ML22091A298

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Idaho State Univ., Response to Request for Additional Information Regarding Renewal of Special Nuclear Materials License 1373
ML22091A298
Person / Time
Site: 07001374
Issue date: 03/24/2022
From: Lybecker D
Idaho State University
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML22091A298 (39)


Text

Idaho State University

24 March 2022

Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject : RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING RENEWAL OF SPECIAL NUCLEAR MATERIALS LICENSE 1373 (Docket 07001374)

License SNM-1373, Docket 07001374

Director, Office of Nuclear Material Safety and Safeguards, The enclosed information is in response to the correspondence dated March 18, 2022 requesting additional information for our submittal (dated February 7, 2021, ADAMS Accession No. 22033A443) regarding ISU 's license renewal application for ISU License SNM-1373. The request is for renewal for a period of ten years in accordance with 10 CFR 70. 22.

The attached renewal application addresses the requests for additional information received, including the issues identified with the public and non -public versions of the LRA. Overall, the renewal application specifies the planned uses of the special nuclear material and measures that will be conducted to ensure safety during use and security for the material. The application addresses all items required in 10 CFR 70. 22.

In addition to the license application, we have sent to you our updated Physical Security Plan (revision 8), which is referenced in the license application.

We thank you in advance for your consideration of the requested license renewal. If you have any questions or require any more information, please contact me at donnalybecker@isu.edu, Dr. Mary Lou Dunzik -Gougar at mldg@isu.edu, or Mr. Mason Jaussi masonjaussi@isu.edu.

Respectfully submitted, D~~

Acting Vice President for Research

Cc:

Osiris Siurano - Perez, Project Manager (Osiris.Siurano-Perez@nrc.gov )

Jonathan Rowlegy (Jonathan.Rowley@nrc.gov )

Mary Lou Dunzik-Gougar ( mldg@isu.edu )

Jonathan Scott ( jonathanscott@isu.edu )

Mason Jaussi ( masonjaussi@isu.edu )

Office for Research 921 Sou th 8th Ave, Stop 8130 I Poca tello, ID 83209-8130 I (208) 282-2592 I isu.edu/research Application for License Renewal Materials License No. SNM-1373 March 25, 2022 License Re-Application - Idaho State University, Pocatello ID 83209

Table of Contents

1. Introduction.................................................................................................................... 4
2. Information about the Applicant [ref. 10 CFR 70.22(a)(1}]............................................... 4
3. Location of Material and Activity for Which It Will Be Used [ref. 10 CFR 70.22(a)(2)]....... 5 3.1. General use plan for the requested SNM............................................................................. 5

3.2. The place in which the activity is to be..e,erformed............................................................... 6 3.2.1. The Counting and Radiation Lab.i!!,oom.......................................................................................... 7 3.2.2. The Nuclear Reactor Lab (Room ************** *** *** **** ***** ** * ***** *................................................................ 7

4. Period of Time for License [ref. 10 CFR 70.22(a)(3)].......................................................... 7
5. Specification of the Special Nuclear Material [ref. 10 CFR 70.22(a)(4)]............................. 8

5.1. Uranium-aluminum fuel plates............................................................................................ 8 5.2. Fission counter and uranium-aluminum foils....................................................................... 8

6. Technical Qualifications of the Applicant and Staff [ref. 10 CFR 70.22(a)(6)].................... 9 6.1. Reactor Safety Committee................................................................................................... 9
7. Equipment and Facilities to Protect Health and Minimize Danger to Life and Property

[ref. 10 CFR 70.22(a}(7}]........................................................................................................ 10

7.1. Equipment and Facilities.................................................................................................... 10 7.2. Working area..................................................................................................................... 11 7.3. Measuring and monitoring instruments............................................................................. 11

7.4. Storage facilities and security measures............................................................................ 12 7.5. Criticality Alarm System..................................................................................................... 12 7.6. Water handling system...................................................................................................... 12

8. Proposed Procedural Requirements to Protect Health and Minimize Danger to Life and Property [ref. 10 CFR 70.22(a)(B)].......................................................................................... 13

8.1. Administrative controls..................................................................................................... 13

8.2. Radiation Hazard............................................................................................................... 14

ISU College of Engineering, March 25, 2022 Page 1 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 8.2. 1. Control of Areas................................................................................................................................... 15 8.2.2. Personnel monitoring.......................................................................................................................... 15 8.2.3. Material Handling................................................................................................................................ 15 8.2.4. Radiation monitoring........................................................................................................................... 15 8.2.5. Leak tests............................................................................................................................................. 16 8.2.6 Surveys................................................................................................................................................ 16 8.2.7 Train ing................................................................................................................................................ 16 8.3 Radioactive Waste............................................................................................................. 16

8.4 Radiation Safety Records.*******************************:****************************************************************** 17 8.5. Fire Hazard........................................................................................................................ 17 8.6. Inadvertent Criticality........................................................................................................ 18

9. Material Control and Accountability [ref. 10 CFR 70.22(b)]............................................ 21 9.1. Material Inventory & Transfer........................................................................................... 21
10. Transportation Security [ref. 10 CFR 70.22(g)(l)}..........................................*................ 21
11. Emergency Plan [ref. 10 CFR 70.22 (i)(l)(ii)]................................................................... 22
12. Physical Security Plan [ref. 10 CFR 70.22(k)].................................................................. 22
13. Criticality Accident Requirements [ref. 10 CFR 70.24)..................................................... 22 13.1. Criticality alarm................................................................................................................. 22 13.2. Emergency evacuation procedure...................................................................................... 22
14. Financial Assurance for Decommissioning [ref. 10 CFR 70.25}........................................ 23
15. Environmental Protection.............................................................................................. 24 15.1. Air Effluents....................................................................................................................... 24 15.2. liquid Effluents.................................................................................................................. 25 15.3. Radioactive Waste............................................................................................................. 25 15.4. Impact from Accidents....................................................................................................... 25
16. Chemical Safety............................................................................................................ 25
17. Attachment I: Idaho State University Roster of Officials.................................................. l
18. Attachment II: Drawings and Images of the Subcritical Facility.................... *................... l
19. Attachment Ill: Specifications of Uranium-Aluminum Fuel Plates, Uranium-Aluminum Foils, and Fission Counter........................................................................................................ l
20. Attachment IV: Qualifications of University Personnel................. *................................... l

