ML24352A301
| ML24352A301 | |
| Person / Time | |
|---|---|
| Site: | 07000113 |
| Issue date: | 12/12/2024 |
| From: | Wilmot A Pennsylvania State Univ |
| To: | Stephen Poy NRC/NMSS/DFM/FFLB |
| Shared Package | |
| ML24352A300 | List: |
| References | |
| Download: ML24352A301 (1) | |
Text
PennState December 12, 2024 Stephen Poy Office of Physical Plant Environmental Health and Safety The Pennsylvania State University Steam Services Building 336 Steam Drive University* Park, PA 16802 U.S. Nuclear Regulatory Commission (NRC)
Office of Nuclear Material Safety and Safeguards (NMSS)
Division of Fuel Management (DFM)
Fuel Facilities Licensing Branch (FFLB)
Phone: 301-415-7135 Email: stephen.poy@nrc.gov Subj: Commitments for Transportation of Special Nuclear Materials License number:
SNM-95 Docket 070-00113
Dear Mr. Poy:
This letter is in follow-up to a visit to our site (the Steam Services Building and the University Park campus) from Mr. Alexander Sapountzis on November 19, 2024. Mr.
Sapountzis's visit was very helpful and informative, and during this time, Penn State University committed to sending a follow-up letter providing clarification of actions related to the security and transportation of Special Nuclear Materials across the University. Note that this letter serves that purpose, and the commitments in this letter are in addition to those conveyed in the submittals related to our recent license amendment (dated April 19, 2024 and October 21, 2024).
Specifically, Penn State makes the following commitments related to Special Nuclear Material operations under the SNM-95 license, which would encompass transportation of special nuclear materials (SNM) from the Steam Services Building (SSB) to one of the other licensed facilities on campus ( either the Academic Projects Building, APB, or the Radiation Science & Engineering Center, RSEC) across public roadways and along a route of approximately 1 mile in length:
- 1. Before beginning any operations involving SNM at the SSB, Penn State commits to developing a SNM Security Plan that will:
0 Require procedures to be developed providing instruction to staff transporting or storing SNM on steps to take in response to thefts or threats [10 CFR 73.67(g)(3)(i)]
Commit to retaining previous versions of these procedures for at least three years after each revision [10 CFR 73.67(g)(3)(i)]
Page 1 of 3
December 2, 2024 Commit to conducting a trace investigation for missing, stolen, or unaccounted-for SNM after the estimated arrival time [10 CFR 73.67(g)(3)(iii)(a)]
D Commit to notifying the United States Nuclear Regulatory Commission Operations Center by phone after discovery of the loss of the shipment and after recovery of or accounting for such lost shipment, in accordance with the provisions of 10 CFR 73.1200 and 73.1205 [10 CFR 73.67(g)(3)(iii)(b), 10 CFR 73.1200(d)(1)(i),10 CFR 73.1200(f)(1)(ix), 10 CFR 73.1205]
- 2. Penn State's procedures for receipt of a package containing Category III SNM at SSB will require staff to:
D Check and evaluate the package for container integrity and the integrity of any applied seals [10 CFR 73.67(g)(1)(iv)]
- 3. Penn State's procedures for receipt of a package containing 1 gram or more of SNM below Category III quantities or Category III SNM quantities at SSB will require staff to:
D To notify the shipper ofreceipt of the material, complete, and submit a computer-readable format Nuclear Material Transaction Report and Material Balance report in accordance with 10 CFR 74.15 [10 CFR 73.67(g)(2)(ii) and 10 CFR 74.15(a)]
- 4. Penn State's procedures for transport of a package containing Category III SNM from SSB to APB or the RSEC will require staff to:
D Check the integrity of the containers and seals prior to shipment [10 CFR 73.67(g) (1) (iv)]
Contact the receiver (someone at the intended laboratory) using direct, two-way communication before initiating transport and:
o Establish an estimated time of arrival and transport mode [10 CFR 73.67(g)(1)(i)]
o Confirm the receiver's readiness to receive the package based on the information established above [10 CFR 73.67(g)(1)(ii)]
Transport the material in a tamper-indicating sealed container
- 5. Penn State's procedures for delivery of a package containing Category III SNM to an intended laboratory at APB or the RSEC will require staff to:
D Ensure that the receiver (intended laboratory) immediately notifies the shipper (PSU EHS) that the package has been received [10 CFR 73.67(g)(3)(ii)]. Note that this is expected to take place as part of in-person communications at the time of delivery since deliveries of SNM materials will be made by PSU full-time staff.
D Confirm the integrity of the container and seals [10 CFR 73.67(g)(2)(i)]
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December 2, 2024
- 6. Penn State's procedures for responding to stolen, lost, or unaccounted for SNM during transit between the SSB and a receiving laboratory at either APB or the RSEC, will require staff to:
Conduct a trace investigation for missing, stolen, or unaccounted-for SNM after the estimated arrival time [10 CFR 73.67(g)(3)(iii)(a)]
D Notifying the United States Nuclear Regulatory Commission Operations Center by phone after discovery of the loss of the shipment and after recovery of or accounting for such a lost shipment, in accordance with the provisions of 10 CFR 73.1200 and 73.1205 [10 CFR 73.67(g)(3)(iii)(b), 10 CFR 73.1200(d)(1)(i),10 CFR 73.1200(f)(1)(ix), 10 CFR 73.1205]
If there are any questions or comments on these commitments, please don't hesitate to contact me using the information below.
Sincerely, J4-w~
Aaron Wilmot, MS, PE (nuclear, PA), CHP Manager, Radiation Protection Office I Radiation Safety Officer Radiation Protection Office I Penn State University Environmental Health & Safety 336 Steam Dr., Steam Services Building Suite 301 University Park, PA 16802 Phone: (814) 863-3976 Page 3 of 3 t-