ML20254A189

Public_DTRA-NRC SNM License Application Final

ML20254A189
Person / Time
Site:	07007029
Issue date:	09/10/2020
From:	Davis S US Dept of Defense, Defense Threat Reduction Agency
To:	Ty Naquin NRC/NMSS/DFM/FFLB
Naquin T
Shared Package
ML20238B813	List: ML20254A189
References
602208
Download: ML20254A189 (88)

Text

NRC FORM 313 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0120 EXPIRES: 0113112023 101.2020) Eshmated burden per response to comply xdlh this mandatory collection requesl: 4 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Submittal of the 10CFR3C 32.

33, 34, 35, 36, applicator is necessary to detetmine that the applicant is qualified and that adequate procedares exist to protect the pabtic health and safety Send comments regarding burden eshmale to the Intotmaton Services Branch (1.6 AtOM),

37. 39, and 40 APPLICATION FOR US Nuclear Regulatory Commission, Washington, DC 20655-0001, or by e-mail to Infocollects.Resource@nrc gov.

MATERIALS LICENSE and to the Desk Officer, Office ot Information and Regulatory Affairs, NEOB-10202. (3150-0120), Office of Management and Budget, Washington, DC 20503. It a means used to impose an infonaton cotlecton does not display a currently valid 0MB cordol number, the NRC may not conduct or sponsor, and a person is rot required to respond to, the informahon collection INSTRUCTIONS: SEE THE CURRENTVOLUMES OF THE NUREG1S55 TECHNICAL REPORT SERIES (CONSOLIDATED GUIDANCE ABOUT MATERIALS LICENSES) FOR DETAILED INSTRUCTIONS FOR COMPLETING ThIS FORM: hflp:Thwnv.nrc.poyIrpadinoctnVdoc.cDIln.cItcmslnwrqe/Maff/sfl). SEND TWO COPIES OF THE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH: IF YOU ARE LOCATED IN:

MATERIALS SAFETY LICENSING BRANCH ILLINOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO. OR WISCONSIN, SEND DIVISION OF MATERIAL SAFETY, STATE. TRIBAL AND RULEMAKING PROGRAMS APPLICATIONS TO:

OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS US NUCLEAR REGULATORY COMMISSION MATERIALS LICENSING BRANCH WASHINGTON. DC 20555-0001 US NUCLEAR REGULATORY COMMISSION. REGION III 2443 WARRENVILLE ROAD SUITE 210 ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS: LISLE. IL 60532-4352 IF YOU ARE LOCATED IN: IF YOU ARE LOCATED IN:

ALABAMA, CONNECTICUT, DELAWARE, DISTRICT OF COLUMBIA, FLORIDA, ALASKA, ARIZONA, ARKANSAS, CALIFORNIA, COLORADO, HAWAII, IDAHO, KANSAS, GEORGIA, KENTUCKY, MAINE, MARYLAND, MASSACHUSETTS, NEW HAMPSHIRE, LOUISIANA. MISSISSIPPI, MONTANA, NEBRASKA, NEVADA, NEW MEXICO, NORTh NEW JERSEY, NEW YORK, NORTH CAROLINA, PENNSYLVANIA, PUERTO RICO, DAKOTA, OKLAHOMA, OREGON, PACIFIC TRUST TERRITORIES, SOUTh DAKOTA, TEXAS, RHODE ISLAND, SOUTh CAROLINA, TENNESSEE, VERMONT, VIRGINIA. VIRGIN UTAH, WASHINGTON, OR WYOMING, ISLANDS, OR WEST VIRGINIA, SEND APPLICATIONS TO: SEND APPLICATIONS TO:

LICENSING ASSISTANCE TEAM NUCLEAR MATERIALS LICENSING BRANCH DIVISION OF NUCLEAR MATERIALS SAFETY US NUCLEAR REGULATORY COMMISSION, REGION IV US NUCLEAR REGULATORY COMMISSION. REGION I I6CO E LAMAR BOULEVARD 2100 RENAISSANCE BOULEVARD. SUITE ICO ARLINGTON, TX 76011-4511 KING OF PRUSSIA. PA 19406-2713 PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO ThE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF ThEY WISH TO POSSESS AND USE UCENSED MATERIAL IN STATES SUBJECTTO U.S. NUCLEAR REGULATORY COMMISSION JURISDICTIONS.

1 THIS IS AN APPLICATION FOR (Check appmpnate item) 2 NAME AND MAILING ADDRESS OF APPLICANT (Include zip code)

A, NEWLICENSE ATTN DIR-ES/Daniel Mannis Defense Threat Reduction Agency D 8725 John J. Klngman Rd. Stop 6201 D C. RENEWAL OF LICENSE NUMBER Fort Belvoir, VA 22060-6201 3 ADDRESS WHERE LICENSED MATERIALS WILL BE USED OR POSSESSED 4 NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION Daniel Mannis BUSINESS TELEPHONE NUMBER BUSINESS CELLULAR TELEPHONE NUMBER Locations described in Section 9 of this application. 571-616-6208 BUSINESS E-MAIL ADDRESS daniel.n.mannis.ciV@maihmii SUBMIT ITEMS S THROUGH 11 ON 6.112 Xli PAPER. THE TYPE AND SCOPE OF INFORMATION TO SE PROVIDED IS DESCRIBED.. LICENSE APPLICATION GUIDE.

S. RADIOACTIVE MATERIAL 6 PURPDSEIS) FOR uMIICH LICENSED.MATERIAL WiLL BE USED a, Element and mass number, b chemical and/or physical form, and c maximum amount 7, INDIVIDUALIS) RESPONSIBLE FOR RADIATIDN SAFETY PROGRAM AND THEIR TRAINING AND which will be poseessed at any one time EXPERIENCE

6. TRAINING FOR INDIVIDUALS WORKING IN DR FREOUENTtNG RESTRICTED AREAS 9. FACILITIES AND EQUIPMENT 10 RADIATION SAFETY PROGRAM 11 WASTE MANAGEMENT 12 LICENSE FEES IFeea required only for new epplicaliona. wish few exceptiona)

(See ID CFR 170 and Section ITO 31) cAT IO0RY 1F ENCLOseD $ 0.00 AmendmeneslRenewals thaI Increase the scope of Iho exIstIng lIcense to a now or hIgher fee category will require a fee.

PER ThE DEBT COLLECTION IMPROVEMENT ACT OF 1995 (PUBLIC LAW 104.1341, YOU ARE REQUIRED TO PROVIDE YOUR TAXPAYER IDENTIFICATION NUMBER. PROVIDE ThIS INFORMATION BY COMPLETING NRC FORM 551:

13 CERTIFICATION. (Must be completed by applicant) THE APPLICANT UNDERSTANDS THATALL STA7EMENTS AND REPRESENTATIONS MADE IN THIS APPLICATION ARE BINDING UPON THE APPLICANT THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT. NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS PREPARED IN CONFORMITY WTH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 3D, 32, 33. 34, 35. 36. 37. 39. AND 4D. AND THAT ALL INFORMATION CONTAINED HEREIN IS TRUE AND CORRECT TO THE BEST OF THEIR KNOWIEDGE AND BELIEF WARNING 16 USC SECTION 1001 ACT OF JUNE 25. 194662 STAT 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT DR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION CERTIFYING OFFICER TYPED/PRINTED NAME AND TITLE DATE

!YflS.SHERRY Digitally signed by DAVIS.SHERRY.J.1 105036910 Sherry J. Davis, Director ESOH J,1105036910 /9/ V:202O.D8.2l 10:04:26-0400 FOR NRC USE ONLY TYPE OF FEE FEE LOG FEE CATEGORY AMOUNT RECEIVED CHECK NUMBER COMMENTS S

APPROVED BY DATE NRC FORM 313 101 -2020)

NRC Category III Special Nuclear Material License Application DTRA Table of Contents 1 of 53 Table of Contents Item 5.0 Radioactive Materials ......................................................................................... 3 5.1 Licensed Material Description ...................................................................................................... 3 5.2 Requested Possession and Use Limits .......................................................................................... 5 5.3 Authorized Uses ............................................................................................................................ 6 5.4 Nuclear Criticality Safety Assessment .......................................................................................... 7 5.5 License Expiration ........................................................................................................................ 8 Item 6.0 Purpose(s) For Which Licensed Material Will Be Used .................................. 9 6.1 General Description of Use ........................................................................................................... 9 Item 7.0 Individual(s) Responsible For Radiation Safety Program and Their Training and Experience .................................................................................. 11 7.1 Radiation Safety Officer ............................................................................................................. 11 7.2 Site-Radiation Safety Officers .................................................................................................... 13 7.3 Authorized Users ........................................................................................................................ 14 Item 8.0 Training for Individuals Working In or Frequenting Restricted Areas ...... 15 Item 9.0 Facilities and Equipment .................................................................................. 18 9.1 Facilities ...................................................................................................................................... 18 9.1.1 DTRA Nuclear Enterprise Contingency Operations .............................................................................. 18 9.1.2 Technical Evaluation Assessment Monitoring Site ............................................................................... 27 9.2 Material Storage .......................................................................................................................... 31 9.3 Onsite Use ................................................................................................................................... 32 9.4 Review and Approval Process .................................................................................................... 32 9.5 Physical Protection and Physical Security .................................................................................. 33 Item 10.0 Radiation Safety Program ................................................................................ 35 10.1 Audit Program............................................................................................................................. 35 10.2 Radiation Surveys and Monitoring ............................................................................................. 35 10.3 Material Receipt and Accountability .......................................................................................... 38 10.4 Occupational Dose ...................................................................................................................... 38 10.5 Public Dose ................................................................................................................................. 39 10.6 Operating and Emergency Procedures ........................................................................................ 39 10.7 Leak Tests ................................................................................................................................... 39 10.8 Transportation ............................................................................................................................. 40 10.9 Minimization of Contamination .................................................................................................. 42 10.10 Other Radiation Safety Program Components ............................................................................ 43

NRC Category III Special Nuclear Material License Application DTRA Table of Contents 2 of 53 Item 11.0 Waste Management ........................................................................................... 44 Item 12.0 License Fees........................................................................................................ 45 Appendix A. Detailed Source Information ............................................................................ 46 A.1. U-233 RSTD: Uranium-233 .......................................................................................................... 46 Attachments ........................................................................................................................................................ 46 A.2. RSTD- uranium-235..................................................................................... 47 Attachments ........................................................................................................................................................ 47 A.3. RSTD- uranium-235...................................................................................... 48 Attachments ........................................................................................................................................................ 48 A.4. Pu RSTD: Plutonium-239 ............................................................................................................. 49 Attachments ........................................................................................................................................................ 49 A.5. ZiPCans .......................................................................................................................................... 50 Attachments ........................................................................................................................................................ 50 Appendix B. Nuclear Criticality Safety Assessment ............................................................. 51 Attachments ........................................................................................................................................................ 51 Appendix C. Radiation Safety Program Appointment Letters ........................................... 52 Attachments ........................................................................................................................................................ 52 Appendix D. In-Use Explanation ............................................................................................ 53 Attachments ........................................................................................................................................................ 53 List of Tables Table 1. Requested special nuclear material maximum amount limits .................................. 5 Table 2. Total mass from all special nuclear material sources, broken down by isotope ...... 7 Table 3. Highest keff values from each scenario ..................................................................... 8 Table 4. Radiation detection instruments ............................................................................. 37 List of Figures Figure 1. Radiation safety program organizational structure ............................................... 12 Figure 2. Fort Belvoir area map ........................................................................................... 19 Figure 3. .................................................................................... 19 Figure 4. .............................................................................. 20 Figure 5. .............................................................................. 21 Figure 6. ........................................................... 22 Figure 7. Pacific Technical Support Group compound map ................................................ 23 Figure 8. Pacific Technical Support Group facility layout .................................................. 24 Figure 9. Kirtland Air Force Base area map ........................................................................ 27 Figure 10. Technical Evaluation Assessment Monitoring Site area map ............................. 28 Figure 11. TEAMS source storage locker ............................................................................ 29

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 3 of 53 This application contains security related sensitive information. The Defense Threat Reduction Agency (DTRA) has accordingly marked (highlighted in yellow) pages, passages, and sections of this application to be redacted prior to public release. Figure or table headings marked in this format indicate the contents of the associated figure or table should also be redacted prior to public release.

Item 5.0 Radioactive Materials This application is submitted for a license to DTRAs Nuclear Regulatory Commission (NRC) license, 45-25551-01, that currently authorizes the possession of SNM, byproduct and source material will expire on August 31, 2021. Therefore, an additional byproduct license application will be submitted to NRC Region I following the submission of this application.

DTRA and the NRC are coordinating the timing of the issuances of these two new licenses to ensure a smooth transition to the new SNM license. The SNM will transfer to the new SNM license and the new byproduct license will not authorize the possession or use of SNM. This coordination and timing will ensure that DTRA will only be authorized the SNM mass as requested in this application. In the event that this coordination is frustrated, an amendment to the byproduct license will be submitted to accomplish this transfer of material.

5.1 Licensed Material Description DTRA requests authorization to possess a combination of uranium and plutonium Radiation Signature Training Devices (RSTD) as described below (detailed RSTD information is provided in Appendix A):

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 4 of 53 The RSTDs are designed to emulate the gamma ray flux and spectroscopic signature of contained within each object are listed below:

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 5 of 53 Depleted Uranium Cladded depleted uranium (DU)

DU material used as shielding or very weak source. This material is not packaged or configured as sealed material and is handled with precautions for heavy metal contamination.