ISU College of Science and Engineering, March 25, 2022 Pa ge 2 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

Table of Figures Figure 1: Campus Map - LEL is building #7 and Campus Security is #27.................................. 26 Figure 2: Basement of Lillibridge Engineering Building...................................*...................... 27 Figure 3: First Floor of Lillibridge Engineering Building.......................................................... 28

ISU College of Science and Engineering, March 25, 2022 Page 3 of 2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

1. Introduction

Th is application documents Idaho State University's request to renew SNM license 13 7 3 for a period of ten years. It provides information required in 10 CFR 70 Subpart D and add resses the review topics of NUREG-1520, Revision 2.

2. Information about the Applicant [ref. 10 CFR 70.22(a)(l)]

Name : Idaho State Un iversity Address: 921 S. 8th Avenue, Pocatello, ID 83209 Description of Business or Occupation : Institution of Higher Learn ing

The Idaho State University {ISU) is operated by the State of Idaho with its principal office at Pocatello, Idaho. The Idaho State Board of Education provides oversight and direction of the higher education institutions in Idaho and is located in Bo ise, Idaho, (P.O. Box 83720 - 0037).

Positions in the Roster of Officials

President of the University

Vice President for Research

Chairperson of the Reactor Safety Committee

Radiation Safety Officer

Chair of the Department of Nuclear Engineering

Reactor Administrator

Reactor Supervisor

The current President of the Un iversity has designated the V ice President of Research as the un iversity official who has overall responsibility for this license. A roster of current university officials with complete contact information is provided in Attachment (I). The info rmation given in this attachment may be subject to change due to personnel reassignments. Such changes w ill require that only the information in Attachment (I) be updated as necessary by no tification of

ISU College of Science and Engineering, March 25, 2022 Page 4 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 NRC. There is no control or ownership exercised over the application by any alien, foreign corporation, or foreign government.

3. Location of Material and Activity for Which It Will Be Used [ref. 10 CFR 70.22(a)(2)]

The Special Nuclear Material {SNM) in this license is used for education, research, and training programs. This license re-application specifies the same total mass of of U-235 rounded up to the nearest gram as was specified in the previous license: of U-235 are contained in uranium-aluminum fuel plates and the remaining U-235 is contained in a fission counter and in uranium-aluminum foils.

3.1. General use plan for the requested SNM

The SNM is used primarily for instructional purposes in senior and graduate-level laboratory courses. The fuel plates are used primarily to create a subcritical assembly {SCA) in which they are loaded in various lattice arrangements in a water-filled tank. The fuel plates may be used singly for a quasi - homogeneous assembly or in groups of two or more to produce a more homogeneous configuration.

Some of the experiments to be carried out with the subcritical assembly are:

Approach to critical Flux distribution measurements Exponential pile measurements Fermi age determination Determination of optimal cell dimensions of a heterogeneous subcritical assembly Effect of fuel-plate thickness on multiplication factor

The uranium-aluminum foils may be used as neutron monitors in some experiments performed with ISU's AGN-201 nuclear reactor. The uranium-aluminum foils have too small a U-235 content to be usefully activated in the subcritical assembly.

In addition, research programs utilizing the materials will be encouraged. For example, fuel plates and uranium-aluminum foils may be used as sources of fissile material for research and development of advanced methods for nondestructive assays and evaluation {NDA/NDE) of fissile material content in various configurations. The uranium-aluminum foils would be used to monitor neutron flux levels, and the fuel plates would be used to represent fissile material in

ISU College of Science and Engineering, March 25, 2022 Page 5 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 various shipping arrangements to investigate effectiveness of NDA/NDE interrogation techniques.

All experiment procedures are reviewed by the Reactor Safety Committee prior to execution.

No experiments or activity involving the use of the SNM will be performed without the prior approval of the Reactor Administrator or Reactor Supervisor.

3.2. The place in which the activity is to be perfo rmed

The SNM will be used exclusively in the Lillibridge Engineering Building {LEL). The Nuclear Engineering Laboratories are in the basement of the Lillibridge Engineering Laboratory Building.

This facility has approximately 30,000 square feet, on three floors {including the below ground level basement). Exterior wall construction is all brick. Floors, on all three levels, are reinforced concrete.

The SNM will be stored, and used, primarily in Room {The Subcritical Assembly Facility),

approximately 400 sq. ft. in area, in the basement of the Lillibridge Engineering Laboratory building at Idaho State University.

standpipe system for the build ing. However, water pressure in the municipal system for Pocatello is maintained by large storage tanks at an elevation of approximately 150 to 200 feet above the level of the LEL building. Fire hydrants are on campus for use by the Pocatello Fire Department, the nearest dispatch station being approximately 0.5 miles away.

A map of the ISU campus showing the location of the LEL building is shown in Figure 1 : Campus Map - LEL is building #7 and Campus Security is #27. The LEL basement floor is shown in Figure 2. Room is 20-feet by 20-feet s uare with a 12-foot ceilin. The floor is 40-inch-thick reinforced concrete slab.

