ML20141B421

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Forwards RAI Re 960628 Application for Renewal of License SNM-362.Response Should Be Submitted within 30 Days
ML20141B421
Person / Time
Site: 07000398
Issue date: 05/13/1997
From: Soong S
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Pevey L
NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL
References
TAC-L30878, NUDOCS 9705150277
Download: ML20141B421 (10)


Text

- .- . .

May 13, 1997

. i Mr. L. E. Pevey, Chief Occupational Health and Safety Division U.S. Department of Commerce National Institute of Standards and Technology-Building 301, Room B124 Gaithersburg, Maryland 20899

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - NATIONAL INSTITUTE OF STANDARDS

.AND TECHNOLOGY (NIST) RENEWAL OF SNM-362 (TAC NO. L30878)

Dear Mr. Pevey:

This refers to your application dated June 28, 1996, requesting renewal of license number SNM-362. Our review of the application has identified additional information that is needed before final action can be taken on your renewal request. This additional information is described in the enclosure to

'this letter.

The additional information should be provided in the form of responses to the individual comments, as appropriate, or as revised pages to the application, within 30 days of the date of this letter. Please reference the above TAC number in future correspondence related to the license renewal.

If you have any questions, please call me at 301-415-8155. )

Sincerely, I Original signed by: 1 Sean Soong Licensing Section 2 Licensing Branch ,

Division of Fuel Cycle Safety l and Safeguards, NMSS Docket 70-398 i License SNM-362 i

Enclosure:

Request for Additional NRC FIE CENTER COPY I

\ l Information I i I Distribution: (Control No. 2005) .,

Docket 30-398 PUBLIC INRCiFile: Center' FCLB R/F NMSS R/F TDragoun, RI Region I FCSS R/F Schotoo I (g:\nist.rai' 0FC FCLB h FCLB .

b FCLB h FCLB /L/) FhB /

NAME 'SSooag/d KHardinOk PShea (ads GPangbd MWek DATE 5//1 /97 5/ /3 /97 5/d/97 5//3 /97 5//' h7 C = COVER E = COVER & ENCLOSURE N = NO COPY / \

0FFICIAL RECORD COPY .

9705150277 970513 PDR ADOCK 07000398 )

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.p 't UNITED STATES -

g j- NUCLEAR REGULATORY COMMISSION

% ,,, g May 13, 1997 s Mr. L. E. Pevey, Chief Occupational Health and Safety Division-U.S. Department of Commerce National Institute of Standards and Technology Building 301, Room 8124 Gaithersburg, _ Maryland 20899

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY (NIST) RENEWAL OF SNM-362 (TAC N0. L30878)

Dear Mr. Pevey:

This refers to your application dated June 28, 1996, requesting renewal of l license number SNM-362. Our review of the application has identified ,

additional information that is needed before final action can be taken on your '

renewal request. This additional information is described in the enclosure to ,

this letter. i The additional information should be provided in the form of responses to the individual comments, as appropriate, or as revised pages to the application, i within 30 days of the date of this letter. Please reference the above TAC j number in future correspondence related to the license renewal. j If you have any questions, please call me at 301-415-8155. l Sincerely, 7 .

/ ,-

ean Soong I w n-}f -

Licensing Section 2 Licensing Branch .

Division of Fuel Cycle. Safety .

I and Safeguards, NMSS Docket 70-398 License SNM-362

Enclosure:

Request for Additional I Information  ;

l l

REQUEST FOR ADDITIONAL INFORMATION NIST RENEWAL LICENSE SNM-362

1. In Section 1.8, Part I, of your renewal application, you request an exemption from 10 CFR 70.24. In our review, we found that your mass limits on SNM, except PuBe sealed sources, are below the limits specified in 10 CFR 70.24. Therefore, no exemption is necessary. This renewal is different from your previous renewal because you have decreased your mass limits by more than 50% which means that you are now applying for a special nuclear material license of less than critical mass quantities. I have attached a copy of Regulatory Guide 10.3 for your information and use. Please keep in mind that if you choose to apply for an increase in your mass limits at a later date, you may have to request an exemption at that time. Per Regulatory Guide 10.3, modify your license as follows:

- Delete Section 1.8.a requesting an exemption from 10 CFR 70.24.

