ML20317A158
| ML20317A158 | |
| Person / Time | |
|---|---|
| Site: | 07000113 |
| Issue date: | 12/03/2020 |
| From: | Ty Naquin Office of Nuclear Material Safety and Safeguards |
| To: | Guo Y Pennsylvania State Univ |
| TNaquin - NMSS/DFM/FFLB - 301.415.7352 | |
| Shared Package | |
| ML20317A156 | List: |
| References | |
| CAC 000222, EPID L-2019-PMP-0202 | |
| Download: ML20317A158 (4) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION SAFETY EVALUATION REPORT DOCKET NO.: 70-0113 LICENSE NO.: SNM-95 LICENSEE: The Pennsylvania State University
SUBJECT:
APPROVAL OF LICENSE AMENDMENT REQUEST AND AMENDMENT 2 TO SPECIAL NUCLEAR MATERIAL LICENSE SNM-95; DOCKET NUMBER 070-0113 (CAC/EPID 000222/07000113/L-2019-PMP-0202)
BACKGROUND By letter dated September 18, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20311A106), the Office of the Vice President for Research for The Pennsylvania State University (PSU) submitted a License Amendment Request (LAR) to remove Room 9 of the Hammond Building from its special nuclear material (SNM) License SNM-95. The Hammond Building is one of the three locations authorized for use of SNM at the University. The LAR only affects the use of SNM in Room 9 of the Hammond Building. There are no other changes to the materials or their authorized uses under this license. The Hammond Building has also been used for byproduct materials under a broad scope license (License PA-100) with the Commonwealth of Pennsylvania Department of Environmental Protection (PA DEP). The LAR provides information of the role of the Commonwealth of Pennsylvania and the future of the building. The building is to be demolished after it is confirmed to meet the release criteria for unrestricted use with the PA DEP. The approval of this LAR is one step in the process to release the building.
REGULATORY REQUIREMENTS Title 10 of the Code of Federal Regulations (10 CFR) Section 20.1402 states a site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent to an average member of the critical group that does not exceed 25 millirem (0.25 milliseivert) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable.
Section 70.38 of 10 CFR provides the regulatory requirements relevant to expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas.
REGULATORY GUIDANCE NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria Final Report, September 2006 (ADAMS Accession No. ML063000243).
Enclosure 1 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION DISCUSSION The Hammond Building is one of three locations where SNM is authorized to be used at the University Park Campus, being approved on September 18, 2014 (ADAMS Accession No. ML14114A300) in response to an LAR dated February 4, 2014 (ADAMS Accession No. ML14041A216). The PSU requested Room 9 of the Hammond Building be approved for limited SNM storage and material use for new research in novel techniques and equipment in nuclear forensics. The technique utilized a laser to vaporize a minute amount of target within a high vacuum chamber. The resulting ionization of the target would be analyzed using optical emission spectrometry to determine the elemental and isotopic composition of the materials and contaminants present. The chamber would be evacuated using a vacuum pump drawing air from the chamber through a high efficiency particulate (HEPA) filter for cleanliness. Room 9 at the Hammond Building was the only laboratory in which this research was conducted.
The identified SNM materials were stored and used in Room 9 of the Hammond Building from October 2014 to May 2016. Special nuclear materials use in the Hammond Building laboratory was discontinued in May 2016, with materials transported back to the permanent storage location at the Radiation Sciences and Engineering Center (RSEC). No SNM is currently stored or used in any room of the Hammond Building. Sealed radioactive sources, licensed under the Universitys broad scope license (PA-100), remain stored in Room 9 of the Hammond Building.
A decommissioning survey of Room 9 for the use of dispersible radioactive materials, including SNMs, was conducted by the radiation protection office in December 2018. The report of this survey was attached as an enclosure to the LAR under review. The radiation protection office will submit a building decommissioning report for the Hammond Building to the PA DEP for review once materials under the state license have been removed. The scope of the report will include all labs in the building that were previously authorized for radioactive material work. A confirmatory survey with the PA DEP Decommissioning Office will be conducted to complete the decommissioning process for this building. The building will be released for unrestricted use after it is confirmed to meet the release criteria for unrestricted use.
FINDINGS The SNM associated with the work performed in Room 9 of the Hammond Building was returned to the main material storage in the RSEC in 2016. All other radioactive materials that were part of the PA-100 license with Pennsylvania were removed from this room prior to the conduct of a radiation and contamination survey to ensure an adequate analysis of any potential residual contamination from SNM use could be determined and evaluated.
The survey of Room 9 included a complete survey of the floor, benchtops, tables, cabinets, drawers, sinks, hoods, and any equipment in the lab at the time of the survey. The survey was conducted with two instruments, a Geiger-Mueller Detector for general contamination and a Zinc-Sulfide detector to evaluate specifically for any alpha contamination. The background for this survey was approximately 0.02 millirem per hour, and was measured in the hallway adjacent to the lab. A survey map was provided in the report identifying locations of survey points and smear wipes taken, along with a corresponding table that lists each analysis result, including direct radiation survey and smear analysis. The radiation level in this room was measured and found to be consistent with ambient background radiation levels measured prior to the research conducted. Areas surveyed were approximately at background radiation levels.