The floor will safely accommodate the weight of the entire SCA. Room 23 is a controlled access area {CAA).

ISU College of Science and Engineering, March 25, 2022 Page 6 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 The material will be stored in a locked steel storage container in Room when not in use. On the occasion when the fuel is being used in the SCA tank, procedures allow fuel plates to remain in the assembly tank (aluminum construction, 36-inch diameter, 36 - inch depth). When stored unattended in this tank, the fuel is secured with a locked aluminum lid on the top.

Small amounts of the SNM, consisting of up to of the U-AI foils and/or up to of the fuel plates may be transported to locations adjacent to Room for temporary one -day use.

These alternate locations artlFigure I The Counting and Radiation Lab (Room and The Nuclear Reactor Lab (Room

  • During such one - day use, the material will be continuously in the custody of an authorized custodian, one of the Nuclear Engineering Department personnel with T&R status. These personnel include the Reactor Administrator, Reactor Supervisor, Nuclear Engineer ing Department Chair, or a trained SCA operator.

The material will not be stored overnight at the alternate locations but will be returned at the end of each day to the CAA, Room for overnight storage in the locked steel container.

3.2.1. The Co unting and Radiation La b (Room 22)

the room contains a small concrete vault where radioactive material is stored. This area is separately locked and controlled from the main room and will not be used to permanently store SNM on this license. The floor layout for the Lillibridge Engineering Building, including room 22, can be found in Figure 2.

3. 2.2. Th e Nuclear Rea c tor Lab (Ro o m._

A description of the Nuclear Reactor Lab {RoomJI can be found in the ISU AGN - 201m Safety Analysis Report Section 3.2.1 located in ADAMS Accession number ML030350328.

4. Period of Time for License [ref. 10 CFR 70.22(a)l3)]

This license is requested for a period of ten (10) years, from the starting date of August 2021. It is expected that a request for renewal will be submitted at the end of that period.

ISU College of Science and Engineering, March 25, 2022 Page 7 of2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

5. Specification of the Special Nuclear Material [ref. 10 CFR 70.22(a)(4)]

5. 1. Uranium-aluminum fuel plates The sealed source fuel plates were fabricated in 1960 by M&C Nuclear, Inc., for Rutgers University, New Brunswick, New Jersey. Each plate consists of a uranium-aluminum (metal alloy) fuel zone completely enclosed by an aluminum clad. The manufacturer's specifications for the plates are as follows :

Total number of plates Total mass of uranium Enrichment of U - 235 Total U-235 content U-235 loading per plate Overall dimensions of plate Dimensions of uranium bearing portion of the plate Cladding thickness

5.2. Fission counter and uranium-aluminum foils Fission counter The fission counter has an active length of 1.0" with an active diameter of 0.20 ".

The counter contains of uranium-235-sealed into one end of a stainless-steel tube 40" long and 0.25" in diameter.

Uranium-235 mass U - 235 enrichment

Uranium-aluminum foils The sealed source uranium -aluminum foils consist of a very small amount of uranium, highly enriched in the uranium-235 isotope, deposited in the center of an aluminum disk. A second aluminum disk is then placed on top and the outside contact area of the disks not containing uranium is sealed. Thus, the foils are each a sealed source containing a small amount of uranium-235.

Total number of foils Uranium-235 mass U-235 enrichment

5.3. Neutron Source (either Pu-Be, Cf-252, Am-Be, or equivalent approved by the Reactor Safety Committee or Radiation Safety Committee) authorized under the ISU Broad Scope NRC License #11-27380-01.

ISU College of Science and Engineering, March 25, 2022 Page 8 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

Specifications for the fuel plates, fission counter, and uranium-aluminum foils were taken from the manufacturing report (Attachment Ill.)

6. Technical Qualifications of the Applicant and Staff [ref. 10 CFR 70.22(a)(6}]

Responsibility for the oversight, supervision, and operation of licensed activities will reside with the Responsible University Officer, Nuclear Engineering Department Chair, Reactor Safety Committee Chairperson, Reactor Administrator, Reactor Supervisor, and the ISU Radiation Safety Officer. Minimum qualifications of these positions are listed in Attachment (IV).

A roster of officials containing information for the current president of the university, vice president of research, chairperson of the reactor safety committee, the reactor administrator, the reactor supervisor, and the radiation safety officer who have responsibility for the oversight, supervision and operation of the uranium are included in Attachment (I). The individuals listed in Attachment (I) have previously been approved by the NRC or the request for review will be included with this license submission. Their CVs are also included with this license submission as separate documents. CVs for new members will be submitted as new people fill these positions.

6.1. Reactor Safety Committee The Reactor Safety Committee is one of Idaho State University's regularly constituted committees. Appointments to the committee are made by the Vice President for Research.

The Reactor Safety Committee shall be comprised of at least five members knowledgeable in fields that relate to nuclear reactor safety, radiation safety, and radioactive material safety. The committee shall consist of the Chair, the Reactor Administrator (ex-officio), the Radiation Safety Officer (ex-officio), the Vice President for Research and at least two other members. The operating staff shall not comprise the majority of the members. The Reactor Administrator, Reactor Supervisor, and licensed reactor and senior reactor operators are considered operating staff.

The Reactor Safety Committee will review new procedures, substantial changes to procedures, and facility changes based on their broad technical knowledge and focus on safety of ISU personnel and the public during these reviews. In addition, the Reactor Safety Committee can consult experts at Idaho State University or at outside institutions if they have additional questions or concerns that aren't covered by the expertise of the members. For chemical safety issues, the reactor administrator will coordinate review with the ISU Environmental Safety and Health Department in accordance with Section 16.

ISU College of Science and Engineering, March 25, 2022 Page 9 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

7. Equipment and Facilities to Protect Health and Minimize Danger to Life and Property [ref. 10 CFR 70.22(a)(7)]

7.1. Equipment and Facilities

The subcritical facility at Idaho State University was originally designed by and placed in use at Rutgers University in New Jersey in the mid-1950s. It was declared surplus by Rutgers University about 1975 and purchased by and moved to Idaho State University, Pocatello, Idaho.

The subcritical assembly (SCA) tank is made of aluminum, 1/4 inch thick side wall, with a 3/8-inch-thick base that is welded to the 36-inch diameter cylindrical side wall. A 3/8-inch-thick aluminum lid fits on the top of the tank and can be secured by padlocks. The tank is 39 inches high and sits on the base consisting of the stack of graphite blocks, 32 inches in height. The blocks contain some removable pieces that slide out, permitting the insertion of neutron flux monitoring foils.

Inside the tank fits a removable and nearly cubical lattice grid (Figure 11-1 in Attachment II), 23 inches on a side. The lattice contains slots for the fuel plates, the slotted portion of the grid being 18 inches by 15 inches. Spacing between the fuel slots is 0. 718 inches center-to-center. The slots are thick (wide) enough to accommodate up to three fuel plates stacked against each other.

The fuel plates, numbering identical plates, are each-inches thick, inches wide, and ~ches. The fuel be~region is an aluminum-uranium cermet, -

inches wide,lllinches long and-inches thick. The cladding is-inches thick aluminum, on both sides of the fueled region. Figure 11-2 (Attachment II) shows the structure of the fuel plates.

The total amount of uranium in the plates is enriched to-uranium U-235 totaling There is a special source holder having the same outer dimensions as the fuel plates, except that it has a-diameter source tube inserted longitudinally at the center of the would-be fuel region.

Filling of the water tank is accomplished from a pump that takes the water from the storage tank and pumps it into the assembly tank. A normally closed solenoid valve in a separate drain line blocks the water from draining from the assembly tank. The controls ISU College of Science and Engineering, March 25, 2022 Page 10 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 for the pump and the solenoid are operated from a control console adjacent to the subcritical assembly tank. The wiring diagram for the controls, including the " criticality alarm" (merely an alarm-equipped Geiger-Mueller detector), is shown in Figure 11-3 (Appendix II). The piping diagram is shown in Figure 11-4 (Attachment II). Five float switches are located inside the assembly tank to measure the water level in the tank.

7.2. Working area

See section 3: "Location of Material and Activity for Which It Will Be Used [ref. 10 CFR 70.22{a)(2)]"

7.3. Measu ring and mon itoring instruments

Beta, gamma, and neutron dosimeters provided by an NVLAP {National Voluntary Laboratory Accreditation Program) certified vendor are issued to staff working with the special nuclear material. Students and visitors will use pen dosimeters or equivalent while handling fuel plates or working around the SCA.

The following hand - held survey instruments will be used:

GM Pancake-Type Detector {ludlum3/44-9 or equivalent)

Zinc Sulfide based Alpha Contamination Detector Ion Chamber with Beta and Gamma Window (Ludlum 9 or equivalent)

Neutron Dose Rate Meter (Ludlum 12-4 or equivalent)

A Ludlum 300 or equivalent gamma radiation monitor serves as a criticality safety alarm for the sub -critical assembly and the readout from the monitor is observable from the SCA control panel. The gamma monitor system will provide direct radiation readings during experiments and subsequent post-irradiation decay of short-lived fission products and induced activity.

In addition, to the instruments described above, the radiation safety department operates laboratory instruments (a liquid scintillation counter and a gas flow proportional counter) to support surveys involving special nuclear material.

All radiation detection instruments used in connection with this license shall be calibrated by the ISU Radiation Safety Office or qualified vendors in accordance with the ISU Radiation Safety Manual.

ISU College of Science and Engineering, March 25, 2022 Page 11 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 Beta/gamma and neutron dose rate survey instruments will be available to personnel to determine radiation fields during and following experimental operations. In addition, contamination survey instruments are available to ensure no rad ioactive mate rial has been released during sub -critical assembly experiments. The types of instruments available to personnel a re described above.

7.4. Storag e fa c ilities an d sec ur ity measure s

(This information is provided in the ISU AGN - 201m Docket No. 50-284, Physical Security Plan, Section 5.)

7.5. Criticality Alarm System

This information is discussed in Section 8.6, "Inadvertent Criticality".

7.6. Water handling system

At the beginning of each experiment deionized water will be pumped from the storage tank to fill the assembly tank. At the end of each experiment the water will be drained out of the assembly tank and into the storage tank through a drain line near the bottom of the tank. An alternative experimental approach would be to pump the water into the tank after the SNM material is loaded with the desired SCA lattice. As the water level increases, the neutron multiplication (kett) can be measured as a function of moderator height.

A schematic diagram of the water handling system is provided in Figure 11-4 of Attachment (II). The drainpipe w ill be opened and closed by a " normally opened" solenoid valve. In the event of a power failure, the pump will shut off and the drain valve will open so that any water in the tank will necessarily drain out of the assembly tank. Without water act ing as moderator the neutron multiplication factor of the assembly will be extremely small. Power feeding the solenoid drain valve and the pump will first go through a double-pole normally-open solenoid switch. This switch will be held open if a signal is generated by the criticality alarm. In the event of an inadvertent criticality (an extremely improbable event) indicated by a radiation alarm on the criticality detector(~ 10 mrem/hr), power to the pump and the solenoid drain valve w ill be automatically cut off, causing water to drain out of the assembly tank. Further, the solenoid switch will be wired in such a manner than any attempt to disconnect the solenoid sw itch from the criticality alarm will result in loss of power to both the pump

ISU College of Science and Engineering, March 25, 2022 Page 12 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 and the solenoid drain valve. The w iring diagram for this installation is shown in Figure 11 -5 in Attachment (II).

