Regulatory Guide 10.7

Guide for Preparation of Applications for Licenses for Laboratory & Industrial Use of Small Quantities of Byproduct Material

ML003740382
Person / Time
Issue date:	08/31/1979
From:	Office of Nuclear Regulatory Research
To:
References
RG-10.7 Rev 1
Download: ML003740382 (20)

{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION ft!m" 1 Aep 117 REGULATORY GUIDE OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 10.7 GUIDE FOR THE PREPARATION OF APPUCATIONS FOR UCENSES FOR LABORATORY AND INDU1STRIAL USE OF SMALL QUANTmES OF BYPRODUCT MATERIAL

1. INTRODUCTION

This guide describes the type of information needed by the NRC staff to evaluate an appl cation for a specific license for laboratories and industries using millicurie quantities of by product material (reactor-produced radionu clides). This type of license is provided for under Title 10, Code of Federal Regulations, Part 30. "Rules of General Applicability to Do mestic Licensing of Byproduct Material Paragraph.

20 1(c) of 10 CFH Part 20. "Stand ards for Protection Against Radiation," states that " .persons engaged in activities under licenses issued by the Nuclear Regulatory Com mission pursuant to the Atomic Energy Act of 19.54, as amended, and the Energy Reorganiza tion Act of 1974 should, in addition to comply ing with the requirements set forth in this part, make every reasonable effort to maintain radiation exposures, and releases of radio active materials in effluents to unrestricted areas, as low as is reasonably achievable" (ALARA). Regulatory Guide R. 10, "Operating Philosophy for Maintaining Occupational Radia tion Exposures As Low As Is Reasonably Achievable,", provides the NRC staff position on this important subject. License applicants should give consideration to the ALARA philos ophy, as described in Regulatory 3uide 8. 10, in the development of plans for work with licensed radioactive materials.

2. LICENSE FEES An application fee is required for most types o)f Licenses The applicant should refer to §170 31, "Schedule of Fees for Materials Licenses and Other Regulatory Services," of*1 '-n1dcate substantave changes from previoub .'.ue 10 CFR Part 170 to determine the amount of fee that must accompany the application.

Review of the application will not begin until the proper fee is received by the NRC. 3. FILING AN APPLICATION An applicant for a byproduct material (radio-j isotopes) license should complete Form NRC 3131 (see the appendix to this guide).' AUl items on the application form should be com pleted in sufficient detail for the NRC to deter mine that the applicant's equipment, facilities, and radiation protection Program are adequate to protect health and minimize danger to life and property.

Since the space provided on Form NRC-3131 is limited, the applicant should append addi tional sheets to provide complete information.

Each separate sheet or document submitted with the application should be identified by a heading indicating the appropriate item number (on Form NRC-3131) and its purpose (e.g., radiation, safety instructions). The application should be completed in trip licate. The original and one copy should be mailed to the Division of Fuel Cycle and Mate rial Safety, Office of Nuclear Material Safety and Safeguards, U.S Nuclear Regulatory Com mission. Washington, D.C. 20555. One copy of the application, with all attachments, should be retained by the applicant since the license will require, ab a condition, that the institution follow the statements and representations set forth in the application and any supplement to it 'Applications (or" medical uses should be submitted on Form NRC-313M.

and applications for use of selled sources in rad-raphy should beasu I. 1ri NRC-313R USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commen. U.S tuim ttagu0tory Guide -a-einu to "-,,be mnd ineao .a blee to uRgulatory Conomatin Wwa Wo 0 C 2066 Atteintion OoClea SW C "nothOd"a to the NRC soft of leamenting 'vec1fac prts of the , rsion's regulations.

to used by the staff on evalu- The guides we rilsuidm the foliowu I tan hoad dairnons "'lng 'pcftIc W-11-16r~ Or postulated accidents, or fto Proside guidance t rippicants Regulatory Guides ae rnt gubseaae for regulaions.

and cornt I Power Reactors 6 Products Pliecs with them is riot raqaujed Maihods and ookn f dffere fyro tmhose 2 Resarch and Test Reactors 7 Transoration set out in fth guides will be erLcaputAte rf the provide a basie for tie woiadngs 3 Fuels and Martialo Feotms 8 OccuoiaaonWs Health requiste to the isuance or continuance of a perrNt or licanse by the 4 Enovrwnen'ta and Sittru . Coa'-mHaon Requests for s-g*e copies of 'Uued Iuades fivhaCh rngy bi eWoduced, or for Comnnts and suggestiOns tor nprOvernts ,n thee guades are encouraged at placement or an etutomat.c agle copaes of ftureL guaee i tlrr*s Wu-des wet Uae resa a s to aCrorrmodante commentd n spi fc dvisons should be nuide a wating to the U S Nuclear Regulefory nO tO f cr 'e information or sotae This guide wasred mosta ComrnmraTtn Wasthington D C 205Mu Alteanon Deoitor. ONvror, of of sobstant" curnmrents re..a. ed fromr the public and addrtional staf reiew Tochn,~i into~rraitocn and Dorumlent Control 0 Gililrt and Fiancial Revew*R 5 M410"ifis am Plant Protection 4. CONTENTS OF AN APPLICATION Most items of Form NRC-313r are self explanatory (see instructions with the form). The following comments apply to the indicated numbered items of the form. Items 2 and 4. Specify the applicant corpo ration or other legal entity by name and address of principal office. Individuals should be designated as the applicant only if the use of the byproduct material is not connected with the individual's employment with a corporation or other entity If the applicant.

is an individual, the individual should be specified by full name and address, including state and zip code Item 5. Specify the street address of the location of use if the address differs from the one given in Item 4. If use is to be at more than one location, the specific address of each should be given Describe the extent of use and the facilities and equipment at each location.

A post office box address is not acceptable.

Item 6 Specify the names of the persons who will directly supervise the use of radioactive material or who will use radioactive material without supervision Item 7. Specify the name of the person who will be designated as the radiation protection officer. 2 Thispj5erson should be responsible for implementing the radiation safety program and therefore readily available to the users in case of difficulty and should be trained and experi enced in radiation protection and in the use 1 and handling of radioactive materials.

In a small program not requiring a full-time radiation protection officer, the duties of the radiation protection officer may be assigned to one of the persons named under Item 6 of Form I NRC-3131.

Note, however, that it must be established that the person acting as radiation protection officer will have the opportunity to devote sufficient time to the radiation safety aspects of the program for the use of radioactive materials.

Items BA, B, C, and D. Describe the byprod uct material by isotope, chemical and/or physi cal form, and activity, in millicuries or micro curies A separate possession limit for each nuclide should be specified Possession limits requested should cover the total anticipated inventory, including stored materials and waste, and shouid be commensurate with the applicant's needs and facilities for safe handling If the use of sealed or plated sources is con tempiated, the isotope, manufacturer, and 'The terms radiation protection officer" and "radioiogrcal safety officer" are synonv.aoul model number of each sealed or plated source should be specified It a source will be used in a gas chromatograph.

gauge, or other device. the manufacturer and model number of the device should be specified Item 8E and Item 9 The use to be made of' the radioactive materials should be clearly described Sufficient detail should he given to allow a determination of the potential for expo sure to radiation and radioactive materials both of those working with the materials and of the public Items 10 and 11. Specify for each radiation detection instrument the manufacturer's name -and model number, the number of each type of instrument available, the type of radiation detected (alpha, beta, gamma, or neutron). the sensitivity range (milliroentgens per hour or counts per minute). the window thickness in mg/cm 2.and the type of use. The type of use would normally be monitoring, surveying, assaying, or measuring.

Describe the instrument calibration proce dure. State the frequency, and describe the methods and procedures for the calibration of survey and monitoring instruments, as well as any other instruments and systems used in the radiation protection program, such as measur ing instruments used to assay sealed-source leak-test samples (see Item 15). contaminationi samples (e.g.. air samples. surface "wipe" samples), and bioassay samples (see Item 12) An adequate calibration of survey instru ments usually cannot be performed with built in check sources Electronic calibrations that do not involve a source of radiation are also not adequate to determine the proper function ing and response of all components of an instrument.

Daily or other frequent checks of survey instruments should be supplemented every 6 months with a two-point calibration on each scale of each instrument with the two points separated by at least 50% of the scale Survey instruments should also be calibrated following repair. A survey instrument may be considered properly caiibrated when the instrument read ings are within +/-10 percent of the calculated or known values for each point checked Readings within +/-20 percent are considered acceptable if a calibration chart or graph is prepared and attached to the instrument If the applicant proposes to calibrate his survey instruments, a detailed description of planned calibration procedures should be sub mitted The description of calibration proce dures should in(lude, as a minimum: a The manufacturer and model number of each radiation source to be used, 10 7-2 b. The nuclide and quantity of radioactive material contained in each source, c The accuracy of the source(s). The traceability of the source to a primary standard should be provided.

d The step-by-step procedures, including associated radiation safety procedures, and e The name and pertinent experience of each perstin who will perform the calibrations.

