ML25260A530

2 - Enclosure 1 - 2023 License Renewal Safety Evaluation Report (Public)

ML25260A530
Person / Time
Site:	07000152
Issue date:	11/19/2025
From:	Division of Fuel Management
To:
References
EPID L-2023-NFR-0000
Download: ML25260A530 (0)

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Enclosure 1 Safety Evaluation Report Special Nuclear Material License SNM-142 Renewal Application Purdue University 550 Stadium Mall Drive, West Lafayette, Indiana Docket No.70-152 Manuscript Completed: August 29, 2025 Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

ii TABLE OF CONTENTS Page I.

INTRODUCTION............................................................................................................ 6 II.

SCOPE OF REVIEW...................................................................................................... 7

1. General Information.................................................................................................. 8

2. Organization and Administration..............................................................................11

3. Integrated Safety Analysis and Management Measures..........................................14

4. Radiation Protection................................................................................................15

5. Nuclear Criticality Safety..........................................................................................28

6. Chemical Safety......................................................................................................33

7. Fire Safety...............................................................................................................34

8. Emergency Management.........................................................................................37

9. Environmental Protection.........................................................................................38

10. Decommissioning/Decommissioning Funding Plan and FInancail Assurance..........40

11. Radioactive Waste Management.............................................................................43

12. Physical Security: SNM at Fixed Sites and in Transport..........................................50

13. Material Control and Accounting..............................................................................56 III.

NATIONAL ENVIRONMENTAL POLICY ACT REVIEW..............................................60 IV.

CONCLUSION..............................................................................................................60 V.

PRINCIPAL CONTRIBUTORS......................................................................................60 VI.

REFERENCES..............................................................................................................61

iii LIST OF ACRONYMS AND ABBREVIATIONS 10 CFR.........................................Title 10 of the Code of Federal Regulations ADAMS.......................................Agencywide Documents Access and Management System AGN.............................................Aerojet-General Nucleonics ALARA.........................................As Low As Reasonably Achievable ANSI............................................American National Standard Institute CAA.............................................Controlled Access Area DAC.............................................Dose Assessment Coordinator DEO.............................................Director of Emergency Operations DOE.............................................U.S. Department of Energy DOT.............................................U.S. Department of Transportation DP................................................Decommissioning Plan EA................................................Environmental Assessment EH&S...........................................Environmental Health and Safety EIS...............................................Environmental Impact Statement ENDF...........................................Evaluated Nuclear Data File EP................................................Emergency Plan FBBF............................................Fast Breeder Blanket Facility FR................................................Federal Register HazMat........................................hazardous material ISA...............................................integrated safety analysis LAR..............................................license amendment request LRA.............................................license renewal application MC&A..........................................material control and accounting NCS.............................................nuclear criticality safety NDA/NDE...................................nondestructive assays and evaluation NFPA...........................................National Fire Protection Association NMMSS.......................................Nuclear Materials Management and Safeguards System NRC............................................U.S. Nuclear Regulatory Commission NVLAP........................................National Voluntary Laboratory Accreditation Program OSHA..........................................Occupational Safety and Health Administration OSLD...........................................optically stimulated luminescence dosimeter PSP.............................................Physical Security Plan 239Pu............................................Plutonium-239 Pu..................................................Plutonium RAI...............................................request for additional information RPP.............................................radiation protection program RS................................................radiation safety RSI..............................................request for supplemental information RSO.............................................radiation safety officer RTR.............................................research test reactor SCA.............................................subcritical assembly SER.............................................Safety Evaluation Report SI.................................................System of International units SNM............................................special nuclear material SPERT........................................Special Power Excursion Reactor Test Program SRP.............................................Standard Review Plan TLD..............................................thermoluminescent dosimeter T&R.............................................Trustworthy and Reliability TSO.............................................Technical Safety Office

iv 233U................................................Uranium-233 235U................................................Uranium-235 U..................................................Uranium U.S...............................................United States

v This page intentionally left blank.

6 I.

INTRODUCTION Special nuclear material license number 142 (SNM-142), issued in December 1957 was set to expire on September 25, 2023. There have been no major concerns identified with Purdue Universitys (Purdue or licensee) U.S. Nuclear Regulatory Commission (NRC)-regulated activities since the license was initially issued.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 70, Domestic Licensing of Special Nuclear Material, in July 2023 Purdue submitted an application for the renewal of the SNM-142 license for a period of 10 years. The NRC staff conducted an administrative review of the license renewal application (LRA) and noted that Purdue did not appropriately mark the information provided (i.e., Security-Related, Safeguards Information, other). The NRC staff contacted Purdue to discuss this issue and, subsequently, by letter dated September 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23268A087), Purdue re-submitted the application (with enclosures) with all the information appropriately marked. Because Purdues initial LRA was submitted at least 30 days before the expiration date stated in the existing license, in accordance with the requirements in 10 CFR Section 70.38, Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas, (a), the NRC staff determined in a timely renewal memo dated October 18, 2023 (ML23285A239), that the SNM-142 license was to remain in effect until the Commission makes its final determination on the LRA.

Purdues license renewal included the following

Enclosures:

License Renewal Application - ML23268A078 (Non-Public)

Appendix A Emergency Plan - ML23268A077 (Non-Public)

Appendix A.2 - Security Plan for the Purdue University Reactor, the Fast Breeder Blanket Facility, and Nuclear Fuel Storage Areas (Safeguards Information (SGI) - Non-Public) - ML23268A075 Appendix A Technical Specifications - ML23268A074 (Non-Public)

Appendix A Operating Principles and Core Characteristics Manual - ML23268A081 (Non-Public)

Appendix A Safety Analysis Report - ML23268A076 (Non-Public)

Appendix A Standard Experiment Procedure - ML23268A079 (Non-Public)

Appendix A Fuel Inventory Example (SGI - Non-Public) - ML23268A075 Appendix A Purdue University Research Reactor (PUR-1) ALARA Program -

ML23268A082 The NRC staff conducted an administrative review of Purdues September 18, 2023, LRA and determined that the LRA contained sufficient technical information. As such, by letter dated December 13, 2023 (ML23324A448), the NRC staff accepted Purdues LRA to proceed with its detailed technical review. In its acceptance letter the NRC staff included observations on information that it could request later during the technical review of the LRA. Initial observations were provided to Purdue to enable expedited resolve of the observations. The observations in the acceptance letter were the following:

The application was not updated to include financial awareness of the Nuclear Energy Innovation and Modernization Act and the requirements therein; The material control and accounting (MC&A) portions of the application included

7 outdated regulatory citations (10 CFR Part 74, Material Control and Accounting of Special Nuclear Material, now covers these requirements);

The radioactive waste management program at Purdue is tied to the NRCs broad scope license under 10 CFR Part 33 and therefore the application must highlight what commitments are needed for the renewal of this 10 CFR Part 70 SNM license.

On November 30, 2023, the NRC staff conducted a conference call with Purdue staff to discuss the observations above and obtain clarification of the information related to these three areas.

Based on the discussions during the call, the Purdue staff identified non-public documents that would provide additional information to address the NRC staff concerns. Following the call, the NRC staff conducted a virtual audit of the documents and determined that they included sufficient information to proceed with the detailed technical review. However, the NRC staff determined that additional information may be needed to resolve the observations.

On February 9, 2024, the NRC published a notice of receipt of Purdues LRA with an opportunity for the public to request a hearing and petition for leave to intervene in the Federal Register (89 FR 9182) (ML24005A120). However, the NRC did not receive a request for a hearing or for a petition for leave to intervene.

The NRC staffs detailed technical review identified additional information that was needed before final action on the LRA could be taken. On February 21, 2024, at Purdues request, the NRC conducted a public meeting (ML24061A046) to generally discuss the draft request for additional information (RAI). The meeting discussions were aimed at ensuring that there was mutual understanding, by the applicant and the NRC staff, of the questions in the RAI. Following the meeting, by letter dated February 23, 2024 (ML24032A473) the NRC staff issued the RAI.

Purdue provided its response to the request for additional information (RAI) (with enclosures) by letter dated March 25, 2024 (ML24086A454).

II.

SCOPE OF REVIEW The NRC staff conducted its safety and safeguards review in accordance with 10 CFR Part 70, Domestic Licensing of Special Nuclear Material; 10 CFR Part 20, Standards for Protection Against Radiation; 10 CFR Part 73, Physical Protection of Plants and Materials; 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material; and other applicable regulations. The NRC staff used the guidance in Draft NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H (ML22335A087), NUREG-1520, Standard Review Plan (SRP) for Fuel Facilities License Applications, Revision 2 (ML15176A258), and NUREG-1556, Volume 11, Program-Specific Guidance About Licenses of Broad Scope, Revision 1 (ML17059D332). This safety evaluation report (SER) documents the NRC staff review and findings regarding Purdues LRA, which included the review of the information submitted by Purdue in its September 18, 2023 LRA (ML23268A087), Purdues March 25, 2024 responses (ML24086A458) to the NRC staffs February 23, 2024 RAI (ML24032A472), and Purdues compliance history.

The LRA consisted of ten sections: (1) 10 CFR 70.22(a)(1) - list of individuals (names, titles and citizenship of the Purdue staff in charge of the SNM-142 licensed program); (2) 10 CFR 70.22(a)(2), Activity and Location for which Special Nuclear Material is Requested; (3) 10 CFR 70.22(a)(3), Requested duration of license; (4) 10 CFR 70.22(a)(4), Description of Special Nuclear Material; (5) 10 CFR 70.22(a)(6), Technical Qualifications of Applicant; (6) 10 CFR

8 70.22(a)(7), Facilities and Equipment for Handling Special Nuclear Material; (7) 10 CFR 70.22(a)(8), Safety Procedures to Protect Health and Minimize Danger to Life or Property; (8) 10 CFR 70.53 and 70.54, Material Control and Accountability; (9) 10 CFR Part 73, Physical Protection of Plants and Materials; and, (10) 10 CFR 70.25, Financial Assurance and Recordkeeping for Decommissioning. The LRA initially included public and non-public versions of the application (ML23268A075 and ML23268A078, respectively).

In its March 25, 2024 letter (ML24086A454), Purdue enclosed public (ML24086A456) and non-public (ML24086A455) versions of its response to the NRC RAI, a copy of its August 3, 2012 license amendment request to allow the transfer [REDACTED]. After reviewing Purdues responses to the RAI, the NRC staff determined that clarification to Purdues response to RAI number (MC&A-5, regarding written procedures for MC&A was needed. The NRC requested Purdue to provide the information via electronic communication dated May 16, 2024 (ML24165A207). Purdue provided the additional information by letter dated May 20, 2024 (ML24165A206).

1.0 GENERAL INFORMATION 1.1 Purpose of Review The NRC staff reviewed the information about Purdue University discussed in Section 1 of the LRA against the acceptance criteria in Section 1, General Information, of Draft NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H (ML22335A087), and Section 1, General Information, of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2 (ML15176A258), to determine whether the license application included adequate information identifying the applicant, the applicants characteristics, and the proposed activities.

1.2 Staff Review and Analysis 1.2.1 Facility Layout In accordance with the requirements in 10 CFR 70.22(a)(7), in Section 6, 10 CFR 70.22(a)(7)

Facilities and Equipment for Handling Special Nuclear Material, Purdue describes its facilities and equipment for protecting health and safety, minimize danger to life or property, for protecting the environment, and maintain radiation doses as low as reasonably achievable (ALARA).

In Section 6.1, Areas of Storage and Use, of its LRA, Purdue states that the main areas where SNM will be used and/or stored are in the Electrical Engineering Building (EE Building) and the Physics Building. In addition, other locations may be used from time to time when approved by the Radiation Safety Committee (RSC).

9

[REDACTED]

Housed Radioactive Material Radioactive materials authorized under the SNM-142 license are [REDACTED]

Equipment In Section 6.2, Shields, Equipment, and Handling Devices, of its LRA, Purdue stated that fuel elements are handled using an 18 ft aluminum fuel retriever, arranged with two hooks that link to the fuel element. There is no direct handling of fuel elements. The fuel elements will be handled in accordance with proper written procedures approved by Purdues Committee on Reactor Operations and the RSC. All other items allow for direct handling of the material and will be done only by individuals with proper radiation safety training and the concepts of "time, distance, and shielding."

In Section 6.3, Measuring and Monitoring Devices, Purdue discusses the equipment used for monitoring radiation doses and its radiation survey equipment. Purdue stated that film badges or other devices such as thermoluminescent dosimeters (TLDs) or optically stimulated luminescence dosimeters (OSLDs) are generally used as personnel monitors of radiation exposure. Any person working with SNM is required to wear personnel monitoring devices whenever entering a restricted radioisotope area under conditions where the individual is likely to receive a dose in excess of 10 percent of the limits specified in 10 CFR 20.1502. In addition, pocket dosimeters or digital dosimeters may be worn by personnel in addition to film badges in cases where exposures would reasonably be anticipated. Pocket dosimeters or digital dosimeters may be utilized in lieu of film badges for individuals entering restricted areas on an infrequent or temporary basis. The film badges, TLDs, and/or OSLDs are read monthly or bimonthly (once every two months) using a National Voluntary Laboratory Accreditation Program accredited supplier. An annual review, not to exceed 14 months, is made of personnel exposures. In cases where individual monthly doses exceed 100 millirem, the Radiation Safety Officer (RSO) will notify the individual (or his/her supervisor) of the exposure as a means of alerting the individual to the occurrence of the dose. Individuals who infrequently enter restricted areas who are provided with a pocket dosimeter or a digital dosimeter, read out their dosimeters immediately upon leaving the restricted area. These results are recorded by the Reactor Team in a logbook and kept on file.

Several radiation area monitoring systems are in place in [REDACTED]. These monitors include digital sodium iodide detectors for radiation area monitors, a continuous air monitor, and a radiation area monitor which has communication [REDACTED].

1.2.2 Process Overview In accordance with the requirements in 10 CFR 70.23(a)(1), in part, an application for a license will be approved if the Commission determines that radioactive material (RAM) will be used for the conduct of activities licensed by the Commission under Section 103 or 104 of the Atomic Energy Act of 1954, as amended, or for such other uses as the Commission determines to be appropriate to carry out the purposes of the Act.

The regulations in 10 CFR 70.22(a)(2), require that an applicant describe the activities for which the RAM is requested. Accordingly, in Section 2, Activity and Location for which Special Nuclear Material is Requested, of its LRA, Purdue discusses the activities for which RAM will

10 be used. Purdue stated that it intends to use SNM in the form [REDACTED] solid helices and discs to measure the effects of rare earth additions on the thermal properties of UO2 and to measure the effects of elevated temperatures on the mechanical properties of UO2. Purdue further stated that typical experimental procedures involve heating solid discs or helices of various 235U enrichment [REDACTED]. Other various samples of both enriched and natural uranium may be obtained for non-destructive testing, chemical and thermal analysis, and other analytical and developmental techniques. Encapsulated Plutonium/Beryllium (Pu/Be) neutron sources are employed in activation analysis studies, for instrument calibration, for neutron studies in a subcritical exponential pile, and for other research approved by the RSC. In its LRA, Purdue noted that the natural uranium subcritical pile is separately licensed under their NRC Source Material License number 296 (SUD-296).

Uranium-235 in the form of Special Power Excursion Reactor Test Program (SPERT)1 fuel rods

[REDACTED]. These operations have been suspended and this material will be stored in place until further notice. The FBBF is a small [REDACTED] consists of a central region composed of

[REDACTED] fuel rods to provide the surrounding blanket mockup with a neutron spectrum typical of that found in the core blanket interface of a large liquid metal fast breeder reactor[REDACTED] The FBBF is subcritical with Keff of less than 0.43. The FBBF was originally driven by 252Cf spontaneous fission neutron sources [REDACTED] remain in place until the facility is decommissioned.

1.2.3 Descriptive Summary of Licensed Material and Possession Limits In accordance with 10 CFR 70.22(a)(4), in Section 4, 10 CFR 70.22(a)(4) Description of Special Nuclear Material, of its LRA, Purdue identified the forms, quantities, and specifications of the SNM it requests authorization to possess and use as follows:

6. Byproduct, Source and/or Special Nuclear Material

7. Chemical and/or Physical Form

8. Maximum that Licensee May Possess at Any One time Under This License A

Uranium enriched in the

[REDACTED]

SPERT fuel rods, enriched < 4.8 w/o

[REDACTED]

B Uranium enriched in the

[REDACTED]

Fuel rods, enriched < 1.3 w/o

[REDACTED]

C Uranium enriched in the

[REDACTED]

Solid helices, enriched < 20 w/o

[REDACTED]

D Uranium enriched in the

[REDACTED]

Solid discs, enriched < 3 w/o

[REDACTED]

E Uranium enriched in the

[REDACTED]

Samples, enriched < 20 w/o

[REDACTED]

F Plutonium Encapsulated Pu/Be neutron sources

[REDACTED]

G Natural Uranium U02 pellets clad in aluminum

[REDACTED]

H Natural Uranium Samples, any form

[REDACTED]

I Californium 10 doubly encapsulated sources

[REDACTED]

J Uranium 233 Calibration Sources

[REDACTED]

Neptunium 237 Calibration Sources

[REDACTED]

1 The SPERT Program was a series of tests focusing on the safety of nuclear reactors.

11 K

Plutonium 239 Calibration Sources

[REDACTED]

L Curium 244 Calibration Sources

[REDACTED]

M Uranium, enriched in the

[REDACTED]

Solid, Oxide or nitrate enriched w/o in contaminated equipment

[REDACTED]

Purdue included a completed NRC Form 313, Application for Materials License.

(ML25240B601) In item 3, Address Where licensed Materials Will be Used, of NRC Form 313, Purdue provided the following information in accordance with the requirements in 10 CFR 70.22(a)(2) as the places where SNM will be used or possessed:

[REDACTED] In Section 2, Activity and Location for which Special Nuclear Material is Requested, Purdue stated that the SNM [REDACTED]

In accordance with the requirements in 10 CFR 70.23(a)(1), in part, an application for a license will be approved if the Commission determines that radioactive material (RAM) will be used for the conduct of activities licensed by the Commission under Section 103 or 104 of the Atomic Energy Act of 1954, as amended, or for such other uses as the Commission determines to be appropriate to carry out the purposes of the Act.

1.3 Evaluation Findings

The NRC staff reviewed the LRA and concluded that Purdue adequately described its facility and the proposed uses of the SNM for which the renewal is sought. Therefore, the NRC staff concludes that the information in the Purdue application and supplements is consistent with the applicable criteria within NUREG-1520 and meets the requirements of 10 CFR 70.22 and 10 CFR 70.33 and is acceptable.

2.0 ORGANIZATION AND ADMINISTRATION 2.1 Purpose of Review The NRC staff reviewed the applicants organization and the qualifications of administrative and radiation protection personnel to determine if Purdues LRA meets the requirements of 10 CFR 70.22(a)(6) and § 70.23(a)(2). Purdue provided the technical qualifications of these individuals in Appendix A.9, Resumes for Reactor Team and Radiation Safety Team, of its LRA. These qualifications and duties are discussed below. The administration of the facility involves operations, organizational structure, and facility security. An application should present information on the facilitys organization, training programs, operational reviews and audits, radiation protection procedures and actions, records keeping and reports. The following discussion summarizes information provided by the applicant and the NRC staffs evaluation as to whether the information provided by the applicant satisfies the regulatory requirements of 10 CFR 70.22(a)(6) and § 70.23(a)(2).