8. Proposed Procedural Requirements to Protect Health and Minimize Danger to Life and Property [ref. 10 CFR 70.22(a)(8)]

8.1. Admin istrative con trols

The Reactor Administrator is responsible for the safe storage and use of the special nuclear material. The Reactor Safety Committee (RSC) has reviewed and approved plans, new procedures, and substantial changes to procedures for the usage of the material in the SCA. The Reactor Safety Committee shall review and approve all new experimental plans and procedures for the use of the licensed material prior to

  • implementation. The Reactor Safety Committee shall review and approve all changes to existing experimental plans and procedures that may affect safety. The RSC was formed at the request of the NRC in 1968 to review and approve experimental procedures performed in the ISU AGN - 201 reactor (License R-110, Docket No. 50-284). The Radiation Safety Officer shall review radiation dose data annually to ensure that doses are maintained ALARA and shall report the findings of the assessment to the Reactor Safety Committee.

There must be a minimum of two persons who have been trained to the Subcritical Assembly Procedure of Idaho State University, at least one person must have current Trustworthy & Reliability {T&R) status, in Room whenever operations involving special nuclear material in the subcritical assembly are in progress. T&R status is defined in and assigned per ISU Administrative Procedure 2. Access to Room will be controlled by key card access maintained by ISU Public Safety. Only the Reactor Administrator or their designee have access to add individuals to the key card access list.

Access will be granted as follows :

The Reactor Administrator, Reactor Supervisor, Radiation Safety Officer, and Reactor Safety Committee members will all be granted access upon assumption of the position. Other personnel, authorized by the Reactor Administrator and who have been granted T&R status, may be granted access to Room as needed. The Reactor Administrator and the Reactor supervisor will control keys to the locks securing the fuel storage container and the assembly access cover.

The Reactor Administrator and the Reactor Supervisor will control keys to the override locks that can bypass the electron ic magnetic lock. These keys may be used in case of emergency.

ISU College of Science and Engineering, March 25, 2022 Page 13 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

Prior to working or handling licensed nuclear material, all personnel shall have received training or shall be under the supervision of persons who have received training in operating the Subcritical Assembly from the Reactor Supervisor or their designee.

Statement of qualifications for personnel responsible for the use of the special nuclear materials under this license are discussed in section 6, "Technical Qualifications of the Applicant and Staff [ref. 10 CFR 70.22(a)(6)] ".

8.2. Radia tion Haz ard

ISU maintains a comprehensive radiation safety program documented in the Radiation Safety Manual and directed by the Radiation Safety Committee and Reactor Safety Comm ittee. The program is implemented by the Radiation Safety Department managed by the RSO. The Radiation Safety Department includes professional radiation safety staff members and technicians.

Applicable chapters in the Radiation Safety Manual include the following 2 Radiation Safety Commitment 3 Safety Conscious Work Environment 4 Organizational Structure and Authority 5 Roles and Responsibilities (Management, Radiat ion Safety Committee,

Reactor Safety Committee, RSO) 6 ALARA Policy and Dose Limits 8 Radiation Safety Training 9 Radioactive Material Requirements (Shipment, receipt, inventory, labeling, leak tests) 10 Control of Areas and Postings 11 Control of Contamination 12 Surveys 13 Safe Work Practices (PPE, hygiene, engineering controls, shielding) 14 Radiation Safety Program Audits 15 Dose Measurement and Reporting (external dosimetry and internal dosimetry) 16 Radiation Monitoring Equipment 17 Radioactive Waste Management 18 Decommissioning of Laboratories and Facilities 20 Emergency Preparedness and Response 21 Radiation Safety Records

ISU College of Science and Engineering, March 25, 2022 Page 14 o f 2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

Radiation protection measures specific to operat ion of the sub -cr itical assembly are discussed below.

8.2.1. Control of Areas The use areas for materials are managed as restricted areas and radiation use areas {materials) in accordance with the Radiation Safety Manual. All areas are posted Caution Radioactive Material and Authorized Personnel Only. Step off pads are not utilized because no dispersible mate rials are handled in SCA operations.

8.2.2. Personn e l monitorin g Reactor personnel {reactor operators, certified observers, the reactor administrator, the reactor supervisor, graduate research and teaching assistants, and faculty) wear dosimete rs that measure beta, gamma, and neutron dose from a NVLAP certified vendor. Over the past five years, no reactor personnel have received whole body dose greater than the limit for members of the public, 100 mrem in a year. Therefore, visitors and laboratory students are monitored with direct reading dosimeters or equivalent.

All personnel frisk gloves and hands after handl ing SCA fue l p lates.

8.2.3. Materia l Ha n dling Dose rates from SCA fuel plates are minimal because of the low amount of fission produced.

Therefore, personnel may directly handle the fuel plates. When handl ing fuel plates and fission foils, all personnel wear disposable gloves to protect the material and the workers if there is an unexpected leakage of radioactive material.

8.2.4. Radiatio n monitori n g Radiation levels {gamma and neutron) from the subcritical assembly are monitored as specified in the Subcritical Assembly Procedure after each fuel addition. If the combined dose rate (gamma and neutron) exceeds 2 mrem/hr at 30 cm, visitors and laboratory students a re removed from the area. If the combined dose rate at 30 cm exceeds 5 mrem/hr, water is drained from the tank. Each time the fuel assembly is lifted from the water, the gamma exposure is measured and recorded.

