ML20054A344
| ML20054A344 | |
| Person / Time | |
|---|---|
| Site: | 07000920 |
| Issue date: | 04/01/1982 |
| From: | Koslor B NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20054A309 | List: |
| References | |
| NUDOCS 8204150383 | |
| Download: ML20054A344 (11) | |
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DISIRIBUT10N:
Docket File 70-920 POR NMSS rf i
FCUP rf i
BMKosla APR 1 j982 LTyson WTCrow JBlaylock JRobertson RErickson Region I DOCKET NO: 70-920 j
t LICENSEE:
Rensselaer Polytechnic Institute (RPI) 1
SUBJECT:
RENEWAL OF LICENSE 4
I.
Background
1 Materials License No. SNM-910 was issued to Rensselaer Polytechnic Institute (RPI) in June 1965, authorizing the possession and use of 236 grams U-235, 96 grams of Pu as encapsulated neutron sources, and 50 grams of either Pu U-233, or U-235 as encapsulated disks.
for educational purposes.
The license was renewed in 1968 and amended in its entirety in 1976 to incorporate material authorized by SNM-ll2 which was subsequently terminated. The current amended license limits authorization for possession at any one time to less than one effective kilogram of SNM, and exenpts the licensee from the requirements of 70.24. providing that less than 450 grams of special nuclear material, excluding encapsulated Pu-Be be present in any one room at any time.
By letter dated February 23. 1979, the licensee requested renewal of
..MM-910 and the license remains effective under the timely renewal l
provisions of 70.33(b) 10 CFR 70. The licensee was asked to submit a I
renewal application with the format required of similar licensees; l
however, the application, which was submitted on April 1,1981, did l
not provide all the infomation necessary for the staff to make an assessment of RPI's Radiation Safety program for Special Nuclear Material (SNM). Following discussion with Region I staff during a June 1981 inspection, and with FC41P staff during an August 1981 facility visit, the licensee submitted a revised rer. mal application dated January 20, 1982.
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AP; 982 In the January 20. 1982 application, the licensee requests authorization to possess and use the following material:
Isotope Form Quantity (grams)
A.
Foils 350 grams 2.
Metal encapsulated 477 grams in stainless steel B.
Plutonius Pu-238 Encapsulated
.21 grams MRC i41 Plutonius Pu-239 M-ll49 96.39 grams M-89 14.86 grams H-90 14.83 grams M-91 14.74 grams M-96 2.12 grams M-97 2.14 grams MRC-N-SS-U-330 47.30 grams 965-5-55 96.37 grams W320C29 29.77 grams W320C30 29.77 grams W320C31 29.77 grams Nuclear Accident 3.00 grams Dosimeter C.
Metal Discs 175 Total in any U-235 combination 2.
Fuel coupons unclad-750 Total sintered UO -Th07 pellets or sintered 0 -Th02 pellets in zir&aloy clad fual rods The licensee limits the quantity of special nuclear material to one effective kilogram. Accordingly, the following condition is added:
Condition 11. The quantity limitations specified in Condition 8 above notwithstanding, the licensee shall not possess at any one time under this license cure than one effective kilogram of special nuclear material as defined in Section 70.4(t) of 10 CFR 70.
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APR 1 1982
- 11. Scope of Review The safety review of RPI's application for renewal included an examination of previous appitcations and amendments, a review of the applications for renewal dated April 1,1981, and January 20, 1982, a review of the compliance history, and a site visit on August 27, 1981.
The findings are discussed below.
!!I. Discussion of Review RPI's revised renewal application demonstrates that they have an estabitshed program and a technically qualified staff who have akinistered an effective and safe radiological protection program.
The following sections contain a description of RPI's organization and radiological safety program, along with additional conditions developed by FCUP staff.
A.
Organization and Akinistration 1.
Radiation Safety is ahinistered by the Office of the Provcst.