2.2 Staff Review and Analysis In item 4 of Form 313, Purdue identified Mr. Joshua A. Young, RSO, as their contact for LRA.

However, by letter dated February 26, 2024 (ML24064A056), due to Mr. Youngs departure on March 8, 2024, Purdue requested the NRC to approve Mr. Nathan Claus as the new RSO. The request included Mr. Claus contact email and phone number. The NRC evaluated Mr. Claus qualifications and determined that he meets the Purdue training and experience requirements

12 for an RSO (see also Section 2.2.7.1 of this document).

In accordance with the requirements in 10 CFR 70.22(a)(1), in Section 1, 10 CFR 70.22(a)(1),

of its LRA, Purdue listed the officials in charge of its SNM-142 licensed program. These individuals include the following:

Eric Butt, Senior Director Environmental Health and Safety Nathan Claus, Radiation Safety Officer Environmental Health and Safety Seungjin Kim, Ph.D., Head/Director Department of Nuclear Engineering/Reactor Facility Department Of Nuclear Engineering True Miller, Reactor Supervisor Department of Nuclear Engineering Brian Jowers, Nuclear Electronics Technician Department of Nuclear Engineering Purdue noted that the above listed individuals are U.S. citizens.

In accordance with the requirements in 10 CFR 70.22(a)(6), in Section 5, 10 CFR 70.22(a)(6)

Technical Qualifications of Applicant, of its LRA Purdue identifies and discusses the technical qualifications and duties of its radiation protection personnel directly responsible for the activities conducted under the SNM-142 license. Purdue also provided the technical qualifications of these individuals in Appendix A.9, Resumes for Reactor Team and Radiation Safety Team, of its LRA. These qualifications and duties are discussed below.

Radiation Safety Staff Department of Nuclear Engineering Staff Purdues radiation safety staff (RSS) currently includes the following individuals within the Department of Nuclear Engineering: Dr. Seungjin Kim, head of the Department of Nuclear Engineering and Reactor Facility Director, Mr. True Miller, Reactor Supervisor, Department of Nuclear Engineering, and Mr. Nathan Claus, RSO. The NRC staff reviewed the technical qualifications provided by Purdue in Appendix A.9 of its LRA, on these individuals and noted the following:

a. Dr. Seungjin Kim, Head of Nuclear Engineering Department, Reactor Facility Director Dr. Kim holds a Ph.D. in Nuclear Engineering completed at Purdue University in 1999.

He has been a professor of nuclear engineering at Purdue since 2017 and, previously, professor of nuclear engineering at the Pennsylvania State University (2007-2016) and the University of Missouri 2003-2007). Dr. Kim a member of the American Nuclear Society since 1997, the American Society of Mechanical Engineering (ASME, 2001-2019), the Korean American Scientists and Engineers Association (KSEA) since 2004, the Korea Nuclear Society (KNS) since 2014, and a consultant for the Korean Atomic

13 Energy Research Institute. He has held leading roles in technical conferences discussing issues of importance in the nuclear field and has made a significant number of journal publications and lectures in the nuclear field since 1995. He also possesses vast research experience, such as in the areas of thermal-hydraulics and reactor safety and reactor thermal-hydraulics system analysis code development. For his work and accomplishments, he has been honored by the Nuclear Energy Advisory Committee, Office of Nuclear Energy, U.S. DOE, in 2018 and again in 2019.

b. True Miller, Reactor Supervisor Mr. Miller holds an M.S. degree completed at the Purdue School of Nuclear Engineering and is currently employed as the reactor supervisor for Purdues PUR-1 research reactor. He is currently pursuing a PhD in the same field also at Purdue and, since 2022 he has been the nuclear engineering radiation laboratories Assistant Director. His experience in this position includes being responsible for performing simulations and calculations to ensure experiments performed with the PUR-1 are safe and remain within the required technical specifications, organizing and training individuals on proper techniques and operation of the PUR-1 reactor, facilitating research partnerships using the PUR-1 for both private industry and academia, managing the biennial maintenance cycle of the PUR-1 as well as the quarterly operator requalification training, and creating and fine-tuning a high-fidelity Monte Carlo N-Particle Transport model of the PUR-1 reactor. Mr. Miller currently maintains an active senior reactor operator license and has extensive experience operating and maintaining the PUR-1 research reactor as well as in validation and verification work using nuclear code systems.

c. Nathan Claus, Radiation Safety Officer At the time of the LRA submittal (September 2023), Purdue stated that the RSO was Mr.

Joshua Young. However, by letter dated February 26, 2024 (ML24064A056), due to Mr.

Youngs departure on March 8, 2024, Purdue requested the NRC to approve Mr. Nathan Claus, as the new RSO, and who was occupying the RSS Health Physicist (HP) position at the time of Mr. Youngs departure. Therefore, the NRC staff did not evaluate Mr.

Youngs technical qualifications.

In its February 26, 2024, letter Purdue stated that Mr. Claus meets the qualification and training requirements found in NUREG-1556 Volume 11, "Consolidated Guidance About Materials Licenses-Program-Specific Guidance About Licenses of Broad Scope."

Moreover, in Appendix A.9 of its LRA, Purdue provided Mr. Claus academic qualifications, training, and experience that demonstrates he is qualified to perform the duties required under the license. The NRC staff evaluated Mr. Claus qualifications and noted that, for the RSO position, Purdue requires the individual to hold a bachelors degree in health physics and experience in the radiation safety field. The NRC staff noted that, as required by Purdue, Mr. Claus holds a bachelors degree (B.S.) in nuclear engineering with a minor in radiological protection engineering completed at the Texas A&M University in May 2021. In addition, Mr. Claus holds a masters degree (M.S.) in health physics from Purdue completed in May 2024. Since September 2021 he has been a HP at Purdue assisting the RSO in administering the radiation safety staff and managing the radiation safety program, ensuring that use of radioactive materials is consistent with recommendations and requirements of the RSC, and ensuring compliance of the radiation safety program with state and federal regulations and NRC license conditions. In addition, Mr. Claus is in charge of providing training and

14 recommendations to individuals that use radioactive materials and performing any other duties associated with the RSO position. Based on the information provided by Purdue, the NRC staff determined that Mr. Claus meets Purdues qualifications for the RSO position under the SNM-142 licensed program.

In addition to the above listed individuals/positions, the RSS is supported by the following, additional individuals/positions:

Health Physicist There is one HP position in Purdues RSS. This individual is required to have a B.S degree in health physics or a related area such as Nuclear Engineering. If the degree is in a related area, experience in a medical or university health physics program is highly desirable.

Environmental Technician The three Environmental Technicians in Purdues RSS are required to have a high school diploma but no other relevant experience. These individuals work under the supervision of the RSO and/or the HP.

Student Assistants These individuals, which include work-study students (for paid wages or course credits) and undergraduate/graduate interns are hired to perform basic health physics tasks or other related tasks under the supervision of members of the RSS. No previous experience is required.

Based on the information provided by Purdue in its LRA, the NRC staff finds that Purdues RSS possess appropriate experience with varying levels of qualifications and corresponding levels of responsibilities for adequately protecting public health and safety and the environment and for safely conducting the activities licensed under the SNM-142 license.

2.3 Evaluation Findings

Purdue described its organization and management policies for providing adequate safety management for the safe operation of the facility.

The NRC staff reviewed the organizational structure and policies and found them acceptable for the following reasons: the management and technical support structure is clear with respect to assignments of primary responsibility and the Purdue management team is qualified, experienced, and has appropriate written procedures in place. The NRC staff determined that the organization and administration for Purdue is consistent with the applicable criteria in NUREG-1520. The NRC staff also finds that the radiation protection program (RPP) meets the requirements of 10 CFR 70.22(a)(6) and § 70.23(a)(2).

3.0 Integrated Safety Analysis Summary and Management Measures The NRC staff reviewed the LRA to determine whether Purdue was required to provide Integrated Safety Analysis (ISA) Summary information, pursuant to the provisions in 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, Subpart H, Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of Special Nuclear Material. The NRC staff determined that Subpart H requirements are not applicable to Purdue because its

15 proposed activities do not include enriched uranium processing, fabrication of uranium fuel or fuel assemblies, uranium enrichment, enriched uranium hexafluoride conversion, plutonium processing, fabrication of mixed-oxide fuel or fuel assemblies, or scrap recovery of special nuclear material, and otherwise are not within the scope of 10 CFR 70.60, Applicability.

Therefore, Purdue is not required to provide ISA Summary information nor maintain a management measures program.

4.0 Radiation Protection 4.1 Purpose of the Review The NRC staff conducted this review to assess whether the RPP described in Purdues LRA is adequate to protect radiological health and safety of workers and the public and complies with the regulatory requirements in 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, and 10 CFR Part 70.

An acceptable RPP will satisfy the relevant regulatory requirements of 10 CFR 70.23(a)(3) and (4). The LRA will be approved if it is determined that the proposed equipment and facilities are adequate to protect health and minimize danger to life or property, and the applicant's proposed procedures to protect health and to minimize danger to life or property are adequate. Section 15 of this report discusses protection of the public and the environment.

4.2 Staff Review and Analysis 4.2.1 Commitment to Radiation Protection Program Implementation The RPP is the means by which the licensee meets the requirements of 10 CFR Part 20.

Pursuant to the requirements in 10 CFR 20.1101, Radiation Protection Programs, an RPP must include: (1) development, implementation, and documentation of an RPP; (2) ALARA program; (3) periodic review of the RPP; and (4) a constraint on air emissions of radioactive material to the environment.

In its license application, Purdue provided a description of its RPP for meeting the requirements of 10 CFR 20.1101. Among other things, it describes practices for personnel monitoring (Section 6, Measuring and Monitoring Devices, and Section 7, Monitoring Procedures),

training (Section 7.4, Training Program, and Section 7.5, As Low As Reasonably Achievable (ALARA)), leak testing sources (Section 8, 10 CFR 70.53 and 70.54, Material Control and Accountability), maintaining dose rates ALARA (Section 7.5, As Low As Reasonably Achievable (ALARA)), and waste disposal (Section 6.4, Radioactive Waste Disposal). The license application also discussed the roles and responsibilities of the different individuals implementing the RPP.

The RSC and the RSO - and/or their staff - conduct reviews of new uses of radiation or materials and major modifications of facilities, which could change personnel exposures or result in radioactive material releases, as well as periodic reviews of radiation doses of staff, students, and visitors to ensure these are kept ALARA. Purdue documents the results of these reviews and any actions that may need to be taken to address any issues.

16 Development, implementation, and documentation of an RPP The regulations in 10 CFR 20.1101(a) require that an applicant develop, document, and implement an RPP commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions 10 CFR Part 20.

In its LRA, Purdue stated that its RPP includes practices for leak testing sources, maintaining dose rates ALARA, waste disposal, personnel monitoring and training, periodic reviews, and a constraint on dose rates on air emissions above the reactor pool. In its LRA, Purdue discussed the roles and responsibilities of the different individuals implementing the RPP. Subsequent sections provide more detail of each element of the RPP as well as an evaluation against the relevant regulatory requirements.

ALARA program See Section 4.2.2 below.

Periodic review of the RPP The regulations in 10 CFR 20.1101(c) require licensees to periodically (at least annually) review the RPP content and implementation.

In its LRA, Purdue stated that it calibrates radiation monitors annually and that the status of SNM will be verified by annual inventory every 12 months. The status of the fuel assemblies will be monitored by leak tests of the sources on a 6-month cycle. A sample will be taken of the entire assembly. It will be analyzed for radioactive contamination with the appropriate instrument capable of detecting the presence of radioactive material. Purdue maintains instrumentation for the determination of contamination, exposure rates, and radioactivity in solid and liquid samples.

Survey instruments are required to be calibrated at least annually.

A constraint on air emissions of radioactive material to the environment The regulations in 10 CFR 20.1101(d) state, in part, that to implement the ALARA requirements of 10 CFR 20.1101(b), a constraint on air emissions of radioactive material to the environment shall be established such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 millirem (mrem) (0.1 millisieverts (mSv)) per year from these emissions.

The NRC staff evaluated Purdues implementation of its ALARA program regarding air emissions using the regulatory acceptance criteria in NUREG-1520. As noted by Purdue in Section 6.4., Radioactive Waste Disposal, of its LRA, there is little to no radioactive waste associated with this license. Since all of Purdues SNM is encapsulated, there is no ventilation monitoring in the room where experiments will be performed and water in the test loop will be monitored to ensure it meets the limits in 10 CFR 20, Appendix B prior to disposal. If low-level waste is created, it will be collected and disposed of in accordance with Purdue Environmental Health and Safety written procedures. The NRC staff determined that this commitment to monitoring liquid effluents ensures that Purdue would meet the 10 CFR 20 regulatory limits.

In Section 6.1, Areas of Storage and Use, Purdue stated that both, outside air supply and exhaust, pass through HEPA filters which are periodically monitored for activity and integrity.

The reactor room is maintained at negative air pressure (minimum 0.05 in. of water). All doors to

17 the reactor room are fitted with rubber seals. Warm and cold-water supply is provided to the room. There is a heater for the room, and an air conditioner circulates and cools the reactor room air.

With regard to contamination that has been identified in historical routine surveys, Purdues LRA includes key considerations, as well as details of the operations that have been conducted in the past. The NRC staff review of these operations concluded that none of the enriched uranium fuel rods have been opened, but that some natural uranium rods have been opened, and uranium oxide pellets were removed while in a glove box (ML12067A120). The NRC staff review also determined that the exhaust air was filtered by a HEPA filter. Air samples were taken during operations. However, all samples were negative for uranium in the air exhausted to the ductwork and environment and no contamination from sealed sources was found.

4.2.2 A Documented Management Commitment to Keep Exposure ALARA The regulations in 10 CFR 20.1101(b) require that a licensee use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as reasonably achievable (ALARA).

The ALARA program at Purdue consists of an HP responsible for reviewing proposed new uses of radiation or radioactive materials, and major modifications of facilities which could change personnel exposure or radioactive material releases. The HP staff shall ensure that radiological activities are carried out in accordance with ALARA principles. All radiological activities at the facility undergo assessment by the RSC to evaluate key ALARA concepts such as time, distance, and shielding. The RSC is also responsible for:

1. Reviewing plans, specifications, and procedures for activities of the FBBF and taking appropriate action.

2. Reviewing any significant proposed changes in design, activities, or decommissioning of the FBBF. Committee approval or RSO approval is required in advance of initiating such changes.

3. Approving activities associated with the FBBF.

4. Authorizing personnel to work in the facility.

5. Overseeing all radiation safety aspects of the FBBF, including routine surveys, leak tests, personnel monitoring, instrument calibration, emergency procedures, and inventory.

Procedures used in teaching, research, and decommissioning activities of the FBBF are reviewed for safety by the RSC and the RSO and/or his staff. Any active procedures will be approved by the RSC and updated at least every 2 years. Currently, the only active procedures involve the use of Pu/Be sources for teaching purposes related to the subcritical pile licensed under Purdues source material license SUD-296.

The radiation protection staff monitors any individual likely to receive 100 mrem in a 2-month reporting period. A report is sent by radiation protection staff to the individual requiring response indicating actions taken to reduce exposures. Exposures greater than 25 percent of the regulatory limits are investigated for causes. Recommendations are made by health physicists to reduce exposures percent of the annual dose limits. The senior HP and the Reactor Operations Committee will periodically assess radiation dose to staff, students, and visitors.

18 4.2.3 Organization and Personnel Qualifications The regulations in 10 CFR 70.22, Contents of applications, (a)(6) require that an application for a license shall contain information regarding the technical qualifications, including training and experience of the applicant and members of his staff to engage in the proposed activities.

In its LRA Purdue provided a general description of its RPP organization. Section 1.3, Radiation Safety Committee, of Purdues Radiation Safety Manual (https://www.purdue.edu/ehps/rem/documents/programs/radman.pdf) states that the RSC regulates the use of radioactive materials. The RSC establishes policies and procedures for the safe use of radioactive materials and is composed of faculty and staff who by their knowledge and experience are qualified to make judgments in radiation safety in accordance with Purdues policy on Environmental Health and Safety Compliance (EHSC) issued May 1, 2011, and revised May 1, 2021. The policy also lists key individuals responsible for the RPP and their respective responsibilities. These individuals are:

Senior Director, Environmental Health and Public Safety (EHPS) administers the EHSC policy with the assistance of the department staff Associate Vice President for Research, Regulatory Affairs provides administrative guidance for systemwide safety committees Director, Purdue Environmental Health and Safety (EHS) Department carries out the policies and procedures established by the RSC through the RSO assists the Senior Director, EHPS, in administering the EHSC policy assists the appropriate Chancellor, vice president, vice provost or dean with implementation of required program responsibilities for environmental, health, safety and preparedness conducts annual safety audits and organizational inspections in accordance with the ISP provides qualifying organizations with Purdues Integrated Safety Plan certification RSO member of the EHS responsible for day-to-day operations including o managing the radiation doses to staff, o managing the RPP, o ensuring compliance of the RPP with State and Federal regulations and NRC license conditions, o providing training and recommendations to individuals that use radioactive materials, o serving as representative of the University to regulatory agencies to act in licensing matters, o providing corrective action when deficiencies are identified, and o reviewing procedures, policies, and practices as part of annual reporting.

The administration of the RPP at Purdue is the responsibility of EHS. The REM office consists of the RSO and its staff, which includes health physicists, technicians, and student assistants.

The RSO, who currently holds a Master of Science degree in health physics, is responsible for the overall implementation of the RPP as well as reviewing and approving minor deviations in work procedures (equivalent to "Radiation Work Permits"). The RSO is further authorized to take action on radiological safety concerns without further administrative approval. In addition, the RSO has a policy for not allowing employees and/or students to conduct radiation-related

19 work, nor any hazardous function to begin, unless all individuals have received all the appropriate training and have been properly authorized.

4.2.4 Written Procedures The regulations in 10 CFR 70.22, Contents of Applications, (a)(8) states that each application for a license shall contain proposed procedures to protect health and minimize danger to life or property. In Section 2, 10 CFR 70.22 Contents of Applications, (a)(2), states that each application shall contain activity for which the special nuclear material is requested, or in which special nuclear material will be produced, the place at which the activity is to be performed and the general plan for carrying out the activity.

Purdue stated that procedures used in teaching, research, and decommissioning activities will be reviewed for safety by the RSC and the RSO and/or his/her staff, and that any active procedures will be approved by the RSC and updated at least every 2 years. Staff, researchers, and students, regardless of prior experience, shall review the procedures, instructions, and other internal rules (e.g., the Radiation Safety Manual) during training as radiation workers and at regular intervals after initial training. Rather than having procedures which cover only this SNM program, the licensee uses joint procedures which cover both the research and test reactor program and the SNM programs. All personnel with the potential for receiving significant exposure from X-ray, gamma, high-energy beta, and neutron radiation are required to wear appropriate dosimeters. Sources are leak tested in accordance with the requirements in 10 CFR 39.35, Leak testing of sealed sources, and users are required to, semiannually, conduct an inventory of all radioactive materials possessed and used and to maintain these records at all times.

4.2.5 Radiation Safety Training The regulations in 10 CFR 70.22, Contents of Applications, (a)(6) require that each application for a license shall contain the technical qualifications, including training and experience, of the applicant and members of his staff to engage in the proposed activities. The regulations in 10 CFR 19.12, Instruction to workers, (a) specify the training requirements for all individuals who in the course of employment are likely to receive in a year an occupational dose in excess of 100 mrem (1 mSv).

The NRC staff reviewed Purdues training commitments against the acceptance criteria in NUREG-1520, Section 4.4.5.3. The following discussion identifies each acceptance criterion from NUREG-1520 and provides the staffs evaluation as to whether the information provided by the applicant is consistent with the criterion:

(1) Design and implement an employee RP training program that complies with the requirements of 10 CFR Parts 19 and 20.

In Section 7.4, Training Program, of its LRA, Purdue stated that all radiation workers receive instruction in accordance with 10 CFR 19.12 prior to beginning work with licensed material.

Radiation workers are initially trained by the RSO and his staff. Purdue further stated that this training program covers the following topics:

Purpose of Environmental Health and Safety Principles of ALARA Special notices (e.g. results from latest NRC inspection)

20 Prenatal Exposures (i.e., NRC Regulatory Guide 8.13)

Discussion of 10 CFR Parts 19 and 20 Personnel dosimetry and exposure limits Hazards associated with commonly used isotopes Decontamination and accident procedures Waste management procedures Marking and labeling of facilities and equipment Demonstration of survey techniques (2) Provide training to all personnel and visitors entering restricted areas, that is commensurate with the health risk to which they may be exposed or provide trained escorts.

In Section 6.3, "Measuring and Monitoring Devices, of its LRA Purdue discusses its requirements for accessing restricted radioisotope areas where individuals are likely to receive a dose in excess of 10 percent of the limits specified in 10 CFR 20.1502. Purdues operating procedures require that all individuals using radioactive materials on campus must be approved by the RSO, the RSC, or the Committee on Reactor Operations (if procedures specifically involve the PUR-1 reactor) to ensures that only qualified and specifically trained personnel carry out work with radioactive material, in a manner that provides adequate safety measures within their procedures for protection of researchers and the general public (see LRA, Section 7.2, Operating Procedures).

(3) Provide a level of training based on the potential radiological health risks associated with that employees work responsibilities.

In addition to the general training discussed above, specialized training appropriate to the material used and for the hazards anticipated will be provided by the RSO.

(4) Incorporate, in the RP training program, the provisions of 10 CFR 19.12 and additional relevant topics such as: correct handling of radioactive materials; the storage, transfer, or use of radioactive material as relevant to the individuals activities; minimization of exposure to radiation and/or radioactive materials; access and egress controls and escort procedures; radiation safety principles, policies, and procedures; monitoring for internal and external exposure; monitoring instruments; contamination control procedures, including protective clothing and equipment; ALARA and exposure limits; radiation hazards and health risks; emergency response; and responsibility to report promptly any condition that may lead to, or cause, a violation of regulations and license or create unnecessary exposure.

The training requirements correspond to the training requirements specified in 10 CFR 19.12.

The training includes, but is not limited to, understanding the health hazards of the SNM commonly used, ALARA principles, personnel dosimetry, waste management procedures and marking and labeling of facilities and equipment.

(5) Review and evaluate the accuracy, effectiveness, and adequacy of the radiation protection training program curriculum and instructors, as applicable, at least every 3 years and to conduct refresher training at least every 3 years.

In Section 7.4, Training Program, of its LRA, Purdue stated that a biennial refresher training is required for all individuals looking to continue work with radioactive material for both open-

21 source and sealed source use. During the biennial principal investigator authorization to work with radioactive material renewal, training status of all personnel under the principal investigators is reviewed and renewal and continuation of radioactive material use is placed on hold if expired training has not been completed. The RSC reviews all aspects of the ALARA program, including personnel training, on a continual basis.

4.2.6 Ventilation and Respiratory Protection Programs The regulations in 10 CFR 70.22, Contents of Applications, (a)(7) require that each application for a license shall contain 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 alarms, etc.).

Purdues use of SNM under the SNM-142 license is not expected to produce airborne activity warranting respiratory protection or bioassay, and therefore compliance with this regulation is not applicable.

In Section 7.3, Emergency Procedures, of its LRA, Purdue stated that the most credible accident scenario with release to the environment would be a facility fire and that, in such a case, the nature of the SNM under their possession (i.e., sealed in aluminum or stainless steel cladding) provides a barrier for release of material to the environment. In addition, Purdue stated that the ventilation system would be shut down as a precaution to minimize the air entering and exiting the building which would minimize the release of combustion products. If any new uses or locations at Purdue in the future are expected to produce airborne activity warranting respiratory protection or bioassay, Purdue must submit a license amendment request for review against the applicable criteria.

4.2.7 Radiation Survey and Monitoring Programs The regulations in 10 CFR 70.22, Contents of Applications, (a)(8) require that each application for a license 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). The NRC staff reviewed Purdues radiation survey and monitoring program commitments against the acceptance criteria in NUREG-1520, Section 4.4.7.3. The following discussion identifies each acceptance criterion from NUREG-1520 and summarizes the staffs evaluation as to whether the information provided by the applicant is consistent with NUREG-1520. The staff also reviewed the application to ensure that Purdue meets the requirements in 10 CFR Part 20, Subparts C, D, and F.

(1) Criterion: Provide radiation survey and monitoring programs that are necessary to comply with the requirements of 10 CFR Part 20 and that are reasonable to evaluate the magnitude and extent of radiation levels, the concentrations or quantities of radioactive material, and the potential radiological hazards.

Purdue controls possession and use of radioactive materials and requires compliance with the NRC and State regulations. Purdue has fully implemented an HP monitoring and survey program in accordance with 10 CFR Part 20 that includes documentation of spills or other contamination events. All contamination events, personnel radiation exposure and facility effluent releases are tracked, and records are retained for the lifetime of the facility and

22 materials license. The HP program is inspected every other year by the NRC staff as a part of the monitoring of the reactor facility license (R-87). After reviewing Purdues radiation survey and monitoring program, the NRC staff concludes that the procedures are reasonable to evaluate the magnitude and extent of radiation levels, the concentration of radioactive material, and the potential radioactive hazards because the program is consistent with the applicable criteria in NUREG-1520. The NRC staff also concludes that Purdue meets the survey and monitoring requirements of 10 CFR Part 20.

(2) Criterion: Prepare written procedures for the radiation survey and monitoring program that include an outline of the program objectives, sampling procedures, data analysis methods, types of equipment and instrumentation to be used, frequency of measurements, recordkeeping and reporting requirements, and actions to be taken when measurements exceed 10 CFR Part 20 occupational dose limits or administrative levels established by EHS.

Purdue controls possession and use of radioactive material in accordance with its general procedures for conducting routine radiological surveys. The procedures outline the possession, use, and transfer of all licensed material on university-controlled property and presents the applicants general procedures for conducting routine radiological surveys. The procedures discuss the monitoring procedures that include access controls, dosimetry, annual inventory, and leak tests of the fuel assemblies every six months. The procedures include an outline of the program objectives, sampling procedures, data analysis methods, types of equipment and instrumentation to be used, frequency of measurements, recordkeeping and reporting requirements, and actions to be taken when measurements exceed 10 CFR Part 20 occupational dose limits or administrative levels established by EHS. The NRC staff concluded that the procedures are acceptable and meet the requirements in 10 CFR Part 20.

(3) Criterion: Design and implement a personnel monitoring program for external occupational radiation exposure that outlines methods or procedures to do the following:

o Identify the criteria for worker participation in the program, o Identify the types of radiation to be monitored, o Specify how exposure will be measured, assessed, and recorded, o Identify the type and sensitivity of personal dosimeters to be used, when they will be used, and how the collected data will be processed and evaluated, and o Identify the plants administrative exposure levels or action levels at which actions are taken to investigate the cause of exposure exceeding these levels.

In Section 6.3, Measuring and Monitoring Devices, of its LRA Purdue discusses its personnel monitoring requirements. Purdue uses a National Voluntary Laboratory Accreditation Program certified vendor. Dose investigations are performed, when necessary, as described in specific procedures. Periodic review of radiation doses of staff, students and visitors is carried out by the RSO and his staff. Radiation monitoring is supplemented with pocket ionization chambers to allow the estimation of personnel dose in between badge readouts. Pocket ionization chambers are calibrated periodically, and the results are recorded at pre-set levels. Personnel dosimetry appropriate for the material being used is provided by a vendor as required. Direct reading dosimeters such as ionization chambers and electronic dosimeters are available for gamma radiation if necessary. All individual monitoring results, incidents, and exposure exceeding the dose limits in 10 CFR 20 will be submitted consistent with the applicable criteria of 10 CFR Part 20, Subpart M. The RSO specifies that dosimetry is required for individuals mentioned 10 CFR 20.1502. The NRC staff concludes that Purdues personnel monitoring program for external

23 occupational radiation exposure outlines methods or procedures meets the requirements of 10 CFR Part 20.

(4) Criterion: Design and implement a personnel monitoring program for internal occupational radiation exposure based on the requirements of 10 CFR 20.1201, 20.1204, and 20.1502(b), that outlines methods or procedures to do the following:

o Identify the criteria for worker participation in the program, o Identify the type of sampling to be used, the frequency of collection and measurement, and the minimum detection levels, o Specify how worker intakes will be measured, assessed, and recorded, o Specify how the data will be processed, evaluated, and interpreted, and o Identify the plants administrative exposure levels or the levels at which actions are taken to investigate the causes of exposure exceeding these levels.

Although there is no current use of authorized SNM that could result in an individuals intake of the material because they are all in sealed form, Purdue has committed to monitoring any individual who could receive in excess of 10 percent of the annual limit on intake. Potential exposure levels for individuals are evaluated by the RSO and his staff during the registration and training of radiation workers. Dosimeters are processed on a quarterly basis and provide the dose record. Radiation monitoring is supplemented with pocket ionization chambers to allow the estimation of personnel dose in between badge readouts. Pocket ionization chambers are calibrated periodically, and the results are recorded at pre-set levels.

The NRC staff concludes that Purdues personnel monitoring program for internal occupational radiation exposure outlines methods or procedures are acceptable and meet the requirements in 10 CFR 20.1201, 20.1204, and 20.1502(b).

(5) Criterion: Design and implement an air sampling program in areas of the plant identified as potential airborne radioactivity areas, to conduct airflow studies and to calibrate and maintain the airborne sampling equipment in accordance with the manufacturers recommendations.

Purdue uses local airborne monitoring equipment to monitor potential exposure to individuals.

However, the SNM under this license is in a sealed form and is unlikely to become airborne.

Purdue evaluates airflow studies, face velocities of fume hoods, and negative pressures.

Purdues LRA also describes the calibration and record keeping of all instruments. Therefore, Purdues local airborne monitoring program identifies potential airborne radioactivity areas, conducts airflow studies, and involves calibrating and maintaining the airborne sampling equipment in accordance with the manufacturers recommendations. The NRC staff concludes that the airborne monitoring program meets the requirements of 10 CFR Part 20 and, therefore, is acceptable.

(6) Criterion: Implement additional procedures, as may be required by 10 CFR Part 20 and the ISA Summary, to control the concentration of airborne radioactive material (e.g.,

control of access, limitation of exposure times to licensed materials, and use of respiratory protection equipment).

Purdues use of SNM is not expected to produce airborne activity warranting respiratory protection or bioassay, and therefore compliance with this regulation is not applicable. If Purdue employs new uses or locations in the future that produce airborne activity warranting respiratory

24 protection or bioassay, Purdue must submit a license amendment request and the NRC will review Purdues program against the applicable criteria. Therefore, the NRC staff concludes that this criterion is not applicable to Purdues license SNM-142.

(7) Criterion: Conduct a contamination survey program in areas of the facility identified in the ISA Summary most likely to be radiologically contaminated (the program must include the types and frequencies of surveys for various areas of the facility and the action levels and actions to be taken when contamination levels are exceeded).

Purdue is not required to have an ISA because it is not engaged in activities listed in 10 CFR 70.60. However, the status of the fuel assembly will be monitored by leak testing the SNM sources on a 6-month cycle. A wipe sample will be taken of the entire assembly and, subsequently, analyzed for radioactive contamination with the appropriate instrument capable of detecting the presence of 0.005 Ci of radioactive material. If the test reveals the presence of 0.005 Ci or more of removable radioactive material, the assembly will be removed from testing for further evaluation. The NRC staff concludes that this criterion is not applicable to Purdue SNM-142.

(8) Criterion: Implement the facilitys corrective action program when the results of personnel monitoring, personnel contamination monitoring, or contamination surveys exceed the applicants administrative personnel contamination levels.

Due to the nature of the limited regulated materials and uses, Purdue is not required to have a formal corrective action program. Any deficiencies that are identified are reviewed during administrative update reviews and the annual review of radiation protection activities. Therefore, the NRC staff concludes that this criterion is not applicable to Purdue license SNM-142.

(9) Criterion: Use equipment and instrumentation with sufficient sensitivity for the type or types of radiation being measured and calibrate and maintain equipment and instrumentation in accordance with manufacturers recommendations or applicable standards.

Purdues reactor facility utilizes portable radiation monitors capable of detecting alpha, beta, gamma, and neutron radiation are also available for use with the special nuclear material.

Comprehensive surveys of laboratories are conducted by EHS and are performed on a regular basis according to the hazard classification of the laboratory. These surveys include checks for contamination, direct exposure surveys, verifying the operation of survey instruments, the correct utilization of protective garments, waste disposal practices, and verification that personnel dosimetry is being utilized properly. In Appendix A.8, Purdue University Research Reactor (PUR-1) ALARA Program, of its LRA, Purdue stated that it commits to follow the guidance in Instrument Specification and Model Survey Instrument and Air Sampler Calibration Program, in Appendix O of NUREG-1556, Vol. 11, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Licenses of Broad Scope. The Purdue LRA does not propose any significant changes to the radiation survey and monitoring programs, which have been successfully implemented for many years. Based on the staffs evaluation of Purdues commitments to follow the acceptance criteria in Section 4.4.7.3 of NUREG-1520, the staff concludes that the proposed equipment and procedures to be used in the radiation survey and monitoring programs will continue to adequately protect health and minimize danger to life and property in accordance with the requirements in 10 CFR 70.23(a)(3) and (a)(4). The NRC staff also concludes that Purdues equipment and instrumentation, in support of its RPP, meets the general survey requirements of 10 CFR 20.1501 and, therefore, is acceptable.

25 (10) Criterion: Establish policies to ensure that equipment and materials removed from restricted areas to unrestricted areas are not contaminated above the release levels presented in Appendix A, Acceptable Surface Contamination Levels, to Regulatory Guide 8.24(Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication).

Purdue commits to monitor the conditions of its fuel assemblies by leak testing the sources on a 6-month cycle. Currently, the use of licensed materials under the SNM-142 license is limited to storage of uranium and use of PuBe sources for activation analysis studies. Because of the limited use of SNM, there is minimal potential for radioactive contamination during the renewal term. Surface contamination surveys will, nonetheless, continue to be conducted every month.

Additionally, Purdue has general rules for the use of radioactive material that include the use of hoods and/or glove boxes and personal protective equipment, such as gloves and lab coats, if there is a potential to utilize dispersible material. Laboratory work surfaces with the potential for contamination would be covered with absorbent paper that will be changed on a regular basis.

Work involving large volumes of material will be required to be conducted in a spill tray. Surveys would be performed by the user of the radioactive materials at appropriate intervals with contaminated items identified for decontamination or disposal as radioactive waste. The NRC staff concludes that Purdue has established policies to ensure that equipment and materials removed from restricted areas to unrestricted areas are not contaminated above the release levels presented in Appendix A, Acceptable Surface Contamination Levels, of NRC Regulatory Guide (RG) 8.24, Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication (ML110400305). The NRC staff concludes that Purdue has established acceptable policies to ensure that equipment and materials removed from restricted areas to unrestricted areas are not contaminated above the acceptable release levels and, as such, meet the requirements in 10 CFR Part 20.

(11) Criterion: Leak test all sealed sources consistent with direction provided in Appendix C, Leak Test Requirements, to RG 8.24, Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication, or the applicable regulations for the materials involved (e.g., 10 CFR 31.5(c)(2) has direction for leak testing of certain byproduct devices).

In its LRA, Purdue committed to monitor the conditions of its fuel assemblies by leak testing the sources on a 6-month cycle. Wipe samples will be taken of the entire assembly that will be subsequently analyzed for radioactive contamination with the appropriate instrument capable of detecting the presence of 0.005 Ci of radioactive material. If the test reveals the presence of 0.005 Ci or more of removable radioactive material, the assembly will be removed from testing for further evaluation. The NRC staff concludes that Purdues process of leak testing sealed sources is consistent with direction provided in Appendix C, Leak Test Requirements, of RG 8.24. Therefore, the NRC staff concludes that Purdue meets the sources leak testing requirements in 10 CFR Part 20.

(12) Criterion: Establish and implement an access control program that ensures that (1) signs, labels, and other access controls are properly posted and operative, (2) restricted areas are established to prevent the spread of contamination and are identified with appropriate signs, and (3) step-off pads, change facilities, protective clothing facilities, and personnel monitoring instruments are provided in sufficient quantities and locations.

In Section 9, 10 CFR Part 73, Physical Protection of Plants and Materials, of its LRA, Purdue describes the physical security and control of SNM under SNM-142. The SNM is used and

26 stored in two buildings on campus. A diagram of the facility location and floor plan are included in Appendix A-5 of the LRA. The primary location for storage and use of special nuclear material will be dry storage facilities, which are secure. Access is limited to people that are deemed "trustworthy and reliable" and have the facility director's approval. All radioactive material will be labeled in accordance with 10 CFR 20.1904 and University requirements. The NRC staff concludes that Purdues access control program ensures that signs, labels, and other access controls are properly posted and operative, that restricted areas are established to the spread of contamination and are identified with appropriate signs, and that step-off pads, change facilities, protective clothing facilities, and personnel monitoring instruments are provided in sufficient quantities and locations. Therefore, the NRC staff concludes that Purdues access control program is consistent with the criteria in NUREG-1520 and meets the applicable 10 CFR Parts 20 and 73 requirements for controlling the access to SNM and preventing contamination spreading and, therefore, is acceptable.

(13) Criterion: Establish a radiation reporting program consistent with the requirements of 10 CFR Parts 19 and 20.

In Section 7.5, As Low As Reasonably Achievable (ALARA) Program, of its LRA, Purdue stated that its RPP includes a system for notifying individuals of potential radiation exposures.

Purdue stated that exposure reports are reviewed by all members of the radiation safety staff to identify any individuals receiving doses exceeding 100 mrem in any bimonthly period. If such an individual is identified, Purdue stated that it notifies and alerts the individual of the dose and the location (whole body, hand, etc.) receiving the dose. The individual is required to sign and return a form to confirm his awareness of the dose and actions are taken to avoid or reduce exposures in the future. In addition, an investigation into the causes may be initiated, including reviewing and revising procedures and making recommendations to assist in reducing exposures to the affected individual(s). Purdue has also established an RPP that includes the following components:

qualification requirements for the radiation protection personnel; written procedures for the safe conduct of radiation activities/investigations; radiation protection training for all personnel who have access to restricted areas; a program for controlling airborne concentrations of radioactive material with engineering controls and respiratory protection; a radiation survey and monitoring program that includes requirements for controlling radiological contamination within the facility and monitoring of external and internal radiation exposures; other programs for maintaining records, report incidents to the NRC in accordance with 10 CFR Part 20 and 10 CFR Part 70 and correct for releases of radioactive material at the facility.

The NRC staff concludes that the applicants RPP is consistent with the requirements of 10 CFR Parts 19 and 20 and, therefore, is adequate for protecting the health and safety of its workers and the public.

4.2.8 Control of Radiological Risk Resulting from Accidents The regulations in 10 CFR 70.22(i)(1), require that each application to possess uranium or plutonium for which a criticality accident alarm system (CAAS) is required, uranium hexafluoride in excess of 50 kilograms in a single container or 1000 kilograms total, or

27 plutonium in excess of 2 curies in unsealed form or on foils or plated sources, must contain either: (1) an evaluation showing that the maximum dose to a member of the public offsite due to a release of radioactive materials would not exceed 1 rem effective dose equivalent or an intake of 2 milligrams of soluble uranium, or (2) an emergency plan for responding to the radiological hazards of an accidental release of special nuclear material and to any associated chemical hazards directly incident thereto.

Purdue is exempt from the requirement to possess a criticality alarm system (see Exemptions or Authorizations - 10 CFR 70.24 Criticality Accident Alarm System Requirements in Section 4.2, Staff Review and Analysis, of this document below), does not possess any uranium hexafluoride, nor possess plutonium in unsealed form or on foils or plated sources in excess of 2 curies. Therefore, Purdue does not need to have an emergency plan in accordance with the requirements in 10 CFR 70.22(i)(1).

4.2.9 Additional Program Requirements Each licensee shall maintain records of the RPP, including the provisions of the program, survey records, audits and other records identified in Subpart L of 10 CFR Part 20. Each licensee shall make reports and notifications, including theft or loss, notification of incidents, and other reports as required by Subpart M of 10 CFR Part 20. The NRC staff reviewed Purdues LRA to identify any additional safety program commitments, made by Purdue, against the acceptance criteria in NUREG-1520, Section 4.4.9.3. The information below identifies and discusses each acceptance criterion from NUREG-1520 and summarizes the NRC staffs assessment of whether the information provided in the LRA is consistent with the criterion regarding maintenance of records of the RPP (including program provisions, audits, and reviews of the program content and implementation), radiation survey results (air sampling, bioassays, external-exposure data from monitoring of individuals, internal intakes of radioactive material),

and results of its corrective action program referrals, radiation work permits (RWPs), and planned special exposures.

(1) Criterion: Retain records of the RPP Purdue has fully implemented a monitoring and survey program in accordance with 10 CFR Part 20 that includes documentation of spills or other contamination events. All contamination events, personnel radiation exposure and facility effluent release are tracked, and records are retained for the lifetime of the facility and materials license. Purdues RPP is inspected every other year by the NRC as part of the monitoring of the reactor facility license (R-87).

Recordkeeping commitments are and will be consistent with the requirements of 10 CFR 20, Subpart L.

(2) Criterion: Establish a program to report incidents under 10 CFR 20.2202 Purdue has established a program to report to the NRC, within the required time frames, any incidents specified in 10 CFR 20.2202, Notifications of incidents, and 10 CFR 70.74 that results in an occupational exposure to radiation exceeding the dose limits in 10 CFR Part 20.

Purdue also refers reportable events to its corrective action program and reports to the NRC the corrective action(s) taken (or planned) to protect against a recurrence as well as any proposed schedule to achieve compliance with applicable license conditions. Purdues program states that all individual monitoring results, incidents, and exposures exceeding the dose limits in 10 CFR Part 20 will be submitted consistent with the applicable criteria of 10 CFR Part 20, Subpart M.

28 (3) Criterion: Annual report of individual monitoring In its LRA, Purdue stated that all individual monitoring reports, incidents, and exposures exceeding the dose limits in 10 CFR Part 20 are submitted consistent with the applicable criteria of 10 CFR Part 20, Subpart M. Purdue further stated that it reports incidents within the required time and describes their safety significance as specified in the NRC regulations. Personnel monitoring devices are required for all people working with radiation sources in the radiation area and for whom monitoring is required, in accordance with the requirements in 10 CFR 20.1502. Monitoring of additional individuals or environments is at the discretion of the RSO.

Personnel dosimetry appropriate for the material being used is provided by an authorized vendor. Direct reading dosimeters, such as ionization chambers and electronic dosimeters, are available for gamma radiation if needed. Purdue submits all individual monitoring results, incidents, and exposure exceeding the dose limits on an annual basis in accordance with the requirements in 10 CFR 20.2206(b). The NRC staff, therefore, concludes that Purdues individual monitoring and reporting program is consistent with the criteria in NUREG-1520 and meets the requirements in 10 CFR 20.1502 and 10 CFR 20.2206(b) and, therefore, is acceptable.

4.3 Evaluation Findings

As discussed above, the staff finds that the minimal radiological risk posed by the contained SNM will be adequately addressed by the RPP described in the LRA, and that Purdues procedures will be sufficient to assure compliance with the radiological protection requirements in 10 CFR parts 19, 20, and 70. The staff finds that the applicant satisfies the requirements of 10 CFR 70.23(a)(2), (3), and (4) with respect to radiological controls and that the health and safety of the public and the environment are protected by Purdues RPP.

5.0 NUCLEAR CRITICALITY SAFETY 5.1 Purpose of Review The NRC staff performed a detailed technical review of the Purdue LRA to ensure that the statements and commitments described within the LRA are consistent with the applicable Nuclear Criticality Safety (NCS)-related requirements of 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, and to ensure that the risk of inadvertent criticality is adequately managed.

5.2 Staff Review and Analysis The NRC staff conducted its review of Purdues LRA to ensure that the statements and commitments described are consistent with the following regulatory requirements:

10 CFR 70.22, Contents of applications; 10 CFR 70.33, Applications for renewal of licenses; 10 CFR 70.24, Criticality accident requirements; 10 CFR 70.50, Reporting requirements; and 10 CFR 70.52 Reports of accidental criticality.

The NRC staff also conducted its review in accordance with the applicable acceptance criteria in Chapter 5, Nuclear Criticality Safety, of NUREG-1520, Standard Review Plan for Fuel

29 Facilities License Applications, Revision 2 (ML15176A258).

In its LRA, Purdue did not request authorization to conduct enriched uranium processing, fabrication of uranium fuel or fuel assemblies, uranium enrichment, enriched uranium hexafluoride conversion, plutonium processing, fabrication of mixed-oxide fuel or fuel assemblies, or scrap recovery of SNM. Therefore, the criticality safety-related requirements of 10 CFR Part 70, Subpart H, do not apply.

In its LRA, Purdue requested authorization to possess, use, and store various sources of natural uranium and SNM primarily for research operations associated with the [REDACTED]

Specifically, Purdue requests authorization to possess and use [REDACTED] of natural uranium samples and [REDACTED] of aluminum-clad uranium dioxide (UO2) pellets. See table in section 1.2.3 above for a description of the licensed material and possession limits.

The regulations in 10 CFR 70.4 provide thresholds for which inadvertent criticality becomes a concern, defining critical mass of SNM as a quantity exceeding [REDACTED] of contained [REDACTED], [REDACTED] plutonium (Pu), [REDACTED] of contained

[REDACTED] of any combinations thereof, or one half such quantities if massive moderators made of graphite, heavy water, or beryllium may be present. Purdues request involves more than a critical mass as defined by 10 CFR 70.4. Therefore, the NRC staff performed a detailed technical review to ensure that the risk of inadvertent criticality is adequately managed in accordance with the applicable requirements in 10 CFR Part 70.

Purdues LRA does not include any substantial changes to its current SNM-142 license with respect to SNM material composition, quantities, or activities. The NRC staff reviewed its Safety Evaluation Report - License Renewal Application for Purdue University Materials License No. SNM-142 (ML12067A120), for the previous (2013) renewal of Purdues SNM-142 license to determine if the conclusions required a re-evaluation based on the information in the current LRA. In the SER for the 2013 renewal, the staff concluded that Purdues NCS program was adequate to protect against NCS hazards during the renewed license term and that there was reasonable assurance that the applicant has provided adequate protection against criticality hazards The NRC staff reviewed the current LRA and determined that potential criticality hazards would be limited to SNM in the form of fuel rods as natural uranium does not pose a credible criticality hazard and SNM present in contamination quantities on equipment or in the form of helices, discs, samples, and sources do not pose a credible criticality hazard due to their type, form, and small quantities. Purdues SNM in the form of fuel rods consists of [REDACTED] contained in fuel rods enriched to [REDACTED] contained in fuel rods enriched to [REDACTED]. Fuel rods are stored [REDACTED].

Fuel Rods [REDACTED]

Fuel rods containing [REDACTED] are stored in room [REDACTED] vertically in six steel cabinets such that they are maintained in a slab thickness of 14 centimeters (cm). No handling or use of the fuel rods is permitted, with the exception of a small subset of

[REDACTED] rods that may be used elsewhere for non-destructive evaluation and testing.

Given the enrichment of the fuel rods [REDACTED], moderation would be required for criticality to be credible. There are no credible moderation sources present in room

[REDACTED] under normal conditions. Therefore, an upset condition would be required for moderation to be present.

Per figure 3 of American National Standards Institute/American Nuclear Society (ANSI/ANS)-

30 8.1, Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors, the subcritical slab thickness limit for a [REDACTED] is approximately 28 cm. This value represents the subcritical slab limit under conditions of optimal water-to-fuel ratio, infinite geometry in the x-y plane, and full light-water reflection. Given that the storage configuration of the fuel rods limits slab thickness[REDACTED], the limited handling of the rods, and the required upset to introduce moderation, multiple unlikely, concurrent, and independent changes in process conditions of both number of rods present (i.e., mass) and moderation would be required for criticality to occur. Therefore, consistent with the NRC staffs conclusions as documented in Safety Evaluation Report - License Renewal Application for Purdue University Materials License No. SNM-142 (ML12067A120), the NRC staff determined that the storage of fuel rods containing [REDACTED] does not present any credible criticality hazards.

Fuel Rods [REDACTED]

Fuel rods containing [REDACTED] are stored in room [REDACTED].

Duncan Annex (Room B77A). Fuel rods containing [REDACTED] are stored in room

[REDACTED] vertically in metal racks along two opposite walls (1.9 meters apart) such that they are maintained in a slab [REDACTED]. No handling or use of the fuel rods is permitted, except for a small subset of ten rods that may be used elsewhere for non-destructive evaluation and testing. Given the enrichment of the fuel rods [REDACTED] moderation would be required for criticality to be credible. There are no credible moderation sources present in room [REDACTED] under normal conditions. Therefore, an upset condition would be required in order for moderation to be present.

Per figure 3 of ANSI/ANS-8.1, the subcritical slab thickness limit for a [REDACTED] uranium oxide-water lattice is approximately 10 cm. This value represents the subcritical slab limit under conditions of optimal water-to-fuel ratio, infinite geometry in the x-y plane, and full light-water reflection. Given that the storage configuration of the fuel rods limits slab thickness

[REDACTED], the fixed spacing of the metal racks (1.9 meters apart) to ensure neutronic isolation, the limited handling of the fuel rods, and the required upset to introduce moderation, multiple unlikely, concurrent, and independent changes in process conditions would be required in order for both moderation to be present and a subcritical slab height to be exceeded. Therefore, consistent with the NRC staffs conclusions as documented in Safety Evaluation Report - License Renewal Application for Purdue University Materials License No.

SNM-142 (ML12067A120), the staff determined that the storage of fuel rods containing

[REDACTED] does not present any credible criticality hazards.

Physics Building (Rooms B28 and B28C). Fuel rods containing [REDACTED]. Room

[REDACTED] that encloses the FBBF. In room [REDACTED], there are a total of

[REDACTED] fuel rods with a maximum enrichment of [REDACTED] stored in a cage within two sealed converters. One additional converter with [REDACTED] fuel rods is stored in the

[REDACTED]. No handling or use of the fuel rods is permitted.

Credible moderation sources are present in rooms [REDACTED] as these areas have a sprinkler system. The SNM present in rooms [REDACTED] were previously evaluated by the NRC staff as documented in Safety Evaluation Report: Application dated May 4, 1999, License Renewal (ML20210L568). In this report, the NRC staff determined that there was reasonable assurance that a criticality in these areas was not credible as the evaluated configurations remained subcritical (kcalc + 2calc 0.75) under fully flooded conditions. Given

31 the licensees request to renew its SNM-142 license does not represent any substantial changes to SNM material composition, quantities, or activities, and does not present any new or revised normal or credible abnormal conditions beyond those previously evaluated by NRC staff, the NRC staff determined consistent with the NRC staffs previous conclusions as documented in Safety Evaluation Report: Application dated May 4, 1999, License Renewal (ML20210L568) and Safety Evaluation Report - License Renewal Application for Purdue University Materials License No. SNM-142 (ML12067A120) that no credible criticality hazards exist related to the storage of SNM in the Physics Building.

Exemptions or Authorizations - 10 CFR 70.24 CAAS Requirements The regulations in 10 CFR 70.24 requires each licensee authorized to possess a critical mass of SNM (as defined by 10 CFR 70.4) to maintain a CAAS that is capable of detecting a criticality that produces an absorbed dose in soft tissue of 20 rads (combined neutron and gamma radiation) at an unshielded distance of 2 meters from the reacting material within one minute for all areas in which such licensed SNM is handled, used, or stored. Such areas must be covered by two detectors.

The regulation in 10 CFR 70.17, Specific exemptions, (a) state that the Commission may grant exemptions from the requirements of the regulations in 10 CFR Part 70 that it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.

By letter dated February 23, 2024 (ML24032A473), the NRC staff issued a RAI to request Purdue to confirm whether Purdue intended to continue the exemption from the 10 CFR 70.24 requirements into the renewed SNM-142 license. In its March 25, 2024, RAI response (ML24086A458), Purdue stated that it does intend to carry the 10 CFR 70.24 exemption into the renewed SNM-142 license. Therefore, the NRC staff evaluated whether the exemption from the requirements of 10 CFR 70.24 remained valid and acceptable.

Because of its possession of SNM quantities [REDACTED] as defined by 10 CFR 70.4, Purdue is subject to the requirements of 10 CFR 70.24. However, the current SNM-142 license grants an exemption from the requirements of 10 CFR 70.24 insofar as such requirements apply to (1) SNM in any fuel rods in the [REDACTED] that are for storage only (license condition 14) and (2) fissionable material in individual unrelated work areas in which the inventory of the material does not exceed [REDACTED], [REDACTED], [REDACTED], or

[REDACTED] of any combination of these three isotopes, with one half such quantities if massive moderators or reflectors made of graphite, heavy water, or beryllium may be present (license condition 15).

As previously discussed, fuel rods containing [REDACTED] are stored in rooms [REDACTED],

respectively. Fuel rods containing [REDACTED]. As discussed in the above sections of this SER, consistent with the NRC staffs conclusions, as documented in the 2013 SNM-142 license renewal, the NRC staff determined that no credible criticality hazards existed for the storage of these rods in their respective locations. However, Purdue intends to occasionally transport a limited number of fuel rods to other campus locations to perform non-destructive evaluation and testing. Fuel rods transported to other campus locations would be limited to less than a critical mass of SNM, kept in a subcritical geometry during transport and interim storage, kept in tubes less than 3 in. in diameter, and maintained in a non-moderated state.

The NRC staff verified that fuel rods transported to other campus locations would contain less

32 than a critical mass as defined by 10 CFR 70.4 (i.e., less than [REDACTED]) and that the geometry during transport would be less than a critical diameter (i.e., less than 8.6 in.) per figure 2 of ANSI/ANS-8.1 (ML24061A046). Based on these factors, the NRC staff determined that no credible criticality hazards exist for the transport or interim storage of a limited number of fuel rods transported to other campus locations to perform non-destructive evaluation and testing.

Nothing in the NRCs regulations or in any other law prevents the NRC from granting an exemption from the requirements of 10 CFR 70.24. Therefore, an exemption from the requirements of 10 CFR 70.24 is authorized by law. As discussed above, the NRC staff determined that no credible criticality hazards exist for the storage of fuel rods in the Duncan Annex and Physics Building, as well as for the transport and interim storage of a limited number of fuel rods transported to other campus locations to perform non-destructive evaluation and testing. Given that there is no credible criticality concern, the installation and maintenance of a CAAS would not provide a meaningful reduction to the risk to workers or the public. Therefore, the absence of CAAS monitoring in this context would not endanger life or property or the common defense and security. The NRC staff determined that an exemption from the requirements of 10 CFR 70.24 as described in license conditions 14 and 15 would otherwise be in the public interest because Purdue is a public university possessing SNM to conduct research activities. Such an exemption would preserve resources for Purdue as it will not have to install and maintain a CAAS which, as discussed above, is not necessary for reasonable assurance of safety in this context. Further, such an exemption would preserve NRC resources as the NRC will not have to dedicate resources to the review and inspection of a CAAS at Purdue. Thus, such an exemption would be otherwise in the public interest as it preserves public resources by exempting a public university from a requirement to install and maintain a system that is, in this case, not necessary for safety. In sum, the NRC staff determined that Purdues request for exemption from the requirements of 10 CFR 70.24, as documented in License Conditions 14 and 15 of the SNM-142 license, remains acceptable, is authorized by law, and will not endanger life or property or the common defense and security, and is otherwise in the public interest. The following license conditions will be retained in the SNM-142 license:

License Condition 14:

The licensee is exempted from the requirements of 10 CFR 70.24 insofar as such requirements apply to the SNM in any fuel rods in the Duncan Annex that are for storage only.

License Condition 15:

The licensee is exempted from the requirements of 10 CFR 70.24 insofar as such requirements apply to fissionable material in individual unrelated work areas in which the inventory of the material does not exceed [REDACTED] of any combination of these three isotopes. One half such quantities if massive moderators or reflectors made of graphite, heavy water, or beryllium may be present.

5.3 Evaluation Findings

The NRC staff reviewed the request for license renewal. Based on the review of the LRA, as discussed in this SER and based on the format of review per NUREG-1520, the NRC staff concludes that Purdues LRA and commitments provide reasonable assurance of subcriticality

33 under normal and all credible abnormal conditions, provide reasonable assurance of adequate protection against the risk of criticality accidents, and otherwise, satisfies the applicable requirements of 10 CFR Part 70. The NRC staff also finds that Purdues request to continue license conditions 14 and 15, as they relate to the exemption from 10 CFR 70.24 requirements is acceptable, authorized by law, and will not endanger life or property or the common defense and security, and is otherwise in the public interest. Based on these conclusions, the NRC staff has determined that the applicants NCS Program meets the requirements of 10 CFR Part 70 and provides reasonable assurance of safety against the consequences of an accidental criticality. Therefore, the NRC staff recommends that Purdues request for renewal of SNM-142 be approved.

6.0 CHEMICAL SAFETY 6.1 Purpose of Review The NRC staff conducted the chemical safety review to ensure that Purdue will adequately protect workers, the public, and the environment from licensed materials chemical hazards and hazardous chemicals produced from licensed material. Purdue must also protect against facility conditions or operator actions that could affect the safety of licensed materials and, thus, present an increased radiological risk. This section discusses the evaluation of Purdues program for identifying and managing chemical hazards that could arise from the activities it will conduct under special nuclear materials license number 142 (SNM-142). This review focuses on those elements which facilitate the identification and management of the potential chemical hazards for activities that will be conducted under the SNM-142 license. A Memorandum of Understanding between the NRC and Occupational Safety and Health Administration clarifies areas of regulatory responsibility between the two agencies.

6.2 Staff Review and Analysis The regulatory basis for this review is found in 10 CFR 70.22, Contents of applications, and 10 CFR 70.23, Requirements for the approval of applications. These sections of 10 CFR describe the required contents of the application and the requirements for NRC approval of applications, respectively. The review focused on those elements that are relevant to chemical safety.