Finally, a gamma radiation monitor {Ludlum 300 or equivalent) serves as a c riticality monitor and is located on the wall approximately five feet from the subcrit ical assembl y.

If the detector measures an exposure rate of 10 mR/hr, the system will automatically drain the water from the system.

ISU College of Science and Engineering, March 25, 2022 Page 15 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 8.2.5. Leak tests Ten percent (10%) of the fuel plates will be leak tested using standard swipes for alpha contamination following each experiment and during one of the bi-annual material inventories. In the second bi-annual inventory, 100 % of the fuel plates are leak tested.

Leak tests following individual experiments will be performed when fuel is returned to the storage cabinet at the end of the experiment.

Ten percent (10%) of the uranium-aluminum foils will be leak tested in conjunction with the fuel plates following use and during one of the bi-annual material inventories. In the second bi-annual inventory, 100 % of the foils are leak tested. Leak tests will not be performed if the foils are stored in a sealed container with a tamper indicating device.

8.2.6. Surveys A general area radiation survey and contamination survey will be performed after each experiment. In addition, a bi-annual confirmatory survey including a general contamination survey and radiation survey will be performed in Room by the Radiation Safety Department in accordance with the Radiation Safety Manual.

Water samples will be analyzed for gross activity following each experiment series to detect possible damage to or defects in the fuel plates. Water samples will be analyzed by the Radiation Safety Department using a liquid scintillation counter. Action levels shall be defined by an H-3 activity greater than 20000 pico -curies per liter, the Environmental Protection Agency, Maximum Contaminant Level (40 CFR 141.66(d). If the H-3 concentration exceeds 20000 pCi/L or if positive radioactivity is detected at energy above that of tritium, the RSO will be notified.

8.2.7. Training All reactor personnel who operate the sub-critical assembly complete initial ISU radiation safety training and, if necessary, annual refresher training in accordance with Chapter 8 of the Radiation Safety Manual and 10 CFR 19.12. ISU Laboratory students who participate in SCA experiments also receive ISU radiation safety training. For visiting students from DOE or other facilities, ISU will accept current comparable radiation safety training (e.g., DOE radiological worker training) in place of ISU radiation safety training. Additional training regarding ISU specific information may be given in accordance with the Radiation Safety Manual.

8.3. Radio active Waste All of the radioactive materials used in association with the sub-critical assembly are solid or sealed materials and are not dispersible. Therefore, radioactive waste is not expected. Any radioactive waste that is generated will be managed in accordance with ISU College of Science and Engineering, March 25, 2022 Page 16 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 Chapter 17 of the Radiation Safety Manual which implements the requirements of 10 CFR 20 Subpart K. Waste may be decayed in storage, disposed by discharge into the sanitary sewer, or disposed by transfer to a licensed waste management facility depending on specific characteristics of the waste. All discharges to the sanitary sewer system will comply with the requirements of the City of Pocatello discharge permit in addition to NRC regulations in 10 CFR 20.

8.4. Radiation Safety Records Radiation safety records are maintained in accordance with Chapter 21 of the Radiation Safety Manual. This chapter addresses storage of worker dose records, survey records, audits, program reviews, internal dose measurements, procedures and other radiation safety records. Current external dose records are maintained in the NVLAP dosimetry vendor database. All other records are maintained in the ISU Box cloud storage application.

Material Control and Accountability records are developed annually through the physical inventory of special nuclear material following the RS-28, "Special Nuclear Material Physical Inventory" procedure. ISU maintains records of all MC&A activities including records of receipts, transfers, NMMSS changes, physical inventories, and annual material status reports. Specific records are listed below.

  • 741 forms for receipt and transfer of SNM and for corrections or changes to NMMSS data.
  • 740M concise note forms.
  • 742 and 742C forms for the annual summary report.
  • Annual physical inventory records from procedure RS-28, SNM Physical Inventory (annual report, sealed item inventory forms, unsealed item inventory forms, SNM container forms, container verification forms, and balance verification forms).

These records are stored electronically on ISU's cloud storage server. These records are maintained and retained in accordance with the requirements of 10 CFR 74.19.

8.5. Fire Ha zard

No materials or chemicals will be stored in Room that could present a fire hazard.

Normal fire rules will be observed. There is a dry-chemical, "ABC"-class fire extinguisher located next to the door of Room Two other fire extinguishers are located nearby in the Nuclear Engineering Laboratory section of the basement of the LEL. A heat - rise sensor is located in the ceiling in Room above the assembly tank. Activation of the sensor by a fire will sound the building fire alarm and energize an indicator light on a fire location annunciator panel, which is located at the east main entrance to the Lillibridge ISU College of Science and Engineering, March 25, 2022 Page 17 of 27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 Engineering Laboratory Building. In the event of a fire that may cause damage to the fuel plates or foils, a subsequent leak test (swipes) will be performed on all fuel plates and foils.

Calculations of the heat that would be generated by the combustion of all of the wood dividers in the steel storage containe r for the fuel plates would result in combustion energy about twice what it would take to raise the-of aluminum.plates) to their melting temperature. However, there are several reasons why melting could not occur, as follows :

The combustion heat released will also go to the walls of the storage box, with far greater mass and heat capacity than the aluminum plates It is virtually impossible for enough oxygen to enter the steel storage container to support combustion of the wooden divider material inside, except over a much longer time (days) that would be needed to have fast combustion to raise the temperature to its maximum theoretically possible.

