation and Nuclear Safety Committee Dr. D. Aulenbach 6541 Environmental Eng.

Dr. R. Harper 6434 Physics Dr. N. Hepfinger 6356 Chemistry Mr. T. McCartney 6238 Physical Facilities Mr. R. Ryan (Ex-Officio) 6409 Office of Rad. & Nucl.

Safety Dr. D. Wilson 6391 Biology Dr. M. Yeater 6543 Nuclear Engineering 3.

Nucles: Safety Review Board Dr. M. Becker 6407 Nuclear Engineering Dr. D. Harris 6406 Nuclear Engineering l

Dr. R. Lahey 6401 Nuclear Engineering Dr. F. Wicks (518)393-4281 Critical Facility l

Mr. R. Ryan 6409 Office of Rad. & Nucl.

Safety l

Dr. J. Wu 6351 Nuclear Engineering The Radiation and Nuclear Safety Group is in the Office of the Provost, and is headed by Dr. Gary Judd, Vice Provost for Academic Affairs.

14 2.6 Training 1.

Faculty and staff involved with using Special Nuclear Materials are approved by the Director of the Office of Radiation and Nuclear Safety based on their previous training and experience. These persons are then given the classification of " User" in Rensselaer's Radiation Safety Program.

(a) Minimum experience is such to have worked 6 months at a level of hazard associated with the isotope.

(b) Minimum education is such to have a B.S.

degree in Engineering or Science.

2.

Graduate and Undergraduate students are in a learning phase and as such are required to be under supervision of a faculty or staff n, ember of the Institute (a " User") if any of their educational pursuits involve radiation or radioactive materials.

Prior to such use they are re-quired to attend a safety lecture provided by his faculty advisor.

Some courses are available in the science and engineering curriculum that are acceptable in lieu of special lectures on radiation safety as deemed appropriate by the Director of the Office of Radiation and Nuclear Safety.

3.

Retraining in radiation safety is provided through lectures given by the Director of the Office of Radiation and Nuclear Safety during the Fall and Spring semesters.

Seminars are also held on specific aspects of radiation safety and courses are available.

15

4. Visitors to Rensselaer Polytechnic Institute are not required to attend any safety lectures. These individuals are restricted in their access to radia-tion areas unless accompanied by a faculty or staff member.

16 j

2.7 Operating Procedures Operating procedures involving the accountability, security and handling of special nuclear materials is set forth in Rensselaer Polytechnic Institute's " Radiation Safety Regulations and Pro-cedures Part I:

Ionizing Radiations" dated March 13, 1976.

Pertinent excerpts from this document are as follows:

1. Control and Accountability Special nuclear material shall be maintained under the control of the Director of Radiation and Nuclear Safety.
2. Transfers Transfers of special nuclear material is permitted only if the receipient is licensed (by the NRC) to receive the type and quantity of material and shall be in accord with 10CFR70.54. All transfers must be accompanied by completed DOE /NRC forms 741.
3. Reporting From DOE /NRC 742 " Material Balance Reports" shall be prepared in accord with 10CFR70.53 by the Director of Radiation and Nuclear Safety. These reports shall be submitted within 30 days of March 31 and September 30 of each calendar year to the appropriate agency.
4. Inventory At intervals not to exceed 12 months the Director of Radiation and Nuclear Safety (or his designated rep-resentative) shall perform a physical inventory of all special nuclear materials under his control in accord wi th 10CFR50.71.

l

5. Leak Tests Sealed sources shall be leak tested by the swipe techniques in accord with existing procedores at intervals not to exceed 6 months.
6. Applicable Regulations The reguietion of Special Nuclear liaterials is estab-lished and criteria for the issuance of licenses to receive title to, own, acquire, deliver, receive, possess, use, transfer, import and export and also to establish and provide terms and conditions of license is outlined in 10CFR70 Special Nuclear futerial.

The physical protection required for those licensed under 10CFR70 Special Nuclear Materials is set forth in 10CFR73 Physical Protection of Plants and futerials. This also includes protection while in transit.

Packaging of Radioactive Materials for Transport and Transportation of Radioactive Materials for Transport and Transportation of Radioactive Materials Under Certain Conditions is detailed in 10CFR71.

Shipments must also conform to Department of Transportation Regulations set forth in 49CFRl-199 Transportation.

2.8 Audits and Inspections Audits and inspections are performed as set forth in "Rensse-laer's Radiation Safety Regulations and Procedures" and outlined above in Section 2.7 Operating Procedures.

Radiation protection inspections are also made by members of the Radiation and Nuclear Safety Committee yearly and by members

18 of the Office of Radiation and Nuclear Safety at a frequency not to exceed once per month.

2.9 Investigation and Reporting of Off-Normal Occurrences Off normal occurrences shall be investigated by the Director of Radiation and Nuclear Safety. The reporting requirements shall be as outlined in USNRC Regulatory Guide 10.1 Revision 4 October 1981 " Compilation of Reporting Requirements for Per-sons Subject to NRC Regulations".

2.10 Records Records of radiation surveys, inventories and personnel moni-toring are maintained and available.

Retention time of records has not been determined and at present can be considered in-definite.

l l

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1

19 3.0 Radiation Protection 3.1 Special Administrative Requirements (This function is inherent in the Radiation and Nuclear Safety Committee).