In Section 2 of its LRA, (ML23268A078), Purdue stated that the SNM will be used for various research operations associated with [REDACTED]. The LRA discusses that SNM has been possessed for use in the operation of a subcritical Fast Breeder Blanket but that the majority of these operations have been suspended and that the material will be stored [REDACTED]

located on Purdues campus until further notice. The only active procedures involve the use of PuBe sources for teaching and research purposes including activation analysis studies, instrument calibration, neutron studies in a subcritical exponential pile, and other research approved by Purdues RSC. This description of Purdues proposed activities did not discuss any chemical hazards.

The NRC staffs independent review of Purdues description of its proposed NRC-regulated activities did not identify any chemical hazards. As such, the NRC staff determined that (1) there are currently no identified chemical hazards under NRCs regulatory jurisdiction for the planned activities involving licensed material, and (2) Purdue has a process for identifying and controlling chemical hazards should there are changes in the activities involving the material authorized under the SNM-142 license. These conclusions are based on the NRC staff assessment of the planned activities identified in the LRA.

34

6.3 Evaluation Findings

Based on the review of the information provided by Purdue in its LRA, the NRC staff finds that Purdue provided a description, in sufficient detail, of the equipment and facilities for protecting workers, the public, and the environment for identifying chemical safety issues related to its licensed activities, in accordance with 10 CFR Part 70.22(a)(7). The NRC staff also finds that Purdues personnel is qualified by training and experience to identify and manage chemical hazards that might arise in its use of SNM in accordance with 10 CFR 70.23(a)(2). The NRC staff also finds that Purdues processes and written procedures for evaluating laboratory facilities for specific activities are adequate to protect health and minimize danger to life or property from chemical hazards and are, therefore, in accordance with 10 CFR 70.23(a)(4). The NRC staff, therefore, finds that Purdues chemical safety program meets the NRC requirements in 10 CFR 70.23, Requirements for the approval of applications, and, as such, Purdues proposed renewal of the SNM-142 license for a period of 10 years should be approved.

7.0 FIRE SAFETY 7.1 Purpose of Review The purpose of this fire safety review is to determine whether the Purdue LRA, provides reasonable assurance of adequate fire protection of workers, the public, and the environment from fire hazards that are under the NRCs regulatory jurisdiction and that could affect the safety of the licensed SNM and thus present an increased radiological risk.

The acceptance criteria for the NRCs review of the fire safety are outlined in Section 7.4.3, Regulatory Acceptance Criteria, of the NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2. The National Fire Protection Association (NFPA)

National Fire Codes are also used, as appropriate, to evaluate a reasonable assurance of fire safety.

7.2 Staff Review and Analysis The regulation in 10 CFR 70.22, Contents of applications, (a)(7) require that each application for a license shall contain a description of the equipment and facilities that 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.).

The regulation in 10 CFR 70.22 (a)(8) require that each application for a license shall discuss the applicants 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.).

The regulation in 10 CFR 70.23, Requirements for the approval of applications, (a)(3) state that an application for a license will be approved if the Commission determines that the applicant's proposed equipment and facilities are adequate to protect health and minimize danger to life or property.

The regulation in 10 CFR 70.23, Requirements for the approval of applications, (a)(4) state that an application for a license will be approved if the Commission determines that the applicant's

35 proposed procedures to protect health and to minimize danger to life or property are adequate.

7.2.1 Facility Design In Section 2, 10 CFR 70.22(a)(2) Activity and Location for which Special Nuclear Material is Requested, of its LRA, Purdue stated that SNM will be stored in two buildings on the university campus: the Duncan Annex of the Electrical Engineering Building (the Duncan Annex) and the Physics Building.

The Duncan Annex In Section 6.1, Area of Storage and Use, of its LRA, Purdue stated that the Duncan Annex is a type IIB construction and is constructed of steel frame with concrete, brick, block, and other fire-resistant materials. The building has fireproofed beams to support the first floor, emergency egress lighting for occupancy safety, heating, ventilation, and air conditioning equipment for air circulation. Purdue further stated that the flammable material used in the laboratory of the Ducan Annex is limited, with only radioactive materials stored within, and that the laboratory is equipped with a sprinkler system and that it is constructed of non-combustible materials.

The Physics Building In Section 6.1, Area of Storage and Use, of its LRA, Purdue stated that the Physics Building is constructed of a steel frame with concrete and brick. The building, which houses the FBBF and will later house research labs, is also provided with supply ventilation and ductwork containing a HEPA filter.

The NRC staff reviewed the facility design, and fire protection features of the Ducan Annex and the Physics Building provided by Purdue in its LRA and determined that a release of the SNM is unlikely in case of fire because: (a) both, the Duncan Annex and the Physics Building, are made of non-combustible materials, (b) combustible materials are limited in these buildings, and (c) the fuel rods are stored in steel cabinets that have adequate separated distances.

7.2.2 Fire Hazards Analysis In its LRA, Purdue stated that, with regard to combustible materials loading, a maximum of 10 liters of flammable liquid may be present or in use at any time only in room B77 (the laboratory) in the Duncan Annex. The NRC staff noted that, because of this limited flammable material stored and used in the laboratory, a formal fire hazards analysis is not required. As such, the NRC staff determined that the activities described in the LRA do not meet the conditions in 10 CFR 70.60, Applicability, which would require a fire hazards analysis.

7.2.3 Fire Protection and Alarm Systems The Duncan Annex In Section 6.1, Area of Storage and Use, of its LRA, Purdue stated that the Duncan Annex is protected by an automatic sprinkler system, in accordance with NFPA 13, Standard for the Installation of Sprinkler systems, with exception that the sprinklers are not installed in rooms B77A and B84 because of concerns about criticality potential. Purdue further described the fire protection features of the Duncan Annex as follows:

36 The fire alarm devices are installed in the Duncan Annex and occupants are notified via audible and visual devices in accordance with NFPA 72, National Fire Alarm and Signaling Code.

The fire alarm supervisory2, initiating, and notification devices are tested annually.

The sprinkler system of the Duncan Annex is tested semiannually; tests include activation of flow switches at each floor zone as well as the building main flow switch.

The ventilation system would be shut down as a precaution to minimize the air entering and exiting the building and minimize the release of combustion products.

The dry pipe system is tested on a semiannual schedule.

In its March 25, 2024, response (ML24086A455, Non-Public) to the NRC staffs February 23, 2024, RAI (ML24032A474) regarding the automatic sprinkler system installed in the Duncan Annex, Purdue further stated that the sprinkler system in the Duncan Annex will not cause a criticality concern to rooms B77A and B84, which are used to store the enriched fuel rods. This is because the fuel rods are stored in steel cabinets with adequate separated distances, are not handled/used in these rooms, and are maintained in a slab thickness of less than the subcritical limit.

Based on the information, as provided by Purdue in its LRA, the NRC staff has determined that Purdues NRC-licensed activities are adequately supported by fire protection and detection systems, alarm devices, fire extinguishers, sprinkler system, ventilation system, and dry pipe system at the Duncan Annex for adequately protecting its workers, the public, and the environment against fires and explosions that could impact the safety of licensed materials.

The Physics Building In its March 25, 2024, response to the NRC staffs RAI regarding fire protection features in the Physics Building, Purdue stated that (1) the laboratory room B28, currently undergoing renovations, will contain a minimal number of combustible materials and will have the fire suppression sprinkler system installed once construction is complete, and (2) the building fire equipment inspections and testing are performed on the same basis as Ducan Annex, and the sprinkler system and the dry pipe system of the building are tested semiannually, and the fire alarm system is tested annually. Purdue further stated that the sprinkler system in the Physics Building poses no criticality concerns to Room B28 which contains the sealed converters containing uranium because the sealed converters remain in a subcritical geometry. Based on this information, the NRC staff determined that there are no criticality concerns identified in room B28.

The NRC staff noted that the fire equipment inspections and testing of Physics Building are performed on the same basis as the Duncan Annex and that the laboratory room B28 will be installed with a fire suppression sprinkler system. Based on this information, the NRC staff has determined that there is reasonable assurance of adequate fire detection and protection systems at Purdue to protect workers, the public, and the environment from fire hazards.

7.2.4 Training and Emergency Response In Section 6.1, Areas of Storage and Use, of its LRA, Purdue discusses its training and emergency response requirements for providing adequate protection of workers, the public, and the environment. Regarding training, Purdue stated that, upon initial employment, facility 2 Devices to ensure that all detection devices are working properly.

37 personnel complete fire extinguisher training and that all personnel are provided with the building emergency plan for the facility. This plan covers procedures on fire, evacuation plans, and shelter-in-place information as well.

The Purdue University Fire Department (PUFD) provides support for emergency response involving any activities conducted under SNM-142. On this regard, in its LRA Purdue stated that the PUFD is located on campus and has an average response time of 2.3 minutes to the Ducan Annex and Physics Building. Purdue further stated that PUFD personnel is extensively trained regarding fire suppression, and all the firefighters are trained to a minimum of Firefighter I/II, in compliance with NFPA 1001, Standard for Fire Fighters Professional Qualifications, and are trained as hazardous material technicians, in compliance with NFPA 472, Standard on Professional Competence of Responders to Hazardous Materials Incidents. Purdue also stated that pre-fire plans involve (1) routine building walkthroughs to identify special hazards or concerns, and (2) roundtable discussions on response, detection, monitoring, and mitigation procedures.

7.3 Evaluation Findings

The NRC staff reviewed the information provided by Purdue in its LRA, and based on this review, the NRC staff finds that Purdues LRA provides sufficient information regarding its fire protection program in accordance with 10 CFR 70.22(a)(7). In addition, the NRC staff finds that Purdue adequately discussed its proposed procedures to protect health and minimize danger to life or property in accordance with 10 CFR 70.22(a)(8). In addition, based on the information provided by Purdue in its LRA, the NRC staff finds that there is reasonable assurance that Purdues proposed equipment and facilities provide reasonable assurance of adequate protection of public health and safety and the environment against fires and explosions that could impact the safety of licensed materials. The NRC staff determined that both, the Duncan Annex and the Physics Building, maintain an adequate level of fire protection to protect public health and safety, in accordance with applicable NFPA codes and that there are no criticality concerns identified in the Duncan Annex rooms B77A and B84 and, as such, Purdues fire protection program meets the requirement in 10 CFR 70.23(a)(3).

The NRC staff also determined that Purdue committed to maintain adequately trained staff and to conduct routine fire drills to ensure protection of public health and safety and the environment from potential fire hazards that could jeopardize the safety of NRC-regulated materials. The NRC staff also determined that Purdue would maintain emergency and pre-fire plans that will include continuation of cooperation and coordination with offsite responders. As such, the NRC staff finds that Purdues fire protection program meets the requirement in 10 CFR 70.23(a)(4).

The NRC staff, therefore, finds that Purdues LRA has provided a reasonable level of assurance of adequate fire protection and, as such, Purdues SNM-142 LRA should be approved.

8.0 EMERGENCY MANAGEMENT 8.1 Purpose of Review The NRC staff reviewed the information presented in Section 7.3, Emergency Procedures, of the Purdue University LRA dated July 11, 2023 (ML23268A087), and in the Purdue response to a RAI dated March 25, 2024 (ML23268A087). The purpose of the NRC staff review was to determine if Purdue University is required to submit an emergency plan under of 10 CFR Section 70.22(i)(1) as part of its LRA.

38 8.2 Staff Review and Analysis The regulations in 10 CFR 70.22(i) states, in part, that licensees requesting a license for radioactive material exceeding certain thresholds must submit either (1) an emergency plan, or (2) an evaluation showing that the maximum dose to a person offsite due to a release would not exceed one rem effective dose equivalent or an intake of two milligrams of soluble uranium.

Section 7.3 of Purdues LRA addresses the need for an emergency plan. Purdue stated that in 1993 it submitted an evaluation which showed that release of radioactive material would not exceed 1 rem effective dose equivalent. Purdue stated that this evaluation was accepted by the NRC in 1994 and again in 1999 as part of the license renewal process. Purdue concluded that the previous evaluation supported its position that there is no need for an emergency plan for the current renewal.

By letter dated February 23, 2024 (ML24032A473), the NRC staff issued an RAI requesting Purdue to provide an updated evaluation or evidence that supported Purdues position that an emergency plan was not required for the current Part 70 license renewal. In response to the RAI, Purdue provided the results of an offsite dose analysis that considered the reduced inventory of licensed material that is requested in its LRA. Purdues dose analysis utilized information and methods presented in NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, dated January 1988 (ML12174A320). The Purdue analysis predicted doses would be less than 145 mrem, with the dose dominated by uranium-238. The Purdue response also identified factors that would reduce the worst-case dose described in their analysis including radioactive material isolation, stainless steel fuel cladding, the limited volatility of uranium dioxide (UO2) and the role the building would play in limiting the release of the uranium.

The NRC staff conducted a review of the information in the RAI response and performed an independent dose analysis to validate the estimates presented by Purdue in the RAI response.

Based on this review, the NRC staff confirmed Purdues assessment that that offsite dose from a worst-case accident would be less than 1 rem.

8.3 Evaluation Findings

Based on its review of the information provided by Purdue in its LRA, as discussed above, the NRC staff finds that Purdue has presented an acceptable evaluation that supports their position that the maximum dose to a member of the public offsite due to a release of radioactive materials would not exceed the limits presented in the 10 CFR 70.22(i). Therefore, the NRC staff finds that Purdue is not required to have an emergency plan for the proposed license renewal 10-year period.

9.0 ENVIRONMENTAL PROTECTION 9.1 Purpose of the Review The purpose of the review is to determine whether the Purdue proposed environmental protection measures are adequate to protect the environment and public health and safety and to comply with the regulatory requirements in 10 CFR Part 20, Standards for Protection Against Radiation, for protection of the environment.

39 9.2 Staff Review and Analysis In Section 6.3, Measuring and Monitoring Dose, of its LRA, Purdue stated that all personnel working with SNM is required to wear personnel monitoring devices whenever the individual is entering a restricted radioisotope area where the individual is likely to receive a dose of excess of 10 percent of the limits specified in 10 CFR 20.1502. Personnel may additionally wear pocket dosimeters or digital dosimeters where exposure would be reasonably anticipated. Additionally, there are several radiation area monitoring systems to ensure occupational dose remains below the limits in 10 CFR 20.1201. Any individual receiving an exposure exceeding 100 millirem in any bimonthly period is identified and notified, as discussed in Section 7.5, As Low As Reasonably Achievable (ALARA) Program, of the LRA.

In Section 7.3, Emergency Procedures, of its LRA, Purdue stated that the most credible accident scenario which would result in a release of radioactive materials to the environment would be a facility fire. Purdue also stated that, since the SNM in their possession is predominantly sealed in aluminum or stainless steel cladding, this first level of containment would be resistant to fire and would provide a barrier for release of material to the environment.

Additionally, Purdue stated that other licensed material under their possession is in the form of sealed sources and would similarly prevent release of licensed material to the environment. All radioactive material is stored within a room in a building which would act to further contain any material that could be released, and some material is further contained within cabinets or in stainless steel converters.

Purdue also stated that its facility characteristics, which include building structures composed of brick, block, concrete, and other fire-resistant materials, which would prevent the spread of contamination beyond the building in case of a fire. The ventilation system in the building would shut down in the case of a fire to minimize the air entering and exiting the building, which further reduces the release of combustion products, including radioactive material.

See Section 11 Radioactive Waste Management for additional discussion on environmental protection and radio-effluence.

9.3 Evaluation Findings

Based on the information provided by Purdue, and as discussed above, the NRC staff finds that Purdues facility features, ALARA program, and radioactive materials, which are in the form of sealed sources, provide reasonable assurance that health and safety of its personnel and the public, and the environment will be adequately protected. Since all the SNM to be possessed and used by Purdue under SNM-142 is in the form of sealed sources, there is minimal likelihood of contamination from operations involving the SNM sources. The NRC staff, therefore, finds that Purdues activities under the SNM-142 during the renewed license term will meet the requirements of 10 CFR 20.1101, Radiation protection programs, and 20.1406, Minimization of contamination, for protecting the environment.

10.0 DECOMMISSIONING/DECOMMISSIONING FUNDING AND FINANCIAL ASSURANCE 10.1 Purpose of Review The purpose of this review to determine whether the Purdue University (Purdue) will be able to decommission the facility safely and in accordance with the NRCs regulations in 10 CFR

40 70.38(g) and the guidance in NUREG-1757, Volume 2, Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria - Final Report, Revision 2 (ML22194A859).

In its application, Section 15.2 Financial Ability to Decommission the Facility, Purdue mentions that they are maintaining surveys and releases that would be required under 10 CFR 70.9 and has provided funding for decommissioning under 10 CFR 70.25, Financial assurance and recordkeeping for decommissioning. No DP nor a discussion of consideration of 70.38 is explicitly discussed anywhere in their application. The NRC staff did confirm with Purdue staff that there are currently no plans for decommissioning the facilities within the next 12 months.

Since the licensee has not positively indicated that it is planning to decommission within 12 months; under 70.38(g), no DP is required.

The NRC staff conducted this review to determine whether Purdue will be able to decommission its facility safely and in accordance with the NRC requirements. Applicants or licensees may be required to submit a decommissioning cost estimate (DCE) and decommissioning funding plan (DFP) in accordance with the requirements in 10 CFR 70.25(b). The purpose of the NRCs evaluation of the DFP is to determine whether: (1) considered decommissioning activities that may be needed in the future; (2) performed a credible site-specific cost estimate for those activities; and (3) presented the NRC with financial assurance to cover the cost of those activities in the future.

10.2 Staff Review and Analysis Nuclear facilities licensed under 10 CFR Part 70 must submit DPs for NRC approval. In accordance with the regulations in 10 CFR 70.38(g)(1), Purdue must submit DP at the time that operations are to be terminated.

In its LRA, Purdue did not state that it intends to decommission its facility withing the next 12 months. Therefore, it is assumed that Purdue has no plans to decommission its facilities within that timeframe. However, in Appendix A.5, Safety Analysis Report, (non-public) Section 15.2, Financial Ability to Decommission the Facility, Purdue did state that it has provided funding for decommissioning under 10 CFR 70.25, Financial Assurance and Recordkeeping for Decommissioning, and that it will maintain, and provide to the NRC, all decommissioning documentation, including records of surveys and radioactive releases, that would be required under 10 CFR 70.9, Completeness and accuracy of information.

Financial assurance and decommissioning funding requirements are found in 10 CFR 70.22(a)(9) and 70.25. Pursuant to these regulations, licensed nuclear facilities are required to establish financial assurance to cover the estimated costs for site decommissioning, decontamination, and reclamation. The regulation in 10 CFR 70.22(a)(9) requires that, as provided by 10 CFR 70.25, certain applications for specific licenses filed under this 10 CFR Part 70 must contain a proposed DFP or a certification of financial assurance for decommissioning.

The regulations in 10 CFR 70.25 stipulate the requirements for financial assurance and recordkeeping for decommissioning to demonstrate how reasonable assurance is provided for funds to be available to decommission the facility. The regulation in 10 CFR 70.25(e)(2) requires that a licensee, at the time of license renewal, resubmit a DFP with adjustments that are necessary to account for changes in costs and the extent of contamination.

