ML22181A686
| ML22181A686 | |
| Person / Time | |
|---|---|
| Site: | 07001045 |
| Issue date: | 06/30/2022 |
| From: | Sara Forster NRC/RGN-III/DNMS/MLB |
| To: | Stamm J Univ of Evansville |
| References | |
| 630840 | |
| Download: ML22181A686 (5) | |
Text
June 30, 2022 Dr. John Stamm, Ph.D.
Radiation Safety Officer University of Evansville 1800 Lincoln Ave.
Evansville, IN 47722
SUBJECT:
ADDITIONAL INFORMATION NEEDED REGARDING RENEWAL APPLICATION FOR UNIVERSITY OF EVANSVILLE, NRC LICENSE NO. SNM-995
Dear Dr. Stamm:
Our office has reviewed the April 28, 2022 request (including an April 29, 2022 NRC Form 313 application and other attachments) for NRC to renew University of Evansvilles (your) U.S.
Nuclear Regulatory Commission (NRC) Materials License No. SNM-995. Upon review, our office has determined that additional information is needed to renew the license, regarding radioactive materials, authorized individuals, and radiation safety program, and waste management program. Your amendment request is available electronically from NRCs Agencywide Documents Access and Management System (ADAMS) at accession number ML22122A094. The NRCs ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
For additional guidance, please refer to NUREG 1556 Volume 17, revision 1, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Special Nuclear Material of Less Than Critical Mass Licenses, Sections 8.5, Item 5: Radioactive Material, pp.
8-4 to 8-6, 8.6, Item 6: Purposes for Which Licensed Material Will Be Used, pp. 8-9 to 8-10, 8.7, Individuals Responsible for Radiation Safety Program and Their Training and Experience, pp. 8-10 to 8-14, 8.8, Item 8: Training for Individuals Working in or Frequenting Restricted Areas (Instructions to Occupationally Exposed Workers and Ancillary Personnel), pp. 8-15 to 8-16, and 8.10, Item 10: Radiation Safety Program, pp. 8-18 to 8-48, and 8.11, Item 8.11:
Waste Management, pp. 8-48 to 8-53.
RADIOACTIVE MATERIAL & PURPOSE OF USE TO BE AUTHORIZED ON THE LICENSE:
1.
The possession limit for the plutonium-239 source is listed in Subitem No. 8.A. However, no possession limit is listed for the activation products authorization in Subitem Nos. 8.B.
Please indicate the per-radionuclide possession limit for each radionuclide to be possessed under Subitem No. 6.B., and confirm that the overall possession limit is 10 microcuries, as currently listed on the license.
J. Stamm 2
2.
No manufacturer or model number is indicated for the neutron howitzer to be authorized in Subitem No. 9.A.
Please either confirm that the model is the VISIFLUX II, or provide the model number for the device to be authorized under the license.
INDIVIDUALS RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING & EXPERIENCE 3.
In the referenced request, changes were indicated for authorized individuals.
Please confirm the following changes or provide documentation of training &
experience as needed:
(a)
Benny R. Riley, Ph.D. is listed as a non-medical Authorized User (AU) on the most recent amendment to the license, but was not listed in the renewal application.
Please confirm that you wish to remove Dr. Riley as an AU, on the license.
(b)
Jeffrey Braun, Ph.D. is requested to be added as a non-medical AU in the application; he is not currently listed as an AU on the license. Training and experience was limited to formal education, writing credentials, and teaching assignments. No description of radiation safety training or hands-on radioactive materials was included in the application.
i.
Please confirm that you wish to add Dr. Braun as an AU, on the license.
ii.
In addition, please provide training and experience documentation for Dr.
Braun, in accordance with NUREG 1556, Vol. 17, rev. 1, Section 8.7.2, Authorized Users and Radiation Workers, pp. 8-12 to 8-14, as noted:
Training on listed topics including dates; locations; format - lecture, video, online, self-study, etc.; and training provider o
radiation protection principles o
characteristics of ionizing radiation o
units of radiation dose and quantities o
radiation detection instrumentation o
biological hazards of exposure to radiation (appropriate to the types and forms of special nuclear material to be used)
Hands-on use of radioactive materials (radionuclides, quantities, types of use dates, etc.), related to the authorizations on the license
J. Stamm 3
TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS (INSTRUCTIONS TO OCCUPATIONALLY EXPOSED WORKERS AND ANCILLARY PERSONNEL):
4.
The application described instruction for users, but omitted how radiation safety training is provided to others who may have access to the licensed material, whether escorted or not.
In accordance with NUREG 1556, Vol. 17, rev. 1, pp. 8-15 through 8-16, for non AUs, including topics covered, groups of workers (e.g., clerical, housekeeping, security, students, etc.), assessment of training, qualifications of instructors, and the method and frequency of training and refresher training.
RADIATION SAFETY PROGRAM:
5.