This material is handled with precautions for heavy metal contamination. Any generated waste is disposed of via the Department of Defense (DoD) low level radioactive waste program.

5.2 Requested Possession and Use Limits DTRA proposes an overall SNM license possession limitation of Category (CAT) III quantities that will normally be distributed and stored between two permanent fixed facilities with smaller quantities used at our satellite facilities or at temporary locations as discussed in Item 9.0 Facilities and Equipment. The proposed limits are based on the sources necessary for mission requirements while maintaining an overall program keff < 1. The radioactive material, form, and maximum possession limits requested by this license application are specified in Table 1 below.

Table 1. Requested special nuclear material maximum amount limits Maximum amount that the

6. Radioactive material Chemical and/or physical form licensee may possess at any one time under this license A. Uranium-233 (U-233) A. Solid metal or oxide form A.

in sealed sources B. Uranium-235 (U-235) B. Solid metal or oxide form B.

in sealed sources C. C. Solid metal or oxide form C.

in sealed sources D. Plutonium (Pu) D. Solid metal or oxide form D.

in sealed sources or plated foils E. Uranium-238 (U-238) E. Solid metal E.

(Depleted Uranium)

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 6 of 53 grams = (grams contained U 235) + 2 (grams U 233 + grams plutonium) Equation 1 grams = (grams contained U 235) + (grams plutonium) + (grams U 233) Equation 2 5.3 Authorized Uses Line Items A to E: For research and development as defined in 10 CFR 70.4; calibration and verification of instrumentation; and teaching and training.

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 7 of 53 5.4 Nuclear Criticality Safety Assessment However, DTRA has conducted a Nuclear Criticality Safety (NCS) assessment which demonstrates that there is no credible criticality accident scenario that is possible given the types and total amount of SNM authorized by the license. The NCS assessment explored the criticality limits for three different scenarios with the entire mass of all the SNM on the license.

The scenarios are listed below:

1. Homogenized Source With and Without a Reflector

2. Nested Shells

3. Homogenous Slurry Each of these scenarios represent highly contrived and non-credible accident situations. The motivation for this was to explore the maximum achievable criticality level by putting together some of the worst-case accident configurations possible. All of these scenarios were run with and without . Table 2 shows the simplified (rounded up from actual values) masses used in the calculations with the side by side actual masses. The simplified masses were used for the calculations.

Table 2. Total mass from all special nuclear material sources, broken down by isotope Simplified ZAID* Mass (g)

Mass (g)

• ZAID is a nomenclature for isotopes, the last three numbers are the atomic mass (neutrons + protons) and the first numbers are the atomic number. Hydrogen: 1001, deuterium: 1002, oxygen-16: 8016, etc.

NRC Category III Special Nuclear Material License Application DTRA Item No. 5 Radioactive Materials 8 of 53 In the Scenario 1 configuration, all of the SNM material on the requested license was assumed to be mixed into a perfectly homogenous solid sphere. The highest keff was found for a bare sphere.

This maximized homogenized sphere was then evaluated while assumed to be surrounded by a variety of 1-m thick reflectors one at a time to include beryllium, graphite, water, and heavy water.

In the Scenario 2 configuration, all of the SNM material on the requested license was assumed to be formed into perfectly spherical nested shells in multiple orders. The highest keff was found for the bare nested shells. These maximized nested shells were then evaluated while assumed to be surrounded by a variety of 1-m thick reflectors one at a time to include beryllium, graphite, water, and heavy water.

In the Scenario 3 configuration, all of the SNM material on the requested license was assumed to be mixed with varying amounts of water in the form of a homogenous slurry until the highest keff was found.

Table 3 below provides the keff values for the three scenarios which assume various reflectors.

The values were determined using MCNP6 v2.0 with ENDF/B-VII.0 library. The full NCS assessment, tables, assumptions, and the MCNP input deck that was used, is provided as Appendix B. Nuclear Criticality Safety Assessment.

Table 3. Highest keff values from each scenario Scenario Configuration keff sigma In addition to the NCS results, DTRA contends that the facilities and equipment it maintains, the training and experience of its staff and the use of the procedures will adequately assure subcriticality for all the possible configurations of sealed SNM objects that would be allowed by the license.

5.5 License Expiration DTRA requests that the license expiration be set to the standard 10 year term. A renewal application will be submitted if continued possession and use is required beyond 10 years.

NRC Category III Special Nuclear Material License Application DTRA Item No. 6 Purpose(s) For Which Licensed Material Will Be Used 9 of 53 Item 6.0 Purpose(s) For Which Licensed Material Will Be Used The material being requested by this application is necessary for DTRA to execute its mission which includes the following:

3. Development, testing and evaluation of advanced radiation detection and identification technologies.

4. Demonstration events for users, guests and dignitaries.

6.1 General Description of Use DTRAs research, development, testing and evaluation (RDT&E) capabilities and training support a variety of US Government (USG) departments, agencies and government-sponsored enterprises.

RDT&E events vary based on the technology readiness level, i.e. the technologies maturation in the development cycle, and the purpose of the technology. A typical RDT&E developmental test use scenario might involve placing the SNM test object on a stand within a facility, an open area, or a static container. Systems under test will pass by or dwell at the RSTD in order to characterize the response. Once the detector and/or algorithm responses have been measured, the RSTD will be returned to secure storage. RSTDs will be used in this manner inside permanent and temporary controlled access areas (CAAs) on government owned or controlled facilities or lands. DTRA also performs operational testing to evaluate a systems performance in an operationally relevant environment, which might require the RSTD to be placed in a vehicle, shipping container or building to provide realistic shielding configurations. Due to the necessity for a variety and variability of background radiation signatures, these locations might include non-governmental lands to include public locations. The changes in road base and materials or building materials (wood, concrete or granite) will result in different background radiation signatures that are necessary to completely evaluate the capability of detection and isotope identification technologies. In these tests, for example, the scenario might be that the source is placed in a moving vehicle to pass by stationary or moving detection systems to evaluate system performance, or vice versa.

NRC Category III Special Nuclear Material License Application DTRA Item No. 6 Purpose(s) For Which Licensed Material Will Be Used 10 of 53 Training events vary in location and scope based on the customers location, mission and experience. These events can occur on or off of federal facilities or lands and, at times, in public locations to train responders in unique, realistic and relevant scenarios that cannot be accomplished only within the confines of governmental lands and facilities. Physical protection and physical security and minimization of public dose in accordance with as low as reasonably achievable (ALARA) will be addressed below.

DTRA facilities will occasionally host users, guests or dignitaries that require demonstrations of radiation detection equipment or the RSTDs. These demonstrations normally take an hour or so and the material is under the constant surveillance of an Authorized User to ensure physical security of the material and to ensure doses to members of the public are maintained within the limits of 10 CFR 20 and in accordance with ALARA principles.

All use scenarios shall be for the purposes of RDT&E and training, and shall be nondestructive.

With the exception of Pu-239 plated foils for instrument calibration and checks and depleted uranium, all SNM possessed under this license are sealed sources and will be maintained in that form. All activities will take place at ambient temperatures (-25°C to +65°C), meaning there will be no high-temperature operations.

NRC Category III Special Nuclear Material License Application DTRA Individual(s) Responsible For Radiation Safety Program and Their Item No. 7 Training and Experience 11 of 53 Item 7.0 Individual(s) Responsible For Radiation Safety Program and Their Training and Experience 7.1 Radiation Safety Officer Daniel N. Mannis Education:

Bachelors of Science in Applied Science and Technology, Nuclear Engineering, 2004 Thomas Edison State College Trenton, New Jersey Master of Science in Radiological Health Sciences, Health Physics, 2013 Colorado State University Fort Collins, Colorado Training Radiation Safety Officer Course, 2007, 157 hours0.00182 days <br />0.0436 hours <br />2.595899e-4 weeks <br />5.97385e-5 months <br /> Naval Undersea Medical Institute New London, Connecticut Radiation Safety Officer Course, 2010, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> Naval Sea Systems Command, Radiological Affairs Support Office Yorktown, Virginia Radiological Hazards Operator Course, 2015, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> US Army Medical Department Center and School/Idaho National Laboratory Idaho Falls, Idaho Security Clearance Radiation Safety Experience:

Defense Threat Reduction Agency 8725 John J. Kingman Road, Stop 6201, Fort Belvoir, VA 22554 Position: Radiation Safety Officer (RSO) (September 2019 - present)

- Maintain compliance for DTRAs byproduct and CAT III SNM license at DTRAs eight sites that use and/or store radioactive materials

NRC Category III Special Nuclear Material License Application DTRA Individual(s) Responsible For Radiation Safety Program and Their Item No. 7 Training and Experience 12 of 53 United States Navy Position: Radiation Health/Safety Officer (2007 - 2019)

- Various health physics program manager positions at DTRA, Norfolk Naval Shipyard Regional Maintenance Department and USS George H. W. Bush (CVN 77).

Position: Nuclear Electronics Technician/Nuclear Reactor Operator (1993 - 2007)

- Performed and supervised instrumentation and control maintenance on radiologically contaminated reactor systems.

With regards to radiation safety, the RSO work under the following organization structure Figure 1. Radiation safety program organizational structure An appointment letter from DTRAs Director, provides the delegation of authority to the Radiation Safety Officer to implement DTRAs radiation safety program. The RSOs appointment includes the authorization to stop any unsafe activities and to shut down operations as needed to maintain radiation safety and compliance. The RSO has direct access to the DTRA Director and the Directors executive management team as needed to address a lack of response from staff members.

NRC Category III Special Nuclear Material License Application DTRA Individual(s) Responsible For Radiation Safety Program and Their Item No. 7 Training and Experience 13 of 53 DTRA utilizes the Radiation Safety Committee (RSC) as the governing body for the licensed use of radioactive materials and other DTRA ionizing radiation sources to ensure the possession and use of radioactive materials is compliant with all regulations and license conditions. The RSCs composition of principal members include an appointed Chairperson; Directors representative -

Director, Environmental, Safety and Occupational Health (ESOH); RSO and senior representatives of the Defense Nuclear Weapons School, Nuclear Enterprise Contingency Operations Department, Research and Development (RD) Nuclear Technology Department , and RD Test Science and Technology Department. The RSC meets as needed, in addition to quarterly meetings, to review events from the previous quarter and upcoming events utilizing radioactive materials that are of sufficient scope to be presented to the entire RSC.

The RSCs Chairperson is appointed by the Director for an indefinite term on the basis of professional qualification. The RSC Chairperson is responsible for overseeing the RSOs implementation of the Radiation Safety Program and conducts annual audits to ensure the adequacy and effectiveness of the program. The level of oversight required will be evaluated during the annual audits and the RSC Chairperson will recommend additional staff as needed.

The RSO is supervised by the Director, ESOH, whose immediate supervisor is the DTRA Director. As such, the RSO is not supervised or directed by any directorate that owns or utilizes licensed materials. This ensures the independence of ESOH and the RSO from the actual users of the licensed radioactive materials. The RSO ensures appropriate written operating and emergency procedures are developed, maintained, and implemented to ensure all licensed material are used in accordance with licensed activities, control and accountability are maintained, and radiation doses received by occupational workers and members of the public are ALARA and compliant with regulatory limits. The review and approval of these procedures is accomplished through the DTRA Review and Approval Process (see Item 9.4).

The appointment letters of the RSC Chairperson and RSO are included in Appendix C.

7.2 Site-Radiation Safety Officers DTRA utilizes Site-Radiation Safety Officers (Site-RSOs) at each facility that utilizes radioactive material who serve as the primary authority for the on-site Radiation Safety Program.

Additionally, due to the remote and worldwide locations of our facilities and missions, each site typically has an Alternate Site-RSO who is trained to the same requirements to act in the absence of the Site-RSO.

The Site-RSO is responsible for managing all aspects of the sites Radiation Safety Program and follows the guidance of the DTRA RSO. The Site and Alternate Site-RSOs are appointed by the site leadership with concurrence of the DTRA RSO. The Site-RSO and Alternate Site-RSO have direct access the DTRA RSO and site leadership. Site-RSOs have training requirements in excess of those for an Authorized User that are included in Item 8.0 Training for Individuals Working In or Frequenting Restricted Areas.

NRC Category III Special Nuclear Material License Application DTRA Individual(s) Responsible For Radiation Safety Program and Their Item No. 7 Training and Experience 14 of 53 7.3 Authorized Users Authorized Users (AUs) will be appointed by the Site-RSO and approved by the DTRA RSO.

Their appointment is based on completion of the required training. All AUs must complete training prior to authorization for unsupervised access to any licensed material. This training covers the AUs security and handling responsibilities stipulated in this license application, DTRA Radiation Safety Program Manual, site instructions and standard operating procedures (SOPs). The details of the AU training are included in Item 8.0 Training for Individuals Working In or Frequenting Restricted Areas. AUs are permitted to work with all materials possessed under this license.

As part of the yearly audits discussed in Item 10.1 Audit Program, the RSC will annually review the AU list to ensure that the list is current and all listed AUs relevant training is up-to-date.

The annual review will also evaluate if each site has a sufficient number of AUs.

