ML24198A033
| ML24198A033 | |
| Person / Time | |
|---|---|
| Site: | 07000113 |
| Issue date: | 08/05/2024 |
| From: | James Chang, Siurano O NRC/NMSS/DFM/FFLB |
| To: | Pennsylvania State Univ, University Park, PA |
| Shared Package | |
| ML24198A031 | List: |
| References | |
| Download: ML24198A033 (1) | |
Text
OFFICIAL USE ONLYSECURITY-RELATED INFORMATION OFFICIAL USE ONLYSECURITY-RELATED INFORMATION REQUEST FOR SUPPLEMENTAL INFORMATION DOCKET NO.: 70-113 LICENSE NO.: SNM-95 LICENSEE:
PENNSYLVANNIA STATE UNIVERSITY
SUBJECT:
LICENSE AMENDMENT REQUEST TO ADD ONE AUTHORIZED BUILDING By letter dated April 19, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession Number ML24120A055), the Pennsylvania State University (PSU) submitted an application requesting U.S. Nuclear Regulatory Commission (NRC) approval of a proposed amendment to special nuclear materials license number 95 (SNM-95) to reflect a planned relocation of the Environmental Health and Safety's Radiation Protection Office. The NRC staff identified the following information that is needed to complete its acceptance review of PSUs submittal, and for proceeding with a detailed technical review.
- 1. General Information (GI) - Description of Activities at New Proposed Facility.
Issue:
In its license amendment request (LAR), PSU provided the following information regarding its licensed activities at the Steam Services Building (SSB, new proposed facility) include:
- radioactive material receipt and package check-in;
- two rooms within the SSB are being renovated to serve as a laboratory and work area and allow PSU staff to continue to perform necessary activities in support of the University's radiation protection program; and
- functional activities previously performed in Room 229 of the Academic Projects building have been reviewed and mapped to the new laboratory and work area in the SSB to ensure continuity of services.
PSU further stated that the SSB would not function as source storage, with the except of up to three small quantity check sources used for instrument response checks and gain adjustments.
The above information provided in PSUs LAR does not fully describe, in sufficient detail, the activities to be conducted at the SSB. For example, in its submittal PSU states that in preparation for the RPO relocation, two third floor rooms within the SSB are being renovated to allow these spaces to serve as a laboratory and work area for EHS-RPO staff. These rooms will allow RPO staff to continue to perform necessary activities in support of the University's radiation protection program. The functional activities previously performed in Room 229 of the Academic Projects building have been reviewed and mapped to the new laboratory and work area in SSB to ensure continuity of services. Moreover, PSU states that the radiation safety review concluded that as long as the functions currently utilized in Academic Projects Building can be successfully carried out in SSB, then the commitments in the license renewal application can still be satisfied. There is not sufficient detail describing the activities for the NRC staff to determine, with reasonable assurance, that the laboratory and work activities at the SSB do not pose an unnecessary risk of radiation exposures to workers, PSU staff, or the public.
OFFICIAL USE ONLYSECURITY-RELATED INFORMATION OFFICIAL USE ONLYSECURITY-RELATED INFORMATION 2
Regulatory Basis:
The regulations in Title 10 of the Code of Federal Regulations (10 CFR) 70.22, Contents of applications, require, in part, that:
(a) Each application for a license shall contain the following information:
(2) the activity for which the special nuclear material is requested and the general plan for carrying out the activity; (8) proposed procedures to protect health and minimize danger to life or property.
Request:
PSU needs to describe, in sufficient detail, the activities it intends to conduct at the proposed new facility and generally discuss its procedures to adequately protect health and safety of its staff, the public, and the environment from the hazards posed by the proposed activities.
This information is necessary for the NRC staff to complete the acceptance review of PSUs April 19, 2024, submittal.
- 2. Fire Safety (FS) - Fire Protection at the Steam Services Building (SSB)
Issue:
In Attachment B, Penn State University Radiation Safety Evaluation of Requested Change, of its submittal, PSU states that the SSB will serve as the Radiation Protection Office (RPO) staff office, RPO counting laboratory, and the location where SNM source receipt inspection, and instrument response checks and gain adjustments are performed. However, the SSB will not function as an area for SNM source storage and SNM processing. As described in Attachment B, RPO staff are planned to be located in rooms 305 and 305D, and the RPO counting laboratory, and work areas will be in rooms 303 and 306 of the SSB.
However, the facility design of the SSB, constructed and completed by 2019, was not designed for the proposed activity as described in this LAR and, although the proposed new facility will not be used to store and process the SNM, the application still needs to describe the fire protection features of the SSB and describe the FS management measures if a fire occurs while the SNM is physically at the SSB awaiting to be transferred to one of the authorized locations. This is described in the guidance in section 7.4.3, Regulatory Acceptance Criteria, of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications.
The guidance in NUREG-1520, section 7.4.3 also states that the NRC reviewer will use national recognized codes and standards (including National Fire Protection Association
[NFPA] codes) when evaluating the FS program.
Regulatory Basis:
The requirements in 10 CFR 70.22(a)(7), state that an application shall include a description of equipment and facilities which will be used by the applicant to protect health and minimize danger to life or property (such as handling devices, working areas, shields, measuring and monitoring instruments, devices for the disposal of radioactive effluents and wastes, storage facilities, criticality accident alarm systems, etc.).
OFFICIAL USE ONLYSECURITY-RELATED INFORMATION OFFICIAL USE ONLYSECURITY-RELATED INFORMATION 3
The requirements in 10 CFR 70.22(a)(8), state that an application shall contain proposed procedures to protect health and minimize danger to life or property (such as procedures to avoid accidental criticality, procedures for personnel monitoring and waste disposal, post-criticality accident emergency procedures, etc.).
Request:
A) Describe the fire protection features of the SSB. The FS features could include, but are not limited to, sprinklers, fire detectors/alarms, extinguishers, and fire-rated walls/ceiling, etc.
B) Describe the measures PSU has in place to prevent, or respond to, a fire if it occurs while the SNM is physically at the SSB awaiting to be transferred to one of the authorized locations.
C) List the relevant NFPA Standards that are applicable to the SSB.
This information is necessary for the NRC staff to complete the acceptance review of PSUs April 19, 2024, submittal.
PRINCIPAL CONTRIBUTORS:
Jimmy Chang, NMSS/DFM/CTCFB Osiris Siurano, NMSS/DFM/FFLB