If the applicant intends to contract out the calibration of instruments, the name, address, and license number of the firm should be speci fied together with the frequency of calibration.

The applicant should contact the firm that will perform the calibrations to determine if infor mation concerning calibration procedures has been filed with the Commission.

If information concerning calibration procedures has not been filed, it should be obtained and submitted.

Quantitative measuring instruments used to monitor the adequacy of containment and con tamination control such as those used for mea suring leak test, air, effluent, bioassay, work area, and equipment contamination samples 3hould usually be calibrated prior to each use. The procedures and frequency for calibration of such instruments should be submitted and should include: a The name of the manufacturer and model number of each of the standards to be used, b. The nuclide and quantity of radioactive material contained in each of the standard sources, c A statement of the accuracy of each of the standard sources. The source accuracy should be. as a minimum, +/-5 percent of the stated value and traceable to a primary standard, such as that maintained by the National Bureau of Standards.

d. Step-by-step calibration procedures and, if appropriate, associated radiation safety pro cedures, and T e. The name and pertinent experience of each person who will perform the instrument "calibrations Item 12 Personnel monitoring is required to ensure .-mplianee with §§20 101 and 20 202 of 10 ('FR Part 20. Personnel monitoring is also required if a person enters a high radiation area (greater than 100 millirems per hour). If p'.sonnel monitoring equipment will be used, the ndine of the organization furnishing film badge or thermoluminescent do.<'imeter (TLD) service and the frequer , for changing badges, dosumeter.-, etc sh,uld be specified If pocket chambers ur pocket dosimeters will be used. the useful range of the devi(e. in milliroentgens, the frequency of reading, and the procedures for maintaining and calibrating the devices should be specified.

If personnel monitoring will not be used, the applicant should submit calculations or docu mentation from radiation surveys demonstrating that it is unlikely that any individual will receive a dose equal to or greater than that indicated in 10 CFR Part 20. The applicant should show that the need for bioassays has been thoroughly considered and should establish the adequacy of the proposed bioassay program in relation to the proposed program of use of radioactive material.

Bio assays are normally required when individuals work with miUicurie quantities of hydrogen-3, iodine-125, or iodine-131 depending on the type of work, equipment, and procedures fol lowed Regulatory Guide 8.20, "Applications of Bioassay for 1-125 and 1-131," and a document entitled "Guidelines for Bioassay Requirements for Tritium"- may be consulted.

Other mate rials may also be used in physical or chemical forms and under conditions that present an opportunity for uptake by the body through ingestion, inhalation,, or absorption A bio assay program to determine and control the uptake of radioaetive material should be con sidered and discussed in relation to each such material, procedure, etc, Regulatory Guide 8 9, "Acceptable Concepts Models. Equations, and Assumptions for a Bioassay Program." may. he consulted.

The criteria tc be used in determining the need for hiioassays, the type and frequency of bioassays that will be performed, and the bio assay procedures should be specified and described in detail If a commercial bioassay service is u., be used, the name and address of the firm should be provided.

Bioassays may not be substituted for other elements of a safety program such as air moni toring and dispersion control (hoods, glove boxes. etc ) and for well-thought-out and well-executed handling procedures Item 13 The facilities and equipment for each site of use should be described in detail. The proposed facilities and equipment for each operation to be conducted should be adequate to protect health and minimize danger to life and property In describing available fa. ilities and equipment.

the following should be included, as appropriate: a Physical plant, laboratory.

or working area facilities Fume hoods glove boxes, waste receptacles, spenjal sinks, ventilation and con tainment systems. effluent filter systems, and jA copy may be obtained by a written request to hte U S Nuclear Regulatory C'.mmision.

Office .)f Nuclear ?ateruidJ Safety and Safeguaro, Div-tsaon of Fuel CycLe and Materi.la Safet

y. Washington

! 20555, A:'enton Director.

office of Nuclear Material Saifet, ant Safeguards hd , n p f O 1 7'.I i ' I I !; d t ý , -i h l' j~ t ..o h n A drawing or sketch should be submitted showing the location of all such equipment and the relationship of areas where radioactive materi:is will be handled to unrestricted areas where rad'ioactive materials will not be handled In those programs where radioactive material may become airborne or may be included in air br-ne effluents, the drawing or -ketch should also include a schematic description of the ven tilation system annotated to show airflow rates, differential pressures, filt ration and other effluent treatment equipment and air and effluent monitoring instruments Drawings or sketches should be drawn to a specified scale, or dimensiLons should be included on each drawing or sketch. Each drawing or sketch should be labeled to specify the location of the facilitles and equipment depicted with respect to the address(es) given in Item 5 of Form NRC-3131 F- C(ontainets, devices. protective clothing.

auxiliary shielding, general laboratory equip ment. a. r sampling equipment.

etc .actually employed in the daily use of material Special provisions for shielding and containment to minimize personnel exposure should be de scribed Storage containers and facilities should provide both shielding and security for materials c The number. type. and length of remote handling devices d If respiratory protective equipment will be used to limit the inhalation of airborne radioactive material, the provisions of §20.103 of 10 CFR Part 20 should be followed and appropriate information should be submitted Item 14 The procedures for disposing of byproduct material waste should be described Under NRC regulations, a licensee may dispose of waste in the following ways a Transfer to a person properly licensed to receive such waste in conformance with para graph 20.301(a) of 10 CFR Part 20 The name of the firm (which should be contacted in advance to determine any Limitations that the firm may ,iave on acceptance of waste) should be given f, Release into a sanitary sewer in confor mance With §20 303 of t0 CFR Part 20 Depending on water usage. releases rf up to I curie per year are permitted c Buria, i" soil in contformance with §20 304 f 10 (-FR Part 20 Up to 12 hurials per year arr permi.,sible The a,. hlc ju o,;it, .upon *h- radionu-Lide ' d Release into air or water in oncentrationf' in conformance with §20 106 of 10 ('FR Part 20 Possible exposure to persons offsite Limits the amount that may be released e Treatment or disposal by incineration in conformance with §20 305 of 10 CFR Part 20 This must be specifically approved by the Commission f Other methods specifically approved by 'he Commission pursuant to §20.302 of 10 CFR Part 20 Item 15 a Survey Program. Commission regulations require that surveys be made to determine if radiation hazards exist in a facility in which radioactive materials are used or stored (see §20.201 of 10 ('FR Part 20) A survey should include the evaluation of external exposure to personnel, concentrations of a-iruorne radio active material in the facility, and radioactive effluents from the facility Although a theoreti cal calculation is often used to demonstrate compliance with regulations regarding airborne or external radiation, it cannot always be used in Lieu of a physical survey Except for those cases where sources of radiation and radioactive material are well known and accurately and precisely controlled, it will usually be necessary that a physical survey be made with appropriate detection and measurement instruments to determine the nature and extent of radiation and radioactive material or, as a minimum, confirm the results of a theoretical determination A radiation protection program should include the following surveys for radioactive contamination and radiation. (I) In laboratory or plant areas (e g checking for contamination on bench tops, han dling and storage equipment, clothing, hands) (2) While work is being done with radiation or radioactive materials (e.g , breathing zone air surveys, general air surveys, personnel exposure measurements.

Luncluding eyes and extremities, checking shutters and "'ontain ment) (3) in areas associated with disposal or release of radioactive materials (e g .checking 'The NRC has proposed an amendment would delete $20 304 of 10 CFlt Part 20 (43 F'R Ssi77 December 4. 19i 8) If this amendent is adopted. all b,,ne.ls of radionuclides in accord~ance with 120 304 of 10 CFR Part 20 wil require NRC approval 10 7-4 disposal containers and disposal sites; liquid, gas, and solid effluents, filters and filter-duct systems) The frequency of surveys will depend on the nature of the radioactive mrterials and their use. However, surveys should be per formed prior to the use of radioactive materials in order to establisl a baseline.

The surveys should be repeated when radioactive materials are present, when the quantity or type of material present changes, or when changes occur in their containment systems cr methods of use. Repetitive surveys may also be necessary to control the location of radioactive materials in the handling system and in the case of the use of sealed sources outside a shielded container.