The Radiation and Nuclear Safety Committee (RNSC) serves in an advisory capacity, and the Office of Radiation-and Nrclear Safety implements policy and procedures for the prograr con-cerning the use of SNM. The Radiation Safety Officer (R50) is Director of the Office of Radiation and Nuclear SC/ety and is a member of the RNSC. The RNSC and RSO are ar, pointed by and report to the Office of Provost, and are diseassed in A.2. and A.3. below.
In the application reference is made to the Safety Cormittee which is responsible for the Institute's critical facility in Schenectady, New York. Operation of the critica?, facility is authorized by NRC License CX-22, and the following condition is recommended to make it clear that insertion of licensed S*
into a nuclear reactor is not authorized under this license:
Condition 12. This-license does not authorize the insertion of special nuclear material into any nuclear reactor.
2.
The Radiation Safety Officer (RS0), as Director of the Office of Radiation and Nuclear Safety, is charged with the responsibility to provide radiation protection, to develop and implement procedures, to evaluate radiation hazards, to protect man and his environment from unwarranted radiation exposure, and to stop any operation in which a radiation hazard exists.
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1,P R i s2 The minimum education and experience requirements for the RSO at RPI are:
a.
Education - BS degree in engineering or science b.
Experience - 5 years' supervisory in Health Physics, preferably at a University.
The educational requirements are consensurate with other licensees', and the required 5 years of previous supervisory experience in Health Physics should be sufficient to develop adequate analytical capabilities for the evaluation of radiation and criticality safety. The current RSO has been at RPI for many years and is highly qualified as is demonstrated by his certification by the Health Physics Society and his many activities as a consultant.
3.
The Radiation and Nuclear Safety Committee (RMSC) is composed of faculty or staff at Rensselaer who are required to have two years experience in the use of sources of radiation and radioactive materials. The ccumittee, which meets bi-monthly during the acadmic year, is responsible for setting Institute policies for radiation and nuclear safety, giving advice and assistance as requested by the RSO, giving approval to reactivate an operation which the RSO has stopped for safety purposes, and for evaluation of the radiation safety program and its admint-stration. These responsibilities are necessary functions for a viable cannittee; however, there is a deficiency in the applicant's regard of (a) audits and inspections, (b) the approval of procedures, and (c) ALARA, and the following condition to correct this deficiency is recommended:
Condition 13. Notwithstanding the words in the January 20, 1982 application pertaining to the Radiation and Nuclear Safety Comittee function in Section 2.3 and experience in Section 2.5, the Committee shall:
a.
Inspect and audit each facility at least once each year not to exceed a twelve-month interval, b.
Review and approve procedures (operational or radiation safety),
which involve SNM, before new procedures are implemented or existing ones are changed.
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APR 1 M92 c.
Review the radiation safety program in terus of ALARA to determine trends and to recommend appropriate corrective action if required. The annual review shall not exceed a twelve-month interval, d.
Have at least one board member, other than the RSO who has analytical capabilities for the evaluation of health physics
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and criticality safety.
l B.
Training Faculty and staff must receive approval from the RSO before working with SMM. The approval is based on previous training and experience.
New students work under the supervision of faculty or staff who have been approved, and safety training is given by a student's faculty advisor. Since the Radiation Safety Officer has the appropriate qualifications to teach Radiation Safety, and because the background of the faculty advisor. is not specified in the application, the following condition is recommended-Condition 14. Radiation Safety training shall be provided by the Radiation Safety Officer or his designee who has equivalent qualifications.
The licensee is cammitted to retraining via Fall and Spring lectures, and seminars. The 1981 Inspection Report described a cohesive f
training program which demonstrates to this reviewer an appropriate degree of dedication to Radiation Safety training at RPI.
C.
Criticality The licensee requests continu.ed exemption from the provisions of 10 CFR 70.24 because there is no area where the possession limit exceeds 700 grams U-235 or 520 grams U-233, or 450 grams Pu or of any combination of this special nuclear material. The licensee maintains a running inventory at each location, and distributica and accountability of SNM is solely the responsibility of the RSO. This practice has been reviewed by Region I inspection, but it is not stated la the application; therefore, the following condition is recommended:
Condition 15. The Radiation Safety Officer shall authorize and control movement and 1
maintain inventories of special nuelaav matmetal to and from storice wrier)
............and between experimmtal areas.