Thus, melting of the aluminum plates is essentially impossible under the current conditions of storage and virtually no combustibles in Room 23. If the plates were stored in the criticality tank, there is nothing combustible in the tank, and hence nothing to raise the plate temperatures. Dispersal of either fission products or SNM material could not occur in the worst-case fire.

Because dispersal of fission products or SNM material cannot occur during the worst case fire, there is no need for a specific procedure for a fire in the SCA. The evacuation procedure listed in the ISU AGN - 201m (Docket#: 50 - 284) Emergency Plan (also listed in section 13.2 below) is sufficient for this event.

8. 6. Inadv erten t Criticality

In co n sideration of the need to assure that criticality cannot ever occur with the materials available for use under the conditions of this license, the following standards have been referenced and relevant compliance established:

ANSI/ANS-8.1-1998, "Nuclear Criticality Safety in Operations with Fissionable Material Outs ide Reactors." (Though this standard primarily addresses aqueous solutions, it does give some guidelines on solid plates.)

ANSI/ANS-8.3 -1997 (R2003), Criticality Accident Alarm System ANSI/ANS 8.23 - 2007, "Nuclear Criticality Accident Emergency Planning and Response."

ISU College of Science and Engineering, March 25, 2022 Page 18 of 2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

The SCA is designed to be subcritical by at least--under all conditions using ordinary water as a moderator and as the radial and top reflectors. Operational measurements have verified the design calculations. The most reactive configuration is a double plate (two plates together, total thickness of-inches), in an array with a cell width of-inches. This configuration, in a geometric arrangement that has closed approximately a circular cross section of diameter 36.4 cm, has a calculated effective multiplication factor of-With a thick graphite radial reflector, - (Confirmation of the validity of the calculation model, a 19-energy group diffusion theory code, was confirmed experimentally with the approach to critical and an exponential experiment.)

Calculations have been done on a variety of geometric arrangements involving ordinary water and graphite reflectors of various configurations and indicate that criticality is not possible with these materials in any configuration with the-fuel plates ~ater

~phite reflector cannot make a critical assembly using the existing-

-and However, heavy water in a larger tank could make a critical configuration with the fuel plates. Criticality would also be possible with the present geometry tank and beryllium reflector. But neither heavy water nor Be or BeO are permitted in the facility.) Prevention of inadvertent criticality is, therefore, accomplished by restricting or prohibiting the use of superior moderator or reflector materials in the SCA room. Specifically, beryllium, beryllium oxide, and heavy water are not permitted in the SCA room. Additional fissile material is limited to no more than I

- I

The use or storage of graphite in the SCA room is restricted. Approximately 4,500 lbs of graphite blocks make up the thermal column beneath the SCA tank. This graphite is stacked in layers within a metal framework and will not be disassembled or otherwise disturbed during operation of the SCA except as to allow for the insertion of suitable neutron source required for the operation of the SCA or fission foils for flux mapping or neutron diffusion experiments. Additional graphite will not be allowed within 4 feet of the SCA or the thermal column, without prior approval of the Reactor Administrator and an analysis of the intended use and its potential effect on the reactivity of the most reactive system.

This criticality safety analysis will be prepared using guidance in DOE -STD-3007-2017, "Preparing Criticality Safety Evaluations at Department of Energy Nonreactor Nuclear Facilities," and ANSI/ANS-8.1 Appendix A, "Nuclear Criticality Safety in Operations with Fissionable Material Outside Reactors." The calculations will be performed using SCALE 6.2.4 with ENDF/B-Vll.1 continuous energy neutron cross sections or equivalent. The

ISU College of Science and Engineering, March 25, 2022 Pa ge 19of 2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 upper subcritical limit (USL) will be established using the guidance in ANSI/ANS-8.24, "Validation of Neutron Transport Methods for Nuclear Criticality Safety Calculations,"

and documented in the criticality safety evaluations as required by section 8.1.6 of ANSI/ANS-8.24. At this time it is expected that the USL will be 0.95. The method used to estimate kett will be validated in accordance with ANSI/ANS-8.24, " Validation of Neutron Transport Methods for Nuclear Criticality Safety Calculations. "

Adherence to the double contingency principle as well as ensuring subcriticality under normal and credible abnormal conditions will be achieved through the following :

1. Performance of the criticality safety evaluation which will establish the necessary limits and controls
2. Implementat ion of the limits and controls established in the criticality safety evaluation through access c ontrols, training, postings, material configuration and exclus ions 3. Documentation of the overall criticality safety program
4. Periodic inspections and reviews

The Reactor Safety Committee must approve the results of the analysis. Any additional graphite shall not be used in conjunction with the operation of the SCA and shall be located away from the licensed material such that there can be only negligible neutroni c interactions between the graphite and the licensed material.

In addition to the restrictions placed on the use of the superior moderating and reflecting materials to guard against inadvertent criticality, restrictions shall be in place for the use of other fissile materials in conjunction with the operation of the SCA. Small quantities (not to exceed total, but not including the Pu - Be neutron source) of fissile nuclides (i.e., U-235 and/or Pu - 239) may be used as approved by the Reactor Administrator as neutron monitors (i.e., fission foils or fission detectors under the broad scope license) for flux mapping experiments.

Accordingly, the following administrative control notice will be posted at the entrance to the SCA room:

" NOTICE: The following materials are NOT to be taken into or stored within the subcritical assembly room - beryllium, bir Ilium oxide, heavy water, or fissile nuclides (i.e., 235 U and/or 239 Pu) exceeding of any one isotope or combinat ion of isotopes except for the Pu - Be sources necessary for facility operation.

Graphite may be taken into the subcritical assembly room only with the approval of the Reactor Administrator."