DTRA is a DoD Joint (Army, Navy, Air Force and Marine) Agency with normal military rotations of typically two to three years. As such, properly trained and approved AUs change on a routine basis. The Site-RSO, under the direction of the RSO, ensure that AUs are proficient at the duties and responsibilities of their assigned duties. AUs are trained and demonstrate appropriate handling and control of exempt and licensed byproduct sources before receiving additional training and qualifying as a SNM AU to include SNM security and procedural requirements. As a demonstration of these individuals trustworthiness and reliability, all are required to maintain active DoD secret security clearance. Prior to use or access to SNM, all SNM AUs will receive training as discussed in Item 8.0 Training for Individuals Working In or Frequenting Restricted Areas.

The AUs primary responsibilities are to ensure appropriate physical security and safe use of radioactive materials under their custody until returned to the designated secure storage location.

The AU is also responsible to ensure that procedures and engineering controls are used to keep occupational doses and doses to members of the public ALARA.

NRC Category III Special Nuclear Material License Application DTRA Item No. 8 Training For Individuals Working In or Frequenting Restricted Areas 15 of 53 Item 8.0 Training for Individuals Working In or Frequenting Restricted Areas DTRA commits to the development and implementation of a training program for personnel that complies with the requirements of 10 CFR 19 and 20. All personnel and visitors that enter restricted areas will receive training commensurate with the health risk to which they may be exposed or will be escorted by personnel with appropriate training. All employees will receive training commensurate with the duties of their work responsibilities. All employees will receive refresher training at least every three years that appropriately address changes in policies, procedures, requirements and facility safety requirements.

The training program, curriculum, and instructor will be reviewed and evaluated for accuracy, effectiveness and adequacy at least every three years.

Per 10 CFR 19.12, individuals whose assigned duties involve exposure to radiation and/or radioactive material, and in the course of their employment are likely to receive in a year an occupational dose of radiation greater than 100 mrem, receive the following trainings, as necessary to their job functions:

• General employee radiation training (with annual refresher) topics include:

- Correct handling of radioactive materials.

- Storage, transfer, or use of radiation or radioactive material as relevant to the individuals activities.

- Minimization of exposures to radiation or radioactive materials.

- Access and egress controls and escort procedures.

- Radiation safety principles, policies and procedures.

- Monitoring for internal and external exposures.

- Radiation exposure reports available to workers.

- Radiation detection and instrumentation.

- Contamination control procedures, including protective clothing and equipment.

- ALARA and exposure limits.

- Radiation hazards and health risks.

- Emergency response.

- Responsibility to report promptly any condition that may lead to, or cause, a violation of regulations and licenses or create unnecessary exposure.

• Job-specific DOT/IATA training for personnel involved with the transportation of SNM includes the following and require a biennial refresher:

- DoD required training for hazardous materials (HAZMAT) as specified in the Defense Transportation Regulation (DTR) Part II, Chapter 204, D.

o These courses meet the requirements specified in 10 CFR 71 and 49 CFR 172.704, Training Requirements, commensurate with the types and forms of materials.

NRC Category III Special Nuclear Material License Application DTRA Item No. 8 Training For Individuals Working In or Frequenting Restricted Areas 16 of 53 o All of these courses are authorized to certify shippers of HAZMAT or Class 7 HAZMAT as appropriate.

- Quality assurance program shipping and receiving procedures in accordance with DTRAs 10 CFR 70 Subpart H, Packaging Quality Assurance Program, (QAP) as directed by DTRA Instruction 4540.01.

All trainings are conducted by DoD certified instructors, private industry (such as NV-5), or, in-house training. All in-house training is provided by the RSO, Site-RSO or a qualified RSO designee who has appropriate training and experience. Trainings may be conducted by lecture, demonstrations, video, and/or self-study.

Only AUs are allowed unsupervised access to the licensed material. If an untrained individual (a visitor or DTRA employee/contractor that is not CAA trained) requires access to the CAA or material storage area, a CAA trained staff member is required to maintain a line-of-sight escort of the untrained individual or individuals. The CAA trained staff ensures material security and that all potential radiation doses are maintained well below the public dose limits and consistent with ALARA principles. Because of the relatively weak radiation levels and sealed form of the sources being requested, in addition to the limited access to them that the escort requirement provides, no additional training is required for administrative or facility staff.

Authorized Users Material Security training topics include:

• Procedures for removing and returning material to storage.

• Line of sight custodial responsibilities for working with material within the permanent CAA.

• Requirements for establishing a temporary CAA on a DoD facility, including notification requirements to the facility RSO and associated security force.

• Procedures and requirements for material control and security during training in a public location.

• Line of sight custodial responsibilities for working with material within a temporary CAA.

• Custodial responsibilities during emergency situations.

• Immediate notification of DTRA Joint Operations Command and DTRA and Site-RSOs when suspicious activity is observed or when an actual attempted theft or diversion occurs.

Additional general radiation training topics for AUs include:

• Radiation protection principles

• Characteristics of ionizing radiation

• Units of radiation dose and quantities

• Radiation detection instruments

NRC Category III Special Nuclear Material License Application DTRA Item No. 8 Training For Individuals Working In or Frequenting Restricted Areas 17 of 53

• Biological hazards of exposure to radiation

• Hands-on use of radioactive materials Site and Alternate Site-RSOs training requirements Site/Alternate Site-RSOs must complete the training requirements for AUs at their site and:

• RSO Training Course (Classroom - 40 Hours/One Time); and

• Department of Defense (DoD) Transportation of Hazardous Materials Training Course (Classroom - 80 hour9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> initial/40 hour refresher) and DTRA Radiation Safety &

Transportation (RST) Training (Classroom - 8 Hours/Biennially); or alternatively a DoD Transportation of Radioactive Materials Training Course (Classroom - Course length may vary). Not required to maintain current if not involved with transportation operations.

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 18 of 53 Item 9.0 Facilities and Equipment 9.1 Facilities DTRA established facilities at locations on military bases to meet the mission requirements based on location and capability.

NRC representatives have visited both sites for familiarity with the sites security and material storage configuration.

9.1.1 DTRA Nuclear Enterprise Contingency Operations 9.1.1.1. Nuclear Enterprise Contingency Operations, Headquarters

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 19 of 53 Figure 2. Fort Belvoir area map NECO HQ Compound 3.

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 20 of 53

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 21 of 53 Material Storage Onsite Use

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 22 of 53 9.1.1.2. Pacific Technical Support Group

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 23 of 53

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 24 of 53 Material Storage

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 25 of 53 Onsite Use 9.1.1.3 Temporary Locations These training scenarios are short, typically under 30 minutes, utilizing the sources above that have relatively weak radiological signatures, i.e. 2 mrem/hour distance is less than 2 feet. Dose rates, time, distance and shielding are always taken into consideration to ensure that members of the public dose limits are not exceeded and that both occupational and public doses are maintained ALARA. The materials may be used within a stationary temporary CAA; such as a parked and locked vehicle or placed in an open area, carried in a backpack by an AU or the backpack is placed at a stationary location. The material will be under the constant surveillance of two AUs when in-used at any temporary location.

Material Storage Material storage requirements are directed by written procedures or, if not covered by a written procedure, a radioactive work permit or equivalent will be developed. When the material must be left unattended during temporary location use, because it is impractical to return the material to a CAA designed for long-term storage of the material, access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over the material. This may be provided by placing the material in a limited access location for

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 26 of 53 which only security forces or AUs have access or the use of increased isolation may be provided by increasing the resistance of existing barriers (e.g. locking doors and windows, placing the material in a locked drawer or supply room). If no such location is available, the material may be protected by a motion alarm covering the area immediately surrounding the material. The material will be stored at a location on a secure military base or government facility, in a location that provides isolation of the material and access control. The location will be coordinated with facility security or police, RSO or Safety Officer at the storage location, NECO supervision and DTRA RSO. For atypical use, the RSC will be briefed on the details of the storage of the materials.

Material Use All material will be used within a CAA. The CAA establishment will be directed by a written procedures or, if not covered by approved procedures, a radioactive work permit or equivalent will be developed. The written procedures will require the following conditions:

• Clearly demarcated CAA consisting of:

o A physical boundary, i.e., walls, fences, ropes or other continuous enclosure or obstruction(s); or o Cleared areas monitored by watchmen qualified for CAA control; or o The use of standard operating procedures (SOPs) or task specific procedures will be used to establish the controls specific to the training mission location and material usage.

o A limited area that can be adequately monitored and controlled by a single watchmen, or as needed, the assignment of additional watchmen to provide constant surveillance and control of the material due to the size of the temporary CAA, number of accesses and visual obstacles.

The size, configuration, number of accesses, visual obstacles and number of personnel permitted into the temporary CAA will be sufficiently controlled to make procedures practical.

o For in-use at a public location:

Requires two dedicated AUs per source, who are qualified for CAA control, with the sole purpose of control and security of the material.

Used in public location only for the purpose of conducting training events.

The material will be within a container, e.g. backpack, either being worn or carried by one of the AUs and monitored by the second; or the container is placed on the floor, or other stationary location, under the constant surveillance of both AUs.

The AUs positioning will allow constant surveillance and control of the material.

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 27 of 53 UAs will be prepared to notify their team lead and/or appropriate responders in the event that there is a theft or attempted theft of the material.

They will maintain the material in a position for appropriate dose limits to members of the public.

• The watchmen are assigned to any temporary CAA to constantly monitor the site for potential intruders.

o Based on the complexity and size of the temporary CAA, the number of watchmen assigned will ensure that the entire boundary is monitored to positively control access to the CAA and material.

o The watchmen will serve as an intruder detection system to detect and report unauthorized penetrations or activities.

• Pre-operation coordination with local or base law enforcement to ensure response force is available and that the AUs have correct contact information.

9.1.2 Technical Evaluation Assessment Monitoring Site Figure 9. Kirtland Air Force Base area map

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 28 of 53 TEAMS

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 29 of 53 Material Storage Onsite Use

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 30 of 53 9.1.2.1 Temporary Locations These tests are at locations that provide for access control, isolation and are not in public locations. RC-EC will brief the RSO on the controls and security of the materials prior to authorization and based on the extent of the event, as proscribed by procedure, or radiation work permit or equivalent will be briefed to the RSC Chairperson or the RSC.

The following controls required for the establishment of a temporary CAA:

• Isolation is provided by:

o a boundary or barrier that clearly demarcates the temporary CAA utilizing use of permanent barriers, or office partitions, or cordons, or other devices or personnel to warn passersby of the restricted nature of the area, or a combination of the above to ensure 360o isolation.

• Access is controlled by:

o limiting the CAA to a single access that is supervised by an AU, if the CAA is sufficiently small and configured such that a single watchperson can maintain positive control of personnel or vehicular access, or o for more complex configurations, each access or area where unauthorized personnel may access the CAA will be supervised by a dedicated watchperson.

• Pre-operation coordination with local or base law enforcement to ensure response force is available and that the AUs have correct contact information.

Material Storage Material storage requirements are directed by written procedures or, if not covered by approved procedures, a radioactive work permit or equivalent will be developed. During temporary location use, when the material must be left unattended, because it is impractical to return the material to a CAA designed for long-term storage of the material, access control and improved isolation for the temporary CAA may be provided to substitute for the discontinued personal supervision over the material. This may be provided by placing the material in a limited access

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 31 of 53 location for which only security forces or AUs have access or the use of increased isolation may be provided by increasing the resistance of existing barriers (e.g. locking doors and windows, placing the material in a locked drawer or supply room). If no such location is available, the material may be protected by a motion alarm covering the area immediately surrounding the material. The material will be stored on a secure military base or government facility, in a location that provides isolation of the material and access control. The location will be coordinated with facility security or police, RSO or Safety Officer at the storage location, NECO supervision and DTRA RSO.

Material Use All material will be used within a temporary or permanent CAA or within the buildings of the facility that provides isolation and access control as discussed above. When the material is used in the confines of the building, a temporary CAA is established specifically for the planned event.

Combustible items or chemicals that pose a fire hazard are not permitted within the established CAA.

9.2 Material Storage Due to the number of distinct locations, the description of the onsite storage is addressed above in the description of each facility.

Storage of combustible materials, hazardous chemicals or any process that may contribute to a fire hazard, is not permitted in the source storage room. The CAAs meet state and local fire codes including annual inspections and testing of fire suppression systems, externally-monitored alarms, and backup generators, if needed. The inspections ensure that the building is appropriately supplied with fire extinguishers, emergency lighting, and fire alarm pull stations.

The inspection schedule is compliant with State, Territory, US Federal and/or territory laws.

DTRA facilities are compliant with National Fire Protection Association (NFPA) 45, "Standard for Fire Projection in Laboratory Facilities" and NFPA 801, "Standard for Fire Protection for Facilities Handling Radioactive Materials" and the applicable building code regulations. The facilities are wired and grounded in accordance with the applicable edition(s) of the NFPA 70, "National Electrical Code."

Each host base has a dedicated on-site fire department that operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Because the materials to be possessed under this license are all sealed sources and are additionally protected

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 32 of 53 by storage inside fireproof safes, further radiation safety training is not required for first responders.

9.3 Onsite Use Onsite use is described in the individual facility discussion above. The permanent and temporary CAAs will satisfy the definitions in 10 CFR Part 73 and Part II of Regulatory Guide 5.59.

9.4 Review and Approval Process DTRA Risk Management Process The DTRA Risk Management Process is intended to identify and assess risks and monitor and/or mitigate them in proportion to the degree of their consequences and their likelihood of occurrence. It is a process used to review and approve all new work and technology development at DTRA, including the use of radioactive materials.

