ML24071A179
| ML24071A179 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 03/11/2024 |
| From: | US Dept of Commerce, National Institute of Standards & Technology (NIST) |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24071A177 | List: |
| References | |
| Download: ML24071A179 (1) | |
Text
NIST Response to NRC RAI (ML23320A133)
A. Technical Review Area: Radiation Protection (RP) - Application section 2.
- 1. RAI # RP-1: Commitment to provide adequate personnel contamination equipment.
Issue description:
In section 2.2.2.4, Minimization of Contamination, of the LRA, the NIST states that personnel contamination monitoring shall be performed as indicated in the hazard analysis associated with a source specific protocol and when exiting contamination control zones. In addition, NIST stated that any detectable skin contamination shall require initiation of decontamination procedures and that personnel decontamination efforts shall be discontinued if there is indication that continued efforts could result in damage to the skin and possible higher risks due to uptakes of material. However, the LRA does not specify that the hazard analysis will ensure that personnel contamination equipment will be appropriate for all reasonably expected isotopes.
Request:
Provide written commitment that NISTs hazard analysis shall ensure that personnel contamination equipment will be appropriate for all reasonably expected isotopes.
NIST Response:
LRA Section 2.2.2.4, Personnel Contamination Monitoring, has been revised to include a commitment that NISTs hazard analysis shall ensure that personnel contamination equipment will be appropriate for all reasonably expected isotopes. Section 2.2.2.4 has been revised as follows:
2.2.2.4. Personnel Contamination Monitoring:
Personnel contamination monitoring shall be performed as indicated in the hazard analysis associated with a source specific protocol and when exiting contamination control zones. NIST shall ensure that personnel contamination equipment will b e appropriate for all reasonably expected isotopes. Any detectable skin contamination shall require initiation of decontamination procedures. Personnel decontamination efforts shall be discontinued if there is indication that continued efforts could resul t in damage to the skin and possible higher risks due to uptakes of material.
B. Technical Review Area: Nuclear Criticality Safety (NCS) - LRA section 3.
- 1. RAI # NCS-1: Subcriticality and Double Contingency Principle
Issue description:
In section 3.4, Subcriticality and Double Contingency Principle, of the LRA, the NIST states that it is committed to practices to ensure that, by applying the sum of the fractions rule, no combination of fissile uranium and plutonium exceeding 80% of a critical mass, as specified in 10 CFR 70.4, shall be used or stored at any single location. However, in section 3.8, Calculational Method Validation, of the LRA, the NIST describes the use of a validated calculational method and states that calculations for criticality are based on summation of special nuclear material (SNM) in each predefined location, suggesting that the use of a validated calculational method may be used to determine criticality safety limits. Furthermore, in section 3.1, Use of Industry Standards, of the LRA, the NIST states that the administration of the Maryland Radiation Safety Division (RSD) NCS program uses Regulatory Guide RG-3.71, Nuclear Criticality Safety Standards for Nuclear Materials Outside Reactor Cores, Revision 3, which endorses American National Standards Institute/American Nuclear Society (ANSI/ANS)-8.1, Nuclear Criticality Safety in Operations with Fissionable Material Outside Reactors. This suggests that criticality safety limits may be derived from the single parameter limits stated in ANSI/ANS-8.1. Given that the use of a validated calculational method is described, and that ANSI/ANS-8.1 contains mass limits (i.e., single parameter limits), it is not clear how this is consistent with the licensees commitment to ensure that no combination of SNM exceeding 80% of a critical mass (as defined in 10 CFR 70.4) will be used or stored at any single location, and it is not clear how criticality safety limits will be determined.
Request:
Clarify the method for establishing criticality safety limits. State whether a validated calculational method (e.g., SCALE or MCNP) may be used to determine criticality safety limits, criticality safety limits are derived from the single parameter limits in ANSI/ANS-8.1, or criticality safety limits are set such that 80% of a critical mass (as defined in 10 CFR 70.4) is not exceeded.
NIST Response:
LRA Section 3.1 has been modified to clarify that t he administration of our criticality program follows the American National Standards Institute/American National Standard ANSI/ANS-8.19-2014 Administrative Practices for Nuclear Criticality Safety. No other ANSI/ANS standard is being used for NISTs NCS Program. References to Regulatory Guide RG-3.71 have been removed.
LRA Sections 3.4 and 3.8 have been modified to show that the NCS program will maintain a preestablished subcritical level, by applying the sum of the fractions rule: no combination of fissile uranium and plutonium exceeding eighty (80) percent of a critical mass, as specified in 10 CFR 70.4, shall be used, or stored at any single location.
C. Technical Review Area: Fire Protection (FP) - LRA section 5.
- 1. RAI # FP-1: Fire safety features of the facility design.
