ML20248H346
| ML20248H346 | |
| Person / Time | |
|---|---|
| Site: | 07007031 |
| Issue date: | 09/04/2020 |
| From: | Frank Tran Division of Nuclear Materials Safety III |
| To: | Peters W Niowave |
| References | |
| 621136 | |
| Download: ML20248H346 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 William Peters, Ph.D.
Radiation Safety Officer Niowave, Inc.
1012 N. Walnut Street Lansing, MI 48906
Dear Dr. Peters:
On May 19, 2020, the NRC received your application dated May 18, 2020 and the applicable application fee in accordance with Tittle 10 of the Code of Federal Regulations (10 CFR) parts 70 and 170. You request a new NRC license for the possession and use of special nuclear material (SNM) scrap as defined by 10 CFR 70.4. A teleconference between Niowave, Inc. and the U.S. Nuclear Regulatory Commission (NRC) including staff from Region III, NMSS and NRR was conducted on August 6, 2020 to discuss the requested material and proposed activities in the application. It was determined that this new license application will be reviewed and licensed by the Region III office.
According to 10 CFR 70.23, Requirements for the approval of applications, the NRC will approve your application if your application meets the requirements set forth in 70.23(a).
We have reviewed your application using the licensing guidance in NUREG-1556, Volume 17, Revision 1, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Special Nuclear Material of Less Than Critical Mass Licenses and other applicable guidance. A copy of NUREG-1556, Volume 17, revision 1 can be found on the NRCs Web site at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v17/. Based on the review and discussion with you on August 28, 2020, we will need the following information.
- 1) 10 CFR 50.2 provides a definition for Production facility. 10 CFR 70.4 provides a definition for Plutonium processing and fuel fabrication plant. In the application, Niowave requests to acquire SNM scrap to extract the fission products and SNM, including uranium-235 and plutonium. Please describe in detail the purpose of use of the requested material and how the licensed material and activities will not meet the definition above.
- 2) Niowave requests authorization for a custom sealed source contain europium-152.
Please provide additional information for this source per Section 5.1.3 and Appendix A to NUREG-1556, Volume 3, Revision 2. A copy of this licensing guidance can be found on the NRCs Web site at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v3/. If the source is a calibration/reference source which is distributed as an exempt source by an exempt distribution licensee, please state.
- 3) Section 5.2.2 of the application states that Niowave will discard the record of radioactive material spills if the spills were completely cleaned up. 10 CFR 20.2103(b) requires the September 4, 2020
W. Peters records generated by activities discussed in 10 CFR 20.1501 be maintained for 3 years.
10 CFR 20.1501(a) requires the licensee to perform area surveys for complying with 10 CFR part 20. Please help us to understand the basis for your deviation from the regulation.
- 4) Sections 8.1 and 8.2 of the application provided that a radiation safety training will be provided for radiation workers and non-radiation workers working in or frequenting restricted areas. This training will be provided by the Radiation Safety Officer or another authorized staff member. Please provide a description of another authorized staff member, including the training and experience of the individual in the use of radioactive material and radiation safety.
- 5) Provide the method that the initial radiation training and annual refresher training will be conducted (in classroom lecture, demonstrations, video, etc.)
- 6) The requested material will pose significant internal and external dose to the radiation workers, members of the public and environment if not proper control. In accordance with 10 CFR 70.23, the applicant's proposed equipment and facilities must be adequate to protect health and minimize danger to life or property; and the applicant's proposed procedures to protect health and to minimize danger to life or property must be adequate. Please provide what industrial standards/codes Niowave will follow in the construction of the facility, specifically the hot cell and its associated equipment, and the industrial standards/codes for the quality assurance program. Alternatively, Niowave could provide in details the construction of the facility and equipment, including the facility diagram with dimensions/scales and construction material for the floor, walls, ceiling, and/or door; the proximity of radiation sources to unrestricted areas and the radiation shielding and dose evaluation (using the most conservative assumptions); the schematic for the ventilation system should include the airflow rates, pressures, type of filtration equipment, and type of monitoring system; and the quality assurance/quality control in place to ensure the designed and as-built system meet and continue perform its intended functions in operations. Please note that based on the dose rate from the requested material, Niowave may have to comply with 10 CFR 20.1601, Control of access to high radiation areas. In addition, as you provided that Niowave will make modifications to the facility and equipment as proposed in the application and will provide to the NRC soon, please submit the proposed modifications.
- 7) Sections 10.1., 10.2., and 10.4. of the application stated that Niowave will conduct physical sources inventory bi-annual or twice a year. The licensing guidance recommends a frequency of every six months. Please clarify if Niowave will perform the physical sources inventory every six months.
- 8) Section 10.5 of the application stated that Niowave has developed written procedures which meet the requirements of NRC regulations which were listed in this section.
However, it appeared that some of the listed regulations are incorrect. Please provide a revision and/or explanation.
- 9) Niowave requests to conduct some licensed activities which may include working with radioactive material with high external radiation dose rate by hands. Please clarify if Niowave will provide ring badges to monitor radiation doses to the extremities of those radiation workers.
- 10) Provide an exchange frequency for personal dosimeters.
W. Peters
- 11) Niowave requests for the possession of 120 grams SNM scrap; however, the evaluation for occupational dose discussed in Appendix 10.1 of the application was calculated based on a quantity of 100 grams of the material. Please provide a revision for the evaluation.
To continue the review of your license application, we request that you submit your signed and dated written response to this letter by October 4, 2020. Please reference Mail Control Number 621136 in the cover letter to facilitate proper mail handling in our office. If you have any questions or require clarification on any of the information stated above, please do not hesitate to contact me at 630-829-9887 or frank.tran@nrc.gov.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely, Frank P.D. Tran Health Physicist Materials Licensing Branch Docket No. 070-07031 Control No. 621136 Frank P. Tran Digitally signed by Frank P. Tran Date: 2020.09.04 07:37:31 -05'00'