For operations involving materials in gas, liquid, or finely divided forms, the survey program should be designed to monitor the adequacy of containment and control of the materials involved. "he program should include air sampling, monitoring of effluents, and sur veys to evaluate contamination of personnel, I facilities, and equipment Physical effluent !measurements are essential to determine compli ance with Appendix B to 10 CFR Part 20. The description of an air sampling program should include the area where samples will be taken, the frequency of sampling, and the location of the sampler with respect to workers' breathing zones Assays performed to evaluate air samples and the methods used to relate results to actual personnel exposures should also be described The effluent monitoring program for releases to unrestricted areas should encom pass all airborne and liquid radioactive material releases Theoretical evaluations should be supplemented by stack monitoring, water sam pling, and other environmental monitoring ap propriate for the planned and potential releases For operations involving only sealed sources, a survey program should include evaluation and/or measurement of radiation levels for storage and use configurations.

When sources are used in devices having "on" and "off" positions, both positions should be eval uated at the tune of installation Supplemental surveys should be performed following any changez. in operation, shielding, or use The types, methods, and frequency of surveys should be described in the application .'*uidance may be obtained from the National Council on Radiation Protection Report No 10. "Radiological Monitoring Methods and Instru ment-s,' and the International Atomic Energy 'CopIes may be ob asnedi rrM NCRp P ublicaon, P o Box 4867 Washun .D ( 20008 Agency's Technical Report Ses No 120, "Monitoring of Radioactive Contamination am Surfaces.

"' b. Records Management Progrm. Provision for keeping and reviewing record of surveys; materials inventories; personnel exposures; receipt, use, and disposal of materials, etc., should be described.

Persons responsible for keeping and reviewing records should be iden tified. c Sealed-Source Leak-Test Procedures.

Sealed sources containing more than 100 micro curies of a beta or gamma emitter or more than 10 microcuries of an alpha emitter must be leak tested at 6-month intervals.

Leak testing of alpha-particle-emitting sources containing more than 10 microcuries of an alpha emitter Is required at 3-month intervals.

If a commercial firm is to perform the leak tests, the name, address, and license number of the firm should be submitted If the tests are to be performed using a commercial "kit," the nme of the kit manufacturer or distributor and the kit moe designation should be given. If the applicant intends to perform his own leak tests without the use of a commercial kit, the following information should be submitted: (1) Qualifications of personnel who will perform the leak test, (2) Procedures and materials to be used in taking test samples, (3) The type, manufacturer's name, model number, and radiation detection and measure ment characteristics of the instrument to be used for assay of test samples, (4) Instrument calibration procedures, including calibration source characteristics.

make, and model number, and (5) The method, including a sample calcu lation, to be used to convert instrument read ings to units of activity, e.g. .microcuries.

d. Instructions to Personnel.

If a number of individuals will use radioactive materials under the supervision of one or more of those persons named in Item 6 of Foim NRC-3131, written instructions should be prepared and submitted with the license application in the form in which they will be distributed to those working with radioactive materials.

These instructions should cover, but not necessarily be limited to: (1) The availability.

selection, and use of laboratory apparel and safety-related equip ment and devices (e g. , laboratory coats, gloves, and remote pipetting devices). 6Copies may be ohrain-- from "'IPUiB in. P 0 Box 433, New .'jrx N " Y 0 'oei 10 7-5 (2) Limitations and conditions to be met in handling liquid or uncontained (unencapsu lated, dispersible, or volatile) 1asdioactive materials and special laboratory equipment to be used in working with these types of mate rials. For example, the instructions should explain when operations with materials should be confined to a radiochemical fume hood or glove box and should specify the use of appro priate shielding and remote handling equipment when energetic beta- or gamma-emitting mate rials are to be used. (3) The performance of radiation survey and monitoring procedures or each area in which radioactive materials are to be used. (4) Safely precautions to be observed in the movement of radioactive materials between buildings, rooms, and areas within rooms. (5) Safety requirements for storage of radioactive materials, including labeling of containers of radioactive materials and posting and securing areas where radioactive materials are to be stored. This should include the stor age of contaminated laboratory equipment such as glassware.

(6) Requirements for posting of areas in which radioactive materials are used. (7) The availability and use of personnel monitoring devices, including the recording of radiation exposures and the procedures to be followed for the processing of personnel moni toring devices such as thermoluminescent dosi meters .and film badges in order to obtain per sonnel monitoring results (8) Waste disposal procedures to be fol lowed, including limitations on the disposal of liquid or other dispersible waste to the sani-tary sewer and proceaures for the LoUeLLLZI, storage, and disposal of other wastes (9) The maintenance of appropriate rec ords as required by 10 CFR Part 20 and 10 CFR Part 30. (10) The requirements for and the method of performing or having appropriate sealed source leak tests performed.

(11) Good radiation safety practices, in cluding the control of contamination, specifica tion of acceptable removable and fixed contami nation levels tor both restricted and unre stricted areas, prohibition of smoking and the consumption of food or beverages in areas where radioactive materials may be used, and prohibition of the frequent transfer of poten tially contaminated equipment between poten tially contaminated areas and unrestricted areas.(12) The use of radioactive materials in animals. If radioactive materials will be used in animals, instructions concerning such use should be prepared and submitted with the license application.

Such instructions should include (a) specification of the facilities to be used to house the animals, (b) instructions to be provided to animal caretakers for handling animals, animal wastes, and carcasses, (c) instructions to appropriate personnel for clean ing and decontaminating animal cages, and (d) methods to be used to ensure that animal rooms will be locked or otherwise secured unless attended by authorized users of radioactive materials.

A description of animal handling and housing facilities should be included uLnd'. Item 13 of Form NRC-3131.

(13) Emergency procedures.

These instruc tions should be addressed to all persons in aV. laboratory or facility areas where radioactive! materials will be used and should cover actions : to be taken in case of such accidents involving! radioactive materials as spills, fires, release or loss of material, or accidental contamination of personnel.

Specifically, these instructions should (a) specify immediate actions to be taken in order to prevent or limit the contami nation of personnel and areas, e.g.. the shut ting down of ventilation equipment, evacuation of contaminated and potentially contaminated i areas, containment of any spills of radioactive material, (b) give the telephone numbers of in dividuals to be notified in case of emergency.

and (c) instruct personnel in proper entry, decontamination, and recovery operations for I contaminated facilities. (Note: Only properly trained individuals should attempt decontamina tion and recovery operations. ) (14) Requirements and procedures for pick ing up, receiving, and opening packages (see §20.205 of 10 CFR Part 20). Items 16 and 17. A resume of the training and experience of each person who will directly supervise the use of material, who will use material without supervision, or who will have responsibilities for radiological safety should be submitted.

The resumi should include the type (on-the-job or formal course work), loca tion, and duration of the training.

Training should cover (a) principles and practices of radiation protection, (b) radioactivity measure ments, standardization, and monitoring tech niques and instruments, (c) mathematics and calculations basic to the use and measurement of radioactivity, and (d) biological effects of radiation.

The description of the use of radio active materials should include the specific iso topes handled, the maximum quantities of mate rials handled, where the experience was gained, the duration of experience, and the type of use The qualifications, training, and 10 7-6

)4ý each terson should be commensu ,I:- w~th J1, mnatriwl arnd its use as proposed T , 'TphPb-ation The amount and type of 'a: ir'd 'xpe; ien(-' with radiation and , a e raaterial.: r1aliu1red to support a ,i('rrmIJ atin I ,f _ad-quauy by the Commission .'. ,,.r mar kru dly with (.,rtain factors .-t -n:.ýh c h as technical assistants

ir~i iab.--rit,;r- workers will use radioactive materials in the absenct: of persons specified , a. specification of the training of such persc.rne!

',hould include (a) instruction in I IA f , -, qs: fr 1. In"udinr, topics covered and by whom taught hb) on-the-job training in use ,-If radlio,-tivt materials, and (c) determination.

of compeienciy to work without the presence of supervisory (ersOnnel "The is' of mitrocurie quantities of a few nonvolaile radioactive materials by a person with a minimum of training and experience under precisely specified and carefully con roliled conditions subject to the surveillance of -,Ompetent and adequately trained radiation protection officer may be justified.

Such mini mum training and experience may consist of a e: hours of training and experience in the use ,f crne or more radioactive materials similar to the use proposed in the -tpplication under the sýupervision and tutorship of a Licensed user. Persons using millicuzri quantities of a num Oer of radionuclideq for general laboratory tracer work under unspecified conditions should have more extensive training and expe rience and, depending on the exact nature of ih.. proposed program of use of radionuclides, zay need to have completed formal course work at !he college or university level covering the areas listed under Item i6 of Form NRC-3131.