Although specific instruments currently used for radiation monitoring were described, the application omitted a confirmation that instruments will meet the criteria in NUREG 1556, Vol. 17, rev. 1, Appendix F, Model Radiation Survey Instrument Calibration Program, that instruments will be calibrated by persons authorized - via license - by NRC or an Agreement State - to perform that service, and that the licensee reserves the right to upgrade survey instruments as necessary.
Based on your May 3, 2012 letter (publicly available at NRCs accession number ML12128A235) and current guidance, please confirm the following still apply:
(a) The statement: We will use instruments that meet the radiation monitoring instrument specifications published in Appendix F to the current version of NUREG-1556, Volume 17, Program-Specific Guidance About Special Nuclear Material of Less Than Critical Mass Licenses. We reserve the right to upgrade our survey instruments as necessary. This statement is indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-23.
AND (b)
The statement: Radiation monitoring instruments will be calibrated by a vendor [or person or other entity, etc.] who is licensed by the NRC or an Agreement State to perform instrument calibrations.
6.
Although the application contained an ordering and receiving procedure, it was unclear regarding other aspects of ensuring material accountability.
Based on your May 2, 2012 letter (publicly available at NRCs accession number ML12128A233) and current guidance, please confirm the following statements, indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-29, still apply:
(a) We will develop, implement, and maintain procedures for ensuring accountability of licensed materials at all times.
AND (b) Physical inventories will be conducted at intervals not to exceed 6 months, to account for all sealed sources and devices received and possessed under the license. Records of inventories will be maintained for 3 years from the date of each inventory and will include the radionuclides, quantities, manufacturers name, model numbers, and the date of the inventory.
J. Stamm 4
7.
Although the application contained a narrative explanation of why certain individuals would not need to be monitored pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 20.1502, no description of documentation of the same to be maintained for inspection was contained in the application.
Please confirm the statement, indicated in the current guidance volume, NUREG 1556, Vol. 17, rev. 1, p. 8-32: We will maintain, for inspection by the NRC, documentation demonstrating that unmonitored individuals are not likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502.
8.
The application did not address all aspects of operating and emergency procedures.
Based on your May 2, 2012 letter and current guidance, please confirm the statement, indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-37, still applies:
Procedures for safe and secure use of materials and emergencies have been developed or will be developed before receipt of licensed material.
In addition, if you wish to continue to be authorized to revise procedures, as indicated in the May 2, 2012 letter, please confirm the additional statement from NUREG 1556, Vol. 17, rev. 1, p. 8-37: Procedures may be revised only if:
the changes are reviewed and approved by the licensee management and the RSO in writing; the licensee staff is provided training in the revised procedures prior to implementation; the changes are in compliance with the NRC regulations and the license; and the changes do not degrade the effectiveness of the program.
9.
The application did not address leak tests.
Based on your May 2, 2012 letter and current guidance, please confirm that the statement, indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-38, still applies: Leak tests will be performed at intervals approved by NRC or an Agreement State and specified in the Sealed Source and Device Registration Certificate. Leak tests will be performed by an organization authorized by NRC or an Agreement State to provide leak testing services to other licensees. Leak tests may be collected by the licensee using a leak test kit suppliers instructions. Such leak test kits will be supplied by an organization authorized by the NRC or an Agreement State to provide leak testing services. As an alternative, we will implement the model leak test program published in Appendix J to the current version of NUREG1556, Volume 17, Program-Specific Guidance About Special Nuclear Material of Less Than Critical Mass Licenses.
10.
The application did not address surveys.
Based on your May 2, 2012 letter and current guidance, please confirm that the statement, indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-38, still applies: We will survey our facility and maintain contamination levels in accordance with the survey frequencies and contamination levels published in Appendix I to the current version of NUREG-1556, Volume 17, Program-Specific Guidance About Special Nuclear Material of Less Than Critical Mass Licenses.
J. Stamm 5
WASTE MANAGEMENT:
11.
The discussion of waste management was incomplete as it did not fully address how decay-in-storage waste or sealed sources would ultimately be disposed.
Based on your May 2, 2012 letter and current guidance, please confirm that the statement, indicated in NUREG 1556, Vol. 17, rev. 1, p. 8-52, still applies: We will ensure that all licensed Special Nuclear Material will be disposed of in accordance with the requirements of 10 CFR Part 20 Subpart K.
Please provide a response via a signed and dated letter within 30 days (on or prior to July 30, 2022). For quickest processing, please submit your response as a pdf file attached to an email message. You may also submit a response via fax or via regular mail. If you have any questions regarding this message, please do not hesitate to reach out to me at 630-829-9892.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the NRCs ADAMS, accessible from the NRC Web site at https://www.nrc.gov/reading-rm/adams.html.
Sincerely, Sara A. Forster, M.S.
Health Physicist Materials Licensing Branch Division of Nuclear Materials Safety Docket No.: 070-01045 License No.: SNM-995 Control No.: 630840 Sara A. Forster Digitally signed by Sara A.
Forster Date: 2022.06.30 10:05:17 -05'00'