- Delete Chapter 6 as written and replace with the following:

Under SNM-362, NIST does not possess and use special nuclear material in quantities and forms sufficient to form a critical mass.

That is, NIST possesses and uses less than 350 grams of contained uranium-235, 200 grams of uranium-233, 200 grams of plutonium (in any form other than plutonium-beryllium neutron sources), or any l combination of them in accordance with the unity rule as shown ,

I below:

arams U-235 + arams V-233 + arams Pu < or = 1 350 200 200 2560 + 6 + 40 - 0.97 <1 350 200 200 NIST commits to adequate procedures to ensure that no more than 450 grams of plutonium as plutonium-beryllium neutron sources will be used or stored at any single location. Therefore, no criticality provisions are required.

Attachment:

Regulatory Guide 10.3 ENCLOSURE

. ~ .

Revision 1

,Fp ucy,S U.S. NUCLEAR REGULATOFY COMMISSION April 1977

@: %,y,f @ f)&

REGULATORYGUIDE OFFICE OF STANDARDS DEVELOPMENT i REGULATORY GUIDE 10.3 i

GUIDE FOR THE PREPARATION OF APPLICATIONS FOR 1 SPECIAL NUCLEAR MATERIAL LICENSES OF LESS THAN l CRITICAL MASS QUANTITIES i l

l

1. INTRODUCTION 10. Code of Federal Regulations. Special nuclear i material, by definition in 10 CFR Part 70 means l 1.1 Purpose of Guide plutonium, uranium 233, uranium enriched in the j isotope 233 or in the isotope 235, and any other  ;

This guide describes the type of information matertd that the Commission determines to be i needed to evaluate an application for a specific special nuclear material or any material artificiall) license for receipt, possession, use, and transfer of l enriched by ans of the foregoing. In addition to 10 special nuclear material. It is intended for applicant';

CFR Part 70. 'the regulations pertaining to special 1 requesting authoritation to possess and use up to nucle,ir material licenses are found in 10 CFR Part 2,000 grams of plutomum, total, in the form of sealed 19. " Notices, instructions, and Reports to worker .

plutomum beryllium neutron sources, and an) Inspections " 10 CFR Part 20 " Standards for 1 special, nuclear material in quantities and forms not Protection Against Radiation;" 10 CFR Part 71, l sufficient to form a critical mass. T he latter quantities " Packaging of Radioactise N1aterial for Transport l are considered to be 350 grams of contained and Transportation of Radioactise N1aterial Under I uran um 235,200 grams of uranium-233,200 grams Certain Conditions;" and 10 CFR Part 170," Fees for of piu'enium (in any form other than plutonium- Facilities and N1aterials Licenses Under the AtomN beryllium teutron sources), or any combination of Energs Act of 1954, as Amended." The apphcant them in acco. dance with the following formula: should study carefully the regulations and this guide and should submit all information requested pams U.235, tams, U-233, grams Pu ,

350 20 200 1.3 Items Requiring Separate Applications For each kind of special nuclear material, ii.c apph. Activities that involve the r ceipt, possession, use. l cant should dc. ermine the ratio between the re- ind transfer of special nuclear material in quantities quested quantity of ti.at special nuclear material and and forms sufficient to form a critical mass are not the quantity specified above for the same kind of within the scope of this guide.

special nuclear material. The sum of such ratios for all kinds of special nuclear material in combination 1,.4 As Low As is Reasonahh 'Achietable i Al. \R \

should not exceed unity if this guide is applicable l For esample, the following in combination would not Paragraph 20.l(c) of 10 CFR Part 20 states that l esceed the limitation of the formula- "

. persons engaged in activities under licenses :s-sued by the Nuclear Regulatory Commission r r-175 (grams contained U 235) suant to the Atomic Energy Act of 1954, as amended.

350 and the Energy Reorganization Act of 1974 should.

in addition to complying with the requirements ,et i

+ 50 (grams U 233) + 50 (grams Pu) = f rth in this part, make every reasonable effort to

-,00 W 1 maintain radiation esposures, and releases of l

I l.2 Appilcable Regulat,ons i radioactne materials in effluents to unrestricted i Special nuclear material licenses are issued pur- areas, as low as is reasonably achiesable.

suant to Part 70, "Special Nuclear N1aterial." of Title Regulatory Guide 8.10. " Operating Philosophy for USNRC REGULATORY GUIDE S rw * . u.u i,, wm , , ~ s., .o.-. ~t - , m - --

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B pneemrt gumrde c to record the location, by

' Maintaining Occupational Radiation Exposure A hcenel specuiFr,uclear material. This system uses Low As is Reasonably Achievable," provides the > tt reolew Reporta g identi6 cation Symbol (RIS) ,

N RC staff position on this important subject. Licem,e w edeatry kne.S who must submit material -

i applicants should give consideration to the ALAR Atran5fm wpertutd periodic material status reports philosophy, as described in Regulatory Guide 8.10,in in anoditer: Wh (470.5.t " Material Status the development of plans for work with licensed Reports,' ard '0 52, " Nuclear Material Transfer ,

radioactise materials. kepteru.' of P IIR Pct 70. Applicants will be as- '

signed an R)S and will be informed how it is to be

2. LICENSE FEES used following issuance of the license. Requirements ,

for reports will be forwarded under separate coser An application fee is required for most types of following the issuance of either a license or an l

licenses. The applicant should refer to (170.31, authorizing greater than I gram of

" Schedule of Fees for Materials Licenses," of 10 amendment special nuclear material.

CFR Part 170 to determine the amount of the fee that l must accompany the application. Review of the ap. No information concerning criticality prosisjons i plication will not begin until the proper fee is received is required if no more than 450 grams of plutonium as , .

by the NRC. plutonium beryllium neutron sources are requestedr For quantities greater than 450 grams as neutron  ;

3. FILING AN APPLICATION sources. no criticality information is required  !

A license application for special nuclear material provided adequate procedures to ensure that no more than 450 grams will be used or stored at any single' should be Gled in letter form and should provide the information specified in 470.22. " Contents of Ap- site are submitted. i plications," of 10 CFR Part 70. All items should be completed in sufficient detail for the NRC to deter- 4. CONTENTS OF AN APPLICATION '

mme that the applicant's equipment, facihties. and radiationprotection program are adequate to protect 4.1 Specification of Applicant health and minimite danger to life and propert). l l

Each separate sheet or document submitted with The applicant corporation. institution. gosernment '

agency, or other legal entity should be specified by l the appbcation should be identified as to its purpose, name, street address of pdncipal ofGee, and the state j e g., response to an item of the regulation, radiation where incorporated. Anv co,-trol or ownership exer, safety mstructions, etc. Seven copies of the applica- cised oser the applicant by ny alien, foreign cor- l tion should be completed. The original and five 4 copics should bc mailed to: Radioisotopes Licensingpotation, or foreign governnwnt should be indicated Branch, Dmston of Fuel Cycle and Material Safety.

The principal officials of the applicant corporation Of0cc of Nuclear Material Safety and Safeguards. should be indicated by name, title, address, and U.S. Nuclear Regulatory Commission, % ashington, citizenship. Individuals'should be designated as the i D C. 20555. One copy of the application, with all at. applicant only if the use of the special nuclear '

tachments. Nuld be retained by the applicant, since material is not connected with employment with a the license will require, as a condition, that the corporation or other entity. If the applicant is an m.

licensee follow the statements and representations set

,bidual, the individual should be specified by full forth m the application and any supplement to it. name, age citizenship, and street address, including SId.and zip c de. The individual applicant sho also mdicate th:ce personal references ident:Ged by 3.1 Proprietars Information name, address and citizenship.