The use of larger quantities of material (dpproaching a curie) under conditions where a potential exists for significant loss and inges uon. inhalation, or absorption of the radio a,-tive material by those working with the mate rnal is normaUy done under carefuoly controlled

onditionrs using specialized equipment.

A person whO is to use radioactive materials inde pendently unnde these conditions should hot only have a background or, forma! traming r, all areas described in tern 16 of F<orm NRý 3131 but should also h.ive expe- ýn--working with material an i a thorough working knowledge of the eqipu.rmenrt required to handle the material safely

5. AMENDMENTS

TO IhJENSES Licensees are required to cor.duct 4heir pr.grams in accordance with statements, renrý.sentations.

and procedures contained in ýtie license application and su.:P)>rtive aocuments The license must therefore be amended if the licensee plans to make any changes in faclt ties, equipment (including.

monitoring and sur vey instruments), procedures, personnel or byproduct material t(; Le used Applications for license amendments may e filed either on the applicatior form or kn ler!tr form. The application.

should identify 1o license by number and should clearly de ;,.r t-. the exact nature of the charges, additions, c"r deletions.

References to previously submitted information and documents should be clear and specific and should identify the pertinent information by date, pag

e. and paragraph

6. RENEWAL OF A LICENSE An application for renewal of a License should be filed at least 30 days prior to the expiration date This will ensure that the license does not expire until final action on the application ha6 been taken by the NRC as provided for in paragraph

30 37(b) of i9 CFP Part 30. Renewal applications .hould Le filed on Form NRC-3131, appropriately suppI-mented, and should contain compjete and up-to-date infor mation about the applicant's current program.

In order to facilitate the review process, t+/-e application for renewal should be submitte.j without reference to previously submitted documents and information If such referene-5 cannot be avoided, they shoild be clear -ad specific and should identify the information by date, page, and paragraph.

10) 7-7 APPENDIX A Form NRC-31 3 (I) iO CFR 30 U.S. NUCLEAR REGULATORY 0O111611ON Form Apifroed by GAO B- ll32S(1tOS79) INSTRUCTIONS FOR PREPARATION OF APPLICATION FOR BYPRODUCT MATERIAL LICENSE FORM NRC-313 (I) GENERAL INFORMATION An applbcant lot a "Byproduct Material (Radioisotopes) License." should complete Form NRC-313 (1) m detail and submit in duplicate to the U.S Nuclear Regulatory Commission.

The applicant should endeavor to cover his entire radmastope program with one application, if possible.

However, separate applhcationk should be submitted for gamma irradiators.

Applicatmlos for medical uses should be submitted ^n Form NRC-313 (M) aad applications for use of scaled sources m radiography should be submitted on Form NRC-313R.

Supplemental sheets may be appened when necessary to provide complete mfoi mation. Item 18 must be completed on all applicatsios.

Submission of an incomplete application will often result en a delay in ,t/ the license because of the correspondence necessary to obtain inhr rnrion requested on the applicatron NOTE When the application incldde: one oi the special sises listed below the applicant should request tihe appropruate pamphlet wlhch provides additionul instructions I Industrial Radiography "'LIcensitng Requirements for Industrial Radiography'" (use. application I orm NRC'-31 3R for Radi ography). 2 Laboratory and Industrial Uses i Small Quantitis-"G(uidc for Preparation ol Applications for Liboratory and Industrial Uses of Small Quantities of Bypr-rduLt Material." 3 Broad License (research and development)-"Laceingm Guie for Type-A Licenses of Broad Scope for Resmarch and )evelop ment ," 4. Licensing Guides for the performance of well l g eperatsoaa.

S Licunrin guide to: the use of scaled sourcs in portable and stint portable gauging devices' The Comm!son charges fees for filing of appblcaloa for hveoaes as specified in Section 170 12, Title 10 Code of Fedwal Regitleioma.

Part 170. The applicant should refer to Section 170.31, Scaleduh.

uf fees Ior materials Ilc'n srs. to determine what fee should accompany the application No action can be taken on applications until fees are paid. ('hecks or money orders should be made payable to the U.S. Nuclear Regulatory ( ommassion.

rwo ,opr," of the ,ompleted Irorm NR(-313 (e) and two copies of ea.h atticlimeni thlicc-o should he eCni to the Division of I rael Cycle mnd Silely. Ottice of Nuclear Material Safety and Safeguards.

IS Ni.lcat Regpilatury Commilsion Washington.

DC 20555 One sopy liukiu bc retained for the appliLant's file Applications may Ji.s be hited in person at the Comnitssion's office at 1717 H Street. N %,. Wishington.

D C or at 7915 1 astern Avenue. Silver Sprin

g. land EXPLANATION

OF FORM NRC-313 (1)I-orm NR('-313 fl) is desgned for use in supplying information on program, nt varying complesty fhc applicant should provide complete information on his proposed program or the possession and use of licensed material I or those items that do not apply. indicati.

As N.A (not appli.able) Item No I Sell -exphndlory The -applicant'" i I lhe organil.ation ii person legall ivc, ponibk for possession and ue of the licensed materials specified in the application 3 Sell-explanatory 4 SelU-tiplanalory Thc actual of use should be listed as indicated.

Per tijnent A[A ilihlie such as field oflfis lot portable gauges or devicei should be identified in Item S by Street. Address.

City and Stait Temporar, field locations of use should be specified as "'temporary job sites of the pplicani" and list the States throughout which the tempora i job sites will he h1,laed Attach additional properli, keyed sheet if miort spas is needed 6 Sell \'eplanatory 7 rhc "Radiation Protection Officer' is the nanied uilividual sho is expected to coordinatc the safe use of the licensed materi~al spekilied in the application and who will ensure srmphanme w!lh the applicable parts of Title 10. ('ode of I cderal Regulations I0 7-9 A List by name Ca,1 iraditisotope it, he and ised under the license 1, ample l) lodtne-I31 t21 lodassc- t 13) Krypton-85 141 Cesium-I 7 0I) (2) I,) I4)Nof Appliuable N A N A Model Z-78 (l) 12) 13) (4l 41) (2) (4)B Iodide lodinated Humani Scruti Albunpin (.as Sealed SouC1. D) 10 mihd:icurie.. I aillicurnic I inillIhuric 2 ISO mitlit. tolne Cacti Attach .red~bonsa pi.perl% keyed sh-,.tsit 11 a ' needed 1 I Stale tile u itf cacti II, cnsed material hlated in 9 V 8. . and D etcript1ion ti c an*d/or device% in ,vJjjh sealed e listd in Iltem h will be stored or uted. I %ample A I I I 1 Source housing Io Curp Model 1-278 10 18 SeIf-.xplanatory (I at those items that do not apply indicate N A (not applicable) PRIVACY ACT STATEMENT Pursuant to 5 U S.( 55 'niacted into law by set,.lon 3 of the I'IVaLvy Act of 1974 (Public: Law 93-579). the Iollowing .- titcileti IS furrnishcd to rndividual% who surply information to the Nuclear Regulatory on I orms NRC-313M, NR(-3 13A, NR(-3131 or NR(_'- 313R I his mformalion is mainiained in a system of re!eoid designated as NRC-3 and descrihed at 40 1 ederal Register 45 114 (Otlober I. 1975) I AUTHORITY SIio n,81 and 1614b) of the Atomic Inerpy Act of 1954. a, amended (42 U.S.( 2111 and 2201ib(1 2 PRINCIPAL PURPOSI"S) The informatmon is e:valuated It, the HKC staif pursuant to the ritleria set forth in 10 ( I R Parts 30-36 to determine whether the application meet, the requircmenti of the Atomic I nergy Act uo 1954. as amctindsd.

ap the C('ommisoon's rclgulsaions.

lot the issuanice of a byproduct maleril license or amendment thereof 3 ROUTINF tjSI S "he informawn itay be: used (0; to provide reuord& to State heaithk c.kpirtmeusi fop the intormpaipanand useand 4h)to provide intformation t4 I ederal. Stiart. and k),.al heafth officials and other in the event of incident of xposutic por thiir trifortnatilon, mvemiwzliarn.

ind protection (it the publitc health and safety The nfotinalicn ma, dlv) be ditslotd to approptiate I .Jeral. Stile and local ait.ticies in the event that the information a vio~Ltioon of ptenlti of law and in the course of in ad"ministrative o luli cuial proceeding In Addition.

this inlormation ri ay be transfeared to An approprate IFederal.

State. or kical agency to i'c esxhint relevant and f>r a NR( dn, ison or to an appropriate I ederal agnev to the .xtent relevant and ne ,LcesAfy lot that afenty'% dcJtioun about sou A npli tit the hin"sc issued will routinely he placed in the NRC's Puhlic Doument Room. 1717 H Street. N W, Washington.

DA 4 WHI T1,11II DIStLOSLRI.

IS MANDATORY OR VOLUNTARY AND. III FCT ON INDIVIDUAL 01 NOT PROVIDIN(; INI.ORMA rION Dit..losurc of the requested infrrmnation is voluntary It the request information is not furnished.

hno ti " apptiation hori I, producl mat 'rial lhcense or 3mendmenl thereof, will not he proceied 5 SYSTIM MANAGFRISI ANI) ADDRI SS Dir."tor Division ti I ucl (Clee .aid Matarial Ofti, ol Nu, tear Material Saetly a4ad S.afeguidf,. ki S Nuclear Regulallory ( ommission.

Washington.

D ( 2055 10 7-10 i FORM NRC-313 I -U.S. NUCLEAR REGULATORY COMMUON

1. APPLICATION

FOR: (1-79) (Chec* and/or conYiDe a opeteJ 10 CFH 30 APPLICATION FOR BYPRODUCT MATERIAL LICENSE INDUSTRIAL a. NEW LICENSE See erached 'nsrucrt,os for details

b. AMENDMENT

TO. L ICEiNSE NUUMBE n'fli)leted is-i,,tins are tlile' in o tre with the Division of FIuel and Material Safetr,. Offit r I'f Nit, lear Material Safetv. o.in Safeguards U.S. Noclear Regulatory Commisusion.

Washington.

DC 20555 or 'nay he, fed in person at the Comnrnision's office at c RENEWAL OFF I77 H Strepr NýW. Washinqtol/ 0 ,'" or 7915 Fastern Avenue. Silver Sprinq. Marylayri.

2. APPLICANT'S NAME (institution.

firm, person, etc.)

E. CONTACT

ED REGARDING THIS APPLICATION TELEFPHONE NUMBER AREA CODE -NUMBER EXTE.NSION.

LEPNONE NUMBER AREA CODE -- FJUMBER EXTENSION 4APPLICANT'S MAILING ADDRESS (Include Zip Code)B STREET ADDRESS WHERE LICENSED MATERIAL WILL BE USED fInclude O EE Code) (IIF MORE SPACE IS NEEDED FOR ANY ITEM. USE ADDITIONAL PROPERI y V'lVV% bAfICC 6. INDIVIDUAL(S) WHO WILL USE OR DIRECTLY SUPERVISE THE USE OF LICENSED MATERIAL (See Items 16 and 77 for required Fraining and experience of ech indjividul n4,,d be low) FULL NAME TITLE Ib C.

7. RADIATION

PROTECTION OFFICER I Attach e resume of person's training end exper.ence a outline if items I 16 and 17 and describe his under Item 15. _____S. LICENSED MATERIAL I L ELEMENT CHEMICAL NAME OF MANUFACTURER MAXIMUM I N NIRAND , MILLICURIES AJ4DOMMEALED N MASS NUMBER PHYSICAL FORM MODEL NUMBER SOURCES AND MAXIMUM ACTI. (if Sealed Source) VITY PER SOURCE WHICH WILL BE POUSESSED AT ANY ONE TVME I NO. A CO UC 0 _ -4 !(31 DESCRIBE USE OF LICENSED MATERIAL (21 I _33 17 313 i 1 -791--- _ ____10.7-11 9. STORAGE OF SEALED SOURCES SCOftTAINtSR AND/OR DEVICE IN WHICH EACH SEALED NAME OF MANUFACTURER MODEL NUMefifR It SOURCE WILL BE STORIED OR USED I A. B. C. 12) (3) (4) 1

0. RADIATION

DETECTION INSTRUMENTS -TYPE MANUFACTURER'S MODEL NUMffR RADIATION SENSITIVITY L OF NAME NUMIBR AVAILABLE DETECTED RANGE M INmsTRMmNT (alpha. beta. (fnbllfoenr.mrno/hour S gamma. neurron) or counts/mmnure) A C D E F 121 (31 1

1. CALIBRATION

OF INSTRUMENTS LISTED IN ITEM 10 0E. CALINRATDO NY SERVICE COMPANY [0

b. CALIBRATED

BY APPLICANT NAME. ADORESS. AND FREQUENCY Attach a Speorate sheet describing method, frequency Mnd staMdards used for caibrating inhtrumwen.

1

2. PERSONNEL

MONITORING DEVICES TYPE SLPPLIER EXCHANGE FREOUENCY fCheft* and/of cran)te as ^wP(OP-o- (Seiwce Company) C A, C 0111 FIL*ISADIGE 0 MONTHLY D12) THERMILUVMINESCENCE 0 QUARTERLY DO1308IT TER (TLD0 S0011 OTHiER (Sw,_y) D OTHER (Specdy) 1

3. FACMILTtMS

AND EQUIPMENT (Check were appropriate and attch annotated sketch(es) and description(s). 0 a LABORATORY FACILITIES.

PLANT FACILITIES, FUME HOODS (Include foltreon, dMany). ETC D bý STORAGE FACILITIES CONTAINERS.

SPECIAL SHIELDING (fixed and/lor teorpoarry), ETC 0 c REMOTE HANDLING TOOLS OR EQUIPMENT.

ETC 0l d RESPIRATORY PROTECTIVE EQ4JIPMENT.

ETC 1q. v1 PaiLr. IK .,GMl_ Na --. OF CONMERCIAL WAST6 DISPOSAL SERVICE EMPLOYED b tF COMMtRCIAL WASTE DISPOSAL SERVICE IS NOT EMPLOYED.

SUBMIT A DETAILED DESCRIPTION OF METHODS WHICH WILL "85 US6D FOR D46POSING OF RADIOACTIVE WASTES AND ESTIMATES OF THE TYPE AND AMOUNT OF ACTIVITY INVOLVED IF TE APPLICAlION IS FOR SEALED SOURCES AND DEVICES AND THEY WILL BE RETURNED TO THE MANUFACTURER.

SO STATE. FO"M NOC 313 0 1-794 10.7-12 INFORMATION REOUIRED FOR ITEMS 15, 16 AND 17 Describe in detail the information required for Items 15, 16 and 17. Begin each item on a separate page and key to the application as follows: 1

5. RADIATION

PROTECTION PROGRAM. Describe the radiation protection program as appropriate for the material to be used including the duties and responsibilities of the Radiation Protection Officer, control measures, bioassay procedures fit needed), day-to-day general safety instruction to be followed.

etc If the application is for sealed source's also submit leak testing procedures, or if leak testing will be performed using a leak test ki0, specify manufacturer and model number of the leak test kit. 16. FORMAL TRAINING IN RADIATION SAFETY. Attach a resume for each individual named in Items 6 and 7 Describe individual's formal training in the following areas where appliable.

Indude the name of person or institution providing the training, duration of training, when training was received, etc a. Principles and practices of radiation protection.

b Radioactivity measurement standardization and monitoring techniques and instruments.

c. Mathematics and calculations basic to the use and measurement of radioactivity d Biological effects of radiation.

17. EXPERIENCE.

Attach a resume for each individual named in Items 6 and 7. Describe individual's work experience with radiation, including where experience was obtained.

Work experience or on the-job training should be commensurate with the proposed use. Include list of radioisotopes and maximum activity of each used. 18. CERTIFICATE (This trem must be completed try appiicant) Th e canr and any official exocurJng this Ofril',cate on behalf ot the applicant named in /rem 2, certify that this application is prepared in confotmitry with Title 10, Code of Federal Regulations Parr 30I and that all 'nformation contained herein including any suPplements atrtached hereto is true and correct ro the best of our knowleade and belief. WARNING 18 U.S.C Section 1001, Act of June 25. 1948; 62 Stai 749; makes it a crimnal offense to nmke a willtully taiae stltemt or repreentation to any department or agency of the United States as to any matter within its ourisdiction.

LII. FNSE FEE REQUIRED (See Secton 170.3? 10 CFR j0 ERTIFYING OFiCiAL c. NAME (Type or print) 11 LICENSE FEE CATEGORY d TITLE 12; LICENSE FEE eNC.:LOSED $ e DATE F0RM NRC-313 1 11 791 10 7-13 _1.. .UN TED STATES 0 NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 July 1984 [[kRATA REGULATORY GUIDE 10.7, Revision 1 GUIDE FOR THE PREPARATION OF APPLICATIONS FOR LICENSES FOR LABORATORY AND INDUSTRIAL USE OF SMALL QUANTITIES OF BYPRODUCT MATERIAL Regulatory Guide 10.7, Revision 1, provides directions for using Form NRC-313I in preparing applications for licenses for laboratory and industrial use of small quantities of byproduct material.