2 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION This area continues to be regularly surveyed in accordance with the terms of their license application (ADAMS Accession No. ML14314A043).
More than 40 smear wipes were collected and analyzed with a calibrated liquid scintillation counter (Beckman LS6500 Liquid Scintillation Counter) for removable contamination. There was no contamination found in these smears. The experimental chamber used for the laser work, approved by LAR on April 4, 2014, was cleaned and surveyed by a hand-held alpha probe after each use of radioactive material. There are no water sources or sinks within the lab for measurement or evaluation. Progress of the survey and status of the effort was reviewed by a Region I inspector in July 2020 (ADAMS Accession No. ML20314A031).
A small quantity of radioactive waste was generated as a result of the work conducted by the LAR issued in April 2014. This consisted of paper towels and gloves used to wipe the interior of the experimental chamber, and a HEPA filter used to screen any potential contamination between the chamber and the mechanical pump from the experiments performed. This filter and all other wastes associated with the research had been properly disposed of at the conclusion of that work and prior to the start of this survey.
The PSU cites conformance to radiological release criteria cited in Table B1, Acceptable License Termination Screening Values of Common Radionuclides for Building-Surface Contamination, of NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance Characterization, Survey, and Determination of Radiological Criteria Final Report, September 2006 (ADAMS Accession No. ML063000243). The table provides unrestricted release values for building-surface contamination of common beta/gamma emitting radionuclides that would be deemed in compliance with the unrestricted use dose limit in 10 CFR 20.1402 (i.e., 25 millirem/yr (0.25 millisievert/yr)). This provides a basis for licensees to demonstrate compliance with the unrestricted release dose criterion and reasonable assurance that the dose criterion in 10 CFR 20.1402 will be met. The PSU is not decommissioning the license, but will be releasing the Hammond Building for unrestricted use, thus using the criteria of the NUREG as a basis for compliance.
As a conclusion, Room 9 has been properly surveyed and decommissioned for the use of dispersible radioactive materials including SNMs. Appropriate surveys were completed and adequate documentation provided to demonstrate reasonable assurance that the space is suitable to be released for unrestricted use in accordance with 10 CFR Part 20 Subpart E after the sealed sources are removed from this room and the confirmatory survey with PA DEP is completed and approved.
ENVIRONMENTAL REVIEW The staff has determined the laboratory has been adequately surveyed and evaluated for any residual contamination from the work approved by an LAR issued on April 4, 2014 (ADAMS Accession No. ML14114A300) and that SNM-95 is categorically excluded from the requirements to prepare a site-specific environmental assessment. Therefore, in accordance with 10 CFR 51.22(c)(14)(v), neither an environmental assessment nor an environmental impact statement is warranted for this action.
Regarding this administrative amendment to the PSU license SNM-95, submitted on September 18, 2020, according to 10 CFR 51.22(c)(14)(v), is eligible for categorical exclusion provided that:
3 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
- i. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
ii. There is no significant increase in individual or cumulative occupational radiation exposure.
iii. There is no significant construction impact.
iv. There is no significant increase in the potential for or consequences from radiological accidents.
The change in the license does not affect the scope or nature of the licensed activity, and will not result in a significant change in the types or amounts of effluents released offsite. There will not be any significant increase in individual or cumulative occupational radiation exposure, and there will not be any significant increase in the potential or consequences from radiological accidents. There is no construction associated with these changes, so there will not be any impact from construction.
CONCLUSION The NRC staff concludes that the actions taken by the PSU, as discussed herein, prior to and after the submittal of their request to delete the use Room 9 of the Hammond Building as an authorized space for use under SNM-95, have provided reasonable assurance to conclude that the amendment can be approved. The decommissioning report has been reviewed and survey results demonstrate compliance with the unrestricted release criteria of 10 CFR 20.1402, as it applies to the SNM-95 usage in Room 9 of the Hammond Building. The decommissioning report meets the requirements of 10 CFR 70.38(j)(2) and (3). Since none of the SNM sources used in Room 9 were disposed of or transferred to a different licensee, no NRC Form 314, Certificate of Disposition of Material, is required for the decommissioning of this room as would be required under 10 CFR 70.38(j)(1). The NRC staff has further determined that the actions taken by the PSU are adequate to provide assurance of the protection of the health and safety of the public and workers, to protect the environment, and to comply with the regulatory requirements imposed by the Commission in 10 CFR Part 70.
RECOMMENDATION With the submittal dated September 18, 2020, the NRC staff finds that the licensee has demonstrated the actions taken to remove Room 9 of the Hammond Building from the SNM-95 to meet the requirements for unrestricted release are acceptable. The amendment should be approved. Final unrestricted release of the room for all radioactive material uses will be concluded between the PSU and the PA DEP upon satisfactory completion of the confirmatory survey for byproduct materials.
Principal Contributor:
Tyrone D. Naquin 4
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION