ML20149G951

Safety Evaluation Rept Approving Renewal of License SNM-362 for NIST

ML20149G951
Person / Time
Site:	07000398
Issue date:	07/17/1997
From:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20149G933	List: ML20149G928 ML20149G948 ML20149G951
References
NUDOCS 9707240142
Download: ML20149G951 (17)

Text

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• g UNITED STATES j

J" NUCLEAR REGULATORY COMMISSION i t WASHINGTON, D.C. 20616 4001

% g! July 17,1997 DOCKET NO: 70-398 LICENSEE: U.S. Department of Commerce National Institute of Standards and Technology Gaithersburg, Maryland

SUBJECT:

SAFETY EVALUATION REPORT, LICENSE RENEWAL APPLICATION DATED JUNE 19, 1997, RE: RENEWAL OF LICENSE NO. SNM-362 I. INTRODUCTION A. General The National Institute of Standards and Technology (NIST) is authorized under Materials License SNM-362 to conduct research and development activities related to the development of radioactive standards and provide services and standard sources to customers.

B. Location Descriotion The NIST site is located on a fenced site of about 575 acres in Montgomery County in Gaithersburg, Maryland, approximately 20 miles northwest of the Capital Building in Washington. D.C. and is bounded by Interstate 270, Muddy Branch Road, and Maryland Route 124. Figure 1 shows the geographic location of the site.

C. License History Materials License SNM-362 was first issued in 1960 by the Atomic Energy Commission to the National Bureau of Standards. The Nuclear Regulatory Commission renewed the license in 1979, 1985, and 1991. In 1988, the licensee changed the name to the National Institute of Standards and Technology which reflected the broadened role and new activities assigned to the agency by national law. License SNM-362 was scheduled to expire on July 31, 1996. By letter dated May 14, 1996. NIST requested a five-year extension of the expiration date of License SNM-362. On June 17, 1996, NRC denied NIST's extension request.

D. License Renewal Aoolication and Staff Review of the Aoolication By letter dated June 28, 1996, NIST resubmitted a full renewal ap)1ication in accordance with 10 CFR 70.33. By letter datea January 28. 1997, iRC staff's comments on the renewal opplication were transmitted to NIST for response. On February 28, 1997. NIST responded to NRC's comments by submitting a revised renewal application. As a result of several teleconferences with NIST representatives and in reply to the staff's May 13, 1997, request for 9707240142 970717 PDR ADOCK 07000398 C PDR

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additional information, on June 6. 1997. NIST submitted a revised renewal application in its entirety. As a result of further teleconferences with a NIST representative--to discuss the application. NIST resubmitted a revised-

renewal application in its entirety on June 19. 1997. This submittal superseded all previous ap)lications except two attachments (containing a Site Plan View Building Floor )lans. Environmental Monitoring Locations and Forms Used in the Radiation Safety Program) to the application submitted by-letters dated' June 28. 1996 and February 28. 1997.

The licensee's renewal application consists of two parts. Part I. Chapters 1 through 7, contains the license conditions of the application and is subject to inspection. Part II Chapters 8 through 12, contains the safety demonstration of the application, which demonstrates the adequacy of NIST's

)roposed license conditions. The information in Part'II is subject to change

)y NIST within the limitations of Part I.

Pursuant to 10 CFR 73.67(c) and 10 CFR 74.31 neither a physical-security plan nor a material control and accounting system is required under License SNM-362. However, in the area of physical protection. NIST is required to follow the provision of 10 CFR 73.67(f) and the reporting requirements of 10 CFR Parts 73 and 74.

In reviewing the NIST renewal application, the staff focused on radiological protection, environmental protection, the emergency plan, and fire safety, as well as decommissioning financial assurance. This Safety Evaluation Report (SER) describes the basis for the NRC staff determination that License SNM-362 can be renewed in accordance with NRC requirements and without adverse effect on public health and safety and the environment.

II. POSSESSION LIMITS In the application. NIST has requested the materials, forms, pnd quantities of the licensed materials. These are indicated in Conditions 6, 7. and 8 of the license and shall read as follows:

6. Material 7. Form 8. 01Lantity y

A. Uranium enriched to A. Any A. 30 grams of U-235

, less than 20 wt*

j in the U-235 isotope B. Uranium enriched to or B. Any B. 230 grams of U-235 greater than 20 wt%

in the U-235 isotope '

C. Uranium-233 C. Any C. 6 grams 1

Conditions 1 through 5 indicate the licensee's name and address, license number and expiration date, and docket number.

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y D. Plutonium, except D. Any D. 40 grams Pu-238 E. Plutonium E. Sealed E. 800 grams sources F. Plutonium enriched F. Any F. 0.1 grams to more t'an 80% in the Pu-238 isotope G. Natural uranium G.I. Any insoluble G.I. 150 kilograms form

2. Any soluble 2. 9 kilograms form H. Thorium H. Any H. 69 kilograms I. Uranium depleted in I.1. Any insoluble I.1. 42 kilograms the U-235 isotope form

2. Any soluble 2. 4 kilograms form J. Co-60 J. Sealed J. 58.000 curies sources K. Cs-137 K. Sealed K. 9.000 curies sources L. Po-210 L. Sealed L. 20 curies sources M. Am-241 M. Sealed M. 40 curies sources k! . Cf-252 N. Sealed N. 10 curies sources

0. Sr-90 0. Sealed 0. 5 curies sources P. Byproduct material P. Any P. 4.000 curies total

1. any nuclide of 1. 4 curies half-life less than 30 days l

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2. any nuclide of 2, 1 curie, I half-li fe except for  :

more than the following 30 days except nuclides:

for the following nuclides:

H 2.000 curies Au-198 300 curies Kr-85 35 curies CS-137, Mo-99. Tc-99m and Xe-133 20' curies each C-14 and Co-60 5 curies each Ac-227 25 mil 11 curies Am-241, -242m, and -243 25 millicuries each Bk-247 25 mil 11 curies

2. Cf-249, -250 -251, -252, and -254 25 mil 11 curies each l Cm-242 -243. -244. -245. -246 -247, 25 millicuries '

-248, and -250 each l

25 millicuries Np-236 and -237 each Sm-146 and -147 25 millicuries each Q. Any byproduct Q. Neutron irradiated Q. 1,100 curies total material with samples or containers except for the

Atomic Number following nuclides:

3 to 83. except for the following nuclides:

Ag-108m 800 curies Eu-152 and -154 800 curies each

, Nb-94 800 curies L Tb-158 800 curies Be-10 500 curies P-32 400 curies

, Os-194 350 curies ,

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Cl-36 200 curies l I-130- 200 curies l i

Hf-178m and -182 100 curies each  !

Bi-210m 30 curies

! I-125 20 curies l Sm-146 3 curies .

1 j R. Irradiated fuel R. Four pellets R. 0.25 grams.of U-235* l III. AUTHORIZED ACTIVITIES AND LOCATIONS l

The typical activities being conducted under this ' license and locations where the licensed material will be used include:

e Materials and equipment irradiation in Buildings 235 and 245. During a telephone conversation between NRC staff and NIST representative on July 14, 1997, the NIST representative indicated that radioactive materials are stored in a locked storage room in Building 245. The access to the storage room is restricted to authorized personnel, and radiation level at the entrance is about 0.05 mr/hr. NIST conducts a radiation survey around the storage room weekly. The NIST representative further indicated that the four irradiated fuel pellets l that NIST possess of are stored in a lead container in the storage room, l NIST will dispose of them by December 2000. j e Reference or counting source uses, incorporation of sources into devices, and general research and development in Buildings 101. 220 through 226, 235, and 245.

e Source preparations and calibrations, instrument calibrations, sample amys, source characterizations, and radiochemistry in Buildings 220 through 226, 235, and 245.

The NRC staff determined that the proposed activities are consistent with the research and development activities specified in the Atomic Energy Act and are in accordance with 10 CFR 70.23(a)(1). Therefore, they are appropriate for l inclusion in the renewed license.

Tc authorize these facilities and activities, the staff proposes the following I license conditions:

.9. Authorized place of use: The licensee's existing facilities at Gaithersburg Maryland.

10. Authorized use: For use in accordance with statements, representations.

-and conditions of Part I (Chapters 1 through 7) of the application dated  !

June 19. 1997.

• storage only, awaiting disposition l

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_y IV. ORGANIZATION AND ADMINISTRATION A. Orcanization. Personnel Resoonsibilities. and Minimum Oualifications

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Cha)ter 2 of the application describes the organizational responsibilities and autlority and administrative requirements that govern the radiological protection program. At NIST, the Director of the Institute has the ultimate responsibility for safe operation. This responsibility is administered through NIST 3rofessional staff. The Chief, Occupational Health and Safety Division _ (OHS)), reports through the Director of Administration to the Director of NIST and is responsible.for establishing and managing the radiological safety 3rogram. This responsibility is implemented through the Health Physics Unit ]y maintaining routine radiological surveillance and a i program that includes periodic inspection of controls and operations. The Chief, OHSD. has, as minimum qualifications, a B.S. in science or engineering and 5 years of professional experience related to safety and health protection.

'The Health Physics Unit is a 3 art of OHSD and consists of a Chief of Health 1 Physics. Supervisory Health P1ysicists, and Health Physics Technicians.

The Chief of Health Physics is responsible for administering the radiological safety program and review and approval of safety issues presented by Supervisory Health Physicists. The Chief of Health Physics, as a minimum, must be certified in health physics by the American Board of Health Physics or must have a bachelor's degree in science or engineering and 5 years of l professional radiological safety experience.

Supervisory Health Physicists (SHP) are responsible for the daily administration of the radiological safety program and approval of radiation projects. As minimum qualifications, the SHPs' must have bachelor's degrees in science or engineering and 2 years of experience in applied health physics.

A Supervisory !lealth Physicist or person at a higher management level has the authority to shutdown an unsafe operation.

The NIST Ionizing Radiation Safety Committee (RSC), which meets at least annually, provides oversig'.t for the radiological safety program: reviews radiological safety projects; advises the Chief, OHSD, on operations: and 4 recommends corrective actions, In addition, the RSC serves as the ALARA review committee and issues an annual report which suninarizes the following information:

e Trend analyses of data from personnel exposures, environmental monitoring, and effluent surveillance.

e ALARA reviews and decisions.

e Program audits and inspections conducted during the previous year Members of the RSC include the Chief of Health Physics or an SHP and experts in the fields of physics, chemistry, health physics, material science, 7

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o industrial safety, and nuclear research reactors. The licensee has proposed that minimum qualifications for the RSC members include a degree or equivalent professional experience in their res)ective field of expertise and at least 5 years of pertinent experience. The 4RC staff has reviewed NIST's RCS members' and alternates' resumes and determined that they are acceptable.

Based on the NRC staff's review NRC staff determined that NIST is qualified by reason of training and experience to use byproduct. source, and special nuclear material for the purposes authorized in Condition 10 in accoraance with 70.23(a)(2).

B. Administrative Practices The licensee has committed to follow written operating, maintenance, and test procedures for work with licensed materials. All proposed work and written procedures are approved by an SHP or a person with the same qualifications. l If the proposed work could credibly lead to a whole body dose greater than i 1.25 rems, it will be reviewed by the RSC.

Health physics o;erating procedures have been established and will be i followed. The Clief of Health Physics will approve any modification of these l procedures. NRC staff has not reviewed NIST's detailed health physics ,

operating procedures. However, the staff has reviewed NIST's management control procedures for the implementation of the radiation protection program ,

and determined that they are adequate. Based on the staff's review of the ,

licensee's procedures. NRC staff has determined that they are adequate to  !

3rotect health and to minimize danger to life or property in accordance with ,

part 70.23(a)(4). )

C. Insoections and Audits At least quarterly, an SHP or person with cualifications equivalent to those l of a Supervisory Health Physicist will concuct safety inspections of radiation work places. The inspections will be conducted by following written plans.  !

Results of the inspections will be documented and needed corrective actions communicated to and implemented by work place supervisors.

The RSC representatives who are not members of the Health Physics staff will conduct an annual audit to examine the performance quality of operations that 3rovide radiological safety assurance. In addition, at least annually, the lealth Physics Unit staff members will review surveillance techniques and results to assure coapliance with applicable protocols and follow-up actions.

D. Trainina The licensee has comitted to a requirement that workers will receive radiation safety training 3rior to working independently with radioactive materials. To determine t1e extent of radiation safety training that an individual needs, a review will be conducted of the individual's prior work experience and training. In addition. Health Physics Technicians are trained in fundamentals of radiological safety. Health Physics Technicians and individuals who work with radioactive materials are required to attend 8

biennial radiological safety training. The Chief of Health Physics is responsible for ensuring that training programs are given as required.

E. Records Retention The Health Physics Unit is responsible for maintaining documentation on the results of required monitoring and surveillance the results of approved proposal reviews, off-normal occurrence investigations and other radiological safety program information. These records are retained as required by regulations. If the regulations require retention for less than 2 years. NIST wi11 retain the records for at least 2 years.

F. Conclusion The licensee has established an organizational and administrative system for the safe operation of the facility. Minimum qualification requirements for positions with safety-related responsibilities are adequate. Operations are conducted in accordance with approved written procedures and an inspection l system ensures that operations are conducted safely. Employees are trained .

prior to working with radioactive material and safety-related records will be i maintained. The staff concludes that the licensee's management organization l and administrative commitments are consistent with good practice, adequate to protect the public health and safety, and acceptable. l 1

V. RADIATION PROTECTION i A. Administrative Reauirements The Health Physics Unit is responsible for maintaining a radiation safety program to ensure the protection of the workers and public. Work involving radioactive material will be conducted in accordance with the operating procedure, which was approved by an SHP. For a special task which is not covered by a standing operating procedure and where radiation exposure is likely to be significant, the Health Physics Unit will issue a Radiation Work Permit (RWP) containing all safety requirements for the task. An SHP or a l person with the same qualifications will approve the RWP. An RWP previously I approved may be reissued by a Health Physics Technician.

B. Monitorina of Radiation Exoosures

1. External Exoosure External radiation exposure to workers is monitored and evaluated in accordance with the requirements specified in 10 CFR 20.1501 and 1502. At NIST, the dosimeters are processed at least quarterly for dose reading. NIST has established a corrective action level at 10 percent of the regulatory limits specified in 10 CFR 20.1201. If doses exceed the 10 percent level.

NIST will review the situation and take corrective actions.

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2. Internal Exoosure The licensee has committed to the protection of the operating personnel from excessive internal exposure by:

(1) Having work performed in a ventilated hood or glove boxes, thus limiting the concentration of radioactivity in the breathing air.

(2) Implementing an internal exposure monitoring program to detect any significant intake of radioactive material by the workers.

If the Health Physics Unit determines that work should be performed in a hood, the hood face velocity is maintained at a minimum rate of 75 linear feet per minute at any measured hood face location, and this flow rate will be checked at least cuarterly, If approved work requires high efficiency particulate filters (FEPA) for hoods or glove boxes at the workplace, the HEPA system will be equipped with a device for monitoring the pressure-differential across the filter to evaluate the filter loading. The pressure-difference is checked on a quarterly basis. The work will be suspended if the pressure reading exceeds the NIST established level. ,

1 The Health Physics Unit conducts a personnel internal dosimetry program using measurements of concentrations of radioactive material in air in work areas; l

or quantities of radionuclide.s in the body; or quantities of radionuclidF i excreted from the body; or any combinations of these measurements.

J The monitoring of workplace airborne radioactivity concentrations will be 3erformed in accordance with Regulatory Guide 8.25 " Air Sampling in the i Workplace" for air sam) ling frequency, and for locations of samplers. A  !

bioassay program will 3e performed based on Regulatory Guide 8 9. " Acceptable l Concepts. Models Equations. and Assumptions for a Bioassay Program " for bioassay frequency type of measurements, and interpretation of bioassay measurements. When the workers' internal exposure exceeds 10 percent of the regulatory limits, NIST will review situation and take corrective actions.

j The external exposure records for the period of 1990 through 1996 show that no employees have received more than 15 percent of the annual limits under this license. The internal exposure levels received by the workers have been i

negligible.

C. Monitorina of Surface Contamination For work areas involving radioactive material, the Health Physics Unit will l conduct weekly radiation and contamination surveys using the appropriate i instruments. When contamination levels exceed specific action levels, l decontamination efforts will be initiated promptly to reduce contamination levels or the affected area will be restricted for a period of time to permit decay of short-lived radionuclides, Action levels used for controlling surface contamination meet the values recommended in Regulatory Guide 8,21,

" Health Physics Surveys for Byproduct Material at NRC-Licensed Processing and Manufacturing Plants."

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NIST has requested authorization to Jossess sealed sources which will be leak tested. The licensee's proposed leac testing program meets the criteria identified by the staff of the Fuel Cycle Licensing Branch for leak testing ,

sealed sources. 1 D. ALARA l

NIST has made a policy statement that NIST is to maintain radiation exposures )

and release of radioactive materials to as low as is reasonably achievable (ALARA). The Health Physics Unit reviews the dosimetry reports, contamination survey results, external; radiation level survey data, and other radiological safety program information for ALARA purposes. The Ionizing Radiation Safety Committee serves as the ALARA review committee,_ evaluates Health Physics j reports of these reviews, and analyzes other safety and operational .

information for ALARA purposes. The NRC staff has determined that NIST commitments in the radiation protection program meet the requirements in 10 CFR 20.1101, including the ALARA requirement in 10 CFR 20.1101(b).

E. Postina -

For precautionary purposes, areas where radioactive material is used or stored, will be posted with proper signs, in accordance with the regulatory l requirements. In addition- the area where an operation is being conducted will be surveyed routinely for any undesirable contamination. During a telephone conversation between the NRC st6ff and a NIST representative on July 14, 1997, the NIST representative stated that the stored material will be l secured in a locked room and the HP unit will conduct a radiation l contamination survey around the storage room area weekly. The NRC staff has determined that NIST posting procedures and storage of radioactive materials meet regulatory requirements. ,

l F. Conclusion The staff has reviewed the licensee's radiation safety program including administrative requirements, the external and internal ex)osure monitoring program, the surface contamination control program, and A_ ARA and posting procedures and has determined that it is sufficient to meet 10 CFR Part 20 requirements and is adequate to protect public health and safety. -The staff has also determined that NIST has the necessary technical staff to administer an effective radiological safety program.

VI. CRITICALITY SAFETY NIST does not possess and use special nuclear material in quantities and forms sufficient to form a critical mass. That is. NIST possesses and uses less than 350 grams of contained uranium-235, 200 grams of uranium-233, 200 grams of plutonium (in any form other than plutonium-beryllium neutron sources). or any combination of these in accordance with the unity rule as shown below:

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1 arams U-235 + arams U-233 + arams Pu < or =

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, 350 200 200 l 252 + 6 + 40 - 0.97 <1 350 200 200 q

-NIST commits to adequate procedures to ensure that no more than 450 grams of plutonium as plutonium-beryllium neutron sources will be used or stored at any single site. Therefore, no criticality provisions.are required.

1 VII. ENVIRONMENTAL PROTECTION 2 A. Environmental Protection The NRC staff has reviewed the licensee's commitments to an environmental protection program including effluent controls and monitoring and environ-mental monitoring. Effluent and environmental monitoring data for the period of-1991 through 1996, provided by NIST in an Environmental Report dated October 18, 1996, were also considered.

1.0 Effluent Monitorina The NIST facility produces airborne, liquid, and solid effluents, which are controlled and monitored to demonstrate com)liance with applicable regulatory limits and are ALARA. Gaseous effluents, w11ch are controlled through the use of HEPA filters, are discharged from laboratory vents and from one stack.

Effluents discharged from the stack originate from the research reactor's Confinement Building, which is licensed under NRC Reactor License TR-5 (i.e.,

outside the activities authorized by the requested renewal license), and from radiochemistry laboratories in Building 235, which are licensed under NRC Special Nuclear Materials License SNM-362. The NIST 1996 Environmental Report indicates that no Jermit for non-radioactive gaseous effluents is required for this facility by t1e state of Maryland.

Each operation is evaluated prior to instigation to determine if releases of airborne radiological effluents in concentrations greater than 10 percent of the limits in 10 CFR Part 20. Appendix B. Table 2. Column 1 are possible. If such releases are possible, radiological effluents are monitored continuously at each discharge point. For caerations where releases between 3 and 10 percent of the limits are possi)le, effluents are monitored at least once in each quarter for continuing operations and at least once for short-term operations.

The NIST air sampling program is designed so that air samples will be representative of the actual release for the sampling period. In addition, the minimum detectable concentration (MDC) of the analysis is no greater than

-10 percent of the concentration given in 10 CFR 20. Appendix B. Table 2, Column 1, for the major nuclides involved in the process being monitored.

Records are keat of evaluations and monitoring results to demonstrate compliance witi 10 CFR 20. Appendix 8. Table 2 Column 1 and the ALARA constraint on air emissions specified in 10 CFR 20.1101(d). For measurements 12

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-which fall below the MDC, the value of the MDC is used in dose assessment calculations to demonstrate compliance.

If any measurement exceeds 25 percent of the effluent limits in 10 CFR 20.

Appendix B Table 2. Column 1. NIST will locate the source of the release and suspend operations. For the period of 1991 to 1996, no radionuclides from operations conducted under SNM-362 ~were released in gaseous effluents in concentrations'above the applicable MDC.

The NIST facility also generates liquid effluents containing radioactive constituents. Liquid wastes from most of the NIST laboratories are drained to tanks for discharge to the sanitary sewer in accordance with Washington Suburban Sanitary Commission Discharge Authorization Permit 05813. Three 19,000 L hold-up tanks are used to collect the liquids. Health Physics personnel assay.the contents of these tanks prior to discharge to the sewer to ensure compliance with the discharge limits in 10 CFR 20.2003 and 10 CFR Part 20, Appendix B. Table 3.

For the remainder of the laboratories and for operations where significant activity concentrations are expected, liquids are collected in specially marked containers. Liquids are then either solidified for disposal as solid 3 radioactive waste or disposed of via i.he liquid waste tanks and sanitary sewage discharge.

Solid wastes collected from the NIST laboratories are transferred one to four times a year for disposal at a licensed burial facility. Prior to transfer, a solid waste compactor may be used to reduce the volume of solid waste.

Alternatively, if the waste consists of short-lived radionuclides, it may be i stored for decay as provided in 10 CFR 20,2001(a)(2). Disposal of decay-in- 1 storage waste is in accordance with the conditions given in 10 CFR 35.92. l Mixed wastes, such as liquid scintillation discards are also generated at the  ;

NIST facility. These wastes are transferred to a licensed disposal contractor '

or are stored pending availability of approved disposal or treatment facilities. Currently, there is no mixed waste stored at the NIST facility that was generated under License SNM-362. Whenever possible, modifications are incorporated into procedures to preclude or reduce mixed waste generation.

The NRC staff has reviewed NIST's program for effluent control and monitoring and has determined that it is sufficient to meet the requirements of 10 C A Part 20 and is adequate to protect public health and safety, and is, therefore, acceptable.

2.0 fnvironmental Monitorina To assess the impact of facility operations on the surrounding environment, an ' environmental monitoring program has been implemented at the NIST facility, which includes measurements of surface water, soil, vegetatinn, and ambient radiation levels.

NIST has committed to quarterly sampling of surface water from on- and off-site locations. Samples are analyzed using gamma spectrometry for l L 13

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approximately two dozen radionuclides typically relevant to NIST operations.

Water samples are also analyzed using liquid scintillation to measure tritium 1 levels. Quarterly sampling of vegetation during spring and summer. and soil l during the fall and winter from five on-site locations are also conducted. i These samales are also analyzed using gamma spectrometry. In addition, l

sixteen t1ermoluminescent detectors (TLD's) are placed at the site perimeter i and are processed quarterly _ to monitor external radiation levels. ,

As discussed in the 1996 Environmental keport. if any environmental monitoring sample indicates a potential dose greater than 10 percent of the public dose limit specified in 10 CFR 20.1301 or if any TLD result for a quarter shows a )

dose greater than i 2 standard deviations from the average value observed for the past five years, an SHP reviews the data and recommends further action.

I No sample of soil, grass, or water taken from 1991 to 1996 has demonstrated measurable levels of radioactivity attributable to NIST operations as determined by gamma spectroscopy. In addition, from 1991 to 1996, average tritium concentrations measured in surface water and in groundwater samples from two off-site wells were not statistically different from the analysis MDC. The MDC's for the tritium analyses ranged from 2.0 to 4.0 x 10' uCi/ml.

The NRC staff has reviewed the environmental monitoring program and has determined that it is adequate to assess any environmental impacts from o)erations at the NIST facility and to protect public health and safety.

T1erefore, the program is acceptable.

3.0 Conclusion The NRC staff has reviewed NIST's environmental protection 3rogram and has determined that the program meets the requirements of 10 CFR Part 20 and is adequate to protect public health and safety, and is, therefore, acceptable.

B. Environmental Review The use of radioactive materials for research and development meets the criteria for a categorical exclusion in accordance with 10 CFR  ;

51.22(c)(14)(v), (viii), and (x). The environmental impacts from these types i of activities were generically evaluated in the rulemaking that established the requirements in 10 CFR Part 51. Therefore, neither an environmental assessment nor an environmental impact statement is warranted for this action.

VIII. EMERGENCY PLAN ,

10 CFR 70.22(1)(1) requires NIST to either: (1) perform an evaluation that demonstrates that the maximum dose to a member of the public offsite due to a release of radioactive materials would not exceed certain specific dose levels, or (2)' submit an emergency plan. By letters dated November 19, 1992, and November 4,1993, NIST chose to submit an evaluation, NIST's evaluation was accepted by NRC staff in an amendment to License SNM-362 issued on December 10, 1993. In this renewal application. NIST has reduced the 3roposed possession limits (i.e., enriched uranium is reduced by 178 grams). T1e staff 14

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-has reviewed NIST's earlier demonstration and concluded that NIST meets the requirements of 10 CFR 70.22(i)(1)(1). Therefore, an emergency plan is not

' required.

IX. DECOMMISSIONING FUNDING PLAN 10 CFR 70.25 requires NIST to have a decommissioning funding plan (DFP) which contains a cost estimate for decommissioning and a description of the method of assuring funds _for decommissioning at the end of plant life. NIST, an agency of the Department of Commerce, fulfilled DFP requirements by filing a statement of intent containing a cost estimate for decommissioning of

$3.38 million and indicating that funds for decommissioning will be obtained when necessary.. NIST's DFP was approved by NRC on May 4, 1994. The NRC staff has reviewed and reaffirmed the previous determination in support.of the renewal.

X. FIRE PROTECTION The licensee's facilities and buildings complied with applicable regulations for Federal facilities at the time of construction. Installed firo protection systems include smoke detectors, heat detectors,. fire alarm pull-boxes, standpipes, and sprinkler systems in a few areas of moderate fire load. Fire loads in most areas are light. Portable extinguishers are deployed in all the buildings in accordance with industry standards.

An underground fire main supplied by the local municipal water system provides fire protection water to the facility. There is an adequate number of hydrants. The fire detectors and other alarm sensors transmit the alarm ,

signal to a console at the fire station, which is continuously manned.

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NIST Facilities Services Division has a Fire Chief, who is responsible for  ;

operating the fire station, as well as periodic fire safety reviews of the l various buildings. The Fire Chief also reviews proposed changes of the '

facilities and processes. A group of trained fire fighters man the fire station, whose equipment include two pumpers and an ambulance.

A Pre-Fire Plan is available at the fire station, which provides information of the location and the contents of an area where an alarm originates. The fire fighters attend regular training sessions and hold several fire drills a year.

The staff has reviewed licensee's fire protection and determined that NIST maintains an adecuate level of fire prot ,cion at its facilities to protect public health anc safety.

XI. SPECIAL AUTHORIZATIONS A. Authorization for Use at Offsite Locations I In Section 1.8.a. of the application, NIST requested authorization to use radioactive material at offsite locations. This material will be subject to the following controls:

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e The proposal is reviewed and approved by Health Physics and, if

' required, by the Ionizing Radiation Safety Committee.

e NIST is responsible for the safe use of the radioactive material and the radioactive material is controlled by an authorized individual in accordance with applicable requirements, who possesses written operating instructions while engaged in the project.

e The radioactive material is an integral part of a measurement instrument or a contained source, such as a check or reference source. '

e Lead-in-paint detectors may not exceed 100 millir.uries of cadmium-109 or I americium-241 as sealed sources in each device, ut % rwise the total quantity of radioactive material for a single authorized use_may not exceed ten times the activity listed in 10 CFR Part 20. Appendix C or. l for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity.

During a telephone conversation between NRC staff and a NIST representative on July 14, 1997, the NIST representative provided additional information regarding the use of the material at offsite locations. These are as follows:

1. .ae use is for research and development on instruments containing ,

radioactive material and calibration of sources in those instruments. l

'2. The material will be used at offsite locations in the United States about 3 to 4 times a year. NIST will obtain an authorization for using the material from the Agreement States if the material will be used in those States.

3. No more than 5 lead-in-paint detectors will be used at one time and location.

The staff reviewed the request and determined that NIST's proposed safety controls and procedures for the use of radioactive material at offsite locations are adequate to protect the health and safety of the personnel and environment. Therefore, NIST's request is acceptable.

B. Authorization to Release Contaminated Eauioment In Section 1.8.b. of the application, NIST requested authorization to release contaminated equipment to unrestricted areas in accordance with the U.S. NRC's April 1993. " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Specidl Nuclear Material." NIST uses NRC's specific guidelines for unrestricted release of contaminated equipment. Therefore NIST's request is acceptable.

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47' XII CONCLUSION The NRC staff has reviewed the licensee's submittals regarding radiological, nuclear, fire safety and environmental protection. Based on this review, the staff has determined that there is reasonable assurance that the facility can be continuously o]erated in a safe manner. The staff, therefore, recommends that the license ]e renewed for a pericd of 10 years.

The staff discussed the renewal with the Regional Inspector. The Inspector has no objections to the issuance of the renewed license.

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_ Princioal Contributors 4'g p Sean Soong Susan Chotco Kim Hardin g p f j $,gi Amar Datta J}

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