The regulations in 10 CFR 70.25(e)(1)(i)-(iv) require, in part, that a DFP must contain:

41 (i) A detailed cost estimate for decommissioning that reflects (A) the cost of an independent contractor to perform the work (B) the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use (C) the volume of onsite subsurface material that will require remediation (D) an adequate contingency factor (ii) Identification and justification for key assumptions used in the DCE (iii) A description of the method of assuring funds will be available for decommissioning; and (iv) A certification by the licensee that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

The cost estimate provided by Purdue includes:

a description of the facility where the SNM and source materials are used and stored types and quantities of material; a description of how the materials are used; quantities of materials or waste accumulated prior to shipping or disposal; number and dimensions of facility components; labor costs for planning and preparation of the facility for decommissioning of the radioactive facility; final surveys; packaging, shipping, and disposal of radioactive wastes; equipment and supplies; and NRC oversight costs.

Section 4, Financial Assurance Overview, and Appendix A.3, Decommissioning Funding Plans, of NUREG-1757, Consolidated Decommissioning Guidance, Volume 3, Financial Assurance, Recordkeeping, and Timeliness, Revision 1, provide guidance for reviewing an applicants or licensees financial assurance for decommissioning.

The licensee submitted a revised version of the DFP on March 4, 2025 (ML2525107A212). The NRC staff reviewed the provided DFP and the Statement of Intent (SOI) as part of the verification that Purdue meets the requirements of 10 CFR 70.22(a)(9). The DFP described the possession, use, and surveys of radionuclide materials and the scope of decommissioning activities, and provided estimates to the cost of decommissioning following the guidance of NUREG/CR 1756. The SOI elements are discussed in Section 7.2.4 Financial Mechanisms of this safety evaluation. Based on this review, the NRC staff determined that the financial assurance mechanisms maintained by Purdue are adequate for NRC staff to conduct a technical review on the sufficiency of the funds to be available to carry out all required decommissioning activities prior to license termination, and for the NRC staff to be able to evaluate on whether Purdue meets the requirements in 10 CFR 70.25(a), 10 CFR 70.25(e), and 10 CFR 70.25(f).

As required by 10 CFR 70.25(e)(1)(i)-(iv) the DFP, submitted for review and approval by NRC, must contain a detailed cost estimate for decommissioning that reflects: the cost of an independent contractor to perform the work; the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; the volume of contamination in the onsite subsurface material that will require

42 remediation; an adequate contingency factor; identification and justification for key assumptions used in the cost estimate; a description of the method of assuring funds will be available for decom-missioning; and a certification statement by the licensee that financial assurance has been provided in the amount of the cost estimate for decommissioning. The cost estimate provided by Purdue includes: a description of the facility where the SNM and source materials are used and stored; types and quantities of material; a description of how the materials are used; quantities of materials or waste accumulated prior to shipping or disposal; number and dimensions of facility components; labor costs for planning and preparation of the facility for decommissioning of the radioactive facility; final surveys; packaging, shipping, and disposal of radioactive wastes; equipment and supplies; and the NRC oversight costs. The DFP accounts for components and labor categories by major decommissioning task. The licensee states that a third-party contractor will be used for radiological characterization of the items designated for packaging and disposal of radioactive material. The estimate does not take credit for salvage value from a potential sale of assets. A 25-percent contingency factor was added to the DCE.

The total DCE is $264,580.

The NRC staff reviewed Purdue Universitys DFP accompanying the application for license renewal. Purdue University is a public university and is financially supported by the State of Indiana. Purdue has chosen a SOI as a financial insurance mechanism.

The regulations in 10 CFR 70.25(e)(1)(ii) require identification of and justification for using the key assumptions contained in the DCE.

The DCE assumptions include the number of rooms where materials would be located, waste disposal costs, and planning and preparation workday estimates. The assumptions were accompanied with justifications based upon current materials being used and their storage location, worst-case scenario values from relevant industry developed figures, and experience of actual site costs.

The cost estimate also clearly stated that it does not take credit for any salvage value that might be realized from the sale of potential assets.

According to the application, decommissioning activities associated with the SNM are conducted in accordance with written procedures and commence after the approval of decommissioning activities is granted by the NRC. Purdues RSC approves the active procedures associated with SNM. The RSC is responsible for reviewing plans, specifications, and procedures for SNM activities, reviewing any significant proposed changes in design, activities, or decommissioning of SNM. A Committee or RSO approval is required in advance of initiating changes.

The NRC staff determined that the key assumptions have been adequately justified because they meet the criteria in NUREG-1757, Volume 3 (ML23268A075). Therefore, the NRC staff finds that the licensee meets the requirement of 10 CFR 70.25(e)(1)(ii).

As required by 10 CFR 70.25(e)(1)(v), the DFP must include a signed original, or, if allowed, a copy, of the financial instrument to be used to cover the decommissioning costs. By letter dated March 4, 2025 (ML25107A212), the licensee submitted an update to the SOI as its method of assuring funds for decommissioning.

10.3 Evaluation Findings The NRC staff reviewed NUREG-1520 and associated regulations to determine with

43 reasonable assurance that the licensee will be able to release the facility safely and in accordance with NRC regulations when the license is terminated. Based on its review as discussed above, the NRC staff determined that the DFP, contained within the LRA, presented the information required for a renewal application in suitable form and detail and is therefore acceptable. The NRC staff concludes that there is reasonable assurance that the necessary funds will be available to support the continued safe use of SNM and to carry out the decommissioning activities per guidance in NUREG-1537 and NUREG-1756.

11.0 RADIOACTIVE WASTE MANAGEMENT 11.1 Purpose of Review The NRC staff reviewed the information discussed in Section 6.4 Radioactive Waste Disposal, of the Purdue LRA (ML23268A087), as updated by Purdues March 25, 2024, responses (ML24086A454) to the NRC staffs, February 23, 2024, RAI (ML24032A474), against the acceptance criteria in NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H - Draft Report for Comment (ML22335A087), Section 2.2.2.6, Waste Management, to determine whether the LRA adequately described Purdues radioactive waste management program and activities.

11.2 Staff Review and Analysis In Section 6.4, Radioactive Waste Disposal, of the LRA, as updated by its responses to the RAI (ML24086A454), Purdue stated that there is little to no radioactive waste associated with this license. If low-level waste was ever to be created, there are provisions through Purdue (i.e.,

Purdue Environmental Health and Safety (EHS) Department) to collect and dispose of the material. Considering the nature of the work, most of the waste that is generated include used gloves, benchtop paper, and other forms of used personal protective equipment. In the vast majority of cases, waste was surveyed and shows readings at background radiation levels upon pickup by EHS staff.

In its LRA, as updated by its responses to the RAI, Purdue stated that radioactive waste is required to be separated into different categories for disposal:

solid radioactive waste with short half-life (less than 30 days) is placed into drums or bags, as appropriate solid radioactive waste with long half-life (at least 30 days) is separated into combustible and non-combustible and then placed into bags or drums liquid radioactive waste is separated into short half-life and long half-life categories and any liquid radioactive waste containing hazardous or non-dispersible components is identified and handled separately vials are required to be returned to their original carton and to remain upright during transport or placed in a drum, which is double-bagged to prevent leakage biological radioactive waste is placed in plastic bags and kept frozen until pickup sharps are required to be in a rigid or semi-rigid container so that handling the container would prevent cuts or punctures to the technicians In its LRA, as updated by its responses to the RAI, Purdue stated additional information about

44 radioactive waste:

solid long half-life radioactive material will be disposed of using a licensed waste broker facility, and final disposal will be completed offsite non-combustible long half-life radioactive waste (metal and glass) is compacted using Teledyne Industries compactor that is equipped with an external air exhaust and HEPA filter, which is monitored on an annual basis for activity and integrity:

o no air sampling is done in the area because the most volatile compound undergoing compaction is Iodine-125 o personnel bioassays have indicated a maximum dose equivalent of 13 millirem per year to the thyroid, which is less than 0.03 percent of the 50 rem occupational limit for the thyroid and is under Purdues ALARA trigger level of 100 millirem o direct radiation surveys and wipe testing of the area are performed on a regular basis The regulatory criteria in NUREG-2212 for the radioactive waste management technical area are:

radioactive waste must be disposed of in accordance with regulatory requirements and license conditions; appropriate records of waste disposal must be maintained; applicants should describe their waste management programs for minimizing and controlling waste generation, and for its disposal in accordance with regulatory requirements.

The applicable regulations for the radioactive waste management technical area are:

10 CFR 70.22(a)(7) - requires, in part, that each application for a license shall provide a description of the 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 and devices for the disposal of radioactive wastes.

10 CFR 20.2001 - requires a licensee to dispose of licensed material only by stated methods. Specifically, the regulations in 10 CFR 20.2001(a)(2) provide that licensees may dispose of licensed material by decay in storage.

10 CFR 20.2003 - provides that a licensee may discharge licensed material into sanitary sewerage when specific criteria are met.

10 CFR 20.2006 - describes the requirements for shipping radioactive waste intended for ultimate disposal at a licensed land disposal facility.

10 CFR 20.2007 - provides that nothing in 10 CFR Part 20, Subpart K, Waste Disposal, 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.

11.2.1 Disposal of radioactive waste by decay in storage In its LRA, Purdue did not specifically state that it may utilize decay in storage prior to disposal in a manner that meets 10 CFR 20.2001(a)(2). In Section 6.4., Radioactive Waste Disposal, of the LRA as updated by RAI responses, Purdue stated that short half-life radioactive material are stored for a minimum of 10 half-lives prior to disposal:

45 solid radioactive material is surveyed with an end-window Geiger-Mueller survey meter and any radioactive material with radiation levels indistinguishable to background are disposed of as normal trash - prior to disposal as normal trash, all radioactive labels and markings are defaced or destroyed liquid radioactive material will be sampled and analyzed for radioactivity by liquid scintillation counting and any radioactive material less than 100 disintegrations per minute/milliliter will be disposed in the sanitary sewer, provided the radioactive material is readily dispersible and non-hazardous - if the activity is above that amount, then the radioactive material will be allowed additional decay time and, if further sampling reveals that the activity is still present, then it will be treated as a long half-life radioactive material a record of all radioactive material that has been disposed of by decay in storage will be maintained.

In its February 23, 2024, RAI (ML24032A473), the NRC staff requested Purdue to provide a written commitment for meeting the 10 CFR Part 20 Subpart K, Waste Disposal, requirements, including 10 CFR 20.2001(a). In its response, Purdue stated that there is little to no radioactive waste associated with the SNM-95 license and that waste shipments would be transferred to a licensed waste broker or facility. Purdue further stated that sealed sources may also be transferred to other licensees for disposal or reuse and that, in all cases, it will meet the 10 CFR 20 Subpart K requirements, including 10 CFR 20.2001(a).

The NRC staff reviewed the following public documents containing information related to Purdues radioactive waste management activities to find out whether Purdue addressed or further discussed its radioactive waste management activities:

(1) Purdue Broad Scope License No. 13-02812-04, Amendment #106 (ML23097A070); and (2) Purdue Radiation Safety Manual (updated 01-07-2022, available at https://www.purdue.edu/ehps/rem/documents/programs/radman.pdf).

The NRC staff noted that, regarding decay in storage, license condition 22 of the broad scope license authorizes Purdue to hold radioactive material with a physical half-life of less than or equal to 120 days for decay in storage subject to surveying the container before disposal in ordinary trash to ensure that radioactivity cannot be distinguished from background and that radiation labels are removed or obliterated, except for labels on materials managed as biomedical waste. In addition, Purdue is required to retain records of disposals permitted under the license for 3 years.

Chapter 7, Radioactive Waste Handling, of Purdues Radiation Safety Manual discusses waste management requirements at Purdue. Based on the guidance in the manual, Purdues EHS, Radiation Safety Section, is responsible for the collection, management, and disposal of all radioactive waste in accordance with NRC regulations.

11.2.1.1 Evaluation findings: disposal of radioactive waste by decay in storage The NRC staff determined that Purdue has an established process for disposing of radioactive waste by decay in storage. The NRC staff finds that Purdue has provided reasonable assurance that disposal of radioactive waste by decay in storage will meet the requirements of 10 CFR 20.2001(a)(2).

46 11.2.2 Radio-effluents In its LRA, Purdue did not state that releases of liquid and gaseous radio-effluents will be verified to comply with the public dose limits specified in 10 CFR 20.1301 and in accordance with the requirements of 10 CFR 20.1302. However, Chapter 8, Personnel Exposure and Monitoring, of Purdues Radiation Safety Manual (01-07-2022) states that the personnel monitoring program at Purdue is designed to keep exposures to ionizing radiation [ALARA].

Section 8.1 Occupational Exposure Limits, of the manual states that the current exposure limits in an occupational setting have been established for two reasons. The first is to prevent acute effects (i.e. erythema, epilation) and the second is to reduce late effects such as cancer and genetic damage to very low levels. The limits for occupational exposure from radioactive material and devices containing radioactive material can be found in [10 CFR Part 20.]

In Section 6.4., Radioactive Waste Disposal, of its LRA, as updated by RAI responses, Purdue stated that short half-life radioactive material is stored for a minimum of 10 half-lives prior to disposal:

liquid radioactive material will be sampled and analyzed for radioactivity by liquid scintillation counting and any radioactive material less than 100 disintegrations per minute/milliliter will be disposed in the sanitary sewer, provided the radioactive material is readily dispersible and non-hazardous - if the activity is above that amount, then the radioactive material will be allowed additional decay time and, if further sampling reveals that the activity is still present, then it will be treated as a long half-life radioactive material records for waste disposal methods for all waste inventory items are kept by REM In its LRA, as updated by RAI responses, Purdue stated that liquid radioactive waste may be disposed of by the sanitary sewer as provided in 10 CFR 20.2003. All short half-life liquid radioactive waste must be indistinguishable from background before drain disposal. Attempts are made to limit daily disposal to less than ten times the Appendix C value in the interest of ALARA. However, if that limit would increase exposure to radiation safety staff (such as subdividing waste packages), then the former limits would be observed. Records are maintained at all times of liquid radioactive material that has been disposed of in sanitary sewers.

In its LRA, as updated by RAI responses, Purdue stated that long half-life liquid radioactive waste is sampled and analyzed according to the radionuclide(s) present. Pure beta emitters are analyzed by liquid scintillation counting and gamma emitters are analyzed by NaI or Ge spectroscopy. An activity is calculated, and a computer program compares the activity with disposal limits and makes recommendations for disposal.

In its LRA, as updated by RAI responses, Purdue stated that all long half-life radioactive waste is sent to the Purdue University hazardous waste team to be blended as mixed waste. That blended waste is then picked up by a licensed waste vendor, currently Bionomics Inc. Records for waste disposal methods for all waste inventory items are kept at REM.

In its LRA, as updated by RAI responses, Purdue stated that scintillation vials are packaged in drums and shipped via a waste broker for treatment or disposal. All applicable U.S. Department of Transportation regulations regarding the shipment of hazardous materials are met.

In its LRA, as updated by RAI responses, Purdue stated that all radioactive waste shipments will

47 be transferred to a licensed waste broker or facility. Currently, waste is transferred to Bionomics for ultimate disposal or treatment at licensed facilities. Sealed sources may also be transferred to other licensees for disposal or reuse, such as J.L. Shepherd and Associates. In all cases, Purdue will follow 10 CFR Part 20, Subpart K, including 10 CFR 20.2001(a) for all radioactive waste disposal.

11.2.2.1 Evaluation findings: radio-effluents The NRC staff determined that Purdue has an established process for disposing of radioactive waste into sanitary sewage, or, if necessary, disposed of by transfer to a licensed radioactive waste broker. The NRC staff finds that Purdue has provided reasonable assurance that disposal of radioactive waste into sanitary sewage will meet the requirements of 10 CFR 20.2003.

11.2.3 Onsite incineration and onsite burial of radioactive waste In its LRA, Purdue did not propose either to perform onsite incineration of radioactive waste in a manner that meets 10 CFR 20.2004 or to perform onsite burial of radioactive waste. In its responses to the RAI, Purdue stated that it does not conduct radioactive waste treatment by onsite incineration.

11.2.3.1 Evaluation findings: onsite incineration and onsite burial of radioactive waste The NRC staff notes that Purdue did not propose either to perform onsite incineration of radioactive waste under 10 CFR 20.2004, Treatment or Disposal by Incineration; or to perform onsite burial of radioactive waste. Therefore, the NRC staff did not evaluate this information.

11.2.4 Transfer of radioactive waste for disposal and manifests In its LRA, as updated by its responses to the RAI, Purdue stated that all waste management operations are carried out by trained technicians. Technicians are responsible for picking up radioactive waste from all laboratories because researchers are prohibited from sink disposal or any other direct means of disposal, unless specifically exempted from the requirements.

In its LRA, as updated by its responses to the RAI, Purdue stated that containers for radioactive waste are supplied by EHS unless a principal investigator (PI) has requested to use alternative equivalent containers. The containers that are delivered to PIs upon request include: (1) plastic carboys (up to 20 liters); (2) plastic drums (5 gallons); and (3) plastic bags (5 gallon and 30 gallon). Prior to pick up by EHS, all containers must be properly labeled to include isotope, amount, authorization number, PI name, date, and any solvents or hazardous materials present.

In its LRA, as updated by its responses to the RAI, Purdue stated that when a PI is ready for a radioactive waste pickup, EHS is called to schedule the pickup. Technicians verify the label to ensure that all required information is completed. The packages are all smeared, surveyed for exposure rate at both the surface and 1 meter distance, and checked to see that the enclosures are secure. Pursuant to 49 CFR, any labeling, marking, notices, shipping papers, and placarding requirements are met prior to transport on public highways.

In its LRA, as updated by its responses to the RAI, Purdue stated that long half-life liquid radioactive waste is sampled and analyzed according to the radionuclide(s) present. Pure beta emitters are analyzed by liquid scintillation counting and gamma emitters are analyzed by sodium iodide (NaI) or germanium (Ge) spectroscopy. An activity is calculated and a computer

48 program compares the activity with disposal limits and makes recommendations for disposal.

In its LRA, as updated by its responses to the RAI, Purdue stated that all long half-life radioactive waste is sent to the PU hazardous waste team to be blended as mixed waste. That blended waste is then picked up by a licensed waste vendor, currently Bionomics Inc. Records for waste disposal methods for all waste inventory items are kept at EHS.

In its LRA, as updated by its responses to the RAI, Purdue stated that liquid radioactive waste may be disposed of by the sanitary sewer as provided in 10 CFR 20.2003. All short half-life liquid radioactive waste must be indistinguishable from background before drain disposal.

Attempts are made to limit daily disposal to less than ten times the Appendix C value in the interest of ALARA. However, if that limit would increase exposure to radiation safety staff (such as subdividing waste packages), then the former limits would be observed. Records are maintained at all times of liquid radioactive material that has been disposed of in sanitary sewers.

In its LRA, as updated by its responses to the RAI, Purdue stated that scintillation vials are packaged in drums and shipped via a waste broker for treatment or disposal. All applicable U.S.

DOT regulations regarding the shipment of hazardous materials are met.

In its LRA, as updated by its responses to the RAI, Purdue stated that all radioactive waste shipments will be transferred to a licensed radioactive waste broker or facility. Currently, radioactive waste is transferred to Bionomics for ultimate disposal or treatment at licensed facilities. Sealed sources may also be transferred to other licensees for disposal or reuse, such as J.L. Shepherd and Associates. In all cases, Purdue will follow 10 CFR Part 20, Subpart K, including 10 CFR 20.2001(a) for all radioactive waste disposal.

In Section 7.4., Training Program, of the LRA, Purdue stated that, if a person uses radioactive material other than sealed sources, a hands-on session on survey and radioactive waste procedures is provided by a HP or radiation safety technician and the information covered by the training includes: (1) principles of ALARA; and (2) radioactive waste management procedures.