The NRC is now using a new NRC Form 313 for all byproduct material applications and is discontinuing the use of Form NRC-313I.

The NRC is developing Revision 2 of Regulatory Guide 10.7 to conform to the new NRC Form 313. Until Revision 2 is issued, this errata sheet provides the information needed to use the new NRC Form 313. The new NRC Form 313 does not have space for providing the information requested in Items 5 through 11. Please provide the information on 8-1/2 x 11 inch paper. In the left-hand column of the following table are listed items of the old Form NRC-3131, most of which are also called out in Regulatory Guide 10.7, Revision 1. The right-hand column identifies the corresponding item of the new NRC Form 313 in which responses should be made. Guide and Old Form NRC-3131 New NRC Form 313 Item 1* Item 1 Item 2 Item 2 Item 3 Item 4 Item 4 Item 2 Item 5 Item 3 Item 6 Item 8 Item 7 Item 7 Item 8 Items 5 and 6 Item 9 Item 9 Item 10 Item 10 Item 11 Item 10 itei 12 Iter; 10 Item 13 Item 9 Item 14 Item 11 Item 15 Item 10 Item 16 Items 7 and 8 Item 17 Item 7 Item 18* Items 12 and 13 *Not called out in Regulatory Guide 10.7, Revision 1. The following cross-reference table may be helpful to you: New NRC Form 313 Item 1 Item 2 Item 3 Item 4 Item 5 Item 6 Item 7 Item 8 Item 9 Item 10 Item 11 Item 12 Item 13 Item 14 Old Form NRC-3131 Item 1 Items 2 and 4 Item 5 Item 3 Items 8A, B, C, and D Item 8E Items 7, 16, and 17 Items 6 and 16 Items 9 and 13 Items 10, 11, 12, and Item 14 Items 18a(1) and (2) Items 18b, c, d, and N/A 2 15 e ,,L_ NRC 'OPV 313 8' 32 33 34 ... APPLICATION FOR MATERIAL LICENSE US. NUCLEAR REGULATORY COMMISSION APPROVED BY OM8 3150-0120 Elxpir,. 5-31-87 NSTRUCTIONS SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION SEND TWO COPIES )' 'HE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW. FEDERAL AGENCIES FILE APPLICATIONS WITH IF YOU ARE LOCATED IN: "I S NUCLEAR REGULATOR Y COMMISSION ILLINOIS, INDIANA, IOWA. MICHIGAN, MINNESOTA, MISSOURI OHIO, OR 3)IVISION OF FLEL CYCLE AND MATERIAL SAFETY. NMSS WISCONSIN.

SEND APPLICATIONS TO WASHINGTON DC 20555 U S. NUCLEAR REGULATORY COMMISSION, REGION III ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS, IF YOU ARE MATERIALS LEIUCENSTNG SECTION LOCATED IN 799 ROOSEVELT ROAD CONNECTICUT.

DELAWARE, DISTRICT OF COLUMBIA, MAINE, MARYLAND, GLEN ELLYN. IL 60137 MASSACHUSETTS, NEW JERSEY, NEW YORK, PENNSYLVANIA, RHODE ISLAND. ARKANSAS, COLORADO, IDAHO, KANSAS, LOUISIANA, MONTANA, NEBRASKA On VERMONT. SEND APPLICATIONS TO, NEW MEXICO, NORTH DAKOTA, OKLAHOMA, SOUTH DAKOTA, TEXAS, UTAH, S NUCLEAR REGULATORY COMMISSION.

REGION I OR WYOMING, SEND APPLICATIONS TO: NUCLEAR MATERIAL SECTION B U.S. NUCLEAR REGULATORY COMMISSION.

REGION IV 63! PARK AVENUE MATERIAL RADIATION PROTECTION SECTION KING OF PRUSSIA. PA 19406 611 RYAN PLAZA DRIVE. SUITE 1000 ALARAMA FLORIDA GEORGIA KENTUCKY, MISSISSIPPI, NORTH CAROLINA, ARLINGTON, TX 76011 PUERTO RICO, SOUTH CAROLINA, TENNESSEE, VIRGINIA, VIRGIN ISLANDS. OR ALASKA, ARIZONA, CALIFORNIA, HAWAII, NEVADA, OREGON, WASHINGTON, WEST VIRGINIA.

SEND APPLICATIONS TO: AND U.S. TERRITORIES AND POSSESSIONS IN THE PACIFIC, SEND APPLICATIONS TO: 'J.S NUCLEAR REGULATORY COMMISSION, REGION II MATERIAL RADIATION PROTECTION SECTION U.S NUCLEAR REGULATORY COMMISSION, REGION V 'I MARIETTA STREET, SUITE 2900 MATERIAL RADIATION PROTECTION SECTION ATLANTA. CA 30323 1450 MARIA LANE. SUITE 210 WALNUT CREEK, CA 94596 PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISDICTION.

I THIS IS AN APPLICATION FOR [Chock o'opritare itEm) 2. NAME AND MAILING ADDRESS OF APPLICANT (Includ.Zip Code) A NEW LICENSE B AMENDMENT TO LICENSE NUMBE9? AJDRESSiES! WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED.

4 NAME OF PERSON TO B

E. CONTACT

ED ABOUT THIS APPLICATION TELEPHONE NUMBER SUBMIT ITEMS 5 THROUGH II ON EN , 11 PAPER THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE E RADIOACTIVE MATERIAL Er'iinl and b 5 nunibr b Ihencal] andlor OnyIsciI aort. and c. mano'" ionn tft 6. PURPOSEIS) FOR WHICH LICENSED MATEPIAL WILL BE USED ,.rlcn wi,' be oo$$s~sec at any onn tinie 'NDIVIDUALiSi RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRA 'ýING AND EXPER:ENCE 8. TRAINING FOR INDIVIDUALS WORKING IN OR FREOUENTING RESTRICTED AREAS ACILITIES AND EQUIPMENT 1

0. RADIATION

SAFETY PROGRAM WASTE MANAGEMENT 12 LICENSEE FEES (Saw ro CFR I70nd 170.31) WAMOUNT FEE CATEGORY ENCLOSED $ C'ERTIFICATU0N !AMiistbecornoloted byaDphcandJ THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPLICATION ARE Hl -ING .PO., Tn5 APPLICANT "-.E APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS cRyFPARLD

N CONFORMITY

WITH TITLE I0. CODE OF FEDERAL REGULATIONS, PARTS 30,32, 33,34,35.

AND 40 AND THAT ALL INFORMATION CONTAINED HEREIN 'S 'RI E AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF PIARNING I6 ý -C SECTION I001 ACT OF JUNE 25 1948.62 STAT 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION T-AY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION ...I.%GO:CSR TYPEDIPRNTEO NAME IIL DT $SOO. -,-I TMIO 8NUMBER OF EMPLOYEES (Totalio d WOULD YOU BE WILLING TO FURNIH COST INFORMATION ('Jolls, anditeho,, $ ~ ittrn aciityPx~iJ~nECJttdfCflt*Ct,,) ON THE ECONOMIC IMPACT OP CURRENT NRC REGULATIONS OR ANY FUTURE PROPOSED NRC REGULATIONS THAT MAY AFFECT YDU? (NRC iwecilationn,'pi.n4 I 251K -500K S' 5V35 7M it t0O1eCitip,~lCn nena o iera~r~i,,.,ion.i, e-r,Ihld to : 5520K -50K s7m -1M c NUMBER OF BEDS th poyin contidenlcs) S-50K V,..A J YES V>NO FOR NRC USE ONLY 0P5 3 i 'SE LOG FEE CATEGORY COMMENTS APPROVED By 4.', " .2 ECE .'C CHECK NUMBER DATE A S AT. T E REV S Y>TIE'T 0O4 THE REVERSE PRIVACY ACT STATEMENT Pjrsuant to 5 U.S.C. 552a(e)(3), enacted into law by section 3 of the Privacy Act of 1974 JPublic Law 93-579), the follow!ng statement is furnished to individuals who supply information to the Nuclear Regulatory Commission on NRC Form 31

3. This information

s maintained in a system of records designated as NRC-3 and described at 40 Federal Register 45334 (October 1, 19751. 1 AUTHORITY

Sections 81 and 161(b) of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2111 and 2201 (bll 2 PRINCIPAL PURPOSE(S): The information is evaluated by the NRC staff pursuant to the criteria set forth ;n 10 CFR Parts 30, 32, 33, 34, 35 and 40 to determine whether the application meets the requirements of the Atomic Energy Act of 1954, as amended, and the Commission's regulations, for the issuance of a radioactive material license or amendment thereof.