Radiation Safety Program The Site-RSOs are responsible to ensure the local operations are compliant with regulations, Agency requirements, and procedures to ensure safe operations. The Site-RSO is responsible to receive authorization for all acquisitions of radioactive materials and operations utilizing licensed radioactive materials. The RSO provides oversight of the day-to-day operations of the DTRA RSP by reviewing and approving routine actions and uses of radioactive materials.

Procedures or guidance developed by the RSO are forwarded to the RSC Chairperson and forwarded to the RSC Principal Members for concurrence.

TEAMS The Site-RSO, program manager, project manager and test director share the responsibilities regarding work processes and evaluation of risk with respect to the testing processes. The initiation of the process begins with the program manager who proposes a new technology that requires evaluation and/or testing. The program manager and project manager must coordinate with the test director to evaluate facility requirements, source requirements, testing capability and schedule availability. Once the program manager, project manager and test director agree on the testing requirements, the test director will develop a test plan that is submitted to the Site-RSO for evaluation of radiological requirements, proposed controls and manpower requirements for proper source control and security. Then based upon the scenarios and consequences, the test director and Site-RSO must develop a comprehensive Radiation Safety Plan or, for repetitive testing actions, utilize an existing preapproved SOP that governs the controls and security measures necessary for the proposed test event. The details of the source security requirements are addressed in the Item 9.4 Physical Protection and Physical Security.

The Radiation Safety Plan or SOP, as applicable, will address the methodology for mitigating the described risks, which can include added training and qualifications, procedures, administrative controls, management review and oversight, etc. As needed, the test director consults with

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 33 of 53 related subject matter experts to develop a package concerning risk scenarios, risk management plans, procedures, facility upgrade proposals and any mitigating measures.

Nuclear Enterprise Contingency Operations Every training operation is briefed to a minimum audience of the Operations Officer and Operations Senior Enlisted Leader. For more complex or infrequent training operations it is briefed to the departments senior leadership and all key staff to include a focused evaluation of all relevant risks. The brief contains specific discussions about the use of radiological sources to include shipment, storage, security, use, dose and public exposure. Once all concerns are satisfactorily addressed, the senior leadership will give approval for the event.

Independent review/validation - For both groups, once a package is complete, briefed and approved by the site leadership, it is submitted to the Agency Radiation Safety Office for an independent review and then forwarded to the RSC Chairperson for evaluation and distribution to the RSC members as needed based on the complexity and frequency of the event. Based on complexity and risk of source control, security, and transportation, and potential for exposure to members of the public, the RSC can perform a virtual review or require a face-to-face brief of the event plan by the Site-RSO or lead AU prior to approval or disapproval.

9.5 Physical Protection and Physical Security The security posture and physical security features described above make up the main elements of the physical protection used to secure SNM possessed by DTRA. They meet the 10 CFR 73.67(f) fixed site requirements.

All DTRA employees, military and civilian, and contractors are required to possess and maintain a minimum of a DoD Secret security clearance, equivalent to a Department of Energy (DOE)/NRC L clearance as a requirement of employment. This security clearance requires fingerprinting and an FBI background investigation. An employer of any visitor must pass their Secret or above security clearance through the Joint Personnel Adjudications System (JPAS) prior to the visit. All personnel or visitors without a Secret or above clearance require continuous escort by a DTRA employee to access DTRAs facilities.

Written security procedures are maintained that call for the host base on-site security force or, if appropriate or needed, local law enforcement to respond to indications of unauthorized penetration or removal of SNM in order to facilitate its prompt recovery. The combination of the physical security features employed and the written security procedures meet the general performance objectives specified in 10 CFR 73.67(a).

DTRA response procedures are developed to deal with threats of theft and thefts of licensed material. Examples of the types of incidents that have been addressed in the response procedures are:

NRC Category III Special Nuclear Material License Application DTRA Item No. 9 Facilities and Equipment 34 of 53

1. possible situations that could lead to theft of SNM (i.e., civil disturbance, emergency events, etc.);

2. entry of an unauthorized person into a CAA or transport vehicle;

3. discovery that the security system has failed, been degraded, or breached; and

4. discovery that SNM is missing or unaccounted for.

Response procedures are maintained on file and will be made available for inspection as long as licensed materials are possessed and for three years following the transfer or disposal of all material authorized by this license. They are enumerated as controlled documents and all superseded documents are retained for a minimum of three years from the date of any changes.

The DTRA security response procedures ensure:

1. an appropriate response is initiated based on any identified safeguards events;

2. the responsibilities of DTRA personnel, the security organization and management involved are well defined;

3. the NRC Operations Center is notified, per 10 CFR 73.71(a)(2), (3), (4), and (5) requirements, by telephone within one hour of discovery, followed by a written report within 60 days, of all applicable safeguards events described in paragraph I of Appendix G to 10 CFR 73, Reportable Safeguards Events;

4. applicable safeguard events described in paragraph II of Appendix G to 10 CFR 73, Reportable Safeguards Events, are recorded in the DTRA Safeguards Event Log within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery.

All notification reports and safeguards event logs will be maintained on file for a minimum of three years from the date of the report or logged event.

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 35 of 53 Item 10.0 Radiation Safety Program DTRAs management is committed to maintain occupational doses and doses to members of the public ALARA. The RSO and RSC members responsibilities include at least an annual review of occupational doses to analyze for trends and abnormalities.

10.1 Audit Program DTRA has established a Radiation Safety Committee for the oversight and support of the Radiation Safety Program. This committee is charged by the DTRA Director with the auditing responsibilities for DTRA NRC license 45-25551-01, which are performed annually. Auditing of this license will be added to the scope of the committees annual review.

The annual audit of this license is based on the suggested audit checklist found in Appendix E, Suggested Audit Checklist, NUREG-1556, Vol. 17, Rev. 1., Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018. It is a comprehensive assessment designed to ensure compliance to all applicable NRC regulations and the terms and conditions of the license (e.g.,

leak tests, inventories, use limited to trained, approved users, etc.), the content and implementation of the radiation safety program to achieve occupational doses and doses to members of the public that are ALARA in accordance with 10 CFR 20.1101, and required records are maintained.

The DTRA RSO:

1. conducts annual audits;

2. ensures that the results of audits, identification of deficiencies, and recommendations for change are documented (and maintained for at least 3 years) and provided to the RSC Chairperson for review;

3. ensures that prompt action is taken to correct deficiencies; and

4. ensures that the audit results and corrective actions are communicated to all personnel who use licensed material.

The RSC Chairperson briefs the RSC on the results of the annual audits.

10.2 Radiation Surveys and Monitoring The sealed nature and quantity of the licensed material being requested by this application; in addition to written procedures to control the use, surveys and monitoring; significantly reduces the possibility of radiological contamination, airborne-radioactivity or internal exposure of DTRA staff or members of the public. The list below provides the surveys and radiological assessments DTRA will conduct as needed to ensure regulatory compliance and to maintain all doses from potential exposure to licensed material ALARA. DTRA maintains appropriate and calibrated equipment, sampling supplies and sufficiently trained staff to conduct surveys and

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 36 of 53 radiological assessments necessary to protect health and minimize danger to life or property related to the possession and use of licensed material.

DTRA will use equipment that meet the radiation monitoring instrument specifications published in Appendix F, Model Radiation Survey Instrument Calibration Program, NUREG-1556, Vol.

17, Rev. 1., Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018.

Instrument calibrations are performed by the instrument manufacturer or a person specifically authorized by NRC or an Agreement State at least annually. DTRA reserves the right to upgrade its survey instruments as necessary.

Some of the surveys and radiological assessments necessary to protect health and minimize danger to life or property related to the possession and use of licensed material are:

• Package surveys

- conducted in accordance with DTRAs 10 CFR 70 Subpart H Packaging QAP

- see available instruments in Table 4 below

• Contamination surveys

- see available instruments in Table 4 below

• Sealed source leak tests

- see available instruments in Table 4 below

- Leak test supplies are available at each location. See below, Item 10.7 Leak Tests.

• Bioassay measurements

- highly unlikely given the sealed form of requested licensed material

- DoD bioassay kits for offsite analysis are available, if needed

• Unrestricted area dose rate measurements

- see available instruments in Table 4 below

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 37 of 53 Table 4 provides examples of the radiation detection/measurement instruments that are maintained, calibrated and available to conduct the surveys and radiological assessments mentioned above:

Table 4. Radiation detection instruments Make Model Type Use Beta and x-ray / gamma Thermo FH-40G Dose rate ambient radiation Scientific measurements Thermo Alpha, beta and gamma FHZ742 ZnS scintillation detector Scientific contamination monitoring Thermo Alpha, beta and gamma FHZ732GM Pancake GM detector Scientific contamination monitoring Thermo Wide range gamma FHZ612 Dual range GM detector Scientific measurements Thermo Rem ball neutron dose rate FHT762H10 Neutron dose monitoring Scientific meter Beta and gamma Fluke 481 GM detector contamination monitoring Nuclear AMD-300AB GM Detector Beta and gamma survey Research Nuclear Alpha and beta AP-100A Scintillation detector Research contamination monitoring Nuclear Rem ball neutron dose rate NP100 Neutron dose monitoring Research meter 3030 Counting system with ZnS Alpha and beta swipe Ludlum w/ 43-10-1 sample counting head sample counting DTRA utilizes a National Voluntary Laboratory Accreditation Program (NVLAP) accredited dosimetry vendor to provide Thermoluminescent Dosimeter (TLD) whole body and extremity monitors. The TLDs measure dose from photonic (x and gamma ray), beta, fast neutron and thermal neutron radiation sources and have a lower limit of detection of 3 mrem photon and 5 mrem neutron.

DTRA requires personnel monitoring devices for all individuals working with radiation sources if the individual is likely to exceed 10% of their allowable annual dose limit in 10 CFR 20.

Monitoring of additional individuals for particular environments is at the discretion of the RSO, who oversees the dosimetry program. Posted dosimetry is utilized to accumulate integrated dose in work spaces adjacent to source storage areas.

The NVLAP accredited dosimetry vendor processes all issued dosimeters and provides DTRA with reports that document the measured deep and shallow equivalent doses (DDE and SDE,

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 38 of 53 respectively). DTRAs dosimetry monitors workers for neutron, gamma and shallow dose. An annual dosimetry report is provided to anyone monitored during a calendar year.

DTRA does not currently utilize secondary dosimeters in addition to the primary whole body and extremity monitors.

DTRA reserves the right to change dosimetry and processors as needed to support mission requirements. DTRA will ensure that any changes are consistent with the current measurement capabilities and processing or calibration standards.

10.3 Material Receipt and Accountability DTRAs material receipt and accountability program utilizes procedures that ensure the following:

• Appropriate coordination between NRC licensee or DOE facilities is accomplished in compliance with the 10 CFR 70.42 SNM transfer requirements and to verify that the total on DTRAs SNM inventory is maintained below license and Category III possession limits.

• All Nuclear Material Transaction Reports (NRC/DOE Form 741), Material Balance Reports (NRC/DOE Form 742) and Physical Inventory Listings (NRC/DOE Form 742C) are filed and retained in accordance with 10 CFR 74 requirements.

• Physical inventories of all SNM authorized by this license are conducted at intervals not to exceed 6 months.

• Licensed material not in storage is maintained under constant surveillance and control.

• Records of receipt, transfer and disposal of licensed material are maintained.

10.4 Occupational Dose DTRA requires personnel monitoring devices for all individuals working with radiation sources if the individual is likely to exceed 10% of their allowable annual dose limit in 10 CFR Part 20, in accordance with the criteria in the section entitled Radiation Safety Program - Occupational Dose in NUREG-1556, Vol. 17, Rev. 1., Consolidated Guidance about Materials Licenses:

Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018.

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 39 of 53 10.5 Public Dose Per DTRAs radiation safety program, public dose is monitored and documented to ensure that all doses are maintained ALARA and within the regulatory limits.

Individuals that are not documented as having received general employee radiation safety training (with current annual refresher training) and any applicable job specific training, as described in Item 8 of this application, are considered to be members of the general public with regards to any potential doses received from the use and storage of materials possessed under this license. Therefore, by this definition, untrained DTRA staff members and visitors are considered to be members of the public.

Due to the relatively weak radiation levels and sealed form of the sources being requested, in addition to the nature of the security controls that limit access to the sources; maintaining public doses well below the 10 CFR 20.1301 limits is easily achieved. Demonstration and documentation of compliance with the public dose limits per 10 CFR 20.1302 is achieved through methods and guidance specified in Appendix H, Public Dose, NUREG-1556, Vol. 17, Rev. 1., Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018.

10.6 Operating and Emergency Procedures DTRA is committed to the development and utilization of written procedures for normal operations and emergency procedures for safe and secure use of materials and emergencies have been developed or will be developed before receipt of licensed material. These procedures will address applicable radiation safety requirements found in 10 CFR 19, 20, 70, and 71 and any other applicable regulations.

Procedures may be revised only if:

1) The changes are reviewed and approved by the RSO in writing;

2) The affected staff members are provided training in the revised procedures prior to implementation;

3) The changes are in compliance with NRC regulations and the license conditions; and

4) The changes do not degrade the effectiveness of the program.

When written and approved procedures are not sufficient, a radiation work permit or equivalent will be utilized. The radiation work permit will define the authorized activities, level of supervision required, period of validity, and expiration and termination times.