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Since strict inventory control is exercised, the possibility of accida tal criticality is negated. Accordingly, the staff recommends that the exemption be granted as folMs:
Condition 16. The licensee is hereby ex mpted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license, and provided that no more than 450 grams of special nuclear material, excluding encapsulated Pu-Be neutron sources, held under this license is present in any one room at any one time.
i In areas where the quantity of ShM exceeds the quantity in the above stated condition and a criticality monitor is required; such as in the storage area, the following condttion is reccamended:
Condition 17. The licensee shall test the criticality iaonitors for operability every three months and shall retain for one year, records of the test results and any necessary corrective action taken.
D.
Radiation Safety The Office of Radiattan and Nuclear Safety is responsible for maintainir.g radiation exposure to ALARA. for distributing monitoring devices, and for collecting and recording exposure data. Based on the personnel exposure records at RPI. which reveal minimal exposures, the staff concludes that the program is effective.
1.
personnel Monitoring l
Information regarding exposure records is computerized and is i
accessible to staff or students who have had entry into controlled i
areas. All areas where special nuclear material is stored or l
used are designated controlled areas and require the issuance of appropriate monitoring devices. Badges are collected and read on a monthly frequency.
2.
The licensee's application addresses the radiation safety aspects of using encapsulated special nuclear material; however, authorization is requested for the use of foil, disks, and fuel coupons which are not specifically described as being encapsulatmi, and d.ich have the potential of being dispersible material. In light of this possibility, the
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ApR 1 Igp application is def tetent in describing policies which govern (1) personal contamination, (2) surface contamt-nation, and (3) ventilation; therefore, the following conditions are proposed:
Condition 18. Suitable clothing (lab coats, gloves, etc.. sNcific to the job) shall be required for work with unencapsulated ShM. Hands, feet and clothing shall te monitored when leaving an area where the material is used. Persons shall not exit an area if personal clothing and/or skin concentration levels are above background levels except by approval of the Radiation Safety Officer.
1 Condition 19. Surface contamination surveys shall be conducted daily when unencapsulated 4
StH Is used, and decontamination shall comence when survey levels of renovable contamination exceeds 5000 DPM =/100 cm2, Condition 20. Work with unencapsulated special nuclear material shall be performed in fume hoods with a mintaum face velocity of 100 1.FM. The exhaust froa this hood i
shall be filtered through absolute filters and sampled prior to discharge to the environment.
3.
Information for calibration of instruments and leak testing of sealed sources in the application is not complete; therefore, the following conditions are reconnended:
Condition 21. Radiation monttors shall be calibrated on a quarterly basis (not to exceed three cenths) and records of calibratton shall be reta1ned by the licensee for a one-year period following f
the calibration.
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APR i 982 Condition 22. The licensee shall comply with the enclosed Annex A dated September 1980,
" License Conditions for Leak Testing sealed Plutonium Sources."
4.
The licensee does not propose a criteria for releasing equipment and packages from the facility for unrestricted use. The followtog condition is reconnended:
Condition 23. Release of equipment or material from RPI for unrestricted use shall be in accordance with the enclosed Annex 8. " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Terutnation for Byproduct. Source, or Spectal Nuclear Material,* dated November 1976.
Iir. Compliance History and Region I Cauments AAreview of the Inspectice and Enforcement record of the SMM license under examination involved nine safety inspection reports dated from 1966. Of the twelve items of non-compliance reported, none had any adverse effect on personnel or the general public. The items were primarily of an administrative nature, such as lack of doceentation and/or failure to post tags or procedures.
On March 8,1982, the proposed renewed license was discussed with Region I staff and there was no objection to the issuance of the renewed license as described in the RPI application and the proposed additional conditions.