3. ROUTINE USES: The information may be (a) provided to State health departments for their information and use, and (b) provided to Federal, State, and local health officials and other persons in the event of incident or exposure, for their information, investigation, and protection of the public health and safety. The information may also be d1,s closed to appropriate Federal, State, and local agencies in the event that the information indicates a violation or potent:ai vwo'at~on of iaw and !n the course of an administrative or judicial proceeding.

In addition, this information may be trans ferred to an appropriate Federal, State, or local agency to the extent relevant and necessary for an NRC decision or to an appropriate Federal agency to the extent relevant and necessary for that agency's decision about you. 4ý WHETHER DISCLOSURE IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVID ING INFORMATION: Disclosure of the requested information is voluntary.

If the requested information is not furn ished, however, the application for radioactive material lik.ense, or amendment thereof, will not be processed.

A request that :nformation be held from public inspection must be in accordance with the provisions of 10 CFR 2.790. Withhold ing from public inspection shall not affect the right, if any, of persons properly and directly concerned need to inspect the document.

5. SYSTEM MANAGER(S) AND ADDRESS: U.S. Nuclear Regulatory Commission L Director, Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555 NRC FORM 313 I NRC 84 C F 1, 3, 4" ý 1 APPLICATION FOR MATERIAL LICENSE US NUCLEAR REGULATORY COMMISSION APPROVED BY OD4E 3150-0120 E-pis 55-31.87 NSTRUCTIONS SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION SEND TWO COPIES )l THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW. "FEDERAL AGENCIES FILE APPLICATIONS WITH IF YOU ARE LOCATED IN [ -S NUCLEAR REGULATORY COMMISSION ILLINOIS, INDIANA, IOWA, MICHIGAN.

MINNESOTA.

MISSOURI, OHIO. OR ilVISION O FUEL CYCLE AND MATERIAL SAFETY. NMSS WISCONSIN.

SEND APPLICATIONS TO: WNASHINGTON.

DC 20555 U S. NUCLEAR REGULATORY COMMISSION.

REGION III ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS. IF YOU ARE MATERIALS LICENSING SECTION LOCATED IN 799 ROOSEVELT ROAD CONNECTICUT.

DELAWARE.

DISTRICT Ol- COLUMBIA.

MAINE. MARYLAND.

GLEN ELLYN. IL 60137 MASSACHUSETTS, NEW JERSEY NEW YORK. PENNSYLVANIA, RHODE ISLAND, ARKANSAS COLORADO, IDAHO, KANSAS. LOUISIANA, MONTANA, NEBRASKA, OPR VERMONT. SEND APPLICATIONS TO. NEW MEXICOO, NORTH DAKOTA, OKLAHOMA, SOUTH DAKOTA. TEXAS, UTAH. OR WYOMING. SEND APPLICATIONS TO: S NUCLEAR REGULATORY COMMISSION.

REGION IO NUCLEAR MATERIAL SECTION B U.S. NUCLEAR REGULATORY COMMISSION, REGION IV 631 PARK AVENUE MATERIAL RADIATION PROTECTION SECTION KING OF PRUSSIA. PA 19406 611 RYAN PLAZA DRIVE, SUITE 1000 ALABAMA. FLORIDA, GEORGIA. KENTUCKY.

MISSI.SIPPI, NORTH CAROLINA, ARLINGTON.TX 76011 PUERTO RICO, SOUTH CAROLINA.

TENNESSEE, VIRGINIA, VIRGIN ISLANDS, OR ALASKA, ARIZONA, CALIFORNIA, HAWAII, NEVADA. OREGON, WASHINGTON.

WEST VIRGINIA.

SEND APPLICATIONS TO AND U.S. TERRITORIES AND POSSESSIONS IN THE PACIFIC, SEND APPLICATIONS TO: 'J S NUCLEAR REGULATORY COMMISSION.

REGION II MATERIAL RADIATION PROTECTION SECTION U.S. NUCLEAR REGULATORY COMMISSION REGION V ',71 MARIETTA STREET. SUITE 2900 MATERIAL RADIATION PROTECTION SECTION ATLANTA GA 30323 1450MARIA LANE, SUITE 210 WALNUT CREEK. CA 94596 PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.& NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISOICTION.

THIS IS AN APPLICATION FOR lChoek aWmpriste it") 2. NAME AND MAILING ADDRESS OF APPLICANT (OncludeeZ Code) A NEWLICENSE 8 AMENDMENT TO LICENSE NUMBER_ C RENEWAL OF LICENSE NUMBER A--A)DRESSIES! WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED 4 NAME OF PERSON TO B

E. CONTACT

ED ABOUT THIS APPLICATION J TELEPHONE NUMBER SUBMIT ITEMS S THROUGH 1 I ON E'i 11 -PAPER THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE 5 RADIOACTIVE MATERIAL a E emeni and mass 'iunibet" b cýhen,cal end/or physlcls for,. end c.

60.mn 6 PURPOSEIS) FOR WHICH LICENSED MATERIAL WILL BE USED ýt,' -C 11 b5, Qosssed at anv one ti-e NIDIVNIUAL(S, RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRA,.,ING AND EXPERIENCE 8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS SACITIES AND EQUIPMENT 10 RADIATION SAFETY PROGRAM " W N12. LICENSEE FEES (See I0CFR 170andSection 170.31/ WASTE MANAGEMENT iAMOUNT FEE CATEGORY jENCLOSED $ ""ErTIF'CATION (Must beomo/eredby*Phl/cAntJ THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPLICATION ARE 8,,'E NG NUPON T.IE APPLICANT "iE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT NAMED IN ITEM 2. CERTIFY THAT THIS APPLICATION IS PRFPAIIED

N CONFORMITY

WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30.32 33. 34 35. AND 40 AND THAT ALL INFORMATION CONTAINED HEREIN ýS TOIJE AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF .ARNINC. IS, U SC SECTION 1001 ACT OF JUNE 25. 1948, 62 STAT 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATIO.N Tr A%' ULEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION .i" i I 'NT OFFICER I TYPED/PRINTED NAME ITITLE DATE SR P 14 V UNTAAY ECONOMIC DATA N'.. R Pb NUMBER OF EMPLOYEES (Tote/i'1o, d WOULD YOU BE WILLING TO FURNISH COST INFORMATION r(JOI8e,.doCImffh., 5 , SIM I SM ...fre .ON THE ECONOMIC IMPACT OF CURRENT NRC REGULATIONS OR ANY FUTURE PROPOSED NRC REGULATIONS THAT MAY AFFECT YOU' (NRC mru1/tionsjDenrmt 25271K S3 5kEV7M It to Dfrorect coifdent"e1 Commn'itl or finncil-Drorietli/--,iiOrmet~on furniShod to S5OOK /501K M 1DM NUMBER OF BEDS c 5j 'ýOK IV -ISIOM E FOR NRC USE ONLY ' p I(F (FE LOG FEE CATEGORY COMMENTS APPROVED BY AV. ".-FCEiTE T O CHECK =NUMBER A'ý S TMENT Ory THE REVERSE PRIVACY ACT STATEMENT Pursuant to 5 U.S.C. 552a(e)(3). enacted into law by section 3 of the Privacy Act of 1974 (Public Law 93-579), the follow ,g statement is furnished to individuals who supply information to the Nuclear Regulatory Commission on NRC Form 313. This information is maintained in a system of records designated as NRC 3 and described at 40 Federal Register 45334 (October 1, 1975). 1, AUTHORITY: Sections 81 and 161(b) of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2111 and 2201(b)).

2. PRINCIPAL

PURPOSE(S): The information is evaluated by the NRC staff pursuant to the criteria set forth in 10 CFR Parts 30, 32, 33, 34, 35 and 40 to determine whether the application meets the requirements of the Atomic Energy Act of 1954, as amended, and the Commission's regulations, for the issuance of a radioactive material license or amendment thereof, 3. ROUTINE USES: The information may be (a) provided to State health departments for their information and use; and (b) provided to Federal, State, and local health officials and other persons in the event of incident or exposure, for their information, investigation, and protection of the public health and safety. The iformation may also be dis closed to appropriate Federal, State, and local agencies in the event that the information irdicates a violation or potential violation of law and in the course of an administrative or judicial proceeding.

in addition, this information may be trans ferred to an appropriate Federal, State, or local agency to the extent relevant and necessary for an NRC decision or to an appropriate Federal agency to the extent relevant and necessary for that agency's decision about you.

4. WHETHER DISCLOSURE

IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVID ING INFORMATION: Disclosure of the requested information is voluntary.

If the requested information is not furn ished, however, the application for radioactive material license, or amendment thereof, will not be processed.