In Section 7.5, As Low As Reasonably Achievable (ALARA) Program, of the LRA, Purdue stated that it is committed to providing a working place relatively free of recognized hazards.

Because any exposure to ionizing radiation can incur some risk of cancer or genetic effects, the goal is to keep exposures low while allowing research with radioactive materials to proceed without undue hardship. The ALARA program uses the following methods to keep radiation exposures ALARA: (1) training; (2) personal dosimetry; (3) exposure notification; (4) exposure investigations; and (5) laboratory audits.

11.2.4.1 Evaluation findings: transfer of radioactive waste for disposal and manifests The NRC staff notes that neither Purdues LRA nor Purdues responses to the NRC RAI include any references to manifest tracking system, radioactive waste manifests (NRC Form 540, Uniform Low-Level Radioactive Waste Manifest - Shipping Paper, and NRC Form 541, Uniform Low-Level Radioactive Waste Manifest - Container and Waste Description).

However, during the public meetings about the NRC proposed RAIs and Purdues proposed responses to the RAIs, those aspects were discussed, and Purdue committed to do what was required. In its LRA, as updated by its responses to the RAI, Purdue stated that, in all cases, it will follow 10 CFR Part 20, Subpart K. The NRC staff determined that Purdue has established a

49 process for shipping radioactive waste intended for ultimate disposal at a licensed land disposal facility. The NRC staff also determined that any radioactive waste that will be generated as a result of Purdues licensed activities will be managed to implement the requirements of 10 CFR Part 20, Subpart K. The NRC staff finds that Purdue provided reasonable assurance that its process for shipping radioactive waste intended for ultimate disposal at a land disposal facility will meet the requirements of 10 CFR 20.2006.

11.2.5 Alternative Radioactive Waste Disposal Methods In its LRA, Purdue did not propose any alternative radioactive waste disposal methods.

11.2.5.1 Evaluation Findings for Alternative Radioactive Waste Disposal Methods The NRC staff notes that Purdue did not propose any alternative radioactive waste disposal methods other than those specifically discussed in its LRA, which are already approved by regulation. Therefore, the NRC staff did not evaluate that information.

11.2.6 Compliance with environmental and health protection regulations The NRC staff notes that neither Purdues LRA nor its responses to the NRC RAI included any references to Purdues understanding that, under 10 CFR 20.2007, nothing in 10 CFR Part 20, Subpart K relieves Purdue 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. In its LRA, as updated by its responses to the RAI, Purdue stated that, in all cases, it will follow 10 CFR Part 20, Subpart K.

In Chapter 5, 10 CFR 70.22(a)(6) Technical Qualifications of Applicant, RSO, of its LRA, Purdue stated that the primary duties of the RSO include, but are not limited to, the following:

(1) ensuring compliance of the radiation safety program with state and Federal regulations and NRC license conditions; and (2) providing training and recommendations to individuals that use radioactive materials. In Section 7.5, As Low As Reasonably Achievable (ALARA) Program, of its LRA, Purdue stated that it is committed to providing a working place relatively free of recognized hazards. Since any exposure to ionizing radiation is thought to incur some risk of cancer or genetic effects, the goal is to keep exposures low while allowing research with radioactive materials to proceed without undue hardship. The ALARA program uses the following methods to keep radiation exposures ALARA: (1) training; (2) personal dosimetry; (3) exposure notification; (4) exposure investigations; and (5) laboratory audits.

11.2.6.1 Evaluation findings: compliance with environmental and health protection regulations The NRC staff determined that Purdue has established responsibility for the oversight, supervision, and operation of licensed activities. The NRC staff also determined that Purdue has procedures and supporting organizations in place to ensure Purdue does comply with all other Federal, State, and local regulations governing any other toxic or hazardous properties of materials. The NRC staff therefore finds that Purdue provided reasonable assurance that its licensed program will meet the requirements of 10 CFR 20.2007 for compliance with Federal, State, and local regulations governing toxic or hazardous materials.

50 11.2.7 Disposal of Specific Radioactive Wastes In its LRA, Purdue did not propose to dispose of specific radioactive wastes under 10 CFR 20.2005.

11.2.7.1 Evaluation Findings for Disposal of Specific Radioactive Wastes The NRC staff notes that Purdue did not propose to dispose of specific radioactive wastes under 10 CFR 20.2005. Therefore, the NRC staff did not evaluate this information.

11.2.8 Disposal of byproduct material In its LRA, Purdue did not propose to dispose of byproduct material under 10 CFR 20.2008.

11.2.8.1 Evaluation findings: disposal of byproduct material The NRC staff notes that Purdue did not propose to dispose of byproduct material under 10 CFR 20.2008. Therefore, the NRC staff did not evaluate this information.

11.3 Evaluation Findings Based on its evaluation of the information discussed above, the NRC staff finds that Purdue has established means for disposing of radioactive waste. The NRC staff finds that Purdues radioactive waste management activities provide reasonable assurance for disposal of radioactive waste by decay in storage, in accordance with the requirements of 10 CFR 20.2001(a)(2). The NRC staff finds that Purdues radioactive waste management activities provide reasonable assurance for disposal of radioactive waste into sanitary sewage, in accordance with the requirements in 10 CFR 20.2003 and for disposing of radioactive waste by shipping the wastes for ultimate disposal at a licensed land disposal facility, in accordance with the requirements in 10 CFR 20.2006. The NRC staff finds that any radioactive waste that will be generated as a result of Purdues licensed activities will be managed to implement the requirements in 10 CFR Part 20, Subpart K. The NRC staff finds that Purdue has processes in place to ensure that it complies with all other Federal, State, and local regulations governing any other environmental and health protection regulations, in accordance with the requirements in 10 CFR 20.2007. Therefore, the NRC staff finds that Purdues LRA provided sufficient information on Purdues management and disposal of radioactive wastes to ensure there is reasonable assurance that public health and safety and the environment are adequately protected. As such, the NRC staff finds that Purdues radioactive waste management program is acceptable.

12.0 PHYSICAL SECURITY: SNM AT FIXED SITES AND IN TRANSPORT 12.1 Purpose of Review The purpose of the NRC staff review was to determine if the Purdue University physical security and transportation in-transit security programs discussed in Purdues LRA meet the applicable NRC regulatory requirements and ensures that activities involving SNM are not inimical to the common defense and security, and do not constitute an unreasonable risk to the public health and safety.

51 12.2 Staff Review and Analysis As part of the LRA, the applicant submitted Revision 7 of their physical security plan (PSP),

Security Plan for the Purdue University Reactor, the Fast Breeder Blanket Facility, and Nuclear Fuel Storage Areas (dated November 2021) that discusses their implementation of applicable physical protection requirements, in accordance with 10 CFR 73.67. This Safety Evaluation Report documents the NRC staffs review of the PSP.

The purpose of this review was to determine whether Purdues PSP meets the applicable regulatory requirements in 10 CFR 73.67(a)(1), (a)(2), (f), (g), as supplemented by the requirements of Order EA-07-074. Compliance with these requirements ensure that activities involving SNM at Purdue are not inimical to the common defense and security, and do not constitute an unreasonable risk to the public health and safety.

12.3 Staff Analysis and Evaluation The regulation at 10 CFR 73.67(a)(1) states Each licensee who possesses, uses or transports special nuclear material of moderate or low strategic significance shall establish and maintain a physical protection system that will achieve the following objectives: (i) Minimize the possibilities for unauthorized removal of special nuclear material consistent with the potential consequences of such actions; and (ii) facilitate the location and recovery of missing special nuclear material.

Section 2, General Performance Objectives, of Purdues PSP states that the physical protection system and security organization will minimize the possibility of unauthorized removal of special nuclear material consistent with the potential consequences of such actions and facilitate the location and recovery of missing SNM.

The NRC staff reviewed section 2 of Purdues PSP and determined that it commits to meeting this performance objective. The NRC has determined that the methods and techniques described in the PSP to accomplish this performance objective meet the intent of 10 CFR 73.67(a)(1).

The regulation at 10 CFR 73.67(a)(2) states To achieve these objectives, the physical protection system shall provide: (i) Early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area containing special nuclear material; (ii) Early detection of removal of special nuclear material by an external adversary from a controlled access area; (iii) Assure proper placement and transfer of custody of special nuclear material; and (iv) Respond to indications of an unauthorized removal of special nuclear material and then notify the appropriate response forces of its removal in order to facilitate its recovery.

Section 2, General Performance Objectives of Purdues PSP states that they shall provide early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area (CAA) containing SNM, early detection of removal of special nuclear material by an external adversary from CAAs, assure the proper placement and transfer of custody of SNM, and respond to indications of unauthorized removal of SNM and then notify the appropriate response force to facilitate recovery.

The NRC staff reviewed Section 2 of Purdues PSP and determined that it meets the intent of earliness of detection, positive control of nuclear material, and has processes and procedures to facilitate recovery in the event of unauthorized removal of SNM. For this reason, the NRC staff finds that Purdues PSP meets the requirements of 10 CFR 73.67(a)(2).

52 Section 6, Security Areas, of Purdues PSP states that the Duncan Annex of The Electrical Engineering Building and the Physics Building are designated CAAs.

Both the nuclear laboratory in Duncan Annex, and the FBBF Laboratory in the Physics Building have walls of poured concrete topped with concrete block and brick veneer. The ceilings are reinforced poured concrete. The Nuclear Engineering Radiation Laboratory has no exterior windows and all windows in the FBBF Laboratory have been bricked closed. All windows in the doors are covered with steel plates.

All doors to the CAAs consist of steel fire doors equipped with at least a 5-pin tumbler lock or emergency crash door that only allows the door to open from the inside.

All access doors to CAAs are either locked or under surveillance of an authorized individual during working hours. During non-working hours these doors are either locked and alarmed or under surveillance by an authorized individual.

Section 7, Controlled Access Areas (Use), of Purdues PSP states that all SNM is used only within a CAA which is illuminated sufficiently to allow detection and surveillance of unauthorized activities whenever personnel are present.

Section 8, Controlled Access Areas (Storage), of Purdues PSP states that all SNM is stored only within a CAA which is illuminated sufficiently to allow detection and surveillance of unauthorized activities whenever personnel are present. All SNM is stored within the CAA. The designated storage areas are the reactor core, reactor pool, security safe, subcritical pile, storage cabinets, fuel storage room and FBBF shielded room.

The reactor pool, reactor core and security safe are protected by tamper-resistant intrusion detection system which will alarm upon entry to or exit from the reactor room.

The NRC staff reviewed Section 6, 7, and 8 of Purdues PSP and determined that they provide effective isolation of SNM and limits personnel access to the SNM. For these reasons, the NRC staff finds that Purdues PSP meets the criteria of 10 CFR 73.67(f)(1).

The regulation at 10 CFR 73.67(f)(2) states Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetration or activities.

Section 6, Security Areas, of Purdues PSP states that all access doors to the CAAs are either locked or under surveillance of an authorized individual during working hours. During non-working hours these doors are either locked and alarmed or under surveillance of an authorized individual.

The NRC staff reviewed section 6 and determined that the use of physical and electronic surveillance meets the intent to provide for early detection and assessment of unauthorized access or activities by an external adversary within the CAA. Accordingly, the NRC staff finds that Purdues PSP meets the criteria of 10 CFR 73.67(f)(2).

The regulation at 10 CFR 73.67(f)(3) states Assure that a watchman or offsite response force will respond to all unauthorized penetrations or activities.

Section 16, Administrative and Security Organization, of Purdues PSP states that the

53 university police department will respond to alarms. The university police are fully trained and qualified armed police officers with full arrest power under state law.

Section 25.8, Unauthorized Intrusion, of Purdues PSP states that in the event of alarm signal in the Central Communications Center, two police officers will respond. During working hours, laboratory personnel will immediately notify the university police of any forced or illegal entry into a CAA. During non-working hours, the CAAs are monitored by the alarm system and the university police department responds to those alarms.

The NRC staff reviewed section 16 and 25.8 of Purdues PSP and determined that an adequate response force exist to respond to all unauthorized penetration and activities. Accordingly, the NRC staff finds that Purdues PSP meets the criteria of 10 CFR 73.67(f)(3).

The regulation at 10 CFR 73.67(f)(4) states Establish and maintain response procedures for dealing with threats of thefts or thefts of this material. The licensee shall retain a copy of the current response procedures as a record for three years after the close of period for which the licensee possesses the special nuclear material under each license for which the procedures were established. Copies of superseded material must be retained for three years after each change.

Section 18, Response Procedures, of Purdues PSP states that response procedures for threats or actual thefts or diversion of SNM have been developed. The response procedures describe the type of response to be accomplished, the duties and responsibilities of the security organization management involved in the response and local law enforcement agencies (LLEA) response.

The NRC staff reviewed section 18 of Purdues PSP and determined that Purdue has well-developed response procedures for actual or attempted threats of theft of SNM. The NRC staff finds that Purdues PSP meets the intent of 10 CFR 73.67(f)(4).

The regulation at 10 CFR 73.67(g)(1)(i) states Each licensee who transports or who delivers to a carrier for transport special nuclear material of low strategic significance shall: (i) Provide advance notification to the receiver of any planned shipments specifying the mode of transport, estimated time of arrival, location of the nuclear material transfer point, name of carrier and transport identification, (ii) Receive confirmation from the receiver prior to commencement of the planned shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport, (iii) Transport the material in a tamper indicating sealed container, (iv) Check the integrity of the containers and seals prior to shipment, and (v) Arrange for the in-transit physical protection of the material in accordance with the requirements of § 73.67(g)(3) of this part, unless the receiver is a licensee and has agreed in writing to arrange for the in-transit physical protection.

Section 19.1, Advanced Notification to Receiver, of Purdues PSP states that that the facility shall notify the receiver of shipment prior to shipment the mode of transport, estimated time of arrival, location where material custody will be transferred, name of carrier, and transport identification.

Section 19.2, Receiver Confirmation, of Purdues PSP states that the advance notification process will include a statement that the receiver will be ready to accept the shipment at the planned time and location.

54 Section 19.3, Inspection, of Purdues PSP states that a checklist will be used to ensure the integrity of the shipping containers and associated locks and seals will be checked prior to shipment. At a minimum, the checklist includes a description of the tamper-proof lock wire and seal (or equivalent), the serial number of each seal, and the serial identification number stamped or engraved on the metal identification tag on the outside of each shipping container.

Section 19.4, Responsibility for In-Transit Physical Protection, of Purdues PSP states that the facility will be responsible for the in-transit physical protection of any shipment of SNM unless a written agreement from the receiver is received that accepts either full or shared responsibility for the in-transit physical protection of material in accordance with 10 CFR 73.67(g)(3).

The NRC staff reviewed section 19.1, 19.2, 19.3, and 19.4 of Purdues PSP and determined that the licensee establishes positive control of SNM and has processes to detect unauthorized access of SNM. The NRC staff finds that Purdues PSP meets the criteria of 10 73.67(g)(1)(i),

(ii), (iii), (iv), and (v).

The regulation at 10 CFR 73.67(g)(2) states each licensee who receives quantities and types of special nuclear material of low strategic significance shall: (i) check the integrity of the containers and seals upon receipt of the shipment, (ii) notify the shipper of receipt of the material as required in § 74.15 of this chapter, and (iii) arrange for the in-transit physical protection of the material in accordance with the requirements of § 73.67(g)(3) of this part, unless the shipper is a licensee and has agreed in writing to arrange for the in-transit physical protection.

Section 20.1, Inspection, of Purdues PSP states that when the facility receives a shipment of SNM a visual inspection of each shipping container and its associated locks or lock wire and seal will be made for evidence of tampering.

Section 20.2, Notification of Shipper, of Purdues PSP states that a copy of standard form NRC-741, Nuclear Material Transaction Report, will be sent to the shipper within 10 days of receiving a shipment of material.

Section 20.3, Responsibility for In-Transit Physical Protection, of Purdues PSP states the shipping facility acknowledges responsibility for in-transit physical protection of SNM unless the licensee receiver has agreed, in writing, to accept either full responsibility or shared responsibility for the in-transit physical protection of this material.

The NRC staff reviewed Section 20.1, 20.2, and 20.3 of Purdues PSP and determined that they establish checks for tampering, maintain custody records, and ensures proper physical protection is maintained during shipment. The NRC staff finds that Purdues PSP meets the criteria of 10 CFR 73.67(g)(2)(i), (ii), and (iii).

The regulation at 10 CFR 73.67(g)(3) states Each licensee, either shipper or receiver, who arranges for the physical protection of special nuclear material of low strategic significance while in transit or who takes delivery of such material free on board the point at which it is delivered to a carrier for transport shall: (i) Establish and maintain response procedures for dealing with threats or thefts of this material. The licensee shall retain a copy of the current response procedures as a record for three years after the close of period for which the licensee possesses the special nuclear material under each license for which the procedures were established. Copies of superseded material must be retained for three years after each change.

(ii) Make arrangements to be notified immediately of the arrival of the shipment at its

55 destination, or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination, and (iii) Conduct immediately a trace investigation of any shipment that is lost or unaccounted for after the estimated arrival time and notify the NRC Headquarters Operations Center by telephone at the numbers specified in Appendix A to this part within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the discovery of the loss of the shipment and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after recovery of or accounting for such lost shipment in accordance with the provisions of § 73.71 of this part.

Section 18, Response Procedures, of Purdues PSP states that response procedures for threats or actual thefts or diversion of SNM have been developed. The response procedures describe the type of response to be accomplished, the duties and responsibilities of the security organization, management responsibilities during an event, and LLEA response.

Section 21.3, Response Procedures, of Purdues PSP states that when the facility is informed, during the periodic checks with the carrier, that a delay in arrival is caused by threat of theft, theft, mechanical trouble or weather, the facility will notify the receiver of the delay and the new estimated time of arrival. The facility will cooperate with any local law enforcement agency as necessary in the event such an agency is required to help solve a problem.

Section 21.4, Notification, of Purdues PSP states the licensee is responsible for the physical protection of SNM in-transit will be notified by telephone when the shipment is received.

Telephone communication will be used to notify the responsible licensee if the shipment is lost or unaccounted for after the estimated arrival at its destination.

Section 21.5, Lost Material Notification, of Purdues PSP states in the event a shipment becomes overdue at its destination or at a scheduled stop on its itinerary and no reasonable explanation has been received by the licensee from the carrier regarding its status, a trace investigation will be initiated by the licensee by contacting state and local law enforcement along the planned route of the shipment. The receiver will be kept advised of any change in the itinerary of the shipment.

Section 24, Security Records, of Purdues PSP states that security records will be maintained at the facility for at least 36 months (3 years).

The NRC staff reviewed section 18, 21.3, 21.4, 21.5, and 24 of Purdues PSP and determined that adequate response procedures are developed for threats or actual theft of SNM, arrangements are made upon arrival, and processes are in place to conduct a trace investigation, if needed. The NRC staff finds that Purdues PSP meets the intent of 10 CFR 73.67(g)(3)(i), (ii), and (iii).

Order EA-07-074, Order Imposing Fingerprinting and Criminal History Records Check for Unescorted Access to All Research and Test Reactor Licensees Section 11, Preauthorized Screening, of Purdues PSP states that all personnel granted unescorted access to CAAs shall be screened. Additionally, all persons granted unescorted access must complete and pass all background checks and other provisions set forth by 10 CFR 73.57 and in accordance with Order EA-07-074. Everyone seeking unescorted access shall be fingerprinted.