The information required in applications usually can be presented without the use of proprietary data. 4 2 Specifiestion of Actisities To Be Performed

% hen its use cannot be avoided, the proprietary in.

formation should be separated from the rest of the The operations for which the special nuclear application, and an application for withholding from material will be used and a general plan for carrying public inspection should be made in accordance without the activity should be described. This information the requirements of n2.790 of 10 CFR Part 2," Rules should be specified for each location where the of practice " special ntn:lcar material will be used. Each indiv operation should be described. The purpose of descriptive information is to enable the Commission l 3.2 Safeguards and Criticality to determine that the special nuclear material will be l used for activities permitted under the Commission's -

For licenses included in the scope of this guide, no regulations and the Atomic Energy Act of 1954, as l

.safeguoid information is required in an initid ap- ame* ded.

plication; The ommission t.ses an electronic data

10. N l

. . - ..- .- - -- - - .~ -.- - - - -,--- .- -- .- .

4 7 .= j i

4 3 Specification of Special Nuclear Material ~i The.nuribn type. and length of remote handl-ing devices. ,

The special nuclear material requested should be 4 identified by isotope; chemical or physical form; ac. 2. Storag: cor' tainers and facilities. Consideration  !

tivity in curies, millicuries, or microcurien and mass of both shielding and security of materials should be l 1 in grams. Specification of ist tope snould include indicated.  ;

[ pWncipal isotope and significa it contaminants. Ma- 3. Co.itaincrs, desices, protective clothing, aus-  !

Jor dose-contributing contaninants present or ex- iliary shielding, uneral laboratory equipment. air

- pected to build up are of particular interest. For ex. sampling equipnh "c., actually employed in the i ample, the quantity of plutonium 236 present in daily use of mate a f,ielding and containment  :

rd designed to minimite 4- plutonium 238 should be specified. provision for lease s personnel exposure sht. > be described.

Possession limits requested should coser the total <

anticipated inventory, including stored materials and 4. l ihysical plant, labor, ey, or working area  !

waste. . facilities. A description of < fume hoods, glose boxes, waste receptacles, spect sinks, ventilation i if the application is for a sealed source or plated and c'ontainment systems, cfl ues. filter systems, in.  !

, source, the special nuclear material content and clading the design specificatioas a d capabilities of ,

manufacturer's name and model number of each these systems should be inclusd. All processing. ,

scaled or plated source should be specified, if a scaled work, and change areas should h iescribed. Ap-  ;

source will be used in a device (holder, gage, analyzer. plications for chemical or phyrie,', pro:essing opera- i etel. the manufacturer's name and model number of tions should include a description of the controk for -

' the device should be identified. Each sour e should fire prevention and the firefighting equipment 4 be keyed to the specific devices used with it, available. Sketches showing laboratory or plant ar-rangements and the nature and use of areas adjacent t areas in which special nuclear materials will be ,

4.4 Technical Qualifications of Personnel processed should be submitted.

A resume of the training and experience of each 5. Radiation detection instruments to be used. The person who will directly supervise the use of material manufacturer's name and model numbers, the 3

or will have radiological safety responsibilities shou'.d number of each type available, the type of radiation i be submitted. The resume should include the type of detected (alpha, beta, gamma, or neutron), the sen-trammg (e g., on the job or formal course work). sitivity range (milliroentgens per hour, neutrons per ,

the location where the training was received, and the secend. er counts per minute). the window thickness

duration of the training. Training should include sub- in mg/cm', and the type of use for each instrument jects such as (1) principles and practices of radiation should be specified. The type of use would normally protection. (2) radioactivity measurements, standard- be monitoring, surveying, assaying, or measuring.