10.7 Leak Tests Leak tests will be performed on licensed materials at an interval not to exceed 6 months, consistent with applicable NRC branch technical positions issued in April 1993, License Condition for Leak-Testing Sealed Uranium Sources or License Condition for Leak-Testing Sealed Plutonium Sources. Demonstration and documentation of compliance with the

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 40 of 53 conditions for uranium and plutonium sealed sources is achieved through methods and guidance specified in Appendix J, Model Leak Test Program, NUREG-1556, Vol. 17, Rev. 1.,

Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018 and consistent with Regulatory Guide 8.24, Health Physics Surveys During Enriched U-235 Processing and Fuel Fabrication.

10.8 Transportation DTRA commits to the establishment of a program that will assure shipment and receipt of radioactive materials consistent with regulations in 10 CFR 20, 10 CFR 71, 49 CFR, and others, as applicable.

Any transport of licensed material on public roads when not in-use (see will be in accordance with the DTRA QAP to ensure compliance with the 10 CFR 71 General License requirements.

DOT 7A Type A packaging and certified fissile packaging are maintained for this purpose. The DTRA Instruction 4540.01, DTRA Quality Assurance for Shipping Special Nuclear Material (QAP SNM), and all associated implementing documents used in support of the DTRA QAP will be made available during any NRC license inspections.

The DTRA QAP implementing documents have been developed based on the recommendations in Part II of Regulatory Guide 5.59 to meet 10 CFR 73(g) in-transit requirements. They ensure the following:

Advance Notification [73.67(g)(1)(i)]

Prior to each shipment of material, the receiver will be notified of the impending shipment and provided with the following types of information:

1. mode of transport (e.g., truck, plane, train, or ship);

2. estimated time of arrival;

3. location where material is to be transferred to the receiver;

4. name of carrier; and

5. transport identification (e.g., truck, train, or flight number; ship name).

Receiver Confirmation [73.67(g)(1)(ii)]

Prior to each shipment of material, an acknowledgment from the receiver of the following is documented:

1. the receiver is ready to accept the shipment;

2. the mode of transport;

3. the planned time and place of the delivery;

4. the receivers obligation to report, upon receipt of the shipment, if the containers integrity has been compromised and if the material is missing.

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 41 of 53

5. If applicable, a written agreement from the receiver in which the receiver accepts either full responsibility or shared responsibility for the in-transit physical protection.

6. If the receiver accepts full responsibility for the in-transit physical protection and the shipment is lost or unaccounted for after the estimated arrival time, the receiver has an obligation to:

a. immediately conduct a trace investigation;

b. within one hour; notify the NRC Operations Center of the loss and, if applicable, the recovery or the accounting for the lost shipment; and

c. report the incident to DTRA.

Tamper Indication [73.67(g)(1)(iii)]

Each shipping container is sealed with a mechanism or system that helps the receiver detect any tampering with the container that may have occurred during the shipment. The seals are chosen so that they have the characteristics recommended in Regulatory Guide 5.15 (Security Seals for the Protection and Control of Special Nuclear Material).

Inspection [73.67(g)(1)(iv)]

Prior to each shipment, the integrity of the shipping containers security seal and the shipping container itself are verified and documented.

Responsibility for In-Transit Physical Protection [73.67(g)(1)(v)]

The DTRA QAP transportation procedures ensure that arrangements are made for the in-transit physical protection of the material in accordance with the requirements of 10 CFR 73.67(g)(3), unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.

Responsibility for In-Transit Physical Protection [73.67(g)(2)(iii)]

Prior to authorizing a shipment to DTRA, arrangements are made for the in-transit physical protection of the material in accordance with the requirements of 10 CFR 73.67(g)(3), unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.

Receiver Confirmation and Notification [73.67(g)(2)(i)&(ii)]. Upon receipt of material, DTRA shall:

1. Verify and document the integrity of the container and its seal to determine if it has been compromised en route and whether any material has been removed;

2. Notify the shipper of the receipt and that the integrity of the seal is in accordance with the prearrangements made with the shipper. If the containers integrity has been compromised and the material is missing, immediate trace and recovery procedures are initiated.

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 42 of 53

3. Immediately notify the shipper if the shipment is lost or unaccounted for after the estimated arrival time and the shipper agreed in writing to arrange the in-transit physical protection, otherwise, in accordance with the DTRA written security response procedures, DTRA shall:

a. immediately conducts a trace investigation;

b. notify the NRC Operations Center of the loss within one hour and, if applicable, the recovery or the accounting for the lost shipment; and

c. report the incident to the shipper.

4. Sends a completed copy of Form NRC-741, Nuclear Material Transaction Report, within 10 days of the receipt to the shipper as required by 10 CFR 74.15.

Response Procedures [73.67(g)(3)(i)]

The DTRA security response procedures deal with threats of theft or diversion of material while in-transit. They ensure the physical protection of material for shipment from this license and for any shipments made from another licensee where DTRA has agreed in writing to take the responsibility for protecting the material while in transit.

Current response procedures are maintained on file and will be made available for inspection as long as licensed materials are possessed and for three years following the transfer or disposal of all material authorized by this license. They are enumerated as controlled documents and all superseded documents are retained for a minimum of 3 years from the date of any changes.

Delivery Notification [73.67(g)(3)(ii)&(iii)]

Per the DTRA QAP implementing documents, arrangements are made and documented that require the receiver of any shipment of material to immediately notify DTRA of the arrival of the shipment at its destination, or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination. The implementing documents also stipulate that an immediate trace investigation is initiated if the shipment is lost or unaccounted for and that the required 10 CFR 73.71(b) notification is made to the of the NRC Operations Center within one hour of the discovery and within one hour after recovery of or accounting for such lost shipment.

10.9 Minimization of Contamination Per item 10.7 above, leak tests will be performed on each sealed source at intervals not to exceed 6 months. In preparation for the very unlikely event that contamination is found above background levels during any routine survey, DTRA provides training to all users on mitigating and containing contamination. Consistent with the ALARA principle, decontamination to background levels is the goal. If it is not possible to get to background levels, DTRA will ensure that contamination is maintained below the levels specified Table I-2, Appendix I, Radiation

NRC Category III Special Nuclear Material License Application DTRA Item No. 10 Radiation Safety Program 43 of 53 Safety Survey Topics, NUREG-1556, Vol. 17, Rev. 1., Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Special Nuclear Material of Less Than Critical Mass Licenses, dated July 2018.

With the exception of the uncladded DU, all of the material requested by this license is contained is sealed sources. Therefore, there is no expectation of contamination from the sealed sources.

The uncladded DU is alloyed with 3/4 wt% Ti. This alloy is relatively resistant to corrosion.

Written procedures, personal protective equipment and trained personnel will handle this material to minimize the potential for contamination. A survey will be performed to evaluate the potential spread each time the material is handled.

DTRA will ensure that all licensed material shall be disposed of in accordance with the requirements of 10 CFR Part 20 Subpart K.

10.10 Other Radiation Safety Program Components

1. Ventilation and Respiratory Protection Programs Since all requested sources are sealed and the potential for internal contamination is very low, DTRA will not establish a ventilation and respiratory protection program at this time.

2. Record Keeping DTRA will maintain records of the radiation safety program (including program provisions, audits, and reviews of the program content and implementation), radiation survey results (bioassays, external exposure data from monitored individuals, internal intakes of radioactive material), results of corrective action program referrals, radioactive work packages, and planned special exposures.

3. Notification of Incidents DTRA will establish a program to report to the NRC, within the timeframe stated in regulations incidents specified in 10 CFR 20.2202, Notification of Incidents, and safety significant events specified in 10 CFR 70.74, Additional reporting requirements.

NRC Category III Special Nuclear Material License Application DTRA Item No. 11 Waste Management 44 of 53 Item 11.0 Waste Management Since the application requests sealed sources, with the exception of the oxidation of depleted uranium (DU), no radioactive contamination is anticipated to be generated.

Oxidized depleted uranium DTRA has two types of depleted uranium, cladded and uncladded. We do not anticipate radioactive contaminated waste generation from the cladded DU. The uncladded DU is alloyed with 3/4 wt% Ti. This alloy is relatively resistant to corrosion. Any waste generated from the unclad sources will be disposed of as low-level radioactive contaminated trash.

DTRA will ensure that all licensed material shall be disposed of in accordance with the requirements of 10 CFR Part 20 Subpart K.

NRC Category III Special Nuclear Material License Application DTRA Item No. 12 License Fees 45 of 53 Item 12.0 License Fees Program Code: 22155 Critical Mass Material - Other Than Fuel Cycle 10 CFR 170.31 License Fee Category: 1F: Full cost

NRC Category III Special Nuclear Material License Application DTRA Appendix A Detailed Source Information 46 of 53 Appendix A. Detailed Source Information A.1. U-233 RSTD: Uranium-233 Attachments

1. IAEA COCA Special Form RAM Certificate

A.1. Attachment 1 East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 U.S. Department IAEA CERTIFICATE OF COMPETENT AUTHORITY of Transportation SPECIAL FORM RADIOACTIVE MATERIALS Pipeline and CERTIFICATE USA/0826/S-96, REVISION 0 Hazardous Materials Safety Administration This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency1 and the United States of America2 for the transport of radioactive material.

1. Source Identification - ORNL U ZipCan.

2. Source Description - An equilateral triangle shaped single encapsulation made of a titanium inner container and a stainless steel outer encapsulation that is tungsten inert gas seal welded.

Approximate exterior dimensions are 57 mm (2.24 in.) on each edge and 11 mm (0.43 in.) thick. Construction shall be in accordance with attached ORNL Drawing No. N3E020995A576, Revision A.

3. Radioactive Contents - No more than 2.66E-1 TBq (7.17 Ci) of Uranium-232, 1.15E-3 TBq (3.11E-2 Ci) of Uranium-233, 7.36E-5 TBq (1.99E-3 Ci) of Uranium-234, 2.56E-7 TBq (6.91E-6 Ci) of Uranium-235, 7.68E-7 TBq (2.07E-5 Ci)of Uranium-236, and 3.84E-8 TBq (1.04E-6 Ci)of Uranium-238. The radioactive content is uranium oxide embedded in zirconium felt. The sum of the mass fractions must be no more than 3.2 grams (U element weight).

4. Management System Activities - Records of Management System activities required by Paragraph 306 of the IAEA regulations shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the requirements of Subpart H of 10 CFR 71.

1 "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, No. SSR-6" published by the International Atomic Energy Agency (IAEA),

Vienna, Austria.

2 Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

A.1. Attachment 1

(- 2 -)

CERTIFICATE USA/0826/S-96, REVISION 0

5. Expiration Date - This certificate expires on May 31, 2024.

This certificate is issued in accordance with paragraph(s) 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the April 23, 2019 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

June 10, 2019 William Schoonover (DATE)

Associate Administrator for Hazardous Materials Safety Revision 0 - Original issue.

A.1. Attachment 1 PARTS LIST ITEM QTY DESCRIPTION NOTE MATERIAL / VENDOR MFG. PN / DET. DWG #

1 ORNL U ZIPCAN BASE 2 SST304L N3E020995A576 SHT 2 2 ORNL U ZIPCAN TOP 2 SST304L N3E020995A576 SHT 2 3 TITANIUM CAPSULE ASSEMBLY N3E020995A575 GENERAL NOTES:

1. [XX] ALTERNATE UNITS IN INCHES.

2. ITEMS 1 AND 2 ARE TO BE DELIVERED TO ORNL WITH THE CMTR HEAT# CLEARLY LABELED ON THE PART BAG OR SIMILAR CONTAINER.

WELD NOTES:

1. ALL SST WELDS PER ORNL WPS-GT8B-A(PP)

APPENDIX 2.

2. < W- > INDICATES WELD IDENTIFICATION NUMBER.

NO WELD SEQUENCE IMPLIED

3. WELD INSPECTION:

"V" - VISUAL PER ORNL NDE-21 SHORT FORM.

4. LEAK TEST TO 1.3 X 10 4 STD. ATM -CC/S@ 25°C PER FHRD-NDE-70.

QUALITY VERIFICATION MECHANICAL AND STRUCTURAL QVCLAUSE DOCUMENTS REQUIRED PROC.NO. PART NO.

303 MAT'L MIU. TEST REPORT (CERT) 1.2 325 MAT'L S13.L.ER CERT 328 SPECIAL MAT'L INSP. REPORT 205 MFG. INSP. AND TEST PLAN 312 FIELD INSP. &TEST PLAN 314 MATERIAL MARKING 321 WELD AND BRAZE INSP. REPORT WELD NOTES 1-4 INDICATED 322 HEAT TREAT REPR.(W/CHART) 310 LEAK TEST REPORT 315 CLEANING CERT C "VII 318 319 DEVIATION REQUEST NONCONFORMANCE REPORT SBMSSA SBMSSA WELD NOTES 1-4 323 DIMENSIONAL REPORT

<W-1> 330 FUNCTIONAL TEST REPORT 333 IDENTIFICATlON & CONTROL OF SPECIAL PROCUREMENT REQUIRED NNF0-10 ORNL U ZIPCAN 100 SYMBOL DOCUMENTATION FORABOVE i/ INDICATES APPLICABLE TO ALL PARTS OR ITEMS.

SCALE: 1.5X W. GEORGE ASKEW 8/24/2017

<W-1> LAST l:l[lll[ll'r'~~l!l~lill~IIIJ~ rmll!

DEFAULT STANDARDS UNLESS OTHERWISE SPECIFIED ~ NONREACTOR NUCLEAR FACILITIES DIVISION UT- BATTELLE OAK RIDGE NATIONAL LABORATORY TOLERANCES:

XX DECIMALS +/- 0.254 Operated by UT-Battelle for the Department of Energy under U.S.

XXX DECIMALS +/- 0.127 Government contract DE-AC05-00OR22725* Oak Ridge, Tennessee ANGLES +/-0°-30' BREAK SHARP EDGES 1/64 MAX. TITLE:

FINISH = 125 RMS JRG JAJ SDM 3/13/2019 ORNL U ZIPCAN JRG JAJ SDM 8/24/2017 THIS DRAWING CREATED IN ACCORDANCE WITH SIZE DWG NO. REV DSNR CHECKER WELD REVIEW DATE ANSI Y14.SM-1994 N3E020995A576 APPROVALS ALL DIMENSIONS ARE IN MM A SCALE: 1.5X SHEET 1 OF 2 A

A.1. Attachment 1 1.524 [.060 inJ-----11--

MIN TOOL RADIUS o.162~ffl MIN

[030~:ggg;n] TOOL RADIUS

0. 762 [.030 in]

A SECTION A-A SECTION B-B B

0 ORNL U ZIPCAN BASE SCALE: 1X ASSY DWG: N3E020995A576 SHT 1 0 ORNL U ZIPCAN TOP SCALE: 1X ASSY DWG: N3E020995A576 SHT MATERIAL: SST 304L MATERIAL: SST 304L GENERAL NOTES:

DEFAULT STANDARDS

1. [XX] ALTERNATE UNITS IN INCHES. UNLESS OTHERWISE SPECIFIED ~ NONREACTOR NUCLEAR FACILITIES DIVISION

2. ITEMS 1 AND 2 ARE TO BE DELIVERED TO ORNL TOLERANCES: UT-BATTELLE OAK RIDGE NATIONAL LABORATORY WITH THE CMTR HEAT# CLEARLY LABELED ON THE PART BAG OR SIMILAR CONTAINER. XX DECIMALS +/- 0.254 Operated by UT-Battelle for the Department of Energy under U.S.

XXX DECIMALS +/- 0.127 Government contract DE-AC05-00OR22725* Oak Ridge, Tennessee ANGLES +/- o* -.30' BREAK SHARP EDGES 1/64 MAX. TITLE:

FINISH = 125 RMS JRG JAJ SDM 3/13/2019 ORNL U ZIPCAN JRG JAJ SDM 8/24/2017 THIS DRAWING CREATED IN ACCORDANCE WITH DSNR CHECKER WELD REVIEW DATE ANSI Y14.SM-1994 SIZE DWG NO.

N3E020995A576 REV APPROVALS ALL DIMENSIONS ARE IN MM A SCALE: 1X SHEET 2 OF 2 A

A.1. Attachment 1 East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0826/S-96 ORIGINAL REGISTRANT(S):

Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC, 20585 USA 1

NRC Category III Special Nuclear Material License Application DTRA Appendix A Detailed Source Information 47 of 53 A.2. RSTD- uranium-235 Attachments

1. Data Sheet NMLDS-001-RR6A-DTRA1

2. Data Sheet NMLDS-001-RF2M-DTRA2

3. IAEA COCA Special Form RAM Certificate

4. Sphere Assembly Drawing

A.2. Attachment 1 Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RR6A December 13, 2011

1. Source Identification: Model Number NMLDS-001 Serial Number 9A37-E4-RR6A

2. Distributor: United States Department of Energy National Nuclear Security Administration Y-12 National Security Complex

3. Lot Identification No: 4.Sample Lot Identification No: 5. Lab Sample Identification No:

3C326HRH17 3C32KYRH17 Y110250053 3C326HRN00 3C32KYRN00 Y110250050

6. Assay Date: October 11, 2010

7. Analytical Results: Mass % - Mass % -

Isotope RH17 RN00 U-234 U-235 U-236 U-238

8. Uranium Mass:

9. U-235 Isotope Mass:

10. Uranium Activity:

11. Date of Manufacture October 2010

12. Source Description - The sealed source has a 4.90 inch diameter. It consists of a depleted uranium (DU) core, aluminum spacers, The device is encapsulated by two welded Ti shells with a thickness of .090. The following engineering drawings document design and construction of the assembly and are attached:

babcock & wilcox y-12, llc., a Babcock & Wilcox company 1 of 2

A.2. Attachment 1 Data Sheet for Radiological Signature Training Device August 3, 2011 (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RR6A

13. Quality Assurance -Design, manufacture, and certification testing of assemblies was performed in compliance with DOE O 414.1D, 10 CFR 830.120, and ANSI/HPS N43.6-2007. The three phases of the project were conducted by Oak Ridge National Laboratory (ORNL), Y-12 National Security Complex, and ORNL Transportation Technologies Group (TTG), respectively.

14. Leak Testing and Freedom From Contamination - Under direction of ORNL, two prototype RSTDs were subjected to tests to demonstrate compliance with 49 CFR 173.469 Tests for Special Form Class 7 (Radioactive) Materials. Leak Tests, Heat Tests, and Percussion Tests were performed on the two units. In both cases, the units met the requirements for Special Form Certification.

15. Planned Use - The sealed source will be used as a passive interrogation source for spectroscopy portals that detect special nuclear material.

Users of the sealed source will be authorized by the United States (U.S.) Defense Threat Reduction Agency (DTRA). These users of the sealed source will use it in accordance with the safety, quality, security and other requirements of the users regulatory authorization basis (i.e. U.S. Nuclear Regulatory Commission (NRC) license or state authorization for special nuclear materials). Some tests (use) may be conducted at U. S. Department of Energy (DOE) facilities, and will be performed in accordance with the authorization basis of the DOE facilities.

16. Conditions of Use -The SNM is totally encapsulated and sealed within the titanium casing of the item and since the radiation from the encapsulated radiological material does not pose a significant exposure threat to users, the sealed source can be contact handled using normal care not to expose the disk to forces which could compromise the casing.

During loading and handling:

a. The device shall not be subjected to conditions or an environment which exceeds its ANSI N43.6-2007 classification testing requirements

b. The device shall not be exposed to an extremely corrosive (acidic or caustic) environment which could degrade or compromise the titanium casing.

2 of 2

A.2. Attachment 2 Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RF2M December 13, 2011

1. Source Identification: Model Number NMLDS-001 Serial Number 9A37-E4-RF2M

2. Distributor: United States Department of Energy National Nuclear Security Administration Y-12 National Security Complex

3. Lot Identification No: 4.Sample Lot Identification No: 5. Lab Sample Identification No:

3C326HRD95 3C32KYRD95 Y102790054 3C326HRDFL 3C32KYRDFL Y102790055

6. Assay Date: October 11, 2010

7. Analytical Results: Mass % - Mass % -

Isotope RD95 RDFL U-234 U-235 U-236 U-238

8. Uranium Mass:

9. U-235 Isotope Mass:

10. Uranium Activity:

11. Date of Manufacture October 2010

12. Source Description - The sealed source has a 4.90 inch diameter. It consists of a depleted uranium (DU) core, aluminum spacers,

. The device is encapsulated by two welded Ti shells with a thickness of .090. The following engineering drawings document design and construction of the assembly and are attached:

babcock & wilcox y-12, llc., a Babcock & Wilcox company 1 of 2

A.2. Attachment 2 Data Sheet for Radiological Signature Training Device December 13, 2011 (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RF2M

13. Quality Assurance -Design, manufacture, and certification testing of assemblies was performed in compliance with DOE O 414.1D, 10 CFR 830.120, and ANSI/HPS N43.6-2007. The three phases of the project were conducted by Oak Ridge National Laboratory (ORNL), Y-12 National Security Complex, and ORNL Transportation Technologies Group (TTG), respectively.

14. Leak Testing and Freedom From Contamination - Under direction of ORNL, two prototype RSTDs were subjected to tests to demonstrate compliance with 49 CFR 173.469 Tests for Special Form Class 7 (Radioactive) Materials. Leak Tests, Heat Tests, and Percussion Tests were performed on the two units. In both cases, the units met the requirements for Special Form Certification.

15. Planned Use - The sealed source will be used as a passive interrogation source for spectroscopy portals that detect special nuclear material.

Users of the sealed source will be authorized by the United States (U.S.) Defense Threat Reduction Agency (DTRA). These users of the sealed source will use it in accordance with the safety, quality, security and other requirements of the users regulatory authorization basis (i.e. U.S. Nuclear Regulatory Commission (NRC) license or state authorization for special nuclear materials). Some tests (use) may be conducted at U. S. Department of Energy (DOE) facilities, and will be performed in accordance with the authorization basis of the DOE facilities.

16. Conditions of Use -The SNM is totally encapsulated and sealed within the titanium casing of the item and since the radiation from the encapsulated radiological material does not pose a significant exposure threat to users, the sealed source can be contact handled using normal care not to expose the disk to forces which could compromise the casing.

During loading and handling:

a. The device shall not be subjected to conditions or an environment which exceeds its ANSI N43.6-2007 classification testing requirements

b. The device shall not be exposed to an extremely corrosive (acidic or caustic) environment which could degrade or compromise the titanium casing.

2 of 2

A.2. Attachment 3 East Building, PHH-23 U.S. Department 1200 New Jersey Avenue Southeast of Transportation IAEA CERTIFICATE OF COMPETENT AUTHORITY Washington, D.C. 20590 Pipeline and SPECIAL FORM RADIOACTIVE MATERIALS Hazardous Materials CERTIFICATE USA/0782/S-96, REVISION 2 Safety Administration This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency¹ and the United States of America² for the transport of radioactive material.

1. Source Identification - U.S. Department of Energy Highly Enriched Uranium (HEU) Test Object.

2. Source Description - Spherical single encapsulation made of CP3 Titanium. Approximate outer dimension is 124.58 mm (4.9 in.) in diameter. Wall thickness is approximately 2.29 mm (0.09 in.).

Construction shall be in accordance with attached UT-Battelle Drawing No. 20101202_002, Rev. 0.

3. Radioactive Contents - Solid uranium metal with maximum radionuclide activities of:

Uranium-233 2.063 MBq (0.056 mCi);

Uranium-234 137.262 MBq (3.710 mCi);

Uranium-235 4.127 MBq (0.112 mCi);

Uranium-236 1.172 MBq (0.032 mCi); and Uranium-238 3.376 MBq (0.091 mCi).

4. Quality Assurance - Records of Quality Assurance activities required by Paragraph 310 of the IAEA regulations¹ shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the applicable requirements of Subpart H of 10 CFR 71.

5. Expiration Date - This certificate expires on August 31, 2020.

¹ "Regulations for the Safe Transport of Radioactive Material, 1996 Edition (Revised), No. TS-R-1 (ST-1, Revised)," published by the International Atomic Energy Agency(IAEA), Vienna, Austria.

² Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

A.2. Attachment 3

(- 2 -)

CERTIFICATE USA/0782/S-96, REVISION 2 This certificate is issued in accordance with paragraph 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the August 12, 2015 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

Aug 24 2015 Dr. Magdy El-Sibaie (DATE)

Associate Administrator for Hazardous Materials Safety Revision 2 - Issued to extend the expiration date.

A.2. Attachment 3 U.S. Department East Building, PHH-23 1200 New Jersey Avenue SE of Transportation Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0782/S-96, Revision 2 ORIGINAL REGISTRANT(S):

Dr. James M. Shuler Manager, Packaging Certification Program Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC 20585

NRC Category III Special Nuclear Material License Application DTRA Appendix A Detailed Source Information 48 of 53 A.3. RSTD- uranium-235 Attachments

1. RSTD Images

A.3. Attachment 1 Equivalent RSTD Figure 1. Placing a large plastic triangle assembly into the icosahedron Figure 2. Partially assembled sphere Managed by UT-Battelle for the US Department of Energy 1

A.3. Attachment 1 Equivalent RSTD Figure 3. 75% assembled sphere Figure 4. Core placement in center of sphere Managed by UT-Battelle for the US Department of Energy 2

A.3. Attachment 1 Equivalent RSTD Figure 5. 75% assembled sphere with core Figure 6. Fully Assembled Sphere Managed by UT-Battelle for the US Department of Energy 3

NRC Category III Special Nuclear Material License Application DTRA Appendix A Detailed Source Information 49 of 53 A.4. Pu RSTD: Plutonium-239 Attachments

1. See A.5. Attachment 1. The inner container of the Pu RSTD ZiPCan is the same canister as the RSTD ZiPCan.

2. Pu RSTD ZiPCan Secondary Encapsulation Assembly Drawing

3. Pu RSTD ZipCan CoCA Special Form RAM Certificate

4. Pu RSTD Cylindrical Core Assembly Drawing

5. Pu RSTD Cylindrical Core CoCA Special Form RAM Certificate UNCLASSIFIED//DOD CONTROLLED NUCLEAR INFORMATION//FOR OFFICIAL USE ONLY

A.4. Attachment 2 A.4. Attachment 3 East Building, PHH-23 U.S. Department 1200 New Jersey Avenue Southeast of Transportation IAEA CERTIFICATE OF COMPETENT AUTHORITY Washington, D.C. 20590 Pipeline and SPECIAL FORM RADIOACTIVE MATERIALS Hazardous Materials CERTIFICATE USA/0817/S-96, REVISION 1 Safety Administration This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency¹ and the United States of America² for the transport of radioactive material.

