ML24222A723
| ML24222A723 | |
| Person / Time | |
|---|---|
| Site: | 07000192 |
| Issue date: | 08/08/2024 |
| From: | Fischer K University of Michigan |
| To: | NRC/RGN-III/DNMS/MLB |
| References | |
| 641252 | |
| Download: ML24222A723 (3) | |
Text
1239KIPKE DRIVE ANN ARBOR,MICHIGAN 48109-1010 (734)647-1143lFAX (734)763-1185 www.ehs.umich.edu
DANIELLE SHEEN,EXECUTIVE DIRECTOR
August8, 2024
Materials Licensing Branch U.S. Nuclear Regulatory Commission, Region III 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352 ATTN: Frank Tran/ Mail Control No. 641252
RE: Additional Information forAmendment Request University of Michigan,License No. SNM-179
Materials Licensing:
Thank you for yourresponseofJuly3, 2024, requestingadditional informationregarding the University of Michigansrequest to extend the term ofthe subject license.
Based on 10 CFR [70.34], provide the basis (ground) for requesting to extend the licenses expiration date for five years.
NRC approved 15-year license terms in 2017. The NMSS memo (ML17200D112, attached) outlines the administrative process, which requires licensees to formally request an extension; the memo does not state or suggest that a justification by the licensee is required. U-M previously requested extension of two other NRC licenses (without justification), and those requests were approved.
Extending the license term to 15 years isconsistent with NRCs intent to standardize the 15-year license term, would reduce the regulatory burden on the licensee (to renew the license sooner than 15 years), and would reduce the administrative burden on NRC (to review and approve thelicense renewal application sooner than 15 years).
Provide a statement that there have been no changes to the current license (Amendment No. 28),
including the statements, representations, and procedures contained in the documents listed in License Condition 17 of the license. Provide a description of changes, if any.
There have been no changes to the current license (Amendment No. 28), including the statements, representations, and procedures contained in the documents listed in License Condition 17 of the license.
Provide the following statement: Pursuant to 10 CFR 30.35(g), 10 CFR 40.36(f), and 10 CFR 70.25(g) and 10 CFR 70.51(b)(3), as appropriate, we will maintain records important to decommissioning and transfer these records to an NRC or Agreement State licensee before licensed activities are transferred or assigned, in accordance with 10 CFR 30.34(b), 10 CFR 40.46, and 10 CFR 70.36, as appropriate. Furthermore, pursuant to 10 CFR 30.51(f), 10 CFR 40.61(f), and 10 CFR 70.51(a)(3), as appropriate, prior to license termination, we will forward the records required by 10 CFR 30.35(g), 10 CFR 40.36(f), and 10 CFR 70.25(g), as appropriate, to the appropriate NRC Regional Office.
Pursuant to 10 CFR 30.35(g), 10 CFR 40.36(f), and 10 CFR 70.25(g) and 10 CFR 70.51(b)(3), as appropriate, we will maintain records important to decommissioning and transfer these records to an NRC or Agreement State licensee before licensed activities are transferred or assigned, in NRC Region III 2
accordance with 10 CFR 30.34(b), 10 CFR 40.46, and 10 CFR 70.36, as appropriate. Furthermore, pursuant to 10 CFR 30.51(f), 10 CFR 40.61(f), and 10 CFR 70.51(a)(3), as appropriate, prior to license termination, we will forward the records required by 10 CFR 30.35(g), 10 CFR 40.36(f), and 10 CFR 70.25(g), as appropriate, to the appropriate NRC Regional Office.
Provide a confirmation that the licensee has maintained a decommissioning financial assurance for the license in an amount of $225,000.00 and it is based on the possession limit of licensed material as required by 10 CFR 70.25(b)(2) and specified in 70.25(d).
U-M maintains decommissioning financial assurance for the subject license in the amount of
$225,000, based on the possession limit of licensed material as required by 10 CFR 70.25(b)(2) and specified in 70.25(d). A copy of the most recent Statement of Intent (dated March 21, 2024) is attached; it was submitted and mailed to NRC on March 28, 2024.
The licensee requested to replace the current Chairperson listed in the license with Peter J. H.
Scott, Ph.D. Based on Section 8.7.2 of NUREG-1556, Volume 11, Revision 1, the Chairperson should have knowledge in radiation safety issues, good leadership abilities, and the authority and credibility by virtue of his or her position. Please provide a brief information for the above for Peter J. H. Scott, Ph.D.
Dr. Scott is a Professor of Radiology (since 2023), Director of the Division of Nuclear Medicine (since 2021), and Director of the Cyclotron and Radiochemistry Facility (since 2012) at Michigan Medicine.
He has been a voting member of the U-M Radiation Policy Committee (RPC) since 2010, a member of the U-M Radioactive Drug Research Committee / Subcommittee on Human Use of Radioisotopes since 2009, and an RPC-approved Authorized User of radioactive material since 2012. He completed his postdoctoral training in radiochemistry in 2007, he is a member of (or serves in a leadership capacity for) several national and international professional societies relating to radiochemistry, and he serves on the editorial board of several peer-reviewed books and journals. He was appointed by the Executive Vice President / Chief Financial Officer (letter provided with amendment submission on June 4, 2024) after a vote of acceptance by the RPC.
Thank you for your consideration of this amendment request. Please contact me [(734) 647-2251 /
kfisch@umich.edu ] if you have any questions or comments.
Sincerely,
Karl W. Fischer, CHP Director / Radiation Safety Officer Radiation Safety Service / EHS
Attachments (2)
cc: Peter J. H. Scott, Ph.D., Chair, Radiation Policy Committee Materials License No. 21-00215-04 Files Martha Pavon
From: Frank Tran Sent: Friday, August 9, 2024 3:19 PM To: Martha Pavon; Tammy Tomczak Cc: Sandy Pavon
Subject:
FW: RE: Request additional information for NRC Materials License No. SNM-179 Attachments: Additional Info 2024-08-08 SNM-179.pdf; 665 641252 Additional information.pdf
Dear Martha,
Please add the attachment to ADAMS as additional information.
Thank you, Frank
From: Fischer, Karl <kfisch@med.umich.edu>
Sent: Thursday, August 8, 2024 3:18 PM To: Frank Tran <Frank.Tran@nrc.gov>
Subject:
[External_Sender] RE: Request additional information for NRC Materials License No. SNM-179
Dear Mr. Tran,
Please see the aached response to your request for addional informaon, along with the two aachments cited in the leer.
Thank you,
Karl Fischer, CHP Director / Radiation Safety Officer Radiation Safety Service / EHS kfisch@umich.edu 734.647.2251
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