ML20236J888
| ML20236J888 | |
| Person / Time | |
|---|---|
| Site: | 07000920 |
| Issue date: | 08/04/1987 |
| From: | Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20078S700 | List: |
| References | |
| NUDOCS 8708060326 | |
| Download: ML20236J888 (8) | |
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l AUG 0 41987 i o !
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i IMUF:MLH 1
DOCKET NO:
- 70-920 LICENSEE: RensselaerPolytechnicInstitute(RPI)'
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SUBJECT:
SAFETY EVALUATION REPORT, LICENSE APPLICATION DATED
, APRIL 10, 1987 AND SUPPLEMENT DATED JUNE 23,1987;- RE - 'I LICENSE RENEWAL' f i
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Background
P,ensselaer Polytechnic' Institute (RPI) was first issued Materials License No. 1 SNM-910 in June 1965. The license was last . renewed April 1,1982. The current 1 license was scheduled to expire on April 30,-1987; however, on April 10, 1987, )
RPI submitted an-application for renewal. The timely renewal provisions of Subsection 70.33(b) of 10 CFR 70, do not apply in this case; however, the staff determined that the license should remain in effect.-
Scope of Review The review of RPI's renewal application included ,the application of April. 10, 1987, the supplemental information dated June 23, 1987, and the compliance history of the license during the past 5 years.
The topics of review include an evaluation of the applicant's radiation safety and nuclear criticality safety programs and the RPI organization. The renewal ;
application was discussed with Mr. J. Roth, NRC Region I Inspector.
i Discussion RPI's renewal application demonstrates that they have adequate technical staff I with the proper qualifications to administer an effective and safe radiological i safety program. The following sections ~contain a description of the applicant's organization, safety program, and proposed license conditions developed by the ~
IMSB staff.
Possession Limits: RPI'has requested the following nuclear material for their activities:
Material Form Amount' -!
A. Uranium enriched in .A. Foils A. 350 grams U-235 the U-235 isotope B.- Plutonium Pu-238 B. Encapsulated PuBe B. 21 gram Pu neutron sources -l 1
8708060326 870804 PDR ADOCK 07000920 C PDR j c - - - --- ___ -
l AUG 0 41987 Rensselaer Polytechnic Institute, SER 2 !
C. Plutonium Pu-239 C. Encapsulated PuBe C. 378.06 grams ~
neutron sources D. Plutonium D. Encapsulated dosimeter D. 3.00 grans Pu E. Pu-239, U-233, E. Metal disks E.175 grams total or U-235 F. U-235 or U-233 F. Fuel coupons unclad- F. 350 grams Sintered U0 -Th pelletsorhintbred 007 -Th07 pellets in zircalloy cladded fuel rods G. U-235 G. Powder and liquid G. 3 grams H. Pu-240 H. Foils H. 24 grams In order to limit the quantity of special nuclear material to 1 effective kilogram, the following condition is added:
Notwithstanding the quantity limitations specified above, the licensee shall not possess under this license at any one time more than 1 effective kilogram of special nuclear material as defined in Section 70.4(t) of 10 CFR 70.
Activities l
l The special nuclear material is used for educational research and development l activities at the Linear Accelerator Laboratory. The Pu-Be neutron sources are used as calibration sources at the Cogswell Laboratory, Plaw Knox I, Science Center, and the Walker Laboratory. The uranium and plutonium calibration sources can be used at West Hall. The following conditions are recommended:
Authorized Use: For receipt, possession, and use in accordance with the statements, representations and conditions specified in the application dated l April 10, 1987, and supplement dated June 23, 1987.
l l Authorized Place of Use: The materials specified in A-H shall be used in i locations specified in the application dated April 10, 1987, and supplement dated June 23, 1987.
Section 11.05(1) indicates that RPI may hold special nuclear material (SNM) under New York State lisenses. All SNM should be under NPC license since RP1 possesses more than 350 grams. If in fact RPI does have SNM under a State license, they should immediately take action to correct the situation by i
amending the NPC license to include the material and removing the material !
from the State license.
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Rensselaer Polytechnic Institute, SER 3 AUG 0 41987 I
Organization The radiation safety program is within the province of the Office of the Provost and is administered by the Vice Provost, Academic Affairs, through the Office of Radiation and Nuclear Safety. There is a Radiation and Nuclear Safety Committee which is appointed by and reports to the Provost. The Director of Radiation and Nuclear Safety (DRNS) is en ex-officio member of the Committee.
The Committee meets bimonthly during the academic year. It is responsible l for establishing Institute policies for radiation and nuclear safety, giving advice and assistance as requested by the DRNS, giving approval to reactivate an operation which the DRNS has stopped, and evaluating the overall radiation safety program and its administration. The Committee attempts to visit each facility once a year. To ensure each facility is inspected and audited on an annual basis, the following condition is recommended: l Notwithstanding the statement in Section 2.3 of the application, the Radiation and Nuclear Safety Committee shall inspect and audit each facility at least annually (not to exceed a 13-month interval).
The DRNS has the authority to stop an operation if a radiation hazard exists, j Institute property is endangered, or neglect of Institute plicies is observed. 1 The DRNS is responsible for providing radiation protection, assuring conformance with radiation safety regulations, investigating any radiological incident or accident, giving written approval for each radiation installation before the installation is placed into operation, approving specific procedures for .
radiation installations, and supervising disposal of all radioactive wastes. j Section 2.1 of the application states that each person using the Institute's equipment and facilities is expected to supplement the procedures when necessary.
This statement implies that the user may supplement procedures without the knowledge and approval of the DRNS. In order to remove the possibility of this occurring, the following condition is recommended:
Notwithstanding the statement in Section 2.1 of the application, prior to implementation, the Director of Radiation and Nuclear Safety shall approve all changes to procedures.
The DRNS is responsible for maintaining the personnel monitoring program, but there is no mention of who is responsible for reviewing exposure records. To correct this deficiency, the following condition is recommended:
The Director of the Office of Radiation and Nuclear Safety shall be responsible for reviewing the personnel exposure records to determine trends and recommending appropriate corrective action if required. The annual review shall not exceed a 13-month interval.
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a l Rensselaer Polytechn,c Institute, SER 4 AUG 0 4198/
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]i Technical Qualifications The application specifies the minimum education and experience requirements for the DRNS. These requirements are deemed adequate.for the position. The application also specifies that members of the Radiation and Nuclear Safety Committee are full-time faculty or staff who have at least 2 years' experience in the use of sources of radiation and radioactive materials.
Radiation Safety Control Control of Personnel Exposure )
Information regarding exposure records are computerized and accessible to staff or students who have had entry into controlled areas. All areas where special nuclear material is stored or used are designated controlled areas and require the issuance of appropriate monitoring devices. Section 3.2 of the application gives different frequencies for the collection of personnel monitoring devices, including periodical distribution and collection, frequercy not to exceed a monthly basis, and exchange on a biweekly basis. To clarify that personnel monitoring devices are collected and read at a minimum, on a monthly frequency, !
tne following condition is recommended: 1 i
Personnel monitoring devices shall be collected and read on at least a I monthly basis.
The applicant refers to legal n'aximum permissible dose levels as specified in the New York State Department of Health Sanitary Code, however, dose limits to 1 be used are those in 10 CFR 20. Therefore, the staff recommends the following condition:
Notwithstanding the statement in Section 2.1 of the application, maximum permissible dose levels shall be those specified in 10 CFR 20.
To ensure suitable protective clothing is used and that contaminated personnel do not exit an area, the following condition is recommended: c Suitable clothing (lab. coats, gloves, etc., specific to the job) shall be required for work with unencapsulated SNM. Hands, feet, and clothing shall be monitored when leaving an area where the material is used. Except by approval of the Director of Radiation and Nuclear Safety, persons shall ,
not exit an area if personal clothing and/or skin contamination levels are above background.
Control of Contamination The application states that the Office of Radiation and Nuclear Safety provides a periodic survey service for the radiation installations; however, no frequency or levels at which. decontamination should commence are stated. The following condition is recommended to correct the deficiency:
Surface contamination surveys shall be conducted daily when unencapsulated SNM is used, and decontamination shall commence when survey levels of 2
removable contamination exceed 5,000 dpm/100 cm ,
e Rensselaer Polytechnic Institutt, SER 5 ,
l Even.though the licensee commits to leak testing sealed plutonium sources, it is recommended that adherence to the standard leak test condition remain as a part of the license. The proposed condition is as follows:
The licensee shall comply with the Annex, " License Condition For Leak l Testing Sealed Plutonium Sources," August 1987. 1 The licensee does not have guidelines for releasing equipment and packages from restricted to unrestricted areas. The following condition is recommended:
Release of equipment or materials for unrestricted use or from contaminated to clean areas shall be in accordance with the Annex,
" Guidelines for Decontamination of Facilities and Equipment Prior l to Release for Unrestricted Use or Termination of Licenses for j Byproduct, Source, or Special Nuclear Materials," August 1987. 3 Section 6 contains a reference to New York State Cedes for the posting ,
requirements. However, posting requirements must be in accordance with NRC j requirements and not the New York State Codes. Therefore, the following i condition is recommended:
Notwithstanding the statement in Section 6.05 of the application, the licensee shall comply with 10 CFR 20.203.
To ensure compliance with the appropriate regulations for receiving and shipping radioa;tive material, the following condition is recommended:
Notwithstanding the statement in Section 10.03 of the application, the licensee shall comply with 10 CFR Part 71 and 10 CFR 20.205.
Section 13 contains general procedures for radiation safety, many of those in l Subsection 13.01 use the word "should" when providing instruction. These l statements need to be made requirements, therefore, the following condition is recommended:
The statements in Section 13.01 of the application dated April 10, 1987, shall be considered license requirements, accordingly, replace "should" with "shall".
l Calibration of Instruments The application states that each radiatien installation must have appropriate l radiation monitoring and survey equipment which is calibrated and maintained '
in an operating condition and available at all times. There is no mention of I calibration frequency. Therefore, the staff recommends the following condition:
The licensee shall calibrate the radM tion monitoring and survey equipment at maximum 6-month intervals or, if the equipment has not been used during the 6-month period, prior to use.
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AUG 0 41987 Rensselaer Polytechni' Institute, SER 6 Training Faculty and staff must receive approval from the DRNS before working with SNM.
The approval is based on their previous training and experience. New users are required to review a videotape covering the basic fundamentals of radiation.
Students are required to be under the supervision of a faculty or staff member who has tsceived approval. Safety training is given by a student's faculty advisor. Since the DRNS has the appropriate qualifications to teach radiation !
safety and because the background of the faculty advisor is not specified in the application, the following condition is recommended:
I Radiation safety training shall be provided by the DRNS or his designee who has equivalent qualifications.
Retraining in radiation safety is provided by the DRNS via Fall and Spring ,
semester lectures, j i
Effluent Control j There should be no liquid or air effluents generated during normal operations. o The DRNS is responsible for the proper disposal of all wastes. The wastes are stored at a Radioactive Waste Storage Area at the Blaw Knox I Building.
Nuclear Criticality Safety The licensee is currently required by license condition to maintain a running inventory at each location with SNM distribution and accountability being the responsibility of the DRNS. This condition has not been stated in the license application, therefore, the following condition is recommended:
The DRNS shall authorize and control the movement of special nuclear material to and from storag and between experimental areas. The DRNS shall maintain inventory records of special nuclear material in each storage or experimental area to assure that the limit stated in the condition below is not exceeded in any one location.
The licensee requests continued exemption frcm the provisions of 10 CFR 70.24 because there is no area where possession limits exceed 700 grams U-235, or 520 grams U-233, or 450 grams Pu-239, or 450 grams of any combination of these special nuclear materials. Since inventory control is exercised and because of the low total possession limits, the possibility of accidental criticality is negated. Accordingly, the staff recommends that the exemption ha --+ed as follows: 1 The licensee is hereby exempt from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license and provided that no more than 450 grams of Special Nuclear Material, .
excluding encapsulated Pu-Be neutron sources, is present in any one room J at any one time.
AUG 0 41987 Rensselaer Polytechnic Institute, SER 7 Environmental Protection The licensing of RPI activities is in accordance with 10 CFR 51.22(c)(14)(v),
and therefore, neither an Environmental Assessment nor an Environmental Impact Statement is warranted fer this action.
Emergency Planning The licensee has emergency procedures in place that outline steps to be taken in the event of accidents involving radioactive contamination, exposure, or injury to personnel.
Compliance History The inspection and enforcement record of the license since the last renet.a1 was reviewed and discussed with Mr. J. Roth, Region I Inspector. Of the two items of non-compliance reported, none had any adverse effect on personnel or the general public. The items were primarily of an administrative nature, such as not maintaining inventories for storage areas and maintaining an inventory exceeding I effective kilogram.
The proposed renewed license was discussed with Region I staff, and there was no objection to the issuance of the renewed license as described in the RPI application and the proposed additional conditions.
Conclusion and Recommendations Upon completion of the safety review of the licensee's application and discussion with the Region I Inspector regarding the licensee's compliance records, the staff has concluded that the licensee has the necessary technical staff to administer an effective radiological safety program. Conformance by the licensee to their proposed conditions, as well as to those developed by the staff, should ensure a safe operation, a quick detection of unfavorable trends or effects, and result in corrective actions being taken.
Based on the discussion above, it is recommended that the license be renewed for a 5-year period in accordance with the application and subject to the above recommended conditions. Origina1 Signed By:
Merri L. Horn Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS Approved by:
Leland C. Rouse, Chief Fuel Cycle Safety Branch l l
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DATE:08/d/87 :08/k/87 (108/0/87: : :
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