A request that information be held from public inspection must be in accordance with the provisions of 10 CFR 2,790. Withhold ing from public inspection shall not affect the right, if any, of persons properly and directly concerned need to inspect the document.

5. SYSTEM MANAGER(S) AND ADDRESS: U.S. Nuclear Regulatory Commission Director, Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555 NRC FORM 313 NRBC 313 US NUCLEAR REGULATORY COMMISSION '84C-I 3C 32 33 34 APPROVED BY Om B I OR M31M0-0120 ... 0APPLICATION FOR MATERIAL LICENSE E ....5-31-87 1 THIS IS AN APPLICATION FOR (Chock , 2. NAME.AND MAILING ADDRESS OF APPLICANT (Includ.Zip Code) A NEW LICENSE B AMENDMENT TO LICENSE NUMBE_ C RENEWAL OF LICENSE NUMBER ADORESSIESI WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED 4 NAME OF PERSON TO B

E. CONTACT

ED ABOUT THIS APPLICATION jTELEPHONE NUMBER SUBMIT iTEMS S TIROUGH 11 ON 8' , 11 'PAPER THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE. S R-ýDIOACTIVE MATERIAL aEcment ecll mass numbe. b checal eImnd/or Dfhys,Col 1orm. Iad c mTlS-.n, anooIt 6. PURPOSEBS) FOR WHICH LICENSED MATEPIAL WILL BE USED h .ch -Ii , o oos$ese4 at a"ny one tlme INDIVIDUALIS, RESPONSIBLE FOP RADIATION SAFETY PROGRAM AND THEIR TRA 'IG AND EXPERIENCE 8, TRAINING FOR INDIVIDUALS WORKING IN OR FREQUEN'ING RESTRICTED AREAS AC:IITIES AND EQUIPMENT 1

0. RADIATION

SAFETY PROGRAM "12 LICENSEE FEES (See ?0CFRt 1tTOrsdlSteor, 170.31) WASTE~~~ MNGMT AMOUNT FEE CATEGORY lENCLOSED $ j '7EPTIFICATION fMus'beomplvridbVyliclnrJ THE APPLICANT UNDERSTANDS THAT Al L TATEMENT R .... ..-BIN' 3 -. N -PTE APPLICANT .AND tP1EUNTI MADE IN THIS APPLICATION ARE -'E APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT.

NAMED IN ITEM 2. CERTIFY THAT THIS APPLICATION IS A EPARED :% CONFORMITY WITH TITLE 10. CODE OF FEDERAL REGULATIONS, PARTS 30.32.33, 34, 35. AND 40 AND THAT ALL INFORMATION CONTAINED HEREIN ,F'IJ AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF VARNINC 16 u S C SECTION 1301 ACT OF JUNE 25. 1948, 62 STAT 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION "TC, ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION .C GOFliCS ' TYPEDIPRINTED NAME TITLE DATE 14 VLUNTARY ECONOMIC DATA A. A R CE'PTS I NUMBER OF EMPLOYEES (Tor al for d WOULD YOU BE WILLING TO FURNISH COST INFORMATION rtIOII. -noo o stf how,,, 1 "'SI'K vM 5v emt, fci,ty -excluoing Orsdi conftrlcrors ON THE ECONOMIC IMPACT OF CURRENT NRC REGULATIONS OR ANY FUTURE PROPOSED NRC REGULATIONS THAT MAY AFFECT YOU' (NRCmoIlerio$s pe-.r S251K NOOK S 5MS ?M Irt ro votcr confidenrti& Or frinolal-oroorrr.

-- f-rnlthld to $5500K -750K S7M -0M c NUMBER OF BEDS py ,nConfidrce) S 50K 'V S '0M F YES NO FOR NRC USE ONLY "PE -F6 .FEEFOG PEE CATEGORY COMMENTS APPROVED By T... ..CE "'E.D CHECK NUMBER .4 .A'T STATEMFNT ON THE REVERSE NSTRUCTIONS SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION SEND TWO COPIES )I THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW. FEDERAL AGENCIES FILE APPLICATIONS WITH IF YOU ARE LOCATED IN NS U'CLEAR REGULATORY COMMISSION ILLINOIS.

INDIANA. IOWA, MICHIGAN, MINNESOTA.

MISSOURI.

OHIO, OR 'JIVISION OF FUEL CYCLE AND MATERIAL SAFETY. NMSS WISCONSIN, SEND APPLICATIONS TO WASHINGTC!q.

DC 20555 U S. NUCLEAR REGULATORY COMMISSION.

REGION III ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS. IF YOU ARE MATERIALS LICENSING SECTION LOCATED IN 799 ROOSEVELT ROAD GLEN ELLYN, IL 60137 CONNECTICUT.

DELAWARE, DISTRICT OF COLUMBIA, MAINE. MARYLAND, MASSACHUSETTS.

NEW JERSEY, NEW YORK, PENNSYLVANIA.

RHODE ISLAND, ARKANSAS.

COLORADO, IDAHO. KANSAS, LOUISIANA, MONTANA, NEBRASKA.

OR VERMONT. SEND APPLICATIONS TO. NEW MEXICO, NORTH DAKOTA. OKLAHOMA.

SOUTH DAKOTA, TEXAS, UTAH. OR WYOMING, SEND APPLICATIONS TO: .S NUCLEAR REGULATORY COMMISSION, REGION I NUCLEAR MATERIAL SECTION B U.S. NUCLEAR REGULATORY COMMISSION.

REGION IV 631 PARK AVENUE MATERIAL RADIATION PROTECTION SECTION KING OF PRUSSIA. PA 19406 611 RYAN PLAZA DRIVE. SUITE 1000 ARLINGTON, TX 76011 ALABAMA FLORIDA GEORGIA. KENTUCKY, MISSISSIPPI, NORTH CAROLINA.

PUERTO RICO, SOUTH CAROLINA.

TENNESSEE, VIRGINIA, VIRGIN ISLANDS, OR ALASKA, ARIZONA, CALIFORNIA, HAWAII, NEVADA. OREGON, WASHINGTON, WEST VIRGINIA.

SEND APPLICATIONS TO AND U.S. TERRITORIES AND POSSESSIONS IN THE PACIFIC, SEND APPLICATIONS TO: 'J S NUCLEAR REGULATORY COMMISSION, REGION It MATERIAL RADIATION PROTECTION SECTION U.S. NUCLEAR REGULATORY COMMISSION, REGION V 101 MARIETTA STREET. SUITE 2900 MATERIAL RADIATION PROTECTION SECTION AILANTA. GA 30323 1450 MARIA LANE. SUITE 210 WALNUT CREEK. CA 94596 PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISOICTION.

PRIVACY ACT STATEMENT Pursuant to 5 U.S.C. 552a(e)(3), enacted into law by section 3 of the Privacy Act of 1974 (Public Law 93-579), the follow inq staxement is furnished to individuals who supply information to the Nuclear Regulatory Commission on NRC Forrr 313. This information is maintained in a system of records designated as NRC-3 and described at 40 Federal Register 45334 (October 1 1975). 1. AUTHORITY: Sections 81 and 161(b) of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2111 and 2201(b)).

2. PRINCIPAL

PURPOSE(S): The information is evaluated by the NRC staff pursuant to the criteria set forth in 10 CFR Parts 30, 32, 33, 34, 35 and 40 to determine whether the application meets the requirements of the Atomic Energy Act of 1954, as amended, and the Commission's regulations, for the issuance of a radioactive material license or amendment thereof.

3. ROUTINE USES: The information may be (a) provided to State health departments for their information and use; and (b) provided to Federal, State, and local health officials and other persons in the event of incident or exposure, for their information, investigation, and protection of the public health and safety. The information may also be dis closed to appropriate Federal, State, and local agencies in the event that the information indicates a violation or potential violation of law and in the course of an administrative or judicial proceeding.

In addition, tt'fs information may be trans ferred to an appropriate Federal, State, or local agency to the extent relevant and necessary for an NRC decision or to an appropriate Federal agency to the extent relevant and necessary for that agency's decision about you. 4, WHETHER DISCLOSURE IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVID ING INFORMATION: Disclosure of the requested information is voluntary.

If the requested information is not furn ished, however, the application for radioactive material license, or amendment thereof, will not be processed.

A request that information be held from public inspection must be in accordance with the provisions of 10 CFR 2.790. Withhold ing from public inspection shall not affect the right, if any, of persons properly and directly concerned need to inspect the document.

5. SYSTEM MANAGER(S) AND ADDRESS: U.S. Nuclear Regulatory Commission Director, Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555}}