Rensselaer has not established an ALARA Committee.

Although the Policy Statement in Section 2.0 addresses ALARA, and is the basis for our program, the program at Rensselaer does not involve radiation exposures that would dictate a large effort. flowever, Rensselaer is committed to the ALARA concept and strives to maintain both radiation e)posure to people and the quantities of radioactive wastes to a minimum.

3.2 Technical Requirements 3.2.1 Access Control 1.

Controlled areas Areas at RPI are controlled radiation areas when:

(a) Storage or Use areas for special nuclear materials 2

(b) Loose contamination levels exceeding 1000 dpm/100 cm 2

beta-gamma or 100 dpm/100 cm alpha (c) Radiation levels exceed 2.5 mrem / hour (d) Airborne radioactive contanination exceeds 25%

of MPC 2.

Personnel Monitoring Personnel monitoring is the process by which an in-dividual is monitored to determine the radiation exposure he or she receives. This is accomplished by the wearing of devices sensitive to the radiations emanating within the installation where the individual has authorized access.

The overall process includes

20 periodic distribution and collection of the monitoring devices, processing of the devices to determine the radiation exposure or dose received by the wearers, interpretation and evaluation of the results and maintenance of records. Any individual receiving an exposure above 100 mR in any week will be notified and interviewed by the Director of Radiation and Nuclear Safety, who may require a formal report from the Supervisor of the Raciation Installation. The Director of Radiation and Nuclear Safety will also notify the appropriate government agencies of any reportable exposures.

(a) Personnel Monitoring Devices Devices used for personnel monitoring must be of the integrating type, responsive to the radiations of interest and of sufficient sensitivity to be able to record accurately exposure levels of 1/10 of the radiation protection guides.

(" Accurately" should be i 10% of calibration radiations.)

(b)

Personnel Monitoring Wearing Criteria (1) Each person who may receive a dose in excess of 25 mrem per week must wear a personnel monitoring device.

(2)

Each person who has occasion to enter a high radiation area (greater than 100 mrem per hour) must wear a person-nel h~aitoring device.

21 (3) Personnel monitoring devices are changed on frequency not to exceed a monthly basis.

(4) Personnel monitoring devices record-ing whole body exposure must be worn between the waist and neck and on the front of the trunk of the body.

(5) Other regions of the body (i.e., the extremities) may be monitored but only by devices explicitly provided for the purpose. Devices provided for whole body monitoring must not be used for this pe pose. These devices will be supplied upon request by the Office of Radiation and Nuclear Safety.

(6) These persornel monitoring devices must be worn at all times when the individual (aser, worban, or visitor) is within a Radiation Installation where monitoring devices are required.

(7) A protected repository in a secure non-radiation area must be used at each installation for storing the personnel monitoring device when not being worn. The Office of Radiation and Nuclear Safety will supply wall-mounted racks for this purpose upon request.

22 (c)

Personnel Monitoring Devices-Maintenance The Office of Radiation and Nuclear Safety shall be responsible for supplying person-nel monitoring devices to users, other employees of RPI and visitors to RPI Radiation Installations at the request of the Installation Supervisor.

(1) Requests for personnel monitoring devices are made by the Installation Supervisor to the Director of the Office of Radiation and Nuclear Safety.

(2) Personnel monitoring devices are ex-changed on a bi-weekly basis by the personnel of the Office of Radiation I

and Nuclear Safety.

(3)

Records complying with existing regu-lations are maintained by the Office of Radiation and Nuclear Safety.

(4)

Reports complying with existing regu-lations are prepared by the Office of Radiatico and Nuclear Safety.

(d) Personnel Monitoring - Visitors (1)

All visitors to Radiation Installations must conform to " Personnel Monitoring Wearing Criteria" above.

(2)

Visitor's devices may be obtained upon request of the Office of Radiation and Nuclear Safety.

24 3.2.4 Internal Exposure Contcol The special nuclear materials at Rensselaer are deemed non dispersable.

Therefore, internal radia-tion exposure is not a probable mode. However, if sus-Dected the use of a commercial vendor such as Teledyne Corporat on would be employed for dose assessment.

I 4%.

I* ts th);I )

23 (e) Records Access Individuals in the active personnel moni-toring listing can access their recoros and their records only from the RPI compu-ter. The signon and password are available 1

from the Director, Office of Radiation and Nuclear Safety. The only entry required is the individual's social security number.

Signoff is innediate following printout of records.

3.2.2 Ventillation Requirements The areas where the encapsulated special nuclear materials are used do not require ventillation. The special nuclear ma-terial encapsulation is of high integrity and the material is deemed non dispersable. However, fume hoods used at Rensselaer for dispersable radioactive materials maintain face velocities of 100 fpm and discharge through " absolute" filters if deemed necessary by the guidelines established in Rensselaer's Radiation Safety Regulations and Procedures. This document also dictates when stack monitoring is required.

3.2.3 Instrumentation The Office of Radiation and Nuclear Safety has available a full i

range of laboratory and portable radiation monitoring equipment.

The calibrating equipment ranges from proportional counting l

automatic sample changers to GeLi detectors.

The portable survey meters can detect and measure alpha, beta, gamma and neu-trons. The personnel monitors (TLD) are read in a Harshaw 2000 system.

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