1. Source Identification - ORNL Pu ZipCan.

2. Source Description - An equilateral triangle shaped single encapsulation made of a titanium inner container and a stainless steel outer encapsulation that is tungsten inert gas seal welded.

Approximate exterior dimensions are 57 mm (2.24 in.) on each edge and 11 mm (0.43 in.) thick. Construction shall be in accordance with attached ORNL Drawing No. SK-NMP-2015121-01, Rev. 0.

3. Radioactive Contents - No more than 12.7 GBq (343 mCi) of Plutonium-238, 4.62 GBq (125 mCi)of Plutonium-239, 16.9 GBq (456 mCi) of Plutonium-240, 76.4 GBq (2.06 Ci) of Plutonium-241, 302 MBq (8.16 mCi) of Plutonium-242, and 13.5 kBq (364 nCi) of Plutonium-244. The Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, and Pu-244 are in solid oxide form and are embedded in zirconium felt. The sum of the mass fractions must be no more than 2.01 grams.

4. Quality Assurance - Records of Quality Assurance activities required by Paragraph 310 of the IAEA regulations¹ shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the applicable requirements of Subpart H of 10 CFR 71.

5. Expiration Date - This certificate expires on August 31, 2021. On April 30, 2017, this certificate supersedes all previous revisions of USA/0817/S-96.

¹ "Regulations for the Safe Transport of Radioactive Material, 1996 Edition (Revised), No. TS-R-1 (ST-1, Revised)," published by the International Atomic Energy Agency(IAEA), Vienna, Austria.

² Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

A.4. Attachment 3

(- 2 -)

CERTIFICATE USA/0817/S-96, REVISION 1 This certificate is issued in accordance with paragraph 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the February 01, 2017 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

Feb 17 2017 William Schoonover (DATE)

Acting Associate Administrator for Hazardous Materials Safety Revision 1 - Issued to revise the authorized radioactive contents.

A.4. Attachment 3 ORNL Pu ZipCan Special Form Application and Test Summary Data Report Revision 1 DOE Docket #16120000 Page 6 of 6

A.4. Attachment 3 U.S. Department East Building, PHH-23 1200 New Jersey Avenue SE of Transportation Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0817/S-96, Revision 1 ORIGINAL REGISTRANT(S):

Dr. James M. Shuler Manager, Packaging Certification Program Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC 20585

A.4. Attachment 5 East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 U.S. Department IAEA CERTIFICATE OF COMPETENT AUTHORITY of Transportation SPECIAL FORM RADIOACTIVE MATERIALS Pipeline and CERTIFICATE USA/0823/S-96, REVISION 1 Hazardous Materials Safety Administration This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency1 and the United States of America2 for the transport of radioactive material.

1. Source Identification - ORNL Pu Cylindrical Source.

2. Source Description - Cylindrical single encapsulation made of Type 304L stainless steel and tungsten inert gas seal welded. An inner cylindrical assembly made of Type 304L stainless steel with a press fit lid contains the radioactive contents. Approximate exterior dimensions are 22.4 mm (0.88 in.) in diameter and 58.4 mm (2.3 in.)

in length. Construction shall be in accordance with attached UT-Battelle Drawing No. N3E020995A537, Rev. A, Sheet 1 of 3.

3. Radioactive Contents - No more than 101 GBq (2.73 Ci) of Plutonium-238, 35.7 GBq (0.965 Ci) of Plutonium-239, 131 GBq (3.54 Ci) of Plutonium-240, 608 GBq (16.4 Ci) of Plutonium-241, 2.33 GBq (63 mCi) of Plutonium-242, and 10.4 MBq (0.281 mCi) of Plutonium-244. The source contents may be a mix of the plutonium isotopes, but shall not exceed 15.54 grams of total plutonium. The Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, and Pu-244 are in solid oxide form.

4. Management System Activities - Records of Management System activities required by Paragraph 306 of the IAEA regulations shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the requirements of Subpart H of 10 CFR 71.

1 "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, No. SSR-6" published by the International Atomic Energy Agency (IAEA),

Vienna, Austria.

2 Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

A.4. Attachment 5

(- 2 -)

CERTIFICATE USA/0823/S-96, REVISION 1

5. Expiration Date - This certificate expires on October 30, 2022.

USA/0823/S-96 Revision 0 may be used until December 31, 2017.

This certificate is issued in accordance with paragraph(s) 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the October 24, 2017 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

November 03, 2017 William Schoonover (DATE)

Associate Administrator for Hazardous Materials Safety Revision 1 - Issued to revise the authorized radioactive contents.

A.4. Attachment 5 A.4. Attachment 5 East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0823/S-96 ORIGINAL REGISTRANT(S):

Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC, 20585 USA 1

NRC Category III Special Nuclear Material License Application DTRA Appendix A Detailed Source Information 50 of 53 A.5. ZiPCans Attachments

1. RSTD ZiPCan Assembly Drawing. The inner container of the U-233, Pu RSTD ZiPCan is the same canister as the RSTD ZiPCan.

2. See A.4 Attachment 2. ZiPCan Secondary Encapsulation Assembly Drawing. The secondary encapsulation of the U-233 and Np RSTD ZiPCan is the same as Pu RSTD

3. ORNL justification of ZiPCans as a sealed source.

A.5. Attachment 1 ITEM NO. DESCRIPTION QTY.

1 TRIANGLE BODY-HIGH CORROSION 1 RESISTANCE GRADE 2 TITANIUM 2 TRIANGLE LID- CORROSION RESISTANT 1 GRADE 2 TITANIUM 3 TITANIUM SCREW 4-40 X .25 LENGTH 4 4 STAINLESS STEEL FILL TUBE AR TITANIUM TRIANGLE ASSEMBLY TITANIUM TRIANGLE ASSEMBLY WELD DIAGRAM N

.013

.022 4X 1/16 N SECTION N-N TITANIUM TRIANGLE ASSEMBLY ISOMETRIC VIEW 3 1 2

NON REACTOR NUCLEAR FACILITIES DIVISION DRAWN BY UT-BATTELLE OAK RIDGE NATIONAL LABORATORY DEFAULT STANDARDS DESIGNER Oak Ridge, Tennessee UNLESS OTHERWISE SPECIFIED T CHECKER OPERATED BY UT-BATTELLE FOR THE DEPARTMENT OF ENERGY UNDER U.S.

O FRACTIONS +/- 1/64 GOVERNMENT CONTRACT DE-AC05-00OR22725 OAK RIDGE, TENNESSEE L XX DECIMALS +/- 0.01 DESIGN REVIEW E

R XXX DECIMALS +/- 0.005 A TASK LEADER ANGLES +/- 0°-30' N

TITANIUM TRIANGLE C BREAK SHARP EDGES 1/64 MAX. ENGINEERING SUPPORT DEPT HEAD E FINISH = 125 RMS S

NO REPRESENTATION OR WARRANTY, EXPRESSED OR IMPLIED, IS REQUESTOR MADE AS TO THE ACCURACY, COMPLETENESS OR USEFULNESS OF THE INFORMATION OR STATEMENTS CONTAINED IN THESE DRAWINGS, OR ALL DIMENSIONS ARE IN INCHES FACILITY MANAGER/DESIGNEE THAT THE USE OR DISCLOSURE OF ANY INFORMATION, APPARATUS, TYPE SPECIAL REVIEW METHOD OR PROCESS DISCLOSED IN THESE DRAWINGS MAY NOT INFRINGE PRIVATE RIGHTS OF OTHERS. NO LIABILITY IS ASSUMED WHENEVER A MANUFACTURER'S NAME OR CATALOG NUMBER IS SPECIAL REVIEW WITH RESPECT TO THE USE OF, OR FOR DAMAGES RESULTING FROM INDICATED, AN APPROVED EQUAL MAY BE SUBSTITUTED NUMBER OR LETTER FOR 1 48 49 50 PLANT BLDG FL SHEET OF CLASS THIS DRAWING THIS DOCUMENT CONTROLLED BY 7920 01 THE USE OF, ANY INFORMATION, APPARATUS, METHOD OR PROCESS ELEVATION, SECTION, OR DETAIL 3 M E U 01 3 U SPECIAL REVIEW DISCLOSED IN THESE DRAWINGS. DRAWINGS MADE AVAILABLE FOR PRODUCED ON SOLIDWORKS ORNL RADIOCHEMICAL PROCESS & FACILITY DESIGN GROUP THIS DRAWING CREATED IN ACCORDANCE WITH SK-NMP-20141118-01 3 INFORMATION TO BIDDER ARE NOT TO BE USED FOR OTHER SPECIAL REVIEW SCALE ID REV REV DESCRIPTION ANSI Y14.5M-1982 (R1988) 4:1 BY DSNR CHK DR TL ESDH REQ FAC DATE SR1 SR2 SR3 SR4 QAS PURPOSES, AND ARE TO BE RETURNED UPON REQUEST OF THE FORWARDING CONTRACTOR.

DO NOT REVISE MANUALLY DRAWING ON WHICH ELEVATION, SECTION, OR DETAIL IS TAKEN.

DRAWING ON WHICH ELEVATION, SECTION, OR DETAIL IS SHOWN.

REVISION OR ISSUE PURPOSE REVISION APPROVALS DRAWING APPROVALS DATE FILE NAME:

A.5. Attachment 1 ITEM 1- TRIANGLE BODY TOP VIEW SCALE 4:1 G +.002

.060 - .000 60.00° TYP 2.051 TYP H

.093 TYP

.120 1.277

+.000

.059 - .005 1/16 RAD. ALL AROUND ALL .030 INTERNAL CAVITIES

.655

.344 R.063 TYP

.250

.080 TYP G .021 R.063

.538 .538 SECTION G-G 60.00° TYP

.667 R.063 TYP

.199 TYP

.30 TYP

.3486

.697 TYP NON REACTOR NUCLEAR FACILITIES DIVISION DRAWN BY UT-BATTELLE OAK RIDGE NATIONAL LABORATORY DEFAULT STANDARDS Oak Ridge, Tennessee DETAIL H DESIGNER UNLESS OTHERWISE SPECIFIED OPERATED BY UT-BATTELLE FOR THE DEPARTMENT OF ENERGY UNDER U.S.

SCALE 8 : 1 T CHECKER O FRACTIONS +/- 1/64 GOVERNMENT CONTRACT DE-AC05-00OR22725 OAK RIDGE, TENNESSEE L XX DECIMALS +/- 0.01 DESIGN REVIEW E

R XXX DECIMALS +/- 0.005 A TASK LEADER ANGLES +/- 0°-30' N

TITANIUM TRIANGLE C BREAK SHARP EDGES 1/64 MAX. ENGINEERING SUPPORT DEPT HEAD E FINISH = 125 RMS S

NO REPRESENTATION OR WARRANTY, EXPRESSED OR IMPLIED, IS REQUESTOR MADE AS TO THE ACCURACY, COMPLETENESS OR USEFULNESS OF THE INFORMATION OR STATEMENTS CONTAINED IN THESE DRAWINGS, OR ALL DIMENSIONS ARE IN INCHES FACILITY MANAGER/DESIGNEE THAT THE USE OR DISCLOSURE OF ANY INFORMATION, APPARATUS, TYPE SPECIAL REVIEW METHOD OR PROCESS DISCLOSED IN THESE DRAWINGS MAY NOT INFRINGE PRIVATE RIGHTS OF OTHERS. NO LIABILITY IS ASSUMED WHENEVER A MANUFACTURER'S NAME OR CATALOG NUMBER IS SPECIAL REVIEW WITH RESPECT TO THE USE OF, OR FOR DAMAGES RESULTING FROM INDICATED, AN APPROVED EQUAL MAY BE SUBSTITUTED NUMBER OR LETTER FOR 1 48 49 50 PLANT BLDG FL SHEET OF CLASS 7920 01 THE USE OF, ANY INFORMATION, APPARATUS, METHOD OR PROCESS THIS DRAWING THIS DOCUMENT CONTROLLED BY ELEVATION, SECTION, OR DETAIL 3 M E U 2 3 U SPECIAL REVIEW DISCLOSED IN THESE DRAWINGS. DRAWINGS MADE AVAILABLE FOR PRODUCED ON SOLIDWORKS ORNL RADIOCHEMICAL PROCESS & FACILITY DESIGN GROUP THIS DRAWING CREATED IN ACCORDANCE WITH SK-NMP-20141118-01 3 INFORMATION TO BIDDER ARE NOT TO BE USED FOR OTHER SPECIAL REVIEW SCALE ID REV REV DESCRIPTION BY DSNR CHK DR TL ESDH REQ FAC DATE SR1 SR2 SR3 SR4 QAS ANSI Y14.5M-1982 (R1988)

DO NOT REVISE MANUALLY 4:1 PURPOSES, AND ARE TO BE RETURNED UPON REQUEST OF THE DRAWING ON WHICH ELEVATION, DRAWING ON WHICH ELEVATION, FORWARDING CONTRACTOR. SECTION, OR DETAIL IS TAKEN. SECTION, OR DETAIL IS SHOWN.

REVISION OR ISSUE PURPOSE REVISION APPROVALS DRAWING APPROVALS DATE FILE NAME:

A.5. Attachment 1 ITEM 2-TITANIUM TRIANGLE LID ITEM 4-STAINLESS STEEL FILL TUBE TOP VIEW TOP VIEW SCALE 4:1 SCALE 4:1

.125 .062 THRU

.122 X 90° 4X .089 THRU ALL 4-40 UNC THRU ALL

.235 X 82°, NEAR SIDE

.250

+.000 1.843 - .002 TYP P .03 X 45° CHAMFER 1.159 .375 60.00° TYP

.062

.112

.01 RAD MAX

.635

.100 P 4-40 THREAD

.313 SECTION P-P

.488 .488 SHOULDERED OUT ON THE FACE OF THE TRIANGLE FILL TUBE INSERTED R R SECTION R-R NON REACTOR NUCLEAR FACILITIES DIVISION DRAWN BY UT-BATTELLE OAK RIDGE NATIONAL LABORATORY DEFAULT STANDARDS DESIGNER Oak Ridge, Tennessee UNLESS OTHERWISE SPECIFIED T CHECKER OPERATED BY UT-BATTELLE FOR THE DEPARTMENT OF ENERGY UNDER U.S.

O FRACTIONS +/- 1/64 GOVERNMENT CONTRACT DE-AC05-00OR22725 OAK RIDGE, TENNESSEE L XX DECIMALS +/- 0.01 DESIGN REVIEW E

R XXX DECIMALS +/- 0.005 A TASK LEADER ANGLES +/- 0°-30' N

TITANIUM TRIANGLE C BREAK SHARP EDGES 1/64 MAX. ENGINEERING SUPPORT DEPT HEAD E FINISH = 125 RMS S

NO REPRESENTATION OR WARRANTY, EXPRESSED OR IMPLIED, IS REQUESTOR MADE AS TO THE ACCURACY, COMPLETENESS OR USEFULNESS OF THE INFORMATION OR STATEMENTS CONTAINED IN THESE DRAWINGS, OR ALL DIMENSIONS ARE IN INCHES FACILITY MANAGER/DESIGNEE THAT THE USE OR DISCLOSURE OF ANY INFORMATION, APPARATUS, TYPE SPECIAL REVIEW METHOD OR PROCESS DISCLOSED IN THESE DRAWINGS MAY NOT INFRINGE PRIVATE RIGHTS OF OTHERS. NO LIABILITY IS ASSUMED WHENEVER A MANUFACTURER'S NAME OR CATALOG NUMBER IS SPECIAL REVIEW WITH RESPECT TO THE USE OF, OR FOR DAMAGES RESULTING FROM INDICATED, AN APPROVED EQUAL MAY BE SUBSTITUTED NUMBER OR LETTER FOR 1 48 49 50 PLANT BLDG FL SHEET OF CLASS 7920 01 THE USE OF, ANY INFORMATION, APPARATUS, METHOD OR PROCESS THIS DRAWING THIS DOCUMENT CONTROLLED BY ELEVATION, SECTION, OR DETAIL 3 M E U 3 3 U SPECIAL REVIEW DISCLOSED IN THESE DRAWINGS. DRAWINGS MADE AVAILABLE FOR PRODUCED ON SOLIDWORKS ORNL INFORMATION TO BIDDER ARE NOT TO BE USED FOR OTHER RADIOCHEMICAL PROCESS & FACILITY DESIGN GROUP THIS DRAWING CREATED IN ACCORDANCE WITH ANSI Y14.5M-1982 (R1988)

SPECIAL REVIEW SCALE ID REV SK-NMP-2014118-01 REV DESCRIPTION BY DSNR CHK DR TL ESDH REQ FAC DATE SR1 SR2 SR3 SR4 QAS PURPOSES, AND ARE TO BE RETURNED UPON REQUEST OF THE FORWARDING CONTRACTOR.

DO NOT REVISE MANUALLY DRAWING ON WHICH ELEVATION, SECTION, OR DETAIL IS TAKEN.

DRAWING ON WHICH ELEVATION, SECTION, OR DETAIL IS SHOWN.

REVISION OR ISSUE PURPOSE REVISION APPROVALS DRAWING APPROVALS DATE 3 FILE NAME:

A.5. Attachment 3 Gomez W. Wright PO Box 2008 Oak Ridge, TN 37831-6011 (865) 576-5843 l wrightgw@ornl.gov March 6, 2019 To Whom It May Concern:

The purpose of this document is to provide both a regulatory framework and other qualifying information on the design, construction, and test qualifications of a Radiological Signature Training Devices (RSTDs) as sealed radioactive sources.

NRC 10 CFR § 30.4 Definitions . States the following for what qualifies as a sealed source.

A. Sealed source means any by product material that is encased in a capsule designed to prevent leakage or escape of the byproduct material; NRC 10 CFR § 70.4 Definitions.

B. Sealed source means any special nuclear material that is encased in a capsule designed to prevent leakage or escape of the special nuclear material.

The RSTD Tiles meets the NRC 10 CFR 70 definition of a sealed source. The RSTD Tile is composed of special nuclear material in the form of a )

oxide/zirconium cermet encased in a Titanium welded capsule designed to prevent leakage or escape of the special nuclear material contained within.

DOE 10 CFR §835.2 Definitions states the following for what qualifies as a Sealed Radioactive Source:

1. Sealed radioactive source means a radioactive source manufactured, obtained, or retained for the purpose of utilizing the emitted radiation.

2. The sealed radioactive source consists of a known or estimated quantity of radioactive material contained within a sealed capsule, sealed between layer(s) of non-radioactive material, or firmly fixed to a non-radioactive surface by electroplating or other means intended to prevent leakage or escape of the radioactive material.

3. Sealed radioactive sources do not include reactor fuel elements, nuclear explosive devices, and radioisotope thermoelectric generators.

RSTD Tiles meet the DOE 10 CFR 835 Occupation Radiation Protection definition of a sealed radioactive source; wherein the:

RSTD Tile is designed to contain a known quantity of radioactive material that itself is comprised of - Special Nuclear Material of a known uranium isotopic distribution in the form of a solid uranium oxide/ zirconium cermet for the expressed purposes of detecting the emission of a certain photon flux (photons/ cm2) of characteristic gamma radiation signatures .

The RSTD Tile known quantity of radioactive material in the form of Oxide/ Zirconium cermet is contained within a sealed capsule non-radioactive containment vessel that is composed Page 1 of 3

A.5. Attachment 3 Gomez W. Wright PO Box 2008 Oak Ridge, TN 37831-6011 (865) 576-5843 l wrightgw@ornl.gov and constructed of welded Titanium metal that is intended to prevent the leakage/ escaped of the contained Oxide/ Zirconium radioactive material.

The RSTD Tile welded Titanium containment vessel has been tested and proven to survive an International Standards Organization (ISO) 2919:1999(E) Class 4 Impact Test that was qualified to have passed by both Before and Post Helium Leak Test assessment. The Helium Leak Test assessment was implemented in accordance with American National Standards Institute (ANSI)

N14.5-2014 American National Standard for Radioactive Materials- Leakage Tests on Packages for Shipment, Table A.1, Test Description A.5.5, Evacuated Envelope (with Helium back pressurization) under applicable ORNL Quality Assurance Program Description (QAPD) requirements that demonstrated the leaktightness of 10-4 torr-1/s (3.1 x 10-4 atm-cm3/s) based on air at 25°C (77°F) and one atmosphere differential for solid radioactive content contained within a capsule resistant to corrosion by water per DOT 49 CFR 173.469(a)(4)(i) requirements. Additionally, a Dry Wipe Test is conducted by an ORNL trained and qualified Radiation Control Technician with NIST calibrated instrumentation demonstrated to detect <20 dpm (<9.0 pCi) removable alpha and < 200 dpm (<90 pCi) removable beta contamination.

The Before Helium Leak Test was implemented to demonstrated that the Ti-welded fabricated containment vessel was entirely intact without any detectable leaks via the Helium Leak Test employed. The Before Dry Wipe Test was employed to demonstrate that there was no evidence of removable radioactive contamination that would indicate that the RSTD Tile outer welded Titanium encapsulation could be leaking radioactive material past the limits of DOE 10 CFR 835.1202 0.005 µCi (5 nCi or 185 Bq or 11,000 dpm) that would necessitate putting the sealed radioactive source Out-of-Service until RSTD Tile detected removable contamination could be linked to a leaking source or cross-removable contamination event.

Both the Before and Post ISO 9978 Class 4 Impact Test - Helium Leak Test and Dry Wipe Test assessment demonstrated that the Ti-welded containment vessel encapsulation integrity of the RSTD Tile remained intact, which provides evidence that the radioactive material content inside the RSTD Tiles is entirely encompassed by a non-leaking Ti-welded encapsulation capable of withstanding/ surviving an ISO 9978 Class 4 Impact Test.

Thus, the RSTD Tile is indeed a sealed radioactive source by DOE 10 CFR 835 requirements.

However, because the RSTD Tile do contain Special Nuclear Material, RSTDs Tiles cannot be registered with the National Sealed Radioactive Source Device Registry.

1. The NRC regulations that established the National Sealed Source Device Registry (NSSDR),

10 CFR §32.210, and the regulation 10 CFR §30.32, that requires Specific Licensees to use sealed sources that have SSDR certificates or at least the SSDR information contained within is Only applicable to sealed sources containing Byproduct Material that are available for commercial use.

2. The regulatory requirement that establishes the National Sealed Source Device Registry, 10 CFR 32.210 is only applicable to Specific Licensees that manufacture Byproduct Material containing sealed sources for commercial distribution.

3. HEU RSTDs are not manufactured nor available for commercial distribution and meet the requirements of 10 CFR 32.210(g) as a Custom Source that does not have to be evaluated by and have an SSDR with the NRC to be used by a Specific Licensee.

Page 2 of 3

A.5. Attachment 3 Gomez W. Wright PO Box 2008 Oak Ridge, TN 37831-6011 (865) 576-5843 l wrightgw@ornl.gov

4. RSTDs are custom sources built to the unique specifications of a particular U.S. Government recipient and contain no more than 7.4 GBq (200 mCi) of any other radionuclide (besides 20Ci of Tritium).

5. RSTDs do not contain Byproduct Material. RSTDs contain Special Nuclear Material (SNM).

6. There are no applicable regulatory compliance responsibility requirements in

• NRC 10 CFR 40 Domestic Licensing of Source Material, and

• NRC 10 CFR 70 Domestic Licensing of Special Nuclear Material (SNM)

For the registration of sealed sources that contain either Source or SNM in the NSSDR or a complementary registry.

In conclusion, RSTDs are inapplicable to SSDR because of their SNM content; wherein, the NRC has not established a regulatory requirement for Source or SNM bearing sealed sources to have SSD certificate evaluated, approved, and registered within the NSSDR by the NRC or an Agreement State equivalent.

If there are any further concerns or additional information required in regard to the design and construction of RSTD Tiles as sealed radioactive source containing solid SNM encapsulated in a welded Titanium metal containment vessel, please do not hesitate to contact me at your earliest convenience and I will make every effort to respond to your request for further information in as timely a manner as is possible.

Very respectfully, Go Gomez W. Wright Radiation Detection & Imaging Isotope & Fuel Cycle Technology Division Oak Ridge National Laboratory Page 3 of 3

NRC Category III Special Nuclear Material License Application DTRA Appendix B Nuclear Criticality Safety Assessment 51 of 53 Appendix B. Nuclear Criticality Safety Assessment Attachments

1. Nuclear Criticality Safety Analysis

NRC Category III Special Nuclear Material License Application DTRA Appendix C Radiation Safety Program Appointment Letters 52 of 53 Appendix C. Radiation Safety Program Appointment Letters Attachments

1. RSC Chairperson Appointment Letter

2. RSO Appointment Letter

C. Attachment 1 C. Attachment 2 DEFENSE THREAT REDUCTION AGENCY 8725 JOHN J. KINGMAN ROAD, STOP 6201 FORT BELVOIR, VA 22060-6201 NOV08 wi MEMORANDUM FOR THE COMPONENT RADIATION SAFETY OFFICER

SUBJECT:

Appointment of Mr. Daniel Mannis as Component Radiation Safety Officer Pursuant to Title 10, of the Code of Federal Regulations 30.33 and Nuclear Regulation (NUREG) 1556 11, I hereby appoint Daniel Maimis as the Component Radiation Safety Officer (RSO) for the Defense Threat Reduction Agency. In this capacity, you are responsible for ensuring the safe and secure use of licensed radioactive materials as well as implementing and managing the Radiation Safety Program (RSP). As the RSO, you will accomplish your assigned tasks as described in NUREG 1556-11, Appendix D and paragraph 8.7.3 as well as be granted the necessary authority to carry out your responsibilities. Specifically, you are responsible for:

• Identifying radiation protection problems, initiating, recommending, and/or providing corrective actions, verifying implementation ofconective actions, stopping unsafe activities, and ensuring compliance with regulations.

• Prohibiting the use of licensed material by employees who do not meet the necessary requirements and shutting down operations, when justified, to maintain radiation safety and compliance.

• Notifying the Director or the Directors executive management if staff does not cooperate anddoes not address radiation safety issues in accordance with all radiation guidance.

In addition, you are free to raise issues with the Nuclear Regulatory Commission at any time to ensure the RSP is complying with regulatory guidance. This memorandum rescinds previous appointments for this position and will remain in effect until superseded.

I, Daniel N. Mannis accept the responsibilities as mentioned above.

• i lo%

Signature o Radiation Safety Officer Date

NRC Category III Special Nuclear Material License Application DTRA Appendix C Radiation Safety Program Appointment Letters 53 of 53 Appendix D. In-Use Explanation Attachments

1. NRC In-Use Explanation

D. Attachment 1 D. Attachment 1