ML24032A474

Enclosure 1 - Purdue Renewal RAI

ML24032A474
Person / Time
Site:	07000152
Issue date:	02/23/2024
From:	NRC/NMSS/DFM/FFLB
To:	Purdue University Research Reactor
Shared Package
ML24032A472	List: ML24032A473 ML24032A474
References
EPID L-2023-NFR-0000
Download: ML24032A474 (6)

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 Commission (NRC) staff has identified the additional information discussed below that is needed to complete its detailed technical review of the Purdue University (Purdue) license renewal application (LRA). Purdue should revise its LRA to provide this information within 30 days from the date of this communication.

A. 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 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.

Request:

Provide an evaluation that an emergency plan is not required to comply with the referenced regulation. This evaluation should revalidate or update the referenced 1993 evaluation based on changes to the dose conversion factors and updates to the calculation methodologies that have occurred since 1993.

B. Technical Review Area - Radioactive Waste Management (RWM)

RWM Waste Disposal

Regulatory Basis:

Enclosure 1 10 CFR 20.2001(a) requires that:

(a) A licensee shall dispose of licensed material only -

(1) By transfer to an authorized recipient as provided in § 20.2006 or in the regulations 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

Description:

The LRA does not include a specific commitment to meet any of the 10 CFR Part 20 Subpart K (Waste Disposal) requirements, including 10 CFR 20.2001(a).

To understand licensees commitments to in the area of RWM, Purdue needs to identify those regulations 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 regulations, Purdue must either:

• Describe of how they intend to meet those regulations; or

• Describe an alternative method for Purdue to meet those regulations

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.

Section 2.2.6, Waste Management of draft guidance 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) provides additional guidance on how to demonstrate compliance with the regulations and includes for RWM.

2 Request:

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) or justify why it does not commit to those requirements.

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

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

Regulatory Basis:

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

Issue

Description:

The LRA does not specifically address the 1-hour reporting requirements for MC&A related loss, theft and diversion indicators as required by 10 CFR 74.11.

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 74.11 are met.

MC&A Material Status Reports:

Regulatory Basis:

10 CFR 74.13 requires each licensee possessing special nuclear material in a quantity totaling 1 gram or more of contained uranium-235, uranium-233, or plutonium to complete and submit, in computer-readable format, Material Balance Reports concerning SNM that the licensee has received, produced, possessed, transferred, consumed, disposed, or lost. The Physical Inventory Listing Report must be submitted with each Material Balance Report.

Issue

Description:

No information on completing and submitting material balance reports and physical inventory listings 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 74.13 are met.

MC&A Nuclear Material Transaction Reports:

3 Regulatory Basis:

10 CFR 74.15 requires each licensee who transfers or receives SNM in a quantity of 1 gram or more of contained uranium-235, uranium-233, or plutonium to complete, in computer-readable format, a Nuclear Material Transaction Report. In addition, each licensee who adjusts the inventory in any manner, other than for transfers and receipts, shall submit a Nuclear Material Transaction Report, in computer-readable format, to coincide with the submission of the Material Balance Report. Each licensee who transfers SNM shall submit a Nuclear Material Transaction Report no later than the close of business the next working day. Each licensee who receives SNM shall submit a Nuclear Material Transaction Report within 10 days after the material is received.

Issue

Description:

Submittal of a nuclear material transaction report for a receipt from a shipper is addressed in the application, and the licensee indicates that notification to the shipper of receipt is provided within 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.

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.

4 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.

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

NCS Exemption Continuation

Regulatory Basis:

10 CFR 70.24 requires, in part, that each licensee authorized to possess special nuclear material in a quantity exceeding 700 grams of contained uranium-235, 520 grams of uranium-233, 450 grams of plutonium, 1,500 grams of contained uranium-235 if no uranium enriched to more than 4 percent by weight of uranium-235 is present, 450 grams of any combination thereof, or one-half such quantities if massive moderators or reflectors made of graphite, heavy water or beryllium may be present, maintain in each area in which such licensed special nuclear material is handled, used, or stored, a monitoring system meeting the requirements of either paragraph (a)(1) or (a)(2), as appropriate, and using gamma-or neutron-sensitive radiation detectors which will energize clearly audible alarm signals if accidental criticality occurs.

The guidance in Section 5.3.A.3 of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2, states that NRC staff reviews should include any sections of the license application and integrated safety analysis summary describing the applicants criticality accident alarm system and emergency response measures for protecting workers and the public from the consequences of accidental criticality events.

Issue

Description:

The current SNM-142 grants an exemption from the requirements of 10 CFR 70.24 insofar as such requirements apply to 1) special nuclear material (SNM) in any fuel rods in the Duncan Annex that are for storage only (License Condition 14) and 2) fissionable material in individual unrelated work areas in which the inventory of the material does not exceed 700 grams uranium-235, 520 grams uranium-233, 450 grams plutonium-239, or 450 grams of any

5 combination of these three isotopes, with one-half such quantities if massive moderators or reflectors made of graphite, heavy water, or beryllium may be present (License Condition 15).

However, the application to renew the SNM-142 Materials License does not specify whether these exemptions apply to the renewal or whether the applicant intends to continue these exemptions.

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.

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