V.
Conclus1on Upon completion of the radiation safety review and the compliance history, the staff concludes that the basis of the radiation safety program is sound. Conformance by Rensselaer-with their proposed conditions as well as those developed by the FCUF staff should insure a safe operation and quick detection of unfavorable trends or effects by RPI or Region I with prompt corrective action.
Based on this analysts, it is concluded that the proposed renetal application is non-substantive and insignificant from the standpoint of environmental impact, and pursuant to subparagraph Sl.5(d)(3) of 10 CFR 51, no environmental impact statement, negative declaration, or envirorvnental impact appraisal need be prepared.
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APR 1 1982 1
Based on the discussion above it is therefore reconsnended that the license be renewed for a five-year period in accordance with the application and subject to the following conditions:
Condition 11. The quantity limitations specified in Condition 8 above notwithstanding, the i
Itcensee shall not possess at any one time under this license more than one effective kilogram of special nuclear material as defined in Section 70.4(t) of 10 CFR 70.
Condttion 12. This license does not authorize the insertion of special nuclear :r.aterial lato any nuclear reactor.
Condition 13. Notwithstanding the words in the January 20. 1981 application pertaining to the Radiation and Muclear Safety Committee function in Section 2.3 and experience in Section 2.5. the Connittee shall:
a.
Inspect and audit each facility at least once each year not to exceed a twelve-month interval.
b.
Review and approve procedures (operational or radiation safety),
which involve special nuclear material, before new procedures are implemented or existing ones are changed.
c.
Review the radiation safety program in terms of ALARA to determine trends and to recausend. appropriate corrective action if required. The annual review shall not exceed a twelve-month interval.
d.
llave at least one board member, i
other than the Radiation Safety Officer.
who has analytical capabilities for the i
evaluation of health physics and criticality safety.
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cog i jggy Condition 14. Radiation Safety training shall be provided by the Radiation Safety Officer or his designee who has equivalent qualifications.
Condition 15. The Radiation Safety Officer shall authorize and control movement and maintain inventories of special nuclear material to and from storage and between experimental areas.
Condition 16. The licensee is hereby exempted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license, and provided that no more than 450 grams of special nuclear material, excluding encapsulated Pu-Be neutron sources, held under this license is present in any one room at any one time.
Condition 17. The licensee shall test the criticality monitors for operability every three months and shall retain for one year, records of the test results and any necessary corrective action taken.
Condition 10. Sultable clothing (lab coats, gloves, etc., specific to the job) shall be required for work with unencapsulated Sm. Hands, feet and clothing shall be monitored when leaving an area where the material is used. Persons slall not exit an area if personal clothing and/or skin concentration levels are above background levels except by approval of the Radiation Safety Officer.
Condition 19. Surface contamination surveys shall be conducted daily when unencapsulated Se is used, and decontamination shall comence when survey levels of removable 2
contamination exceeds 5000 DPM =/100 cm,
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11 APR 1 jgp Condition 20. Work with unencapsulated special nuclear material shall be performed in fume hoods I
with a minimum face velocity of 100 LFM.
i The exhaust from this hood shall be filtered through absolute filters and sampled prior to discharge to the environment.
Condition 21. Radiation monitors shall be calibrated l
on a quarterly basis (not to exceed l
three months) and records of cali-bration shall be retained by the licensee for a one-year period following the calibration.
Condition 22. The licensee shall comply with the enclosed Annex A, dated September 1930
" License Condition for Leak Testing Sealed Plutonium Sources."
l Condition 23. Release of equipment or material from i
RPI for unrestricted use shall be in accordance with the enclosed Anr.ex B.
" Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination for Byproduct Source, or Special Nuclear Material, dated November 1976.
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- , - M B. H. Kosla Uraniwn Process Licensing Section
-Uranium Fuel Licensing Branch Division of Fuel Cycle and 1
MMd @'d N8 Naterial Safety, WSS l
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l Approved by:
l W. T. Crow, Section Leader l
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