ISU College of Science and Engineering, March 25, 2022 Page 20 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 A fixed criticality alarm system is installed in Room as described in Section lO(a). The alarm fulfills the criticality alarm requirement stated in 10 CFR 70.24(a)(2).

9. Material Control and Accountability [ref. 10 CFR 70.22(b)]

9. 1. Material Inventory & Transfer

ISU performs inventory of all special nuclear material associated with the subcritical assembly on an annual basis following the RS - 28, " Special Nuclear Material Physical Inventory " procedure to comply with the requirements of 10 CFR 74.19 c) because ISU possesses more than-of U-235 but less than These records are maintained and retained on ISU's cloud storage server in accordance with the recordkeeping requirements of 10CFR74.19. Procedure, RS-28, NMMSS Phys ical Inventory, specifies the methods used to perform the measurement based physical inventory {10 CFR 74.4).

After the physical inventory is completed, ISU prepares and submits the annual material status report on Forms 742 and 742C following Procedure RS-05, NMMSS Reporting, that implements the requirements of 10 CFR 74.13 following the guidance of NUREG/BR -0007 and the Nuclear Materials Management and Safeguards System (NMMSS) User's Guide for material owned by the Department of Energy.

For all transfers and receipts of special nuclear material above applicable thresholds, ISU prepares and submits Form 741 following Procedure RS-05, NMMSS Reporting, that implements the requirements of 10 CFR 74.15 following the guidance of NUREG/BR -

0006 and the guidance from the Nuclear Materials Management and Safeguards System (NMMSS) Users Guide for material owned by the Department of Energy.

10.Transportation Security [ref. 10 CFR 70.22(g)(1)]

ISU will not deliver special nuclear material of low strategic significance to a carrier fo r transport.

ISU College of Science and Engineering, March 25, 2022 Page2 1 of2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 11.Emergency Plan [ref. 10 CFR 70.22 (i)(l)(ii)]

The ISU AGN-201m, License No. R-110 and Docket No. 50 - 284, Emergency Plan is located in ADAMS under accession number ML16285A191 or as updated. This plan contains procedures for response to radiological hazards satisfying 10 CFR 70.22(i)l(ii).

12. Physical Security Plan [ref. 10 CFR 70.22(k)]

The ISU AGN-201m, License No. R-110 and Docket No. 50-284, Physical Security Plan is located in ADMAS under accession number ML191150A123 or as updated. The Physical Security Plan details how ISU meets the requirements of 10 CFR 73.67(f). The ISU AGN-201m Emergency Plan contains the emergency procedures including response to thefts of special nuclear material, satisfying 10 CFR 73.67(f)(4).

Material Control and Accountability activities are performed by following the RS - 28,

"Special Nuclear Material Physical Inventory" procedure. This procedure was developed to comply with the physical inventory requirements of 10 CFR 74. 19 and to ensure that all special nuclear material is present and has not been lost, stolen, or diverted. In the event a discrepancy is identified the Radiation Safety Officer will notify the NRC Operations Center through the Emergency Notification System w ithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery as required by 10 CFR 74.11.

13.Criticality Accident Requirements [ref. 10 CFR 70.24]

13. 1. Criticality alarm

The installed criticality alarm is discussed in deta il in sections 7.3 "Measuring and monitoring instruments " and 7.38.6 " Inadvertent Criticality".

13. 2. Em ergency ev ac uation pro ce dure

The procedures given below will be carried out unde r the direction of the person responsible for the assembly at the time the emergency occurs. Detailed emergency procedures are provided in the approved facility Emergency Plan referenced in section 11 above.

All power to the pump and solenoid drain valve will be shut off by placing the drain valve and pump power switch in the OFF position. (This step backs up the function performed when the criticality alarm is activated.)

ISU College of Science and Engineering, March 25, 2022 Page 22 of2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

The portable ion chamber survey meter will be taken from Room 23 by the evacuating personnel.

Once all personnel are out of Room the door will be closed and a radiation dose rate survey will be performed in all areas adjacent to Room If radiation levels exceed 10 mrem/hr outside or Room the building fire alarm will be activated to evacuate the entire building. Pull stations for activating the fire alarm are located in the main corridors near the stairs as shown in the basement building floor plan in Figure I Exits and access routes to and from the basement are shown on the basement building floor plan and in the first-floor plan (Figure I.

Building ventilation will be secured by pushing the "Penthouse Power Emergency Trip" switch located on the wall facing Room 15 about 6 feet inside the door entrance #14 to the Nuclear Engineering Laboratory complex.

The Reactor Administrator, the Radiation Safety Officer, and the Reactor Supervisor or their designated alternates are all on an emergency call list and will be notified of the emergency. Building reentry will be directed by the Reactor Administrator and/or the Reactor Supervisor in consultation with the Radiation Safety Officer (or their alternates).

Emergency equipment and communication and alarm systems will be tested annually.

Emergency procedures will be reviewed with permanent staff and personnel who work with the SNM. Periodic review of these procedures will be accomplished by annual instruction and drills.

14.Financial Assurance for Decommissioning [ref. 10 CFR 70.25]

10 CFR 70.25 requires financial assurance for uranium enrichment facilities and facilities that handle dispersible special nuclear material in quantities greater than 105 times the values in 10 CFR 30 Appendix B. All of the material that will be used in the ISU sub critical assembly is sealed (fuel plates, fission foils, fission counters, and sealed sources).

Therefore, the requirement to provide financial assurance does not apply.

The special nuclear material in the sub-critical assembly, fuel plates, fission foils, and fission counter is owned by the Department of Energy. At the time of decommissioning, the materials will be returned to the DOE in appropriