ML20217G864

Matls Licensing Package for Amend 7 to License SNM-200 for South Dakota State University.Control:465667

ML20217G864
Person / Time
Site:	07000218
Issue date:	02/24/1998
From:	Campbell V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
References
465667, NUDOCS 9804290227
Download: ML20217G864 (47)

Text

l NRC F* RM 374 PAGE 1 OF 3 PAGEs U.s. NUCLEAR REGULATORY Commission Amendment No. 07 i

MATERIALS LICENSE

! Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10 Code I

of Federal Regulations, Chapter I, Parts 30,31,32,33,34,35,39,40 and 70, and in reliance on statements and representations heretofore mIda by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, cnd special nuclear material designated below; to use such material for the purpose (s) and at the place (s) designated below; to deliver

( or tran;fer such material to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conddions specifed in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable ruts, regulations and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.

Licensee In accordance with application dated June 2,1995

1. South Dakota State University 3. Ucense number SNM-200 is amended in its entirety to read as follows:

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i 2. P.O. Box 2202 4.' Expiration date February 29,2008 Brookings, South Dakota 57007-0896 5. Docket No. 070-00218 Reference No.,

6. Byproduct, source, and/or special 7. Chemical and/or physical form 8J" Maximum amount that licensee may nuclear material possess at any one time under this s license A. Plutonium-239 A Sealed n_eutron sources ;

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A. '80 grams (5 sources, not to (Mo'nsanto, Serial Nc's.13 . exceed 1 Curie per source) t _ M495, hj496 M497 M498, r$a T and M499); ', #.

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9. Authorized use L,, y i65" A. For use in experiments and d k$h strations gstuIl ction and activation analysis of biological and environmental samples. ' S ?f.i pV ' % [Y M CONDITIONS l 10. Licensed material shall be used only at the licensee's facility located at Crothers Hall, South Dakota State University, Brookings, South Dakota.

11, A. Licensed material shall only be used by, or under the supervision of, individuals designated by the Radiation Safety Committee, Leo H. Spinar, Ph.D., Chairperson.

l B. The Radiation Safety Officer for this license is Leo H. Spinar, Ph.D.

l

12. A. Sealed sources and detector cells shall be tested for leakage and/or contamination at intervals not to exceed 6 months or at such other intervals as specified by the certificate of registration referred to in 10 CFR 32.210.

B. Notwithstanding Paragraph A of this Condition, sealed sources designed to emit alpha particles shall be tested for leakage and/or contamination at intervals not to exceed 3 months.

C. In the absence of a certificate from a transferor indicating that a leak test has been made within  !

6 months prior to the transfer, a sealed source or detector cell received from another person shall not be put into use until tested. s e 0 OfflCIAL RECORD COPY 9eo4290227 9l30224 ML40 PDR ADOCK 07000218 C PDR

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N2C FORM 374A U.s. NUCLEAR REGULATORY Commission PAGE 2 of 3 PAGES License Number SNM-200 i MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 070-00218 Amendment No. 07 D. Sealed sources need not be leak tested if:

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they contain only hydrogen-3; or (i)

(ii) they contain only a radioactive gas; or (iii) the half-life of the isotope is 30 days or less; or ,

1 (iv) they contain not more than 100 microcuries of beta and/or gamma emitting material or not more than 10 microcuries of alpha emitting material; or (iv) they are not designed to emit alpha particles, are in storage, and are not being used. However, when they are removed from storage for use or transfeged-to another person, and have not been tested within the reqbired leak test interval, they shall be_ tested before use or transfer. No sealed source or detector cell'shall be stored fordperiod of more than 10 years without being tested for leakage and/ohont'aminatio~n.** -

t ,f / /e ]y' ' b E. The leak test shall be capable o'f detec'tio.g die'presen'ce of 6.005 microcurie of radioactive material on the test sample. If the test /hveals the' presence ' foOIOOS[nicrocu' rie or more of removable contamination, a report shhRbEfiliniwith the U.S. Nuclear R'eg'ulatory Commission in accordance with 10 CFR 30.50(b)(2),~and thd5Ece siY$flbe removd imme'dfately from service and decontaminated, repaired, or disposed of in acc68ancd:'witt1 Commi$s(ion'rd days of the date the leak test r'e'sultIisTnow$'with thTLIS!

Nuclear gulations.-

Regulatory The Region Commission, reportIV, shall be TeSas"760iil ATTN: Director, Division of Nuclear l

611 MaterialsRyan Plaza Safety. Drive, The report shallSuite specify 400, t ArlIngto'ri[h'e'so'urce involved the test resul taken.

l l F. Tests for leakage and/or contamination shall be performed by the licensee or by other persons )

! specifically licensed by the Commission or an Agreement State to perform such services. l l

13. Sealed sources or detector cells containing licensed material shall not be opened or sources removed from  ;

source holders by the licensee.

14. The licensee shall conduct a physical inventory every 6 months to account for all sources and/or devices received and possessed under the license.

15. In addition to the possession limits in item 8, the licensee shall further restrict the possession of licensed material to quantities below the minimum limit specified in 10 CFR 70.25 for establishing decommissioning financial assurance, l

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NRC FORM 374A u.s. NUCLEAR REGULATORY CoMMISsloN PAGE 3 of 3 PAGEs License Number SNM-200 MATERIALS LICENSE oxket or Reference Number SUPPLEMENTARY SHEET 070-00218 Amendment No. 07

16. Except as specifically provided otherwise in this license, the licensee shall conduct its program in accordance with the statements, representations, and procedures contained in the documents, including any enclosures, listed below. The U.S. Nuclear Regulatory Commission's regulations shall govern unless the statements, representations, and procedures in the licensee's application and correspondence are more restrictive than the regulations.

A. Application dated June 2,1995 .

B. Letter dated December 19,1997 'f.

C. Letter dated February 20,1998 /

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1 FOR THE U.S. NUCLEAR REGULATORY COMMISSION Date By 7 ~

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1" A Vivian H. Campbell Nuclear Materials Safety Branch 1 Region IV Arlington, Texas 76011

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( 8 o NUCLEAR REGULATORY COMMISSION 5 ;E REGION IV O

611 RYAN PLAZA DRIVE SUITE 400

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l February 24,1998 South Dakota State University ATTN: Leo H. Spinar, Ph.D.

Radiation Safety Officer Regulatory Compliance Office P.O. Box 2202 Brookings, South Dakota 57007-0896

SUBJECT:

LICENSE RENEWAL Please find enclosed License No. SNM-200. You should review this license carefully and be sure that you understand all conditions. If you have any questions, you may contact me at (817) 860-8217.

NRC expects licensees to conduct their programs with meticulous attention to detail and a high standard of compliance. Because of the serious consequences to employees and the public ,

which can result from failure to comply with NRC requirements, you must conduct your program }

involving radioactive materials in accordance with the conditions of your NRC license, representations made in your license application, and NRC regulations. In particular, note that j you must: j

1. Operate in accordance with NRC regulations 10 CFR Part 19, " Notices, instructions and Reports to Workers: Inspection and Investigations," 10 CFR Part 20, " Standards for Protection Against Radiation," and other applicable regulations.

2. Possess radioactive material only in the quantity and form indicated in your license.

3. Use radioactive material only for the purpose (s) indicated in your license.

4. Notify NRC in writing of any change in mailing address (no fee required if the location of radioactive material remains the same). '

5. - Request and obtain written NRC consent before transferring your license or any right thereunder, either voluntarily or involuntarily, directly or indirectly, through transfer of control of your license to any person or entity. A transfer of control of your license includes not only a total change of ownership, but also a change in the controlling interest in your company whether it is a corporation, partnership, or other entity. In  !

l addition, appropriate license amendments must be requested and obtained for any other l planned changes in your facility or program that are contrary to your license or contrary j to representations made in your license application, as well as supplemental l correspondence thereto, which are incorporated into your license. A license fee may be charged for the ametidments if you are not in a fee-exempt category.

6. Maintain in a single document decommissioning records that have been certified for completeness and accuracy listing all the following items applicable to the license:

l -

Onsite areas designated or formerly designated as restricted areas as defined in 10 CFR 20.3(a)(14) or 20.1003.  !

South Dakota State University . . Onsite areas, other than restricted areas, where radioactive materials in quantities greater than amounts listed in Appendix C to 10 CFR 20.1001-20.2401 have been used, possessed, or stored.

Onsite areas, other than restricted areas, where spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site have occurred that required reporting pursuant to 10 CFR 30.50(b)(1) or (b)(4), including areas where subsequent cleanup procedures have removed the contamination.

Specific locations and radionuclide contents of previous and current burial areas within the site, excluding radioactive material with half-lives of 10 days or less, depleted uranium used only for shielding or as penetrators in unused munitions, or sealed sources authorized for use at temporary job sites.

Location and description of all contaminated equipment involved in licensed operations that is to remain onsite after license termination.

7. Submit a complete renewal application with proper fee, or termination request at least 30 days before the expiration date on your license. You will receive a reminder notice approximately 90 days before the expiration date. Possession of radioactive material after your license expires is a violation of NRC regulations.

1 8.- Request termination of your license if you plan to permanently discontinue activities involving radioactive material.

- You will be periodically inspected by NRC. Failure to conduct your program in accordance with NRC regulations, license conditions, and representations made in your license application and supplemental correspondence with NRC will result in enforcement action against you. This could include issuance of a notice of violation; imposition of a civil penalty; or an order suspending, modifying, or revoking your license as specified in the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG 1600.

Thank you for your cooperation.

Sincerely, l

1

- jam.

Christi Hernandaz, Radiation Specialist Nuclear Materials Safety Branch 1 l

Docket: 070-00218 License: SNM-200 Control: 465667' L

Enclosures:

As stated

! South Dakota State University I i

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DOCUMENT NAME: G:\NMLS.0\MCH\SNM-200.MLC To receive copy of document, inglicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:NMSB1 h NMSB1 M MCHemandez h VHCampbell /h 02/ 3/98 02df/98 OFFICIAL RECORD COPY i

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State University Bos 2M2, Shepard Han 153 BrooNeige. 50 570014896 Phnne noSuwM SDSUFabruary 20, 2998 =eL_..

US Nuclear Regulatory Commission Region IV Attention: Christi Harnandez, Radiation Specialist.

Nucinar Materials Li' ansing Branch FEB 2 0 8 0' 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 -_

Reference:

Docket: 070-00218 License: SNM-200 Control: 465667 This is in response to your February 5,1998 request for additional information.

1. Material Control Provisions.

No purchases of Pu-239 sources are anticipated since the five cources are adequate to meet current or anticipated needs. If a need develops to acquire additional sources, a License amendment would be required to increase the possession limit.

2. sealed source Leak-Testing Provisions.

k- The sources are leak-tented every six months by the Radiation Safety officer using a leak test kit supplied by licensed costa Mesa, service. Currently, ICN Dosimetry Services, California supplies the service. The Radiation Safety Officer maintains a leak-test history of each source.

Each nourco is removed from the well, one at a tian. The sources are handled with 4-foot long tongs. An authorized user holds the cource with the tongs while the entire surface of the source is wiped with a moiston filter paper or cotton swab (depending on the kit). The RSO uses 9-inch tongs to hold the paper or swab during the wipe. In order to reduen exposure, the test is performed quickly while remaining as far from the source as practical.

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08/20/,98 '14:09 C609 688 6364 SDSU REG. COMP 1- f/J 003 Docket 070*-00218; License SNM-200? Control 465667 page 2 February 20, 1998

3. General Safety Instructions.

The sources are used in experiments and demonstrations for l student instruction and activation analysis of biological and environmental samples in instructional laboratories.

The laboratory and classroom demonstrations are carried out by an Authorized User with the students at least one meter from the source.

Junior, senior and graduate students enrolled in upper level and graduate nuclear physics courses are permitted to carry out l experiments using the sources without specific approval of the l Radiation Safety Committee or the Radiation Safety Officer l provided the work is carried out under the direct supervision of  !

l an Authorized User and an Authorized User has instructed the students as to the risks and radiation protection procedures associated with the experiment.

Several sealed sources are used in the nuclear phynics laboratories. The instructor, who is an Authorized Principal Investigator User, provides a written set of " Radiation Safety i procedures" covering the use of sources of different activity I levels. As each type of source is used during semester, an oral i review of procedures is made. The current written procedures, which may undergo editorial changes in the future, contain the following regarding the SNM sources:

"There are several radioactive sources stored and used in Celi ll3A which pose a more significant risk of exposure. ,

c) "High" activity isotopio neutron sources (2 x 10' neutrons / source) used in experiments 2 and 7 are stored normally in a 0 ft deep well with a cement cover than can only be lifted by an electric chain hoist. For experiment 2, the lab instructor will transfer one neutron source to a paraffin filled cadmium lined pail. The pail, together with a distance of 2 meters or greater from the pail while doing the experiment, should minimize your exposure to neutrons. It will only be necessary to be near the pail while removing the irradiated silver coins from the pail. Renove the paraffin plug on top of the pail. Use the string attached to each coin to cruickly remove the coin. Then quickly replace the paraffin plug. Other instructions for experiment 2 are contained in the lab manual. You will be asked to wear a neutron exposure monitor while performing experiment 2."

,02/20/.98 14:08 TF605 688 6364 SDSU REG. COMPL. @ 004 1

l Docket 070-00218; License SNM-200; control 465667 page 3 February 20, 1998 "For experiment 7, the lab instructor will give special instructions for handling the neutron source and minimizing neutron exposure to you and the gamma detector used. There are also special instructions and '

calculations contained in the lab manual concerning the l~ potential for neutron exposure. Do not attempt to l remove a neutron source from the well, and begin this experiment until the lab instructor gives permission.

You will be asked to wear a neutron exposure monitor while performing experiment 7."

l Authorized Users of the Pu-239 sources receive the instructions to workers required by 10 CFR 19.12. The RSO provides' the training. Topics covered in the session incipde:

a. Radiation basics

b. Radiation units l c. Risk management l

d. Radiation risks

e. ALARA

l. f. Risk monitoring l g. Risk reduction

h. (Institutional) Operational Policies

! i. Rights and Responsibilities

-j. Radiation Safety Office functions

k. Declared Pregnant Worker information l

4. muergency and Decontamination Procedures

[The following is excerpted from the " Emergency Procedures" chapter of the South Dakota State University Radiological Safety Progran manual. This maerial and Form NRC 3 are posted in the l laboratory.) l 1

EMERGENCY PROCEDURES i Sealed Plutonium-239 Neutron Sources ]

Plutonium and beryllium are very toxic in addition to the radiological hazards.- The sources should be moved from storage j j to a use area only by an Authorized User using the 4-foot tongs. )

Students are to stay at least two meters away from a source except when carrying out an experiment. Then they should spend a minimum amount of time near te source.

Plutonium-239 sources should not be damaged if dropped or l otherwise subjected to stress. If the housing appears to be

! deformed, the source should be leak tested by the RSO before handling.

Docket 070-00218; License SNM-200; Control 465667 page 4 February 20, 1998 Although the sources should easily survive a fire intact, the fire procedures for all sealed sources should be followed:

1. Leave the area immediately in case of fire. Close and lock the door if it can be done without risk to life.

2. Call Campus Security and advise them of the fire and nature of the radioactive materials involved (Five 1-Curie sealed Plutonium / beryllium neutron sources).

3. Call the RSO who will aid in recovering and securing the source (s).

Every precaution must be taken to prevent theft. If theft (or any attempt to steal) or loss occurs, call the Rso and Campus Security immediately The incident must be1616Xreportinethe NRC immediately by the RSO.

If additional details are needed, please call me.

For South Dakota St e University, r

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Radiation Safoti Officer FEB 2 0 P M l h"h

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, 3 $ REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8064 U.S.N.R.C. REGION IV FACSIMILE FORM DATE: February 5,1998 MESSAGE TO: Leo H. Spinar, Ph.D. Docket: 070-00218 Radiation Safety Officer License: SNM-200 South Dakota State University Control: 465667 MESSAGE FROM: Christi Hernandez, Radiation Specialist Nuclear Materials Safety Branch 1 U.S.N.R.C., Region IV Telephone number 817-860-8217 Facsimile number 817-860-8263 NUMBER OF PAGES: 1 PLUS TRANSMITTAL SHEET FACSIMILE NUMBER: 605-688-6364 VERIFICATION NUMBER: 605-688-4264 SPECIAL INSTRUCTICN/ ATTACHMENTS:

I Dr. Spinar, Per our telephone conversation of February 5,1998, the items on the following page(s) are the deficiencies which require your response. Please respond to this fax within 15 days. Our fax number is (817) 860-8263. If you have any questions regarding our discussion or this fax, please call me at (817) 860-8217. When responding to this fax, please include the license, docket, and mail control numbers, located at the top of this page. Thank you.

AA Christi Hernandez 2r _._

Radiation Specialist i

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1 Please respond to the following items as they pertain to your application dated June 2,1995 and your letter dated December 19,1997:

Material Control Provisions - your submittals did not include procedures for ordering

/= and receiving material, notification upon receipt, and opening packages.

Provide the procedures listed above or a statement that no additional material will be

, procured under this license.

)

j J Sealed Source Leak-Testing Provisions - your submittals did not include procedures 4 for performirg leak-tests. Information is required regarding the procedures followed when obtainng leak-test samples, particularly if these procedures differ from those of the commercir.1 provider.

Provide the safety procedures followed by the RSO when obtaining leak-test samples, or state that the commercial providers procedures will be followed.

/ General Safe?v instructions - your submittals did not include the general radiation safety instructiora to be followed by all personnel while working with radioactive material.

The review of these procedures is an integral part of the review of your overall radiation safety program.

Provide the general radiation safety procedures for the handling of licensed material.

Emergency and Decontamination Procedures - your submittals did not include emergency procedures to be posted in all laboratory or work areas where radioactive materials are used.

Provide the emergency procedures, including a description of actions to be taken in case of an emergency and the names of responsible persons to be notified in the event of an emergency.

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South Dakota v::,t; State University ==

Box rMJ,'hepard Hn1153 Bmnktes M 7007 0896 Phm ens A.4Pe4 FAX 806 enn eM4 1)S J E me t. FRcOWmg utstate eGu i

1 November 19,1997 F  ;; 7 ._. ,

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US Nuclear Regulatory Commission . . _ _[_

Region IV Attention: Cluisti Hernandez, Radiation Specialist Nuclear Materials Licensing Brancti 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 FAX: (817) 860-8263

Reference:

Docket : 070-00218 License: SNM 200 Control: 465667 Your request for additional information relating to the renewal oflicense SNM-200 has been received. An extension in the response due date to December 31,1997 is hereby requested so that a more adequate response maybe made.

For South Dakota Sta e University, s

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I US Nuclear Regulatory Commission Region IV Attention: Christi Hernandez, Radiation Specialist Nuclear Materials Licensing Branch 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

Reference:

Docket: 070-00218 License: SNM-200 Control: 465667 ,

Attached are South Dakota State University's responses to the request for additional information relating to the renewal of License SNM-200.

Please modify your address records to expedite receipt of mailings:

ITEM 4.1: Specification of Applicant Name: South Dakota State University Mailing Address: P.O. Box 2202, Brookings, SD 57007-0896

• Address: Shepard Hall, South Dakota State University, Brookings, SD (Crothers Hall is the physical location of the sources. The RSO is located in Shepard Hall)

Specify principal officials:

Name: Leo H. Spinar

Title:

Radiation Safety Officer

• Address: SDSU, Regulatory Compliance Office, P.O. Box 2202, Brookings, SD 57007-0896 Telephone: 605-688-4264 If additional information is required, please contact me.

ForsSou)th Dakot S University, I

M eo H. S r Radiat on Saf#t Officer

/

Additional Information, License Renewal December 19, 1997 License: SNM-200 Licensee: South Dakota State University Docket: 070-00218 Control: 465667 Item 4.5.42 (Room layout and description)

The plutonium sources are stored and used in the Physics Department Nuclear Laboratory, Room 113A, Crothers Engineering Laboratory. A floor plan for the room is shown in Figure 1A.

The walls are constructed of 6-inch thick concrete block. The room is approximately 12 feet high.

The room is on the lowest level of the building. The sources I are stored in a well that extends 6 feet below the floor. The I well is covered with a 6-inch thick concrete slab which is lifted with an electric winch.

An instructional classroom is directly above Room 113A. The floor is 12 inches of poured concrete.

There is a Structural Materials instructional Laboratory adjacent to the south and west walls. There are no openings in ,

the south wall. The double door on the west wall has been i sealed.

A public hallway runs along the north wall. A set of double doors provides access to the Nuclear Laboratory. These doors are kept locked. Only Authorized Users have a key to the doors.

A set of windows, 4.2 meters long by 1.2 meters high, approximately one meter above the floor are located next to the doors.

A concrete humidity testing chamber is adjacent to the east  !

wall. The test facility is occupied only when samples are being moved in and out during class periods. There are no openings in the east wall.

Item 4.5.5 Radiation Detection Equipment A. One Victoreen Model 491 GM with Victoreen Model 491-30 probe used for monitoring radiation in the laboratory.

Characteristics of the Model 491-30 probe:

Detects gamma radiation above 12 kev Detects beta radiation above 200 kev Window thickness is 30 mg/cm2

Figure 1 A. Room 113A, Crothers Hall Physics Department Nuclear Lab Structurel Materials Laboratory (Sealed Double Doors)

Shelf Shelf A Double Doors + E

- 4 m

g Table n -

{s: hl E

B.

E F T

E

3. C 3 Table Computer Computer Table O

C 2h h E.

Table Well Storage Water J/ Tank Cabinet hl LL Sources *

< 4.6 m >

Concrete Test Chamber

>N

• LL Source a Low Activity Scaled Sources Covered By License 40-0219417

O Docket 070-00218; License SNM-200; Control 465667 page 3 December 19, 1997 Calibration procedures:

Frequency: Annual l Reference Sources:

Radiation Source A:

ICN Model Number 375. Serial Number 1243. =

Co-60 9.2 mci (8/28/78); 0.74 mci (11/10/97).

l Radiation Source B: 1 National Bureau of Standards (NBS) gamma ray )

standards set of 10 sealed glass ampoule containing l certificated quantities of radium dissolved in I solution. Certificates for NBS Tests Numbered G-5081-5 through G-5081-14, February 6, 1947, are on file in the Radiation Safety Office.

Standards contain 0.1, 0.2, 0.5, 1.0, 2.0, 5.0, 10.0, 20.0, 50.0, or 100.0 yg radium. l Procedures:

1. A portable survey meter is designated as the 1 Certified Calibration Meter. This meter is used exclusively by the RSO. (Currently, an Eberline  !

Model ESP-1 meter with Eberline Model HP270 probe. I l

Its range is 0 to 2,000 mR/hr.)

2. The designated meter is sent annually to a licensed service for a certified calibration. (Currently,  !

Ludlum Instruments supplies the calibration.) l

3. Within 30 days after return of the calibrated unit, it is used in the secondary calibration of other survey meters including the Model 491.

4. The " working" meter is examined for damage, worn parts and battery replacement.

5. The Calibrated unit is used to measure the exposure rate at distances from either the ICN #1243 Co-60 or a NBS Standard Radium where the rate is approximately 1/3 and 2/3 of full scale on each scale.

6. The Calibrated probe is replaced by the Model 491-31 probe. If the reading differs from the Calibration unit reading by more than ten per cent, the Model 491 nieter is adjusted until the difference is less than ten per cent.

7. A label is attached to the meter giving its calibration date and parameters. The RSO maintains appropriate records of the secondary calibrations.

B. The Ortec, Inc. Ge Crystal detector and Nuclear Data Model ND-60A pulse height analyzer are a unit used to measure the radioactivity induced in irradiated samples during student experiments. The instruments are not utilized directly in the management of the Pu-Be sources. Therefore, reference to these instruments is withdrawn from the Renewal Application.

Docket 070-00218; License SNM-200; Control 465667 page 4 December 19, 1997 Item 4.6.1 Radiation Responsibilities and Duties A. Management Responsibilities and Duties The . University President has delegated responsibility for operation of the Radiation Safety programs under License SNM-200 and its By-Products Materials license to the Radiation Safety Committee (RSC) and the Radiation Safety Officer (RSO). The President formally appoints the RSC members.and the RSO and may replace them for failure to meet NRC requirements. Upon recommendation of the RSC, the President establishes general University policies for use of radioactive materials. The President is responsible for providing adequate funding and personnel to manage the Radiation Safety program.

The President or his designated representative serves as a member of the RSC. The Vice President for Administration currently is the President's representative. The Vice President often acts on behalf of the President on radiation safety issues. In addition to the items considered at RSC meetings, the Vice President is briefed on needs and problems of the Radiation Safety program.

B. Radiation Safety Committee The duties of the Radiation Safety Committee (RSC) 'are:

a. to establish procedures for compliance with the conditions of all NRC licenses;

b. to recommend policy to the President regarding the use of all radioactive materials;

c. to develop procedures for implementing and enforcing these policies under its delegated authority, and

d. to review the actions of the Radiation Safety Officer.

Procedurally, the RSC meets at least once each quarter:

a. to review the Personnel Radiation Exposure Report;

b. to review the activities of the RSO and provide direction regarding future activities;

c. to review the findings of any NRC inspection;

d. to recommend to the President changes in institutional policies regarding management of radioactive materials program and the control of radiation sources at SDSU;

e. to establish operational procedures implementing institutional policies;

f. to approve all proposed uses of the SNM sources and the Principal . Investigator (s) responsible for handling, storage and monitoring of the sources after a review of procedures to be followed;

g. to' designate the areas.where the SNM sources may be used or stored;

h. to establish the minimum level of training- and experience required for an individual to be authorized users of SNM sources;

w

('! '

>!'s j

UEC 30 mg, Docket 070-00218; License SNM-200; Control 465667 page 5 December 19, 1997

1. to approve all Principal Investigator users of SNM sources after review of their training and experience;

j. to act as the responsible body for SDSU in accepting the terms and conditions imposed in the SNM License l issued to the institution and to see that these terms and conditions are met by the individual users.

C. Radiation Safety Officer The RSO reports to the President through the Vice President for Administration. The RSO conducts an annual review of the Radiation Safety program with the Vice President.

The RSO may call upon the authority of the President or Vice President for Administration to enforce all requirements for the safe usage of the sources and to ensure that all users comply with the institution's policy of adherence to the ALARA concept. The RSO may suspend immediately any authorization to use radionuclides if there is a blatant disregard of prescribed procedures raquired to achieve ALARA.  !

The duties of the RSO include: , ,

a. to approve, using the guidelines established by the l RSC, subsidiary users of the SNM sources; j

b. to train, as required by 10 CFR 19, all users of SNM  !

sources;

c. to manage the Personnel Radiation Exposure Record )

I system including the distribution, collection and i I

return to service vendor of film badges;

d. to review and maintain individual exposure record and notification of individuals and their supervisors of any unusual exposures that may lead to exceeding the ,

maximum permissible dose; '

e. to leak test the sources;

f. to measure radiation levels in the unrestricted areas adjacent to the storage site;

g. to calibrate the survey meter used in the laboratory, and

h. to post required informational and cautionary signs and  !

notices.

D. Users These sources are used for instruction in upper level and graduate nuclear physics courses and for classroom demonstrations. An authorized Principal Investigator is responsible for conducting the experiments and demonstrations in the manner outlined when the RSC granted approval. The PI is responsible for obtaining RSC approval before any of the procedures are changed significantly. The PI shall ensure that the sources are returned to storage as soon as practicable after use.

Docket 070-00218; License SNM-200; Control 465667 page 6 December 19, 1997 l Item 4.6.3 Radiation Survey Program l

A. Types, Methods, and Frequency of Surveys Radiation surveys using a G-M survey meter near the storage well within Room 113A have demonstrated that there is no radiation other than background in the room. This confirms the absence of gamma radiation that is associated with neutron production.

Radiation surveys of the areas in and around the room are conducted on an annual basis as a requirement of the Byproducts Materials License.

B. Operations involving only sealed sources Evaluation and/or measurement of gamma and neutron radiation levels for storage and use configurations.

Storace conditions:

No surveys of the Radiation Levels are required since the l sources are stored in a 6-foot deep subterranean well and i covered with a 6-inch concrete cover. The ceiling is located  !

about 12-feet above the top of the well. The ceiling is a 12- I inch concrete slab. The radiation is collimated by the well so )

, that the only possible public exposures are in the classroom '

i directly above the well.

]

As shown in Appendix 1A, the calculated dose rate to the public in the classroom above the storage well is 0.022 mrem /hr at floor level. It is anticipated that at most, an individual ,

would occupy this area six hours per week for 45 weeks per year, i The maximum dose to the feet would be 6 mrem which is well below I the dose limit of 100 mrem per year. The laboratory is l

accessible for less than 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> per day, five days per week or 3,900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> per year (without holiday closings). The dose associated with 3,900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of exposure is 86 mrem well under the public dose limit. The probability of any one person occupying a 1-meter diameter circular space directly above the l

well for a greater time is infinitesimally small.

Use conditions:

(These conditions were given in the 1995 renewal application.)

"only junior, senior and graduate students are allowed to participate in the neutron activation experiments. The work is carried out under the direct supervision of an Authorized User.

In actual practice, it is unlikely a student will come within l two feet (0.61 meter) of an unshielded source since 4-foot long I tongs are used to handle the sources. The irradiation portion of the experiment is carried out by a trained user. The irradiation lasts for about 15 minutes. Counting and other laboratory work is done at least six feet from the source. A student performs the experiment once during the year. Personnel monitoring of these students is not required because the radiation level is well below regulatory limits.

Docket 070-00218; License SNM-200; Control 465667 page 7 December 19,.1997 The dose from neutron activity from an unshielded source is:

2 feet (0.61 meter) for 15 minutes 5.0 mrem 4 4 feet (1.22 meter) for 15 minutes 1.3 mrem 6 feet (1.83 meter) for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 2.2 mrem The regulatory limit for students is 100 mrem per year.

Shielding is used. The shielded exposure is less than one per cent of these values. Authorized Users, who handle the sources, come closer to the sources for longer periods of time than the students have never recorded a detectable (10 mrem) exposure.

The gamma radiation associated with a source is less than 0.2 mR per hour at 2.5 feet and is at background at the bench where the irradiated product is counted. A student will spend no more than three hours per week in the laboratory working on neutron source experiments."

Added comment (December, 1997):

Recalculation of_the doses from the unshielded sources during use yields:

2 feet for 15 mi 11tes 4.8 mrem 4 feet for 15 minutes 1.2 mrem 6 feet for three hours 6.4 mrem Authorized users wear film badges with neutron detecting chips l while handling.the sources.

The radiation levels in the room are monitored with the Victoreen Survey Meter and Probe when the sources are in use. j l

supplemental surveys performed following changes in operation, sbialding, use or location of device It is highly unlikely that the storage location of these sources will be changed since the storage well provides ideal shielding for the sources. Before any significant change in the use or location of the sources is approved by the RSC, the RSO will estimate the dose levels for the new conditions. _ Shielding and/or keeping the "public" at greater distances to keep l exposure level below 100 mrem per year will be required before any change is approved. This will be confirmed by G-M surveys of the associated gamma radiation after the changes are made.

Item 4.6.4 waste Disposal The Radiation Safety Officer is responsible to the University President for the proper storage and disposal of unwanted sealed sources. Disposal will-be made in accordance with 10 CFR 70.42, 10 CFR Part 71 and 10 CFR Part 20, Appendix G. A licensed transporter will be used to transfer the sources to a site that is licensed by the NRC or by an Agreement State. The requirements of the disposal site operator will be met.

l 1

1 Docket 070-00218; License SNM-200; Control 465667 page 8 December 19, 1997 An amendment to this License to allow long term storage on site will be requested if there is no need to use the sources and permanent disposal is not feasible. The University has isolated areas that can be secured against intrusion. The amendment would detail storage conditions.

4.6.5 Records Management.

The Radiation Safety Officer surveys the radiation levels associated with storage and use areas (Crothers Hall 113A for this license). The source inventory is verified during the l semi-annual leak testing conducted by the RSO. Personnel  !

exposures are measured using film badges with " neutron strips"  !

worn by authorized users when handling the sources. There are i no plans to acquire or dispose of SNM sources during the License period. l The RSO maintains a permanent record of the radiation surveys, j leak tests and personnel exposures. The records are reviewed l before filing.

1 i

l l

4

• DEC 8 01997 Docket 070-00218; License SNM-200; Control 465667 page 9 December 19, 1997 Appendix 1A. Calculated Dose Rate Conditions:

239

1. There are five one-Curie Pu/'Be sources.

2. The neutron flux for each source is assumed to be 6 x 10 6 neutrons sec'l.

3. It is assumed that there is no moderation of the neutron flux by the stainless steel encapsulation.

4. The fluence for 239 Pu/'Be neutrons is taken to be 24 x 10 6 neutrons rem ~1 c m-2 [ Table 10 CFR 20.1004(b)2]

5. Sources are stored in a subterranean well about 1.8 m deep by C.3 m diameter.

6. Well is covered with a 6-inch (15 cm) thick concrete slab.

7. Closest edge of well is abut 1 meter from the "public access" side of the nearest wall which is constructed of 6-inch (15 cm concrete block.

8. Because of the well depth, the neutron beam is heavily collimated. the shortest path from a source at the far end of the bottom of the well to "public side" of the nearest wall is 6.1 meters. The beam would exit at 6 meters above the floor. This higher than the ceiling is above the well.

9. The ceiling is approximately 3.6 meters above the top of the well. It is 30-cm poured concrete.

10. Attenuation factor for concrete from Turner, " Atoms, Radiation, and Radiation Protection", Second Edition, Wiley-Interscience, 1995. pp. 473-476.

Fluxa= Flux o/4nR2 =

(6 x 10 6neutrons sec-!) /4n(R cm)2

=

(4.8 x 10 neutrons sec-1/ (R cm)2 5

Hg =

(Flux a) (Fluence) 5 2 6

= (4.8 x 210 /R neutrons cm-2 sec ) / (24 x 10 neutrons 3 rem'8 cm-2)

=

(20/R ) mrem 2 sec-3 at R cm from the source.

= (72,000/R ) mrem hr' at R cm from the source.

Dose rate (unshielded) at ceiling level:

H,,ge = [(72,000 mrem cm 2hr'l) / (180 cm + 3 60 cm)23

= 0.25 mrem /hr Attenuation factor for 15-cm concrete cover:

AF = eem9/cmx15 cm) = e'i# = 0.26 Attenuation factor for 30-cm concrete ceiling:

AF = e***"X3"") = e-2.67 = 0.069 Total attenuation factor for concrete shielding:

i AF = (0.26)(0.069) = 0.018 Dose rate at ceiling above the storage well:

H,,im = 0. 018 ( 0. 2 5 mrem hr-3) = 0. 0045 mrem hr-3 per source.

= 0.022 mrem hr'3 for five sources.

e s UNITED STATES

[ga %g *r . NUCLEAR REGULATORY COMMISSION g REGION IV 611 RYAN PLAZA DRIVE, SulTE 400

%'+,*s***#0[ AR LINGTON, TEXAS 760118064 October 29,1997 South Dakota State University

- Physics Department '

ATTN: Leo H. Spinar Radiation Safety Officer P.O. Box 2202  !

Brookings, South Dakota 57007-0896

)

Subject:

LICENSE RENEWAL We have reviewed your application dated June 2,1995, requesting renewal of your byproduct material license to use radioactive materials. Before further action can be taken, we shall need the information identified in the enclosed CHECKLIST FOR REVIEW OF APPLICATION FOR SPECIAL

{

NUCLEAR MATERIAL LICENSES OF LESS THAN CRITICAL MASS QUANTITIES. Specific items I that should be addressed are indicated as the red areas in the checklist. Additionally, you should examine the comments in the Note boxes. The enclosed copy of Regulatory Guide 10.3, GUIDE FOR THE PREPARATION OF APPLICATIONS FOR SPECIAL NUCLEAR MATERIAL LICENSES OF LESS THAN CRITICAL MASS QUANTITIES, provides specific information which will also assist you in providing the information required by the renewal process.- Review the information provided in your application and compare it to that outlined in the licensing guide and the corre.sponding NRC regulations. Additionally, you should update operating and emergency procedures and the radiation j safety manual to reflect changes implemented as a result of changes made to the application / amendment request.

Prior to submitting your response to this letter, we encourage you to utilize the checklist as a review mechanism. This additional review will ensure that you have addressed all items of concern and have not inadvertently overlooked information necessary to the renewat process.  !

In order to continue review of your application, we request that you submit your response to this letter within 30 calendar days from the date of this letter. Please reply in duplicate and refer to the license, docket, and control number specified below, if you have questions or require clarification on any of the Information stated above, we encourage you to contact us at (817) 860-8100.

, Sincerely, Christi Hemandez, Radiation Specialist  :

Nuclear Materials Licensing Branch Docket: 070-00218 License: SNM-200 Control: 465667 Enclosure (s): See next page

South Dakota State University -2 Physics Department Enclosure (s):

1. Checklist for Review of Application for Special Nuclear Material Licenses of Less Than Critical Mass Quantities.

2. Regulatory Guide 10.3 Guide for the Preparation of Applications for Special Nuclear Material Licenses of Less Than Critical Mass Quantities.

l

South Dakota State University Physics Department I

l DOCUMENT NAME: G:\NMLS.O\MCH\SNM200CK.DEF To recolve copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy e enckmuros "pr = No copy RIV:NMLB /\/,

MCHernandez /A/g 10/e21/97 -

OFFICIAL RECORD COPY l

CHECKLIST FOR REVIEW OF APPLICATION FOR SPECIAL NUCLEAR MATERIAL LICENSES OF LESS THAN CRITICAL MASS QUANTITIES Regulatory Guide 10.3 LICENSE INFORMATION:

[] new {X) License No SNM-200

[] amendment [X) Docket No 070-00218

[X) renewal [X) Control No 465667 CONTENTS OF AN APPLICATION ITEM 4.1: Specification of Applicant

[X) Name: South Dakota State University d X ilin Address: P.O. Box 2202, Brookings, SD 57007-0896

[X) Address: ...t .e.e Hall, South Dakota State University, Brookings, SD

[] State where incorporated (if appropriate):

[] Indicate control or ownership by any alien, foreign corporation, or foreign government:

[X) Specify principal officials: 7 (X) Name: Leo H. Spinar /NJ}

(X)

Title:

Radiation Safety Offly/

(X) Address: SDSU, I:,,a:ce .ept., P.O. Box 2202, Brookings, SD (X) Telephone: 605-688-4264

() Citizenship: RSO on cun ent license ITEM 4.2: Specification of Activities To Be Performed

[X)

Description:

For use in experiments and demonstrations for student instruction and activation analysis of biological and environmental sampi,es.

ITEM 4.3: Specification of Special Nuclear Materia Isotope Chemical / physical form Activity Plutonium-239 Sealed Neutron Sources (80 grams) A Note: Specification of isotope should include principal isotope and significant contaminants.

}

Y) )((D l

ITEM 4.4: Technical Qualification of Personnel

[X] Identify users Users authorized by Radiation Safety Committee (approved by amendment 5,6/21/95)

Academic rank of Asst. Professor or higher in the physical or biological sciences or engineering; a Minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> formal training and experience; Orientation session with RSO; Received and read policies; and Suitable plan for use.

[X] Training

() Principles and practices of radiation protection

() Radioactivity measurements, standardization, and monitoring techniques and instruments

() Mathematics and calculations basic to the use and measurement of radioactivity

() Biological effects of radiation

[X] Experience

() Isotopes handled

() Maximum quantities handled

() Where experience gained

() Duration of experience

() Type of use ITEM 4.5: Description of Equipment, Facilities, and Instrumentation

[X] For each site of use For each site of use, please provide information regarding 1) area description (annotated map) and 2) calibration of radiation detection / measuring instruments.

(X) Number, type and length of remote handling devices (X) Storage containers and facilities (shielding and security)

Rm.113A, Crothers Engineering Hall. Sources stored in a 6-foot deep well with a cement cover. Sources transferred one at a time in pall lined with cadmium and filled with paraffin. Room is marked with appropriate signs. Keys to room are limited to AUs.

(X) Equipment employed for daily use (container, devices, protective clothing, etc.)

k) Physical plant, laboratory, or working area facilities (description).

(X) Radiation detection instruments

1. Victoreen Model 491 GM - Monitoring

2. Ortec, Inc. Ge Crystal detector - Measuring

3. Nuclear Data Model ND-60A 2018-channel pulse height analyzer -

Measuring

{X} Manufacturer's name and model number Number and type available Type of radiation detected - h Sensitivity range g Window thickness in mg/cm2 .30 m-

}

Type of use for each instrument (monitoring,hh surveying, assaying, or measuring)

(} Survey instrument calibration procedures Frequency M Procedures - Licensee calibration

)(f Manufacturer and model number of each radiation

( source to be used g\ y Nuclide and quantity of radioactive material contained in each source

. {' Q , Accuracy and traceability of each source yl  %() Step-by-step procedures

() Name and experience of person who will perform the pI calibration Contr mtnr i

j () Name ,

/

() Address M M A n.a. -

() License number Quantitative measuring instrument calibration procedures Q <> Calibrated prior to each use f> Name of manufacturer and model number of each of the p r standards to be used

<> Nuclide and quantity of radioactive material contained in each standard source

<> Statement of accuracy for each standard source kr <> Step-by-step calibration procedures

< <> Name and pertinent experience of each person who will

) perform calibration ITEM 4.6.1: Specification of Radiation Safety Responsibilities and Duties Your application states that the Radiation Safety Officer (RSO) and the Radiation Safety Committee (RSC) are responsible for all aspects of License SNM-111, and that the RSC is charged with the development and supervision of the University Radiation Safety Program.

However, a detailed list of the responsibilities and duties, AS THEY PERTAIN TO THIS SNM LICENSE, of Management, the RSC, the RSO, and authorized users is not included.

Provide a detailed list of the responsibilities and duties of Management, the RSC, the RSO, and authorized users, AS THEY PERTAIN TO THIS SNM LICENSE.

[ lished responsibilities and duties Management

Radiation safety committee

( Radiation safety officer Users ITEM 4.6.2: Personnel Monitoring

[X] Name of organization furnishing personnel monitoring device Siemens Dosimetry Services >

(X) NVLAP Accreditation

[X] Type of device used (X) Film badge (X) TLD (for neutron dosimetry) i [X] Exchange frequency )

(X) 1 month for film badge 1 l

() 3 months for TLDs .

l

[X] Personnel monitoring not used (for Students)  !

Calculations or documentation from radiation surveys demonstrating that it's j i (X) unlikely to receive a. dose > that indicated in 10 CFR Part 20 Bioassays (Sealed sources only) j

[X]

() Criteria used in determining the need for bioassays l () Type l () Frequency l () Procedures described in detail l

() Commercial bloassay service used l

{} Name and address of firm (X) Not applicable ITEM 4.6.3: Radiation Survey Program l' Your application does not include information on a Radiation Survey Program. The types, methods, and frequency of surveys should be specified according to the nature and complexity

! of the special nuclear material program. For operations involving only sealed sources, a survey program should include evaluation and/or measurement of gamma and neutron radiation levels for storage and use configurations. When sources are used in devices having "on" and "off" positions, both positions should be evaluated at the time of installation.

Supplemental surveys should be performed following any changes in operation, shielding, use, or location.

Provide the information required below, regarding your Radiation Survey Program. ,

[ Specify types, methods, and frequency of surveys Operations involving only sealed sources

1. include evaluation and/or measurement of gamma and neutron radiation d levels for storage and use configurations g Supplemental surveys performed following changes in operation, shielding, use or location of device 6

l 1

5-(N/A) Operations involving forms other than sealed sources

() Survey to monitor the adequacy of containment and contamination control i

{} Air sampling program: including areas where samples will be taken, i frequency of samples, relationship to processing or maintenance phase, and orientation of sampler with respect to workers' breathing .

zones

{} Effluent monitoring program f

{} Evaluating alpha contamination of personnel and plant surfaces l

{} Specify acceptable limits of fixed and removable contamination  !

{} Survey program for pilot studies and initial phases of operations. l ITEM 4.6.4: Waste Disposal Your application states that should disposal of the sealed sources be necessary, the sources will be sent to the Southwestern LLRW Compact Ward Valley site or other disposal site.

1 Provide a commitment to use a licensed disposal company / disposal site. l Your application also states that water soluble materials are released to the sanitary sewer and that other materials are held for 10 half-lives before released as ordir.ary trash.

Please note that radioactive material generated by neutron activati en experiments is not j covered by this SNM license. SNM-200 only authorizes possession sad u::c of the Pu-Be {

sources. Possession, use, and disposal of the activated material should be authorized by your Part 30 license,40-02194-17.

I t

Administrative procedures and technical information provided for:

(( Commitment to use licensed disposal company Liquid disposal procedures provided g)y/}

/

Provisions for monitoring wastes discussed and I includes ALARA considerations l h Long term storage. f NOTE: Information in NRC Information Notice 90-09 must be provided.

ITEM 4.6.5: Record Management Your application states that the RSO maintains a file of the monthly dosimetry reports. This is the only information provided concerning record management.

Prov:de the information below regarding record management.

Describe provisions for keeping and reviewing records of surveys, inventories,

r l

personnel exposures, receipt, use and disposal

[] Identify person /s responsible

! ITEM 4.6.6: Material Control Provisions Your application does not provide procedures for ordering and receiving material, notification upon receipt, and opening packages.

Should you plan to procure material authorized by this license (additional PuBe sources),

please provide the procedures for ordering material, receiving material, notification of responsible person upon receipt, and opening packages. If no purchases of PuBe sources are planned under this SNM license, please so state.

[] Provide procedures for:

() Ordering material

() Receiving material

() Notifying responsible persons upon receipt

() Opening packages ITEM 4.6.7: Sealed Source Leak-Testing Provisions

[X] Frequency at 6 month intervals, unless in storage Please note that a current license condition (12.D) requires that sources in storage be leak tested at intervals not to exceed 10 years.

[X] Applicant performs leak tests

(X) Qualifications of persons performing leak test RSO Provide the safety procedures followed by the RSO during tests. Please indicate whether or notthese procedures are those of the commercial provider. In addition please indicate if a commercial kit is not used.

() Safety procedures followed during tests Test procedures and materials or commercial kit to be used (moistened (X) filter paper).

(N/A) Instrument used to assay test samples Licensed commercial service provides analysis of leak test samples.

{} Type

{} Manufacturer's name i {} Model number ITEM 4.6.8: General Safety Instructions

i 1

Your application does not include a copy of the general radiation safety instructions to be followed by laboratory personnel while working with radioactive material.

l Provide a copy of your general radiation safety instructions.

l'

[] Suomit copy of general radiation safety instructions )

l ITEM 4.6.9: Emergency and Decontamination Procedure  !

Your application does not include a copy of the emergency procedures to be posted in all laboratory or work areas where radioactive material is used.

Provide a copy of your emergency procedures.

[] Submit copy of emergency procedures

() Description of immediate action to be taken l () Ident4y names and telephone numbers of responsible persons to be notified ITEM 4.6.10: Procedures for Training Personnel 1

l Your application indicates that Authorized Users will be named by the RSC. However, your application also indicates that students shall be permitted to carry out experiments using the sources without specific approval of the RSC or RSO under certain conditions. These conditions do not include a description of the training requirements for the students.

ProUdNdescription of the training requirements for all personnel who ar's involved in or associated with thhse.of the sources, to include the information below.

[] Description of training program for all personnel who are involved in or associated with the use of material

() Form of training (formal course work, lectures, on-the-job instructions, and l

l written instructions'or manuals) j l () Duration of training N

/4 1

() Retraiping provisions y (U'

() Subject matter to be included ., .v

pp v"l" V

/ v p f.'l bA o,J

,pb p<. s>l W

Acceptance Review Check List f~5 Action Type:

[] New Q d g- )WWHD n fDa d 2 divigal Mail Control No. gg N

[ enewal j hh kQ b b k' h4Nbsk - N M b .60 Administrative Exclusion Iten5Nequiring Retum to AhplicaM:

y- - x

[] Current Guidance Not Used M f> . _ _ - -

[] References in Application Not to Currera Och Regulat]

[ ions \f

[] All Attachments Re'erenced Are Not included g-.g,ge[Me lh.kddt

[] Signature Not on Application >

Technical Exclusion items Requiring Technical Reviewer Time Estimates:

[] Request f$r Expedited Handling for Radiation Safety / Business Concerns

[] Request [for Exemption to Specific Regulation (s)

[] Change in Ownership Concerns

[] Financia' Assurance /DFP Required - Off, bq LC

[] Decom issioning Plan Review

[] Qualit anagement Plan

[] Termi tion of License Requiring NRC Closecut Survey

[] Bank ptcy Notification

[] Appr al of Long Term Storage / Alternative Form of Waste Disposal

() Facilit odifications Requiring Shielding Calculations

[] Authori ation to Possess and Use Large Quantities of Unsealed Materials

[] HDR/ Gamma Knife

[] Major Appro/ncrease In Authorized Users

[] val Of Training Program

[] Approhl of incineration of Radioactive Waste

[] Authonpation For Sealed Source or Device Requiring SSD Approval Review i

[] Environmental Assessment or impact Statement Required

[] Eme ncy Plan Contingency Plan Required

[] Type,r Broad Scope / Complex Research & Development Application Reviewer: N hph Estimate f Time Needed:

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$ REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 AR LINGTON, TEXAS 760118064 1

June 8, 1995 ...

South Dakota State University Docket No. 070 00218.-

ATTN: Dr. Leo H. Spinar, RS0 . License No. SNM 200 Physics Department Control No. 465667 Brookings, South Dakota 57007 0896 -

Gentlemen:

This is to acknowledge receipt of your application for renewal of the special.

nuclear material license identified above. Your application is deemed timely filed and, accordingly, the license will not expire until final action has been taken by this office. l Any correspondence regarding the renewal application should reference the' control number specified and your license number. -

Sincerely, h

Billie Gruszynski (Ms.)

Nuclear Materials Licensing Branch

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Environmental Regulatory Compliance office Radiation Safety )

Chemical Hygiene )

Laboratory Safety l Box 2202 Shepard Hall 153 j South Dakota state University Phone: (605) 688-4264 W M 57 Brookings, SD 57007&% FAX: (605) 6884364 I

June 2,1995 {)

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.L . UN - 5 W i Nuclear Materials Licensing Section United States Nuclear Regulatory Commission gg {,g J Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 i Gentlemen:

REFERENCE:

License No. SNM-200 Enclosed are two copies of the Application for the Renewal of License Number SNM-200. The entire application has been rewritten since the current license is based on an application submitted in 1983. The major change proposed 'n the program is to make the Radiation Safety Committee responsible for designating the individuals who may use the sources. The current license names the authorized individuals.

Other changes in the application are editorial and are not intended to change the j operation of the program. '

Your consideration of this application is appreciated.

For South kota State University,

%fL Leo . Spinar, Pr fesyor of Che-istry Radiation Safety fficer r

465667

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U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OME. NO31634120

• ,,og EXPIRES 8 30-es 10 CfR 30,32,33 ESTIM AT ED BURDEN PER RESPONSE TO COMPLY WITH THIS 34' 36,38,30 W IN ORMATION COLLECTION REQUEST: 9 HOURS. SUBMITTAL OF THE

.I APPUCATION IS NECESSARY TO DETERMINE THAT THE APPUCANT IS g QUAUFIED AND THAT ADEOUATE PROCEDURES EXIST TO PROTECT THE PUBUC HEALTH AND SAFETY, FORWARD COMMENTS APPLICATION FOR MATERIAL LICENSE a'a^*'"**u*'"'"^'"

MAN AGEM ENT BRANCH (T 8 F33), '"."S.

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' ""^" ^"o a'co*5 NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20666 0001, AND TO THE PAPERWORK REDUCTION PROJECT (3160 0120). OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON. DC 20603.

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INSTRUCTIONS: SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION SEND TWO COPIES OF THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.

APPUCATION POR DISTRISUTION OF EXGMPT PRODUCTS PILE APPUCATIONS WITH: IF YOU ARE LOC ATED IN:

1 DIVISION OF INDUSTRIAL AND MEDICAL NUCLEAR SAFETY ILUNOls, INDIANA. IOWA, MICHIGAN MINNESOT A. MISSOURI, OHIO. OR WISCONSIN, l OFFICE OF NUCLEAA MATERIALS SAFETY AND SAFEGUARDS SEND APPUCATIONS TO: j U.S. NUCLEAR REGULATORY COMMISSION 1 WASHINGTON, DC20666 0001 MATERIALS UCIS4 SING SECTION U.S. NUCLEAR F4GULATORY COMMISSION, REGION lli ALL OTHWI PWISONS PILE APPUCATIONS AS FOLLOW 8: 801 WARRENVILLE RD.

USLE, IL 806324361 GP YOU ARE LOCATSD IN: j ALASKA Ant 20NA. ARKANSAS, CAUPORMA. COLORADO. HAWAel, IDAHO, KANSAS,  ;

CoalNSCTICUT, DSLAW ARE, DISTNCT OF COLUMelA. MAINE. MARYLAND. LOU 181ANA. MONTANA, NEERASKA. NEVADA, NEW MEXICO NORTH DAKOTA, MASSACHUSETTS. NEW HAMPS6eRF. NEW JER8JY, NEW YORK, P6MNSYLVAMA. OKLAHOMA, OREOON, PACIFIC TRUST TERNTORIES, SOUTH DAKOTA. TEXAS, UTAH.

RHODE ISLAND, OR VWm40NT, SEND APPUC AT f 48 70: WAS6eNGTON, OR WYOM6NG. SEND APPUC ATIONS TO:

UCENSING ASSISTANT SECTION NUCLEAR MATERIALS UCENSING $!CTION NUCLEAR MATERIALS SAFETY BRANCH U.S. NUCLE AR REGULATORY COMMIS$10N, REGION IV U.S. NUCLEAR REGULATORY COMMISSION, REGION 1 811 RYAN PLAZA DRIVE SUITE 400_ __..-.._m n

475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406 1416 ARUNGTON,T

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ALARAMA, FLORIDA GEOROBA, KENTUCKY. MISSISSIPPl. NORTH CAROUNA. PUERTO RICO, SOLTTH C AROUN A. TENNESSEE, VIRGINI A. VIRGIN ISLANDS. OR WEST VIRGINIA. Il hl CEND APPUCATIONS TO:

91 - 5 866 Cgb v NUCLEAR MATERIALS UCENSING SECTION U.S. NUCLEAR REGULATORY COMMIS$10N. REGION fl 101 MARIETTA STREET, NW. SulTE 2000 -

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ATLANT A. GA30323 0199 y]QN Q PERSONS LOCATED IN AGREEMENT STATES SEND APPUCATIONS TO THE U.S. NUCLEAR REOULATORY COMMIS860N ONtf1P^THEY WlSH TO PONWhND USE UCENSED MAT 9 RIAL IN STATES SUSJECT TO U.S. NUCLEAR REOULATORY COMMIS$10N JUNSDICTIONS.

1 THISIS AN APPUCATION FOR tch.ca appepa.te/ tem) 2. NAME AND MAIUNG ADDRESS OF APPUCANT (Avehuselip sedel 4

_ A. NEw uCENSE South Dakota State University l

_ B. AMENDMENT TO UCENSE NUMBER P.O. Box 2202 0 C. RENEwAt OF uCENSE NUusER _jNM - 200 Brookings, SD_ 57007-0896

3. ADDRESS (ES) WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED 4. NAME OF PERSON TO BE CONTACTED ABOUT THl3 APPUCATION Crothers Hall South Dakota State University Leo H. Spinar, Radiation Safety Brookings, South Dakota Officer y,,,,,,,,,y,,,,

605-688-4264 SullMIT ITEMS 6 THROUGH 11 ON 0-112 X 11' PAPER. THE TYPE AND SCOPE OF INFORMATION TO DE PROVIDED IS DESCRISED IN THE UCENSE AFPUCATION GUIDE.

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7. INDIVIDUALISI RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THElR 8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS TRAINING EXPERIENCE.

9. FACluTIES AND EOulPMENT, 10. RADIATION S AFETY PROGRAM.

11. WASTE MANAGEMENT, 12. UCENSEE FEES (h. r0 C(n f 70 and s ar,oa 170.371 AMCUNT FEE CATEGORY 170.11(a)(4) ENCLOSED $ EXEMPT

13. CERTIFICATION. Waar 6 :eder appheenalTHE APPUCANT UNDERSTANDS THAT ALL ST ATEMENTS AND REPRESENTATIONS MADE IN THIS APPUCATION ARE BINDING UPON THE APPUCANT.

THE APPUCANT AND A'lY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT, N AMED IN ITEM 2, CERTIFY THAT THIS APPUC ATION IS PREPARED IN CONFORMITY WITH TITLE 10. CODE OF FEDERAL REGULATIONS. PARTS 30,32,33,34,38,39 AND 40, AND THAT ALL INFORM ATION CONT AINED HEREIN IS TRUE AND CORRECT TO THE BEST OF THE!R KNOWLEDOE AND BEUEF, WARNING: 18 U.S.C.SECTION 1001 ACT OF JUNE 26,1948 82 STAT,749 M AKES IT A CRWiiN AL OFFENSE TO MAKE A WILLFULLY F ALSE ST ATEMENT OR REPRESENT ATION TO ANY OFPAATMENT OR AGENCY OF THE UNITFD ST ATES A9 TO ANY M ATTER WITHIN ITS JURISQlCTION CERTIFYlNG OFFICER. TYPED / PRINTED N AME AND TITLE SIGNAT DATE ROBERT T. WAGNER, President /y [ 6)]

FOR NRC USE'QNLY u '

TYPE OF FEE FEE LOG FEE CATEGORY buuNTRCUVED CHECK NUMBER COMMENTS APPROVED BY DATE A65667

y Attachment to Application for License Renewal June 1,1995 Number SNM-200, South Dakota State University Page 1 Item 5. Radioactive Material

a. Nuclide: Plutonium-239

b. Form: Sealed neutron sources (Monsanto Serial Nos. M495, M496, M497, M498, M499)

c. Amount: 80 grams item 6. Purpose (s) for which licensed material will be used.

a. For use in experiments and demonstrations for student instruction and activation analysis of biological and environmental samples.

Item 7. Individual (s) responsible for radiation safety program and their training and experience.

South Dakota State University also holds Broad Scope Byproducts Materials license number 40-02194-17. The radiation safety program regarding sealed sources under that license is applied to these sources. The Radiation Safety Officer and Radiation Safety Committee are responsible for all aspects of both licenses.

7.1. Radiation Safety Officer Dr. Leo H. Spinar, Environmental Regulatory Compliance Officer and Professor of Chemistry, has served as the University Radiation Safety Officer since August,1983.

The duties as Radiation Safety Officer are incorporated into the broader duties of the Regulatory Compliance Officer. The Radiation Safety Officer reports to the Director of Research who reports directly to the University president. When appropriate, the Radiation Safety Officer has direct access to the Vice President for Administration.

B.A.: Chemistry, University of South Dakota (Vermillion),1951 M.S.: Chemistry, University of Wisconsin (Madison),1953 The M.S. degree was in the area of radiochemistry with formal course work in radiochemistry and safety. There was a significant effort to maintain safe practices in the use of radionuclides in the research laboratory. The research work, supervised by Dr. John E. Willard, involved the use of a 10 curie antimony-beryllium photoneutron source over a 15-month period to prepare radioactive bromine, extraction of radio-bromine, carrying out the reaction with rnethane, and counting the activity in the methyl bromide product. The bromine-80 activity handled in the laboratory was less than 1 mci.

Ph.D.: Physical Chemistry, University of Wisconsin (Madison),1958 The PhD research was in high temperature chemistry and was carried out under the supervision of Dr. John L. Margrave.

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Attachment to Application for License Renewal June 1,1995 Number SNM-200, South Dakota State University Page 2 l

1957-62: Instructor-Associate Professor of Chemistry, Colorado State University (Fort !

Collins) l Used, under license, the following nuclides while teaching physical chemistry j laboratories and the instrumental analysis laboratory: {

Cobalt-60: < 30 mci (sealed source for demonstrations)

Phosphorus-32: < 1 mci l Licensed as an operator of a small traimng reactor.

1966-70,1982-present: Associate Professor / Professor of Chemistry, South Dakota l State University (Brookings) )

Used, under license, the following nuclides while teaching physical chemistry )

laboratories and the instrumental analysis laboratory:

Phosphorus-32: < 1 mci Sulfur-35: < 1 mci Radiation Safety Officer since 1983 )

Instructor, graduate level Radioisotope Techniques course since 1989.

7.2. Radiation Safety Conunittee The Radiological Safety Subcommittee of the Research Advisory Council serves as the University Radiation Safety Committee and is charged with development and supervision of the University Radiation Safety program. The University President appoints the Subcommittee members. The membership of the Subcommittee i i

consists of the Radiation Safety Officer, the Dean of the Graduate School and Director of Research (who is designated as the representative of the University president), and one faculty member each from physics, chemistry, pharmacy, and two faculty members from the biological sciences. The faculty members are 1 appointed to three year terms and may serve successive terms. Faculty members on the Subcommittee for 1994-95 are:

Chandradhar Dwivedi, Professor of Pharmaceutical Sciences.

B.Sc.: Chemistry / Biology, Gorakhpur University (India),1964 Ph.D.: Pharmacology, Lucknow University (India),1972 Post-doctoral studies: Pharmacology, Vanderbilt University (Tennessee), 1973-76 1976-85: Meharry Medical College (Tennessee) 1986-87: Ohio State University 1987-present: South Dakota State University Radiometric Biochemical Assays using Carbon-14 and Tritium were carried out at Vanderbilt, Meharry, Ohio State and South Dakota State University.

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1 Attachment to Application for License Renewal June 1,1995 Number SNM-200, South Dakota State University Page 3 Harry G. Hecht, Professor of Chemistry B.S.: Chemistry, Brigham Young University,1958 M.S.: Chemistry, Brigham Young University,1959 Ph.D.: Physical Chemistry, University of Utah,1961 1961-62: Post doctoral research, Argonne National Laboratories l 1966-73: Research scientist, Los Alamos National Laboratories 1973-present: Professor of Chemistry, South Dakota State University Performed radioisotopic experiments as a graduate student.

Worked with natural uranium / thorium, plutonium and neptunium at IAs Alamos Laboratories and at Argonne Laboratories.

Brad Farber, Research Associate / Farm Manager, Plant Science B.S.: Agricultural Education, South Dakota State University,1980 M.S.: Agronomy, South Dakota State University,1984 Master's degree involved use of neutron moisture probes. i Paul Prasher, Professor of Horticulture B.S.: Government Agricultural College (Ludhiana, India),1952 M.S.: University of Minnesota,1955 Ph.D.: University of Missouri (Columbia),1960 1960-present: Faculty, South Dakota State University Development of new tomato varieties by exposing seeds to ionizing radiation.

John H. Kitterman, Associate Professor of Physics l B.S.: Physics, Kansas State University,1959 l M.S.: Physics, Kansas State University,1961 Ph.D.: Physics, Colorado State University,1970 l l Nuclear physics was a part of academic training.

l Item 8. Training for Individuals Working In or Frequenting Restricted Areas.

! All work with these sources is supervised by an Authorized Principal Investigator User who has been approved by the Radiation Safety Committee. Individuals are approved as Authorized PrincipalInvestigator Users of sealed sources provided they:

a. have the academic rank in the University of Assistant Professor or higher in the physical or biological sciences or in engineering; and

b. have had at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of formal training and experience in the safe handling of radioactive materials and in the characteristics of ionizing radiation, unite of radiation dose and quantities, radiation detect. ion instrumentatic:., and 'oiological hazards of exposure to radiation; and

c. have attended an orientation session with the Radiation Safety Officer; and

Attachment to Application Er License Renewal June 1,1995 Number SNM-200, South Gea State University Page 4

d. have received and read the institution's policy on the acquisition, use and disposal l

of radioactive materials, the maintenance of appropriate records, and the requirements of the ALARA concept; and

e. have provided a suitable plan for the use, monitoring, storage and disposal of J radioactive materials.

The Radiation Safety Of6cer may approve individuals as Authorized Subsidiary Users using criteria adopted by the Radiation Safety Committee. Subsidiary Users work under the supervision of an Authorized Principal Investigator. The Principal Investigator is responsible for the activities of the Subsidiary User and for training in proper procedures relating to the use of radioactive materials within the scope of his duties.  !

Junior, senior and graduate students enrolled in upper level and graduate nuclear physics courses shall be permitted to carry out experiments using the sources without speciEc approval of the Radiation Safety Committee or the Radiation Safety Officer provided:

a. The Radiation Safety Committee has approved the experimental procedures in general; I

b. The work is carried out under the direct supervision of an Authorized User;

c. An Authorized User has instructed the students as to the risks and radiation l protection procedures associated with the experiment;

d. The sources are transferred to and from the storage well by an Authorized User; l

e. At least one student wears a device that measures neutron exposure; i

f. No student utilizes the sources for more than three hours per week for no more l than three weeks per year. l The sources may be used for laboratory and classroom demonstrations provided,

a. The sources are used by an Authorized User;

b. The sources are kept in the parafHn/ cadmium-lined transfer pail or in a container with equivalent shielding;

c. Students stay at least one meter from the source.

Item 9. Facilities and Equipment a

The five Plutonium-Beryllium sources are kept in the Nuclear Laboratory, Room 113A,

, Crothers Engineering Hall, South Dakota State University. Access to the laboratory is restricted to those persons who are authorized users. The sources are stored in a 6-foot deep well with a cement cover which is lifted by an electric motor. When in use, the sources are transferred one at a time in a pail, lined with cadmium and filled with paraffin.

There is a hole for the source in the center of the paraffin. The hole is closed with a paraffin cover. Each source emits 2 x 10 6neutrons per second. The neutron Dux at the surface of the pail is well below 55 neutrons /sec cm2 due to shielding of 10 centimeters paraffin and 1 millimeter cadmium.

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Attachment to Application for License Renewal June 1,1995 Number SNM-200, South Dakota State University Page 5 A Victoreen Model 491 GM survey meter is used for general radiation monitoring in the nuclear physics laboratory.

The activity in the radioactive samples produced by neutron activation using these sources is very low. The half-lives of the induced radionuclides are short. A germanium crystal detector (Ortec, Inc.) and a 2048-channel pulse height analyzer system (Nuclear Data, Model ND-60A) are used to count the induced radioactivity.

Item 10. Radiation Safety Program The Radiation Safety Committee authorizes faculty members to use the sources for demonstrations and for laboratory experiments. The Committee reviews the proposed usage mid the training and experience of the faculty member. The use and user are approved if the Committee determines that the faculty mem'aer can carry out the experiments with low .

exposures to the students and a the faculty meinber. Authorized users of the sources wear j a film badge with neutron dosimeter vcben working with the sources. The badges are processed by a licensed service provider. Siemens Dosimetry Services, Hoffman Estates, Illinois, is the current supplier of the badges and dosimeters. The badges are exchanged on a monthly basis. The Radiation Safety Officer maintains a file of the monthly reports provided by Sienuns.

Only junior, senior and graduate students are allowed te participate in the neutron activatica experiments. The work is crried out under the direct supervision of an Authorized User.

In actual practice, it is unlikely a student will come within two feet (0.61 meter) of an unshielded source since 4-foot long tongs are used to handle the sources. The irradiation portion of the experiment is carried out by a trained user. The irradiation lasts for about 15 minutes. Counting and other laboratory work is done at least six feet from the source.

A student performs the experiment once during the year. Personnel monitoring of these students is not required because the radiation level is well below regulatory limits.

The dose from neutron activity from an unshielded source is:

2 feet (0.61 meter) for 15 minutes 5.0 mrem 4 feet (1.22 meter) for 15 minutes 1.3 mrem 6 feet (1.83 meter) for I hour 2.2 mrem The regulatory limit for students is 100 mrem per year.

Shielding is used to reduce exposure to less tnan one per cent c . these values. Authorized Users, who handle the sources and come closer to the sources for longer periods of time than the students, have never recorded a detectable (10 mrem) exposure.

9- j Attachment to Application for License Renewal June 1,1995 Number SNM-200, South Dakota State University Page 6 The gamma radiation associated with a source is le'.s than 0.2 mR per hour at 2.5 feet and is at background at the bench where the irradiatedI .;oduct is counted. A student will spend no more than three hours per week in the laboratory working on neutron source experiments.

Leak tests on the stainless steel capsules are performed by the. Radiation Safety Officer every six months unless the sources are in long term storage. The capsule is wiped with a moistened filter paper. The removable activity on the paper is measured by a licensed service provider. At present, the measurements are made by Siemens Dosimeter Services, Hoffman Estates, Illinois.

Individual exposures are kept ALARA by (a) limiting the handling of the sources to authorized users. (b) use of shielding such as water, cadmium, and/or paraffin, (c) keeping the sources in the storage well when not in use, (d) use of 4-foot long tongs in handle the sources, and (e) keeping the source in the paraffin / cadmium lined transter pail during demonstrations. In addition, the hazards ad protection measures are described before students are permitted to ent:r the laboratory. Transfer operations are limited to authorized users.

Storage is in Room 113A of Crothers Hall. The room is marked with appropriate signage. i Keys to the room are limited to authorized users.

The Radiation Safety Officer performs leak tests on the sources every six months. This constitutes a physical inventory of the sources since each one must be handled individually.

11. Waste Management The radioactive material generated by neutron activation experiments using these sources is very small in volume and very low in activity. During an experiment less than 0.1 microcurie of relatively short lived nuclides, such as sodium-24, iron-59, tungsten-187 and manganese-54, are generated. Water ' soluble materials are released to the sanitary sewer.

Other materials are held for 10 half lives before released as ordinary trash.

It very improbable that the University will dispose of any of these sources during the lifetime of this license renewal. If disposal becomes necessary, the sources will be sent to the Southwestern LLRW Compact Ward Valley site if it is operational, or to another disposal site if available. If no site is available, the S. urces would be transferred to a I licensee who provides interim storage or redistributic ..

Since these are scaled sources, a Decommissioning Fading Plan is not required for this license.

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i Attarnment to Application for License Renewal June 1,1995 Nuraber SNM-200, South Dakota State University Page 7 Appendix 1. Dose Calculations

'Be(cr,n)i2C yields 5.76 MeV Fluence = 23 x 106 n/ rem cm2 for 5 MeV neutron [ Table 20.1004(b)2]

2 5 13 o = Io/4rr = (6 x 106 n/sec)/4r(1 cm)2 = 4.8 x 10 n/cm2 sec 5 2 2 Dose rate n (4.8 x 10 n/cm sec)/(23 x 106 n/ rem cm )

= 21 mrem /sec at I cm

= 1.2 rem /m:n at I cm 2

= (1.2/r ) rem / min at r cm

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