ML24086A456

Purdue Renewal - Response to Request for Additional Information - Redacted Version

ML24086A456
Person / Time
Site:	07000152
Issue date:	03/25/2024
From:	Purdue University Research Reactor
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML24086A458	List: ML24086A454 ML24086A456
References
L-2023-NFR-0000
Download: ML24086A456 (1)

Text

REQUEST FOR ADDITIONAL INFORMATION

LICENSING ACTION: APPLICATION FOR RENEWAL OF SPECIAL NUCLEAR MATERIALS LICENSE -ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2023-NFR-0000

LICENSEE: PURDUE UNIVERSITY

DOCKET NO.: 70-152

LICENSE NO.: SNM-142

The U.S. Nuclear Regulatory Commiss ion (NRC) staff has identified the additiona l information discussed below that is needed to comp lete its detailed technica l review of the Pu rdue Un iversity (Purdue) license renewal application (LRA). Purdue should revise its LRA to provide this informat ion within 30 days from the date of this communication.

A. Technical Review Area-Fire Safety (FS)

FS-1 - Duncan Annex Fire Safety

Regulatory Basis:

Title 10 of the Code of Federal Regulations (1 0 CFR) section 70.22(a)(7), requires that the LRA inc lude "A description of equ ipment and facilities wh ich will be used by the appl icant to protect health and minimize danger to life or property."

Issue

Description:

Section 6. 1 of the LRA describes that the

- is pro tected by an automat ic sprink ler system, but sprinklers are not installed in because of concerns about critical ity potential.

The staff reviewed Figure 2.3 in Appendix A.5, "Safety Analys is Report for the Purdue Un iversity PUR - 1 Reac tor," for map of the

However, the LRA, inc luding Figure 2.3 above, does not provide sufficient information to explain how the automatic sprinkler system, installed in the *

• will not cause a criticality issue to

.Request:

Describe the features (e.g., drainage, ra ised thresholds for doors, elevated storage of nuclear materials) that prevent fire suppression water from areas outs ide of room from intruding into those rooms and presenting a c riticality hazard.

Response :

Enclosure

- - Fire Protection at

2 Regulatory Basis:

10 CFR 70.22(a)(7), requires that the LRA include A description of equipment and facilities which will be used by the applicant to protect health and minimize danger to life or property.

Issue

Description:

Section 6.1 of the LRA describes the fire protection features (e.g., sprinklers, fire alarms, occupancy notification, etc.), the combustible loading, and the fire protection equipment inspection, testing and maintenance (e.g., test type and test frequency) of However, there is no such information provided in the LRA for

Request:

Provide information of the fire protection features, the combustible loading, and the fire protection equipment inspection, testing and maintenance for the

Response

B. Technical Review Area-Emergency Preparedness (EP)

EP Emergency Plan

Regulatory Basis:

10 CFR 70.22(i) requires that licenses authorizing radioactive material exceeding certain thresholds must either (1) submit an emergency plan, or (2) submit 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.

Issue

Description:

In the LRA, Purdue University states:

Under the requirements of 10 CFR 70.22(i)(1), Purdue was required to submit either an emergency plan, or 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. By letter dated 16 February 1993, Purdue submitted such an evaluation, which was accepted in the 1994 license

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renewal, and again in 1999. Therefore, there is no specific emergency plan in place, and ANSI/ANS-8.23, which covers emergency planning, is not applicable.

The NRC staff notes that certain possession limits have changed since 1999 when the last evaluation was submitted by the applicant.

Request:

Provide an evaluation or evidence based on the possession limits identified in the 2023 license renewal that supports the conclusion that an emergency plan is not needed.

Response

A separate emergency plan is not required for this license.

The following material and facility characteristics make the intake of 2 grams of soluble uranium or 1 Rem effective dose equivalent highly unlikely.

. Using the equation found in NUREG-1140 Section 2.3.1.3, one can compute the quantities required to deliver 1 rem effective dose equivalent:

The terms HGCi, and HCSi for ground contamination and cloudshine can be ignored since the inhalation pathway would dominate.

However the worst case situation would be lesse ned due to the following factors:

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Therefore, w e be lieve that the precede n t o f an Em erge n cy Plan no t b e ing requ ired for this space continues to b e appropr ia te.

C. Techn ica l Review Area - Radioactive Waste Management (RWM)

RWM-1 - Waste Disposal

Regulatory Basis:

10 CFR 20.2001(a) requ ires that:

(a) A licensee shall d ispose of licensed material only -

(1) By transfer to an author ized recipient as prov ided in § 20.2006 or in the regu lations in parts 30, 40, 60, 61, 63, 70, and 72 of this chapter;

(2) By decay in storage ; or

(3) By release in effluents within the limits in § 20.1301 ; or

(4) As authorized under§§ 20.2002, 20.2003, 20.2004, 20.2005, or 20.2008.

Issue Desc ription:

The LRA does not include a specific commitment to meet any of the 1 0 CFR Part 20 Subpart K (Waste Disposal) requ irements, includ ing 1 0 CFR 20.2001 (a).

In order for the NRC staff to know what the licensee comm its to in the area of RWM, Purdue needs to identify those regu lations in the LRA. If Purdue decides not to commit to a regulation, then, the NRC staff expects that they would state that and provide a reason.

In order for the NRC staff to know how Purdue intends to meet those regu lations, Purdue must e ither:

• Comm it to desc riptions of how they intend to meet those regu lations; or

• Include descr iptions of how Purdue intends to meet those regulations

5 The NRC staff notes that the NRC Form 313, Application for Materials License includes: Submit items 5 through 11 on 8-1/2 x 11" paper and Item 11. Waste Management. However, in the NRC Form 313 for the PU LRA for SNM-142, there is no Item 11 and there is no Waste Management section.

The NRC staff notes that the following public Purdue documents do contain information related to RWM activities; but, Purdue did not provide that information in the LRA:

(1) PU Broad Scope License (Amendment #106, ML23097A070); and (2) PU Radiation Safety Manual (Updated 01-07-2022, found on the Internet).

The NRC notes that, in the LRA, Purdue committed to follow Appendix F to 10 CFR 20.1001 to 20.2401 for land disposal of all wastes. However, Appendix F to 10 CFR 20.1001 to 20.2401 is not the current reference to the regulatory requirements for land disposal of all wastes.

Guidance:

The draft guidance 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) is one option for Purdue to demonstrate compliance with the regulations and includes for RWM the following:

• Regulatory Criteria: Radioactive waste must be disposed of in accordance with regulatory requirements and license conditions. Appropriate records of waste disposal must be maintained.

• Discussion: Radioactive waste is normally generated when performing licensed activities. Such waste may include used or unused radioactive material and unusable items contaminated with radioactive material (e.g., absorbent paper, gloves). Licensees may not receive radioactive waste from other licensees for processing, storage, or disposal, unless the NRC specifically authorizes them to do so.

All radioactive waste must be stored in appropriate containers until its disposal, and the integrity of the waste containers must be assured. Radioactive waste containers must be appropriately labeled. All radioactive waste must be secured against unauthorized access or removal. The NRC requires licensees to manage radioactive waste generated at their facilities by one or more of the following methods:

o transfer to an authorized recipient o release into sanitary sewerage o extended interim storage o prior approval by the NRC of any alternate method o release in effluents to unrestricted areas, other than into sanitary sewerage o incineration

Licensees may choose any one or more of these methods to dispose of their radioactive waste.

It has been the NRCs experience that many of the facilities dispose of Special Nuclear Material by the first method. Applicants should describe their program for management and disposal of radioactive waste. The program should include procedures for handling of waste, safe and secure storage, characterization, minimization, and disposal of radioactive waste. Appropriate training should be provided to waste handlers. Regulations require licensees to maintain all appropriate records of disposal of radioactive waste.

Request:

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Provide text with the Purdue commitment to meet the 10 CFR Part 20 Subpart K (Waste Disposal) requirements, including 10 CFR 20.2001(a) and with the description of how Purdue intends to meet the 10 CFR Part 20 Subpart K (Waste Disposal) requirements, including 10 CFR 20.2001(a).

Response

There is little to no radioactive waste associated with this license.

If low-level waste were ever to be created, provisions through Radiological and Environmental Management (otherwise known as:

Environmental Health and Safety) to collect and dispose the material.

All waste management operations at Purdue University are carried out by trained technicians.

Technicians are responsible for picking up radioactive waste from all laboratories since researchers are prohibited from sink disposal or any other direct means of disposal unless specifically exempted from the requirements.

Containers for waste are supplied by REM unless a PI has requested to use alternative equivalent containers. The containers that are delivered to investigators upon request include the following:

Plastic carboys: up to 20 liters

Plastic drums: 5 gallons

Bags: 5 and 30 gallon plastic

Prior to pickup by REM, all containers must be properly labeled to include isotope, amount, authorization number, investigator name, date, and any solvents or hazardous materials present.

Waste is required to be separated into a number of different categories so that it may handled. At this time the categories for waste include:

Solid short half-life (< 30 days) is placed into drums or bags as appropriate.

Long half-life material is separated into combustible and non-combustible and placed into bags or drums.

Liquid waste is separated into short and long half-life. Any liquid waste containing hazardous or non-dispersible components is identified and handled separately.

Vials are required to be returned to their original carton to remain upright during transport or placed in a drum which is double-bagged to prevent leakage.

Biological 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.

When a PI is ready for a waste pickup REM is called to schedule the pickup. Technicians verify the label to ensure that all information necessary is complete. The packages are all smeared,

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surveyed for exposure rate at the surface and at 1 meter, and checked to see that the enclosures are secure. Any labeling, marking, notices, shipping papers, and placarding requirements are observed pursuant to 49 CFR prior to transport on public highways.

After pickup waste is delivered to various handling facilities for processing and disposal.

Description of those facilities is provided elsewhere in this application.

Short half-life materials are stored for a minimum of 10 half-lives prior to disposal. Solid material is surveyed with an end-window GM survey meter and any material with radiation levels essentially equal to background are disposed as normal trash. Prior to disposal all radioactive labels and markings are defaced or destroyed. A record of all radioactive material that has been disposed of by decay in storage (DIS) will be maintained. Liquid material will be sampled and analyzed for radioactivity by liquid scintillation counting. Any material less than 100 dpm/ml will be disposed in the sanitary sewer provided the material is readily dispersible and non-hazardous.

If the activity is above this amount the material will be allowed additional decay time. If further sampling reveals that the activity is still present it will be treated as long half-life material (see below).

Solid long half-life material will be disposed of using a licensed waste broker facility, and final disposal will be completed off-site. Currently waste is disposed of by Bionomics Inc.

Non-combustible long half-life waste (metal and glass) is compacted using Teledyne Industries compactor. The Teledyne compactor is equipped with an external air exhaust and HEPA filter which is monitored on an annual basis for activity and integrity.

No air sampling is done in the area since the most volatile compound undergoing compaction is I-125. Personnel bioassays, probably the most sensitive exposure indicator, have indicated a maximum dose equivalent of 13 millirem per year to the thyroid. This is less than 0.03% of the 50 rem occupational limit for the thyroid and falls well under our 100 mrem ALARA trigger level.

Direct radiation surveys and wipe testing of the areas are performed on a regular basis.

Long half-life liquid 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.

Liquid waste may be disposed of by the sanitary sewer as provided in 10 CFR 20.2003. Attempts are made to limit daily disposal to less than ten times the Appendix C value in the interest of ALARA. However, if this limit would increase exposure to radiation safety staff (such as subdividing waste packages) the former limits would be observed. Records are maintained at all times of material that has been disposed of in this manner.

Scintillation vials are packaged in drums and shipped via a waste broker for treatment or disposal.

All applicable DOT regulations regarding the shipment of hazardous materials are observed.

All waste shipments will be transferred to a licensed waste broker or facility. Currently waste is transferred to Bionomics Inc. 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, we will follow 10 CFR 20 Subpart K, including 10 CFR 20.2001(a) for all waste disposal at Purdue University.

Purdue University does not conduct waste treatment by incineration.

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Conside ring the nature o f the w o rk conducted in areas with most of the waste that is gen erated are simp ly used g loves, benchtop pape r, and other forms of used personal protective equipment. In the vast ma jority o f cases, w aste is already reading at background rad iation levels upon pickup b y REM staff.

D. Technical Review Area-Material Control and Accounting (MC&A)

MC&A Reports of Loss or Theft of Special Nuclear Material:

Regulatory Basis:

10 CFR 7 4.11 requires each licensee who possesses one gram or more of contained uranium-235, uran ium-233 or plutonium to not ify 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 d iscovery of any loss or theft or other unlawful d iversion of SNM which the licensee is licensed to possess, or any incident in wh ich an attempt has been made to commit a theft or unlawful d iversion of SNM.

Issue

Description:

The LRA does not specifically address the 1-hour reporting requ irements for MC&A related loss, theft and diversion indicators as required by 1 O CFR 7 4.11.

Request:

Provide a description of the MC&A act iv ities that are performed or the measures in place to demonstrate how the requirements of 10 CFR 7 4.11 are met.

Response :

9 MC&A-2 - Material Status Reports:

Regulatory Basis:

Issue Desc ription:

No information on complet ing and su bmitting mater ial ba lance reports and phys ical inventory listings has been p rovided in the subm ittal.

Request:

Provide a descr iption of the MC&A act iv ities that are performed o r the measu res in p lace to demonstrate how the requirements of 10 CFR 7 4.13 are met.

Response :

MC&A-3 - Nuclear Material Transaction Reports:

Regulatory Basis:

Issue

Description:

Submittal of a nuclear materia l transaction report for a receipt from a shipper is addressed in the application, and the licensee in d icates that not ification to the shipper of receipt is provided within

10 10 days as required. However, no information on completing nuclear material transaction reports for shipments from the licensee has been provided in the submittal.

Request:

Provide a description of the MC&A activities that are performed or the measures in place to demonstrate how the requirements of 10 CFR 74.15 are met.

Response

MC&A Recordkeeping:

Regulatory Basis:

10 CFR 74.19(a) requires each licensee to 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 MC&A 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.

Issue

Description:

In section 6.4 of the submitted Technical Specifications document, the licensee lists operating records including fuel inventories, shipments, and receipts. However, the licensee mentions a 5-year retention period for those records and the requirement in 10 CFR 74.19(a) indicates that records must be retained for as long as the licensee retains possession of the SNM and 3 years thereafter.

Request:

Provide a description of the MC&A activities that are performed or the measures in place to demonstrate how the requirements of 10 CFR 74.19(a) are met.

Response

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MC&A Written MC&A Procedures:

Regulatory Basis:

10 CFR 74.19(b) requires each licensee authorized to possess SNM in a quantity exceeding one effective kilogram at any one time to 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.

Issue

Description:

The licensee provides a list of operating procedures in Section 6.3 of the Technical Specifications document. However, the list does not include any procedures related to MC&A activities including shipment of SNM, receipt of SNM, conduct of inventory, or submitting reports to the national database. No information on establishing, maintaining, and following written MC&A procedures has been provided in the submittal.

Request:

Provide a description of the MC&A activities that are performed or the measures in place to demonstrate how the requirements of 10 CFR 74.19(b) are met.

Response

The Technical Specifications are not applicable for material under the SNM-142 license, but only under the R-87 license. Technical Specifications were attached as an appendix for reference in other areas of the renewal application. 10 CFR 74.19(b) regulations are met by the following:

Additionally, all sealed sources on inventory with any Purdue license issued by the NRC are inventoried and leak tested by the Radiation Safety Team in accordance with 10CFR 39.35. At the end of each calendar year, the Radiation Safety Team sends out an Inventory Reconciliation to be completed by all Principal Investigators responsible for any licensed radioactive material. This inventory reconciliation serves the purpose of verifying/updating all current inventory items, and associated radioactivity amounts, within the P.Is possession.

E. Technical Review Area - Nuclear Criticality Safety (NCS)

NCS Exemption Continuation

Regulatory Basis:

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Issue

Description:

Request:

State whether the applicant intends to continue the exemptions from the requirements of 10 CFR 70.24 (License Conditions 14 and 15) as part of the SNM-142 Materials License renewal. If the applicant intends to continue these exemptions, provide a request for exemption in accordance with 10 CFR 70.17.

Response

Purdue was previously granted an exemption from the provisions of 10 CFR 70.24(a) for the (SER dated July 30, 1999) and requests continuation of that exemption. This exemption is not in conflict with any other regulations and the staff determined that it will not endanger life or property or the common defense and security. Since the conditions under which the NRC staff granted that exemption have not changed the staff recommends granting the exemption request for as follows: -

"The licensee is exempted for the requirements of 10 CFR 70.24 insofar as the section applies to the material

The applicant had also requested an exemption from the provisions of 10 CFR §70.24 for the However, in its response dated January 31, 2012 (ML12033A076) to the staff's RAls, the applicant withdrew this request. The staff reviewed the monitors used in the

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and find that these area mon itors meet the requirements of 10 CFR 70.24.

In the response to staff RA ls dated May 8, 2013 ( ML13149A295), the applicant requested exempt ion from the prov isions of 10 CFR §70.24 as it wou ld otherwise app ly to var ious campus locations approved by the Rad iation Safety Committee. At these locat ions, non-destruct ive evaluation and testing is proposed The reason prov ided for this exempt ion

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