Issue description:
In the LRA, the NIST does not provide sufficient information on the new H -Wing of Building 245 and its subsequent renovation for the NRC staff to make its final regulatory findings.
In section 5, Facility Design, of the LRA, the NIST stated that the new H -Wing of Building 245 (the building where the majority of NISTs operations involving use of licensed materials are conducted and also houses NISTs Gamma IR lab and the panoramic beam and self-shielded irradiators) is separated from the existing building by back-to-back 2-hour fire rated barriers. The NIST also stated that the new H-Wing and its subsequent renovation is a noncombustible Type II-B building constructed per the International Building Code (2015 Edition) and NFPA codes described in section 5 of the LRA. However, the NIST did not include a layout of the building clearly showing the new H-Wing and its fire safety features.
The staff is not sure whether these features are included in Figure 2-1 (Enclosure 2) or Figure 3-1 (Enclosure 3) of the LRA.
Request:
To adequately evaluate the fire safety features in Building 245, provide the following information:
- 1. Provide the layouts which show:
- a. the back-to-back 2-hour fire barriers, and other fire safety features (e.g., fire suppression systems, fire detection/alarm system, etc.) of Building 245, including those for the new H-Wing;
- b. the location of the H-Wing in relation to Building 245.
- 2. Describe the fire safety features in the new H-Wing and its subsequent renovations which may affect the buildings fire protection features.
NIST Response:
The requested layout s for the evaluation of the fire safety features in Building 245 are provided in Enclosure 7 Fire Safety Facility Schematics provides the location of the H -
Wing in relation to Building 245 as well as the layouts which show the back -to-back 2-hour fire barriers, and other fire safety features (e.g., fire suppression systems, fire detection/alarm system, etc.) of Building 245, including those for the new H -Wing.
In preparation of the response to NRC RAI (ML23320A135 & ML23320A133), the NIST requested assistance from its fire protection engineers and it was determined that the description of the fire safety features in the new H -Wing, as originally presented in LRA Sections 5.1 and 5.2.1, adequately describe the fire safety features in the new H -Wing.
No construction activities have taken place or are currently planned that will a ffect the narrative of these sections.
D. Technical Review Area: Material Control and Accounting (MC&A) - LRA section 7.
- 1. RAI # MC&A-1: Physical Inventory
Request:
Provide clarification in section 7.6 that physical inventories of all SNM under the license as required by 10 CFR 74.19(c) are conducted at intervals not to exceed 12 months.
NIST Response:
LRA Section 7.6, Physical Inventories, of the LRA has been revised to include that physical inventories of all SNM under the license as required by 10 CFR 74.19(c) and are conducted at intervals not to exceed 12 months.
7.6. Physical Inventories RSD maintains procedures that provide guidance on the planning, conducting, assessing, and reporting of physical inventories of SNM. SNM physical inventory reports are submitted in accordance with 10 CFR 74.13.
Physical inventories of all SNM under the license as required by 10 CFR 74.19(c) are conducted at intervals not to exceed 12 months.
Source Custodians shall maintain inventory records of, and conduct an annual physical inventory for, all sealed and unsealed licensed sources under their responsibility. Source Custodians shall also comply with applicable shipment, transfer, and waste disposal requirements for all sealed and unsealed licensed sources under their responsibility.
E. Technical Review Area: Radioactive Waste Management (RWM) - LRA section 11.
- 1. RAI # RWM-1: Commitment for meeting the requirements in 10 CFR 20.2006, Transfer for disposal and manifests, and discussion on how NIST intends to meet these requirements.
Request:
Provide NISTs written commitment for meeting the requirements in 10 CFR 20.2006 and discuss how it intends to meet these requirements.
NIST Response:
Section 2.2.6, Waste Management, of the LRA has been revised to include a commitment for meeting the requirements in 10 CFR 20.2006 and how NIST intends to meet these requirements.
E. Technical Review Area: Radioactive Waste Management (RWM) - LRA section 11.
- 2. RAI # RWM-2: Commitment for meeting the requirements in 10 CFR 20.2007, Compliance with environmental and health protection regulations, and discussion on how NIST intends to meet the requirement.
Request:
Provide NISTs written commitment for meeting the requirements in 10 CFR 20.2007 and discuss how it intends to meet these requirements.
NIST Response:
Section 2.2.6, Waste Management, of the LRA has been revised to include a commitment for meeting the requirements in 10 CFR 20.2007. The regulations at 10 CFR 20.2007 provide that nothing in Subpart K of 10 CFR Part 20 relieves the licensee from complying with other applicable Federal, State, and local regulations governing any other toxic or hazardous properties of materials that may be disposed of under this subpart.
NIST ensures compliance with 10 CFR 20.2007 by confirming that waste contracts are only established with brokers and disposal sites that have proper procedures, permits, and certifications.