itation, and monitoring techmques and instru-ments,(3) mathematies and calculations basic to the Instrument calibration provisions should be f use and measurement of fadioactivity, and (4) described. State the frequency, and describe the l biological effects of radiation. The description of the methods and procedures for calibration of sursey l; actual use of radioactive materials or equivalent ex. and monitoring instruments, as well as any other m-perience should include the specific isotopes handled. strumen:s and systems used in the radiation protee

, the masimurp quantities of ' materials handled, where tion program, such as measurmg mstruments used io the cxperience was gained, the duration of cp assay sealed-source leak test samples, contammaticm ,

perience, and the type of use. The quahfications, samplei (e g, air samples, surface smear test sam. ,

training, and experience should be commensurate ples), and bioassay samples (see item 4.6.3.3).

with the proposed use of the material requested in the An adequate calibration of survey instrumems apphcation. usually cannot be performed with built in check sources. Electronic calibrations that do not insche a 4,5 Description of Equipment, facilities, and s urce of radiation are also not adequate to deter-Instrumentation mine the proper functioning and response of all com i

ponents of an instrument. I

, The equipment, facilities, and radiationdetection Daily or other frequent checks of sursey instru- i mstrumentation for each site of use should be ments should be supplemented every 6 months with a j described in detail. The proposed equipment and two-point calibration on each seale of each nstru- !

facilities for each activity must be adequate to protect ment with the two points separated by at lost 509 ot  !

. health and mm,mize i danger to hfe and property. In the scale. Survey instruments should also be <

, describing available equipment and facilities, the fot* calibrated following repair. A survey instrument mas !

lowing' types of irSrmation should be meluded, as

' appropriate. . tanes in$cate substantwe changes from preucus mue 10.3-3

b d Step-batep eabbranon procedures and. d

! be conudered properly cahbrated when the mstru- approprun. .assouated radiation safety procedures.

ment readings are withm 110'i of the calculated or Readings and know n s alues for each point checked within t20'i are considered acceptable if a calibra- c. I he f.ume and perunent esperience of each tion chart or graph is prepared Jnd attached to the m. person w ho will perform the instrument cahbrauont strument 4.6 Proposed h uudres fo Protect Health and If the appheant proposes to eahbrate ha sune) Minimite Danger instruments, a detailed description of planned cahhranon procedures should be submitted The Procedures should be established to ensure com-desenption of cahbration procedures should include, phance with prosnions of 10 CFR Part 19. "Nouces as a mimmum: instructions. and Reports to Workers; inspechons.'

and 10 CFR Part 20. " Standards for Protection

a. The manufacturer and model number of Against R adiation." The procedures should be each radunon source to be used, specific for the acliuties for w hich a heense is sought Depending on the types and quantities of materuts b The nuclide and quantity of radioactne and the scope of use, the following informahon matenal contained in each source, should be submitted:
e. The accuracy of each source The 4.6.1 Specification of Radiation Safel) Hrspon-
traecabihty of the source to a primary standard sibilities and Duties should be prouded The responsibihues and dunes of managemem.

d The step-by step procedures, includmF m an) raduuon safet) committees, raduuon saiet) 01-soeuted radianon safet) procedures and fieers and users should be clearly estabbshed in-dniduah haung redution safety responubihnes e The name and pertment esperience of each ,

should be idenufied by name, and peronent tram.np  !

person who will perform the eahhratmns and esperience should be desenbed (see Section 4 4

\ssignment of duties should coser all aspech of the If the appheant mtends to contract out the radiauon safety program.

cahbrauon of sune) instruments, the name, address, l and license number of the cahbration firm should be 4,62 Personnel \lonitoring l I

specified together with the frequency of cabbration. 1. Personnel mou:onnF equipment tfilm nadge.

