ML20332A026

Idaho State Univ., License Amendment Request Update University Officers Roster

ML20332A026
Person / Time
Site:	07001374
Issue date:	11/13/2020
From:	Lybecker D Idaho State University
To:	Osiris Siurano-Perez Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML20332A026 (3)

Text

Idaho State University November 13, 2020 ATIN: Documents Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Idaho State University-Special Nuclear Materials License Number 1373, Amendment Request to Update University Officers Roster Docket Number (70-1374)

Dear Mr. Siurano-Perez:

In response to your letter dated October 13, 2020, regarding our request to update university officers roster with SNM License Number 1373, I am writing to supply additional information and ask for consideration of an amendment of this license.

As previously noted, Attachment N of our license application dated September 26, 2016 (ADAMS Accession Number ML 16279282) states that the minimum qualifications for the Responsible University Officer (currently me, the Vice President for Research) are as follows:

a. PhD or equivalent education in a scientific/ engineering/ technology field, and

b. At least 5 years of supervisory/ administrative experience.

In your letter dated October 13, 2020, it was noted that the NRC staff evaluated the provided information and determined that my PhD in Political Science does not meet the requirement for education in a scientific/ engineering/ technology field. Given this determination, Idaho State University requests your consideration to amend the license by (a) adding a senior manager requirement while eliminating the technical degree requirement and (b) adding the chairperson of the university Reactor Safety Committee.

Our reasoning is that at ISU, we believe the significant level of expertise on the Reactor Safety Committe<; supplies the needed expertise to the senior manager who serves as the Responsible Officer. The Reactor Safety Committee has always been a major source of expertise, providing the Responsible Officer with the in-depth information and detailed understanding of the work done under our license.

Not only will this addition formally document the technical expertise available to support the Responsible University Officer, it matches the organizational structure for the reactor and the SNM licenses specified in the Radiation Safety Manual. The specific textual changes to address these issues are provided in the document attached at the end of this letter.

Office tor Reuarch 921 South 8th Ave., Stop 8130 I Pocatello, ID 83209-8130 I (208) 282-2592 I isu edu/research

Idaho State University If you have any additional questions, please contact me via email at lybedonn@isu.edu Sincerely, Do~,~

Acting Vice President for Research Idaho State University Pocatello, Idaho 83209 Cc:

Mr. Osiris Siurano-Perez, NRC (email),

Mr. Kevin Ramsey, NRC (email),

Dr. Mary Lou Dunzik Gougar, ISU (email),

Mr. John Longley, ISU (email)

Office for Research 921 South 8th Ave, Stop 8130 I Pocatello, ID 83209-8130 I (208) 282-25921 lsu.edu/research

Idaho State University ATTACHMENT IV - Revised: September 2016 Minimum Qualifications of Un iversity Personnel Responsible for Materials License SNM-1373, Docket No. 1374 (also for R-110 Reactor License)

A) Responsible University Officer, currently the Vice President for Research and Dean of the Graduate

~

• PhD or equivalent education in a soientifiolengineering/teohnology field

• Senior manager at ISU

• At least 5 years of supervisory/administrative experience B) Chairperson of Reactor Safety Committee

• BS or higher in an engineering field or phy ical science field

• At least 5 years of experience related to nuclear reactor operations (need not have power reactor experience).

• A professional engineering licen e is desirable but not essential.

C-Sj Reactor Administrator and/or Assistant Reactor Administrator

• MS or PhD in an engineering or physical science field

• At least 2 years of experience related to nuclear reactor operations (need not have power reactor experience).

• A professional engi neering license is desirable but not essential

• Certification as a Health Physicist is desirable but not essential

• Note: it is not necessary for the Reactor Administrator or the Assistant Reactor Admin istrator to have or retain certification as either a Reactor Operator or Sen ior Reactor Operator.

oq Reactor Supervisor

• BS in an engineering or physical science field

• At least 2 years of experience related to nuclear reactor operations (need not have power reactor experience).

• Pass the requirements, or equivalent, for having a Reactor Operator License, and obtain a Senior Reactor Operator License within one year of qualifying for the Reactor Operator License.

• Must maintain certification as a Senior Reactor Operator E-D) Radiation Safety Officer One of the following are the minimum requirements for the Radiation Safety Officer

• BS (or higher degree) in health physics, nuclear engineering, or a closely related field, and five years of experience related to health physics/radiation protection.

• Certification by the American Academy of Health Physics or nominal equivalent relevant certification.

SNM License Personnel Qualifications Revised 9/ 15/201 6 Office for Research 921 South 8th Ave., Stop 8130 I Pocatello, ID 83209-8130 I (208) 282-2592 I isu.edu/research