ML22081A296

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Request for Clarification of Idaho State University Responses to NRC RAI
ML22081A296
Person / Time
Site: 07001374
Issue date: 03/14/2022
From: Osiris Siurano-Perez
NRC/NMSS/DFM/FFLB
To: Suzanne Ani, Richard Jervey, Lybecker D, Alison Rivera, James Rubenstone, Alexander Sapountzis, Jacob Zimmerman
Idaho State University
OSPEREZ NRC/NMSS/DFM/FFLB 3014157827
References
Download: ML22081A296 (2)


Text

From: Siurano-Perez, Osiris To: Donna Lybecker Cc: Ani, Suzanne; Sapountzis, Alexander; Zimmerman, Jacob; Jervey, Richard; Rubenstone, James; Rivera, Alison

Subject:

Request for Clarification of Responses to NRC Request for Additional Information Date: Monday, March 21, 2022 9:26:00 AM Importance: High

Dear Dr. Lybecker:

During our review of the Idaho State University (ISU) responses (Agencywide Documents Access and Management System (ADAMS) Accession Number ML22075A290) to the U.S.

Nuclear Regulatory Commission (NRC) staffs request for additional information (RAI) dated February 7, 2022 (ADAMS Accession No. ML22033A443), regarding ISUs license renewal application (LRA), the NRC staff identified the following issues with the public and non-public versions of your revised LRA:

A. Incorrect 10 CFR citations

a. Issue 1: In Section 8.4, the last sentence states the following: These records are maintained and retained in accordance with the requirements of 10 CFR 79.19.

Resolution: The correct regulation should be 10 CFR 74.19.

b. Issue # 2: In Section 9.1, in the first paragraph the following is stated:

These records are maintained and retained on ISUs cloud storage server in accordance with the recordkeeping requirements of 10 CFR 79.19.

Resolution: The correct regulation should be 10 CFR 74.19.

c. Issue # 3: In the second paragraph in Section 12, in the last sentence the following is stated: In the event a discrepancy is identified the Radiation Safety Officer will notify the NRC Operations Center through the Emergency Notification System within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery as required by 10 CFR 71.11.

Resolution: The correct regulation should be 10 CFR 74.11.

B. Clarification questions

1. On page 7, 3rd paragraph, first sentence of the revised Physical Security Plan (PSP), ISU stated that Room 22 is the Counting Laboratory, and is not a Controlled Access Area (CAA), while on page 6, Section 5.1, 3rd paragraph, first sentence, ISU stated Room 22 is designated as a temporary CAA... while SNM is in use. In the February 7, 2022, RAI on physical security, the NRC staff requested ISU to identify Room 22 as a temporary CAA when the SNM is in use. The staff noted that ISU did so in its revised PSP in response to the RAI. However, on page 7, 3rd paragraph of the revised PSP, ISU stated that Room 22 is not a CAA but small quantities of SNM (a fuel plate) will be used there to count activity and measure gamma rays.

Please clarify if ISUs intent is to use Room 22 as a temporary CAA when it

transfers many fuel plates above a Category III SNM quantity, and if it will not be called a temporary CAA (temporary) at those other times when it transfers only 1 fuel plate and some fission foils (which would be below a Category III SNM quantity).

2. In Section 6, ISU stated that the NRC had previously evaluated and approved the individuals listed in Attachment I (Roster of Officials) of the LRA. The list includes Dr. Chad Pope, Chair of the Department of Nuclear Engineering. The NRC staff could not locate evidence that it had previously evaluated the qualifications of Dr. Pope.

Please clarify whether the information provided is correct. If so, please provide the reference (i.e., ADAMS Accession Number) to the NRC letter documenting this evaluation. If not available, please supplement your LRA by providing Dr. Popes resume/curriculum vitae for evaluation .

We request that ISU revise/update the public and non-public versions of the application addressing the above discussed issues and resubmit for NRC staff evaluation within 5 business days from the date of this communication.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this communication will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). The PDR is currently closed. You may submit your request to the PDR via e-mail at PDR.Resource@nrc.gov or call 1-800-397-4209 between 8:00 a.m. and 4:00 p.m. (EST), Monday through Friday, except Federal holidays.

If you have any questions regarding this communication, please contact me at 301-415-7827, or via e-mail to Osiris.Siurano-Perez@nrc.gov.

Sincerely, Osiris Siurano-Pérez, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 07001374 License No.: SNM-1373