ML20217P951

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Safety Evaluation Accepting Changes to License SNM-0180
ML20217P951
Person / Time
Site: 07000157
Issue date: 03/04/1998
From: Weber M
NRC COMMISSION (OCM)
To:
Shared Package
ML20217P896 List:
References
NUDOCS 9803110225
Download: ML20217P951 (5)


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, g f:t p* \" UNITED STATES j l NUCLEAR REGULATORY COMMISSION i

'f WASHINGTON, D.C. 20565-4001 March 4, 1998

! DOCKET: 70-157 l LICENSEE: University of Texas at Austin

! Austin, Texas l

SUBJECT:

SAFETY EVALUATION REPORT: RENEWAL APPLICATION DATED OCTOBER 24,1997

1. INTRODUCTION )

A. General The Nuclear Engineering Teaching Laboratory of the University of Texas at Austin (UT) uses special nuclear materials to supplement training and instruction programs in the field of nuclear -

engineering. The licensee is authorized to posses uranium dioxide impregnated in high density polyethylene as 8,10-inch diameter disks and 36,1-inch diameter disks, which comprise a subcritical assembly core. The licensee is also authorized to possess 128 grams of plutonium contained in sealed plutonium-beryllium neutron sources.

The licensee also has a research reactor, which operates under NRC Reactor License R-129, and a charged particle accelerator, which operates under a Certificate of Registration from the Texas Department of Health, Bureau of Radiation Control (License TDH LOO 485), independent of the SNM license.

B. License History Special Nuclear Material License SNM-180 was first issued to UT in 1958 and was last renewed on November 20,1992. The license renewal was for a five-year period and expired on November 30,1997. By letter dated October 24,1997, UT submitted a renewal application.

Because the application was submitted before the expiration date, the license has remained in effect under the timely renewal provisions of 10 CFR 70.38(a).

In the renewal application, the licensee indicated that it could not account for some of its special nuclear material. This was first reported on December 19,1974, when the licensee informed the NRC staff by telephone of the loss of 3 of the 36,1-inch diameter disks, which consisted of a total of 0.12 grams of 20% enriched uranium. The staff determined that the quantity and circumstances of the loss were such that no substantial hazard could result to persons in unrestricted areas and that the reporting requirements in 10 CFR 20.402(a) did not apply. This determination is documented in a memorandum dated January 24,1975, written by Richard L.

! Bangart of NRC Region IV. Since that time, the licensee has located two of the threemissing

! fuel disks.

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II. E.OSSESSION LIMITS The licensee has requested the following nuclear material for its activities:

Material Form Quantity A. Uranium enriched to A. Uranium dioxide in A. 470 grams 25U 20% in the285 U polyethylene isotope B. Plutonium B. Sealed plutonium- B.128 grams Pu beryllium neutron sources The possession limit for uranium includes the amount of rasU contained in the missing fuel disk.

Ill. AUTHORIZED USE in the license renewal application, the licensee has committed to and will be held accountable to the requirements of its license (SNM-180). Accordingly, the license renewal application is incorporated as a condition of the !icense, as follows:

9. Authorized use: For use in accordance with the statements, representations, and conditions specified in the licensee's application dated October 24,1997.

, 10. Authorized place of use: The Nuclear Engineering Laboratory facilities located at the University's J. J. Pickle Research Campus (formerly known as the Balcones Research Center).

IV. PERFORMANCE HISTORY Only one health and safety inspection has been performed since the license was last renewed in 1992. The inspection was conducted on February 23,1994. No violations were observed.

V. ORGANIZATION AND ADMINISTRATION The President of the University of Texas at Austin has established a Radiation Safety Committee (RSC) whose purpose is to define policies and practices regarding the safe use of radioisotopes and sources of radiation on the university campus. The Radiation Safety Officer (RSO)is delegated the authority by the RSC for establishing and inspecting the radiation safety program. The RSC consists of three faculty and/cr staff members from the science or engineering departments.

There is also a Reactor Committee, responsible to the Dean of the College of Engineering, with at least three members knowledgeable in nuclear safety. The Reactor Committee reviews, evaluates, and approves standards associated with the operation of the laboratory, including all nuclear operations. The RSO is a member of the Reactor Committee.

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Thelaboratory operation is under the direct control of the Laboratory Supervisor or a licensed Senior Operator designated by the Laboratory Supervisor. Laboratory staff includes the reactor operator, health physicist, and, as needed, research associates and technicians.

The responsibilities of the Laboratory Supervisor include direction of the daily activities of the laboratory, which involves use of the reactor, as well as the subcritical assembly licensed under Materials License SNM-180. The responsibilities of the Laboratory Supervisor also include maintenance of equipment records, review of experiments and procedures, and supervising the use of radioactive materials and sources.

1 The licensee's renewal application demonstrated that there is adequate technical staff with j appropriate qualifications to administer an effective radiological safety program. The following j sections contain a description of the licensee's relevant organization and radiological safety i program, along with additional conditions developed by the staff.

VI. RADIATION PROTECTION 1

The licensee provided a description of the radiation protection program at the facility to meet the requirements of 10 CFR Part 20, including personnel monitoring and training practices, commitments for leak-testing sources, commitments for maintair ,ng doses as low as reasonably ,

achievable (ALARA), and waste disposal practices.

l A. Personnel Exposure Control Personnel exposure is controlled through the use of area or portable radiation monitors to  ;

assess gamma and neutron levels during operation of the suberitical assembly. In addition, personnel monitoring devices are required for all persons working with radiation sources and for all visitors to the laboratory areas. Personnel external exposure is controlled and evaluated on the basis of data from the personnel dosimeters.

B. Training Program The subcritical assembly is used to teach basic concepts to undergraduate and graduate students during laboratory exercises. Each student rewives training in radiation hazards, dose measurements, and laboratory procedures, and the experiments are performed under supervision of laboratory staff. Staff personnel are trained to handle materials through a combination of formal classroom instruction and laboratory training.

Although the licensee indicated that experiments are performed under the supervision of trained personnel, the licensee also indicated that the SNM may be handled and transferred at times other than during experiments. To ensure that licensed SNM is always handled under the supervision of or by an individual who has successfully completed the necessary training, the staff imposes the following license condition:

11. Prior to working with or handling licensed nuclear material, all personnel shall receive training or shall be under the supervision of persons who have received training in the formal radiation safety program.

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  • . 1 C. Containment Control '

The eight,10-inch diameter disks comprising the suberitical assembly core are enclosed in a polyethylene jacket. Since 1960, swipe tests have shown no measurable leakage of activity.

Thus, the core is handled by hand. Axial and radial holes in the subcritical assembly may be filled with 36 smaller fuel disks of about 1-inch diameter. The small disks are not encapsulated j in polyethylene, so gloves are used in handling the smaller disks to protect against possible  !

contamination. Personnel are also required to survey hands for contamination after this activity.

In the renewal application, the licensee has committed to leak tests of the sealed Pu-Be neutron sources every 6 months.

D. As Low As Reasonable Achievable (ALARA) Commitment The licensee has committed to maintaining doses ALARA. Both occasional and periodic review of the radiation doses to staff, students, and visitors is carried out by laboratory staff and the Radiation Safety Office. A review of significant deviations from expected values will be reviewed by the Radiation Safety Committee or the Reactor Committee. A review of typical dose measurements from operation of the assembly, which were provided by the licensee in the renewal application, indicates a minimal exposure potential.

Because the licensee did not specify a schedule for review of radiation dose data, the staff imposes the following license condition:

12. The licensee shall review radiation dose data at least annually to ensure that doses are maintained ALARA and shall report the findings of the assessment to the Radiation i Safety Committee or the Reactor Committee. l E. Waste Disposal Sources of radioactive waste from operation of the subcritical assembly are slightly contaminated gloves originating from contact with the small polyethylene impregnated fuel elements and activation products generated in the assembly. Provisions exist for temporary storage and disposal of low-level radioactive waste materials such as gloves and rags. This duty is held by the Radiation Safety Office. In general, radionuclides found in contamination on  ;

or activity products in foils or materials irradiated in the assembly have a short half-life and are  ;

thus not disposed. Instead, the foils and other irradiated materials are stored for decay and then l reused in subsequent experiments.

Vll. HUCLEAR CRITICALITY SAFETY Experiments have been conducted with the suberitical reactor assembly and neutron sources (Eichenbaum, F.D., Final Physics Report-University of Texas Subcritical Reactor.

Lockheed-Nuclear Products, NR 57, March 1959.) which show a multiplication factor (MF) of less than 7.5 for all reflector and fuel conditions, including proximity to the research reactor.

Using the formula, k-effective = (1 -1/MF), this corresponds to a k-effective of 0.87 which means that the fuel is insufficient to achieve accidental criticality. Therefore, the licensee shall continue

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to be' exempted from the criticality monitoring system requirements in 10 CFR 70.24.

Accordingly, the following condition is incorporated into the license:

13. . The licensee is exempted from the requirements of 10 CFR 70.24 insofar as this section applies to the materials covered by this license.

Vill. DECOMMISSIONING Pursuant to 10 CFR 70.25(c)(2), the licensee provided a decommissioning cost estimate and a Statement of Intent that $20,000 would be available at the time of decommissioning by letters l dated November 14 and December 11,1990. This certification was approved by the NRC staff

. by letter dated January 9,1991.

r The 1990 cost estimate was reviewed by the staff to determine if the Statement of intent should l be revised to reflect any significant increases in decommissioning costs. The staff determined that the certification amount is sufficient to cover current, estimated costs associated with disposal of the subcritical assembly. Costs to perform the final status survey and sny necessary ,

remediation may exceed this amount. However, the licensee also has a Statement of Intent in  !

l- the amount of $2.5 million for decommissioning of the reactor, which was approved by the NRC l by' letter dated December 16,1991. Since the suberitical assembly is stored and operated in the .

i reactor facility, decontamination and final status surveys will not be necessary until the reactor is decommissioned. Funding for these final decommissioning activities will be available under the reactor license. Therefore, the staff determined that the original decommissioning funding edimate for the subcritical assembly is adequate.

IX. ENVIRONMENTAL REVIEW l =

l The staff has determined that the proposed activities do not adversely affect public health and safety or the environment because the activities involve the use of radioactive materials for research and development or for educational purposes. Such activities are categorically excluded from the requirement to prepare a site-specific environmental assessment. Therefore, in accordance with 10 CFR 51.22(c)(14)(v), neither an environmental assessment nor an

- environmental impact statement is warranted for this action.

X. CONCLUSION Upon completion of the safety review of the licensee's application and compliance history, the staff concludes that renewal of the license as conditioned will not adversely affect human health  ;

and safety or the environment.

The Region IV Inspection staff has no objections to this licensing action.

Principal Contributors g% '

Susan Chotoo Harry Felsher - p

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Michael Lamastra

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