Purdues PSP also states that the Laboratory Director may recommend that an individual be granted unescorted access to the CAAs based on a need for access, and a favorable review of information obtained on the individual for trustworthiness and reliability. This review is to be done by the NRC-approved reviewing official. This official shall determine whether an individual

56 may have or continue to have unescorted access.

The NRC staff reviewed Section 11 of the PSP and determined that it provides adequate procedures to verify the identity of personnel and provides an effective process to make trust and reliability determination for persons granted unescorted access to CAAs. The NRC staff finds that Purdues PSP meets the intent of Order EA-07-074.

12.4 Evaluation Findings The NRC staff reviewed the applicants PSP, Revision 7 (dated November 2021) and determined that the methods and procedures outlined in the PSP satisfy the performance objectives, and reporting requirements of 10 CFR 73.67(f), 73.67(g), and Order EA-07-074.

Therefore, the NRC staff finds the revised Purdue SNM renewal application, with its supporting materials, acceptable and that it provides reasonable assurance that the requirements for the physical protection of Category III SNM will be met.

13.0 MATERIAL CONTROL AND ACCOUNTING 13.1 Purpose of Review The purpose of this review was to determine whether Purdue MC&A practices are adequate to detect and protect against the loss, theft, or diversion of SNM that the licensee possesses, stores, and utilizes at its facility, and to comply with the applicable regulatory requirements in 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material.

13.2 Staff Review and Analysis In accordance with 10 CFR 70.22(b), applicants requesting a license to possess SNM must submit a full description of their program for the control and accounting of SNM in the applicants possession and to show compliance with 10 CFR 74.31, 74.33, 74.41, or 74.51, as applicable. However, the requirements in 10 CFR 70.22(b) contain an exclusion for licensees governed by 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, including non-power reactors (e.g., research and test reactors), and for uses of SNM as sealed sources. The same exclusions are contained in the MC&A requirements in 10 CFR 74.31, 74.33, 74.41, and 74.51, which contain specific control and accounting requirements for certain licensees, depending on the different types and quantities of SNM in possession. The MC&A requirements applicable to Purdue are contained in 10 CFR Part 74, Subpart B, General Reporting and Recordkeeping Requirements. Licensees who possess, transfer, or receive SNM in a quantity of one gram or more of contained uranium-235, uranium-233, or plutonium are subject to the general reporting and recordkeeping requirements of 10 CFR 74.11, 74.13, 74.15, and 74.19.

By letter dated September 18, 2023 (ML23268A087), Purdue submitted its license renewal package for license SNM-142. By letter dated February 23, 2024 (ML24032A473), the NRC staff issued a RAI. On March 25, 2024, Purdue submitted supplemental information (ML24086A454) addressing the RAI. A phone call was conducted on May 3, 2024 (ML24165A207), to request Purdue to clarify its response to RAI MC&A-5. Purdue provided the requested information by letter dated May 20, 2024 (ML24165A206).

The following discussion identifies each of the applicable MC&A requirements and summarizes the NRC staffs evaluation as to whether the information provided by Purdue in its LRA letter

57 and the supplements meet the requirements.

13.2.1 Reports of loss or theft or attempted theft (10 CFR 74.11)

The regulation in 10 CFR 74.11, Reports of loss or theft or attempted theft or unauthorized production of special nuclear material, requires licensees who possesses 1 gram or more of contained uranium-235, uranium-233, or plutonium to notify the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery of any loss or theft or other unlawful diversion of SNM which the licensee is licensed to possess, or any incident in which an attempt has been made to commit a theft or unlawful diversion of SNM.

In its RAI response letter, Purdue addressed RAI MC&A-1 on reporting loss, theft, or diversion of SNM. Purdue stated that authorized users are required to notify the RSO upon discovery of attempted or actual loss or theft of SNM or attempt of unlawful diversion. The licensee stated that after immediate notification of an incident to responsible personnel such as the RSO, the NRC Operations Center is notified within one hour of the incident in accordance with 10 CFR 74.11.

The NRC staff reviewed Purdues description for notifying the NRC of loss, theft, or diversion of SNM, or attempted theft or diversion of SNM. Purdue stated that activities are performed to ensure any indicator of loss or theft (or diversion), or attempted theft (or diversion) of SNM is responded to appropriately in accordance with 10 CFR 74.11. Based on the review, the NRC staff has determined that Purdues MC&A measures include adequate procedures to ensure that the NRC is notified in a timely manner in the event of a loss or theft or diversion of SNM, or attempted theft or diversion of SNM. Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.11 requirement.

13.2.2 Material status reports (10 CFR 74.13)

The regulations in 10 CFR 74.13, Material status reports, require that each licensee possessing SNM in a quantity totaling one gram or more of contained uranium-235, uranium-233, or plutonium must complete and submit, in computer-readable format Material Balance Reports concerning SNM that the licensee has received, produced, possessed, transferred, consumed, disposed, or lost. The Physical Inventory Listing Report must be submitted with each Material Balance Report. The reports shall be prepared in accordance with NUREG/BR-0007, Instructions for the Preparation and Distribution of Material Status Reports (DOE/NRC Forms 742 and 742C).

In its RAI response letter, Purdue addressed RAI MC&A-2 on material status reports. Purdue stated that it will submit electronic copies of the Physical Inventory Listing and the Material Balance Report on a semiannual basis in accordance with 10 CFR 74.13. Purdue further stated that inventories are performed by the Nuclear Engineering team and Radiation Safety, and that the reports are submitted to the Nuclear Material Management and Safeguards System by the RSO.

The NRC reviewed Purdues description of preparing and submitting material status reports.

Purdue stated that material status reports will be submitted at the required frequency and in accordance with 10 CFR 74.13. Based on the review of the information provided, the NRC staff determined that Purdues MC&A measures include adequate procedures to ensure that material balances and physical inventory listings are reported as required. Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.13 requirement.

58 13.2.3 Nuclear material transaction reports (10 CFR 74.15)

The regulations in 10 CFR 74.15, Nuclear Material Transaction Reports, require that each licensee who transfers or receives SNM in a quantity of 1 gram or more of contained uranium-235, uranium-233, or plutonium completes, in computer-readable format, a Nuclear Material Transaction Report. In addition, each licensee who adjusts the inventory in any manner, other than for transfers and receipts, shall submit a Nuclear Material Transaction Report, in computer-readable format, to coincide with the submission of the Material Balance Report. These reports shall be completed in accordance with NUREG/BR-0006, Instructions for Completing Nuclear Material Transaction Reports (DOE/NRC Forms 741 and 740M). Each licensee who transfers SNM shall submit a Nuclear Material Transaction Report no later than the close of business the next working day. Each licensee who receives SNM shall submit a Nuclear Material Transaction Report within 10 days after the material is received.

In its RAI response letter, Purdue addressed RAI MC&A-3 on submitting Nuclear Material Transaction Reports. Purdue stated that there are no plans for SNM to be transferred or received from/by them. If receipt of SNM would occur, Purdue stated that it would submit a transaction report in accordance with instructions within the required 10 days. Purdue further stated that if it would transfer material, it would submit a transaction report in accordance with instructions no later than the close of business the following working day.

The NRC staff reviewed Purdues description of completing and submitting Nuclear Material Transaction Reports. Purdue stated that there are no plans to transfer or receive SNM.

However, it stated that if receipt or transfer was to occur, transaction reports would be submitted in accordance with instructions within the proper time frame. Based on the review, the NRC staff determined that Purdues MC&A measures include adequate procedures to ensure that transfers and receipts of SNM are reported through Nuclear Material Transaction Reports as required. Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.15 requirement.

13.2.4 Recordkeeping 10 CFR 74.19(a)

The regulations in 10 CFR 74.19(a) require that a licensee keep records showing the receipt, inventory (including location and unique identity), acquisition, transfer, and disposal of all SNM in its possession regardless of its origin or method of acquisition. Each record relating to material control or material accounting must be maintained and retained for the period specified by the appropriate regulation or license condition. Each record of receipt, acquisition, or physical inventory of SNM must be retained as long as the licensee retains possession of the material and for 3 years following transfer or disposal of the material. Each record of transfer of SNM to other persons must be retained by the licensee who transferred the material until the Commission terminates the license authorizing the licensees possession of the material.

In its RAI response letter, Purdue addressed RAI MC&A-4 on recordkeeping. Purdue stated that it has all shipment receipts and inventory records, dating back to the original procurement of the material, stored onsite in secured storage. Purdue also stated that it will prepare a directive stating that all inventory, shipment, and receipt records will be stored for the lifetime of the facility plus three years.

The NRC staff reviewed Purdues description of MC&A records and recordkeeping. Purdue stated that records are generated and maintained for all material under license, and that records will be maintained for the lifetime of the facility plus three years, as required by 10 CFR 74.19(a). Based on the review, the NRC staff determined that Purdues MC&A measures

59 include adequate procedures to ensure MC&A records are completed and maintained.

Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.19(a) requirement.

13.2.5 Written MC&A Procedures (10 CFR 74.19(b))

The regulations in 10 CFR 74.19(b) require that a licensee authorized to possess SNM in a quantity exceeding one effective kilogram at any one time shall establish, maintain, and follow written MC&A procedures that are sufficient to enable the licensee to account for the SNM in its possession under license. The license shall retain these procedures until the Commission terminates the license and retain any superseded portion of the procedures for 3 years after the portion is superseded.

In its RAI response letter, Purdue addressed RAI MC&A-5 on written MC&A procedures.

However, in the response Purdue discussed inventory and inventory reconciliation, and it was not clear to the NRC staff that the licensee addressed the RAI on written procedures adequately. A clarification call with the licensee was conducted on May 3, 2024. Purdue submitted a clarification letter on May 20, 2024, which stated that Purdue has created a document detailing MC&A procedure to satisfy 10 CFR 74.19(b). Purdue stated that the written document details the process necessary to submit all forms for performing inventory.

The NRC staff reviewed Purdues description of its MC&A procedures provided in the clarification letter. Purdue affirms that it created a document detailing their MC&A procedures to satisfy 10 CFR 74.19(b). Based on the review, the NRC staff determined that Purdues MC&A measures include adequate written MC&A procedures to ensure that Purdue can account for all SNM in its possession. Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.19(b) requirement.

13.2.6 Physical inventories (10 CFR 74.19(c))

The regulations in 10 CFR 74.19(c) require that certain licensees who are authorized to possess SNM in a quantity greater than 350 grams of contained uranium-235, uranium-233, or plutonium, are to conduct a physical inventory of all SNM in its possession under license at intervals not to exceed 12 months. The results of these physical inventories shall be retained in records by the licensee until the Commission terminates the license authorizing the possession of the material.

In Section 8, 10 CFR 70.53 and 70.54, Material Control and Accountability, of its LRA, Purdue stated that inventory of SNM is completed by the Reactor Team semiannually. Purdue stated that an inventory reconciliation is performed to verify/update all current inventory items.

The NRC staff reviewed Purdues description of physical inventory. Purdue affirms that an inventory will be performed at intervals not to exceed 12 months, as required by 10 CFR 74.19(c). Based on the review, the NRC staff determined that Purdues MC&A measures include adequate procedures to ensure physical inventories of its SNM are completed at the required frequency. Therefore, the NRC staff finds that Purdue meets the 10 CFR 74.19(c) requirement.

13.3 Evaluation Findings Based on the review of the LRA, RAI responses, and RAI clarifications, the NRC staff finds that Purdues MC&A program, as described in its LRA and supplemental information, provides assurance that Purdue will satisfy the applicable requirements in 10 CFR §§ 74.11, 74.13,

60 74.15, and 74.19 during the renewed license term. Therefore, the NRC staff finds that Purdues MC&A program is acceptable.

III.

NATIONAL ENVIRONMENTAL POLICY ACT The National Environmental Policy Act of 1969 was enacted by Congress to ensure Federal agencies consider the environmental impacts of their actions and decisions. Federal agencies are required to systematically assess the environmental impacts of their proposed actions and consider alternative ways of accomplishing their missions, which are less damaging to and protective of the environment.

Purdue University uses SNM-142 for research and development purposes. Pursuant to 10 CFR 51.22(c)(14)(v), renewal of materials licenses issued under 10 CFR Parts 30 or 70 (among others) for research and development and for educational purposes is a category of actions which the NRC has determined does not individually or cumulatively have a significant effect on the human environment and thus, no environmental assessment (EA) or environmental impact statement (EIS) is required. Little to no radioactive waste would be generated as part of the Purdue University license renewal and, if any waste is generated, it would be properly labeled to include the isotope, amount, authorization number, investigator name, date, and any solvents or hazardous materials present, and would be disposed of consistent with all applicable federal regulations. Accordingly, the Purdue license renewal falls within a category of actions that does not require the preparation of either an EA or an EIS.

IV.

CONCLUSION The NRC staff finds that the Purdue program under SNM-142 will provide adequate protection of public health and safety and that an adequate level of safety will be maintained during the proposed license renewal term. The NRC staff also finds that Purdues LRA and its supporting/supplemental information, meets the requirements of 10 CFR Part 70.23, Requirements for the approval of applications, and provides reasonable assurance that the proposed operations at Purdue will not have an adverse impact on the public health and safety, the common defense and security, or the environment.

Based on the information provided by Purdue, as discussed in this SER, the NRC staff concludes that Purdues safety programs will continue to meet the applicable requirements in 10 CFR Parts 19, 20, 33, 36, 70, 73, and 74. The NRC staff recommends that Purdues SNM-142 license be renewed for a 10-year term in accordance with the statements, representations, and conditions in its September 18, 2023, LRA (ML23268A087) and Enclosures, and supplemental letter dated March 25, 2024, (ML24086A454) and Enclosures.

V.

PRINCIPAL CONTRIBUTORS Suzanne Ani Material Control and Accounting Jimmy Chang Fire Safety, Irradiator and 10 CFR Part 36 Exemptions Nicole Cortés Chemical Safety Jeremy Munson Nuclear Criticality Safety Harry Felsher Radioactive Waste Management Eliezer Goldfeiz Radiation Protection, 10 CFR Part 36 Irradiator and Exemptions, 10 CFR Part 32 Manufacturing, 10 CFR Part 33 Broad Scope

61 James Hammelman Emergency Management, Chemical Safety Isaac Johnston Environmental Review Kenneth Kline Decommissioning Financial Assurance Emil Tabakov Decommissioning Financial Assurance Michael Norris Stephen Poy Emergency Management Project Manager Charles Teal Physical Security (Fixed/In-Transit)

Osiris Siurano Project Management, General Information, Purpose/Use/Location of Radioactive Materials, Integrated Safety Analysis, Management Measures James Smith Decommissioning VI.

REFERENCES The following references are listed in the order they appear in this document.

1. Purdue University, Revised License Renewal Application, September 18, 2023, ML23268A087.

2. Title 10 of the Code of Federal Regulations (10 CFR).

3. U.S. Nuclear Regulatory Commission (NRC), Timely Renewal Memo, October 18, 2023, ML23285A239.

4. NRC, Acceptance of Purdues Application, December 13, 2023, ML23324A448.

5. NRC, Federal Register Notice for opportunity for the public to request a hearing, February 9, 2024, ML24005A120.

6. NRC, Public meeting summary to discuss draft RAIs, February 21, 2025, ML24061A046.

7. NRC, NRC Request for Additional Information, February 23, 2024, ML24032A473.

8. Purdue, Purdue Response to RAI, March 25, 2024, ML24086A458 (Package).

9. Purdue, Purdue Response to RAI, March 25, 2024, ML24086A454.

10. Purdue, Purdue Response to RAI Public Enclosure, March 25, 2024, ML24086A456.

11. Purdue, Purdue Response to RAI Non-Public Enclosure, March 25, 2024, ML24086A455 (non-public).

12. Purdue, Copy of Purdue August 3, 2012 license amendment request to allow the transfer of natural uranium and 1.3 percent enriched uranium rods to the U.S. Department of Energy for disposal, August 3, 2012, ML24086A453 (non-public).

13. NRC, Email to Purdue from NRC requesting clarification to MC&A RAI 5, May 16, 2024, ML24165A207.

14. Purdue, Purdue response to NRC May 16 email, May 20, 2024, ML24165A206.

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15. NRC, NUREG-2212 (Draft), Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H, September 2022, ML22335A087.

16. NRC, NUREG-1520, Standard Review Plan for Fuel Facilities License Applications, Revision 2, June 2015, ML15176A258.

17. NRC, NUREG-1556 Volume 6, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About 10 CFR Part 36 Irradiator Licenses, Revision 1, January 2018, ML18026A698.

18. NRC, NUREG-1556 Volume 7, Program-Specific Guidance About Academic, Research and Development, and Other Licenses of Limited Scope, Including Electron Capture Devices and X-Ray Fluorescence Analyzers, Revision 1, February 2018, ML18065A006.

19. NRC, NUREG-1556, Volume 11, Consolidated Guidance About Materials Licenses:

Program-Specific Guidance About Licenses of Broad Scope, Revision 1, February 2017, ML17059D332.

20. Purdue, License Renewal Application, July 11, 2023, ML23268A078 (non-public).

21. Purdue, Appendix A Emergency Plan, December 20, 2021, ML23268A077 (non-public).

22. Purdue, Appendix A Security Plan for the Purdue University Reactor, the Fast Breeder Blanket Facility, Nov. 2021, ML23268A075 (non-public).

23. Purdue, Appendix A Technical Specifications, March 31, 2015, ML23268A074 (non-public).

24. Purdue, Appendix A Operating Principles and Core Characteristics Manual, July 22, 2021, ML23268A081 (non-public).

25. Purdue, Appendix A Safety Analysis Report, November 30, 2016, ML23268A076 (non-public).

26. Purdue, Appendix A Standard Experiment Procedure, February 24, 2022, ML23268A079 (non-public).

27. Purdue, Appendix A Fuel Inventory Example, February 16, 2023, ML23268A075, (SGI

- non-public).

28. Purdue, Appendix A Purdue University Research Reactor (PUR-1) ALARA Program, September 18, 2023, ML23268A082 (public).

29. Atomic Energy Act of 1954, as amended.

30. NRC, Acceptance of Purdues LRA, December 13, 2023, ML23324A448.

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31. Purdue, Purdue License Amendment Request to Propose New Radiation Safety Officer, February 26, 2024, ML24064A056.

32. Purdue, Safety Evaluation Report - License Renewal Application for Purdue University Materials License No. SNM-142, September 25, 2013, ML12067A120 (non-public).

33. NRC, Regulatory Guide (RG) 8.24, Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication, June 30, 2012, ML110400305.

34. Purdue, Safety Evaluation Report: Application dated May 4, 1999, License Renewal, July 30, 1999, ML20210L568.

35. Purdue, Purdue updated decommissioning funding plan and statement of intent, March 4, 2025, ML25107A212.

36. Purdue, Purdue Broad Scope License No. 13-02812-04, Amendment #106, April 5, 2023, ML23097A070 (non-public).

37. Purdue, Revised NRC Form 313, August 28, 2025, ML25240B601 (non-public).

38. NRC, NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, January 1988 (ML12174A320).

39. NRC, NUREG-1757, Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria, Volume 2, Revision 2 (Final Report), July 2022, ML22194A859.

40. NRC, NUREG-1757, Consolidated Decommissioning Guidance: Financial Assurance, Recordkeeping, and Timeliness, Volume 3, Revision 1 (Final Report), February 2012, ML12048A683.

41. NRC, NRC Form 540, Uniform Low-Level Radioactive Waste Manifest - Shipping Paper, ML13083A180.

42. NRC, NRC Form 541, Uniform Low-Level Radioactive Waste Manifest - Container and Waste Description, ML13083A182.