4 The appheant should contact the firm that will per- TLD, dosimeters)* should be specified, including the form the cabbrations to determine if informanon 13 pe of radiation monitored (beta. gamma, or

concermng cahbration procedures has been filed with neutront the frequency of evaluation, and the type el the Commnuon 'Iinformat on concernmg cabbra- seruces to be obtained from a commercul suppher non procedures ha not been filed. it shoe' . be ob- This specification should include w hether the
tained and subrmtted. monitoring is to evaluate w hole body or estremit) es-posure. If dosimeters are to be used, the type, range, Quanntatne measunng instruments used to IfCF icy of reading, and maintenance and cah5r a-monitor the adequacy of containment and con. w . proustons should be specified tammahon control such as those used for measunng leak test, air ef0uent, bioassa) work area, and 1 If no 3ctsonnel momtoring is specified. the equipment contamination samples should usually be applicant should submit an evaluanon of espee:ed eahbrated poor to each use. The procedures and fre- esposures from the proposed use. This esaluanon

} quency for cabbranon of such instruments should be should demonstrate that no indnidual n hkch to recene a dose in any calendar quarter in esces\ of i

submitted and should include-031 rems to the whole body, blood forming organs lens of the eye. or gonadu 4 69 rems to estremices

a. The name of the manuf acturer and model (hands forearmt feet. or anklest or 1 % rem, to the number of each of the standards to be used. skin of the whole body from all sources and typcs of
b. The nuchde and quamity of radioactne occupational exposures.

materul contained in each of the standard sources, 1 For processing operations where a potentu!

e. A statement of the accurac) of each of the for internal depoution of radioactne mate ul custs.

standard sources. T he source accuracy should be, as a a bioassay program may be required. Regulatory i

nummum,2 Fr of the stated salue and traceable to a Guide 8.11. " A pplications of Bioassas for 1 primary st ndard, such as that maintained by t'e Uramum," deals with depleted natural and enriched Nauor .I Bure u of Standards,

'O34

uranium, but the general requirements and methods protective clothing, equipment, or tools required dur- I are applicable for a special nuclear material bioassa) ing processing should be described. Surface con. '

program. tamination evaluation should include unrestricted areas such as lunch rooms, offices, etc. The sursey 4.6.3 Radiation Suncy Program program to monitor cleanup efforts for work areas where dust or loose materials are produced or spread >

s sursey is denned as an evaluation of the should be described. Reasonable efforts should be radiation hazards incident to production, use, made to remove all residual contamination. Accep-release, disposal, or presence of radioactive materials table limits of fixed and removable contamination for When appropriate, such evaluation includes a facilities in restricted areas should be set.

physical sursey of the location of materials and equipment and measurements of levels of radiation or concentrations of radioactive material present in 4. Acceptable limits of 0xed and removable con.

air, water, or other materials and on surfaces. The tamination for facilities and equipment in un-types, methods, and frequency of surveys should be restricted areas and for release for unrestricted use specined according to the nature and complexity of should be set. For example, after reasonable effort to the special nuclear material program. remose all residual contamination, if maximum alpha levels are 300 dpm*/100 cm or less and the 3

2. For operations involving only sealed sources, average is 100 dpm/100 cm' or less. unrestricted use a survey program should include esaluation and/ is permissible, provided that removable alpha con- .

or measurement of gamma and neutron radiatior' tamination does not exceed 20 dpm/100 cmL These l levels for storage and use configurations. When guidelines apply to all special nuclear material except sources are used in devices having "on" and "off' mistures of the naturall) occurring isotopes of ,

poutions, both positions should be evaluated at the uranium (U 234, U-235, U-238) for which the lesch l tin.c of installation. Supplemental surseys should be may be a factor of 5 higher.

performed following any chanFes in operation. i shieldmg. use. or location of the device.

5. A suncy program for pilot sludies and in tial {
3. For operations insohing materials in forms phases of a full scale production operation needed l other than as scaled am the suncy proFram for evaluating and verifying actual hazards may be should also be designed to mone-'he adequacs of more extensive than the suncy program that ma) be ,

containment and contaminatioe m irol. 'T he appropriate for the day-to-day program. Provisions ,

program should melude air sampLng. Noaways, for the evaluation of all changes in operation should momtoring ef0uent releases, and sunep to evaluate be made. j alpha contamination of personnel, work areas, and

  1. 4 "' P ** "I' l 4.6.4 Waste Dhposal l
a. The specification of an air sampling 1. Wastes generated as a result of operations in-prograrn should include the areas ahere samples will sching special nuclear material need to be disposed be takeri, the frequency of sampling, the relationship of m a safe manner. Such *astes may include items to the processing or maintenance phase, and orienta- such as contaminated tools, gloses, clothing, absor-tion of sampler with respect to workers' breathing bent materials, filters, resin columns, decontamina-iones. Tne type of assays that will be performed to tion solutions, or process wr.stes(see %420.30120.305.

esaluate air samples and the methods used to relate which deal with waste dbposal, of 10 CFR Part 20) results to actual personnel exposures should ne described

2. Wastes that are soluble or readily dispersible in water may be disposed of via the sanitary sewer i
b. The effluent monitoring progrJm for system sub[ect to the concentration and' dail). I releases to unrestricted areas should encompass all monthly, and annuallimits specified in %20.303 of to airborne and liquid releases. Calculational evalua* CFR Part 20. For example, up to 0.1 microcurie of tions should be supplemented by stack monitorinB uranium 233 may be disposed of daily, provided the appropriate for the planned and potential releases. concentration in sewage released does not exceed 9 s 10" microcurie / milliliter when diluted by the as erage
c. The survey program for evaluating alpha daily quantity of sewage. Releases to sewage of all contamination of personnel and plant surfaces radioactive materials by a licensee are limited to one should include provisions for monitoring protective curie / year and .verage monthly concentrations not clothing, hands, and feet of w orkers leaving restricted exceeding restricted area water concentrations.

areas before bre^s and at the end of shifts. Evalua-tion (alpha anaf or gamma levels) of gloves or other . Aiph, o,unic,,, tion, per minute. not counti per minute 10.3 5

, 1

/ v dn,.o e enk-Testing Pro >isions l

3. Burialin soilis another method of waste ; s- l posal.* Such burials are subject to the 4 footaudepth 1 N unwn vr>llium scaled neutron sources i 6-foot separation, and 12/ year limitations of(20.304 certain pluuium gamma sources are required ;

of 10 CFR Part 20. The quantity per burialis limited 5) 1; cense undien to be tested for leaka I to 10 microcuries for special nuclear material. tamination at Scaled sources designed as alpha sources and othef '

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.t The most commonly used method of disposal exceed 3 months.When the supplie) is transfer to a commercial firm licensed to accept that such tests ha$e been performed within the ap- '

such wastes. Lists of such firms are available propriate frominterval, the Ihe sources are not to be u Commission upon request. In dealing with such firms, prior contact is recommended to determine leak tested. The test should be capable of detecting specific services provided, the presence of 0.00$ microcurie of alpha contam tion on the test sample. The test sample should be !

$. Other methods of disposal may be consideredtaken from the source or from appropriate accessibI andjustiGed on a case by case basis. The information surfaces of the device in which the sealedl specified in (20.302 of 10 CFR for any Part 20 should permanently alternative be sub- mounted or stored where contaminl rmtted to support a request could appear if the source were defective. Recordl methods of disposal. This information should include leak-test results are required by license condition to the quantitles and kinds of materials, the leselsbeofmaintained for inspection by the Commission.

radioactivity, a description of the manner and condi-tions of disposal, an evaluation of environmental Any leaking sources must be withdr considerations, and the control procedures. should be made.

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6. The applicant should spectGeally indicate 2. If the applicant desires to perform his own  ;

how wastes will be disposed of. leak tests, the following ir! formation should be sub-mitted:

4.6.5 Record Management U""' I P ""*l

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Provision for keepmg and reviewing records of form the leak test, surveys; inventories; personnel exposures; receipt use, b. Safety' procedures to be followed during and disposal of materials; etc., should be desenbed Persons responsible for keeping and reviewing the test' ,

l records should be identified. c. Test procedures and materials or commer-cial kit to be used, and 4.6.6 Material Control Provisions

d. Type, manufacturer's name, and model Procedures fo; ordering materials, receiving materials, notify mg responsible persons upon receipt, number of the instrument to oc used for ass samples' and opening packages should be indicated. Section 20.205 of 10 C FR Part 20 requires monitoring of cer- 4.6.8 (;eneral Safety instructions tain packages upon receipt, depending on the quan-tity of radioactive material contained and its form. A copy of the general radiation safety instrue.

Packages containing less than 10 microcuries oftions to be followed by laboratory or Geld personn plutonium 100 microcuries of uranium 233,or i while mil- working with radioactive material should be licurie of uranium 235 are exempt from monitoring. submitted.

Monitoring of external surfaces is required if these 4.6.9 Emergency and Decontamination Procedures quantities are exceeded. If remo$able contamination in excess of 0 01 microcurie /100 cm is foundA on the copy of emergency procedures to be poste externalsurface of tne outer container,notincation of or work areas where radioactne all laborator'v the shipper ami the Comrmssion is required, materials are used should be submitted, These in.

Packages containing scaled sources are exempt from surface momtonng requirements as "special form." structions should describe immediate taken in case of an emergency in order to present Momtoring of external radiation levels is also re' release of radioactive material or further c quired for certain quantities- tion of work areas and personnel. Examples of emergency procedures are turning off the vent 4he Commnuun a conudenng amendments to 10 Cf R Part 20 that would prohibit the dnpout of transuramum elements b)

If adopted. the amendments systems, evacuation of the ill s, etc.The instructions area should bunal in soit punuant to (20 M4 spectfically state the names and telephone would require that si,ich wasic be transferred to the Commnuon 1er n, for corq< n won a practicadte dut mihin 5 yean responsible persons to tic notified.

generation.

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8.6.10 Procedures for Training Personnel References to presiously submitted information and i documents should be clear and specific and should  ;

A description of the training program for all per- identify the pertinent information b) date, page. and l sonnel w ho are invohed in or associated with the use paragraph of maternal should be submitted. The description i

6. RENEWAL OF A LICENSE should include the form of training (e.g., formal course work lectures. on-the-job instructions. and An ap;' uvo for renewal of a hcense should be a  !

written instructions or manuals). the duration of filed at least 30 dass prior to the espiration date. This l training, retraining pro 6isions, and the subject matter will ensure that th'c heense does not espire until final to be included action on the application has been taken by the NRC j as pr vided for in paragraph 70.33(b) of 10 CFR Part

5. AMENDMENTS TO A LICENSE 70' Licensees are required to conduct their programs in accordance with statements, representations, and Renewal applications Pould be filed in the same procedures contair'ed in the license application and mannes as the o:iginal application. appropriately  ;

supportive documents. The license must therefore supplemented and should contain complete and up- l be amended if the licensee plans to make any changes to-date information about the applicant's current I in facilities, equipment (including monitoring and program. l sursey instruments), procedures, personnel, or l special nuclear material to be used. in order to facilitate the review process. the ap-phcation for renewal should be submitted without Apphcations for license amendments may be filed reference to previously submitted documents and m- l in letter form. The application should identify ihe fo mation. If such references cannot be asoided. the> I heense by number and should clearly describe the ex- should be clear and specific and should identify the  !

act nature of the changes additions, or deletions. pertinent information by date, page, and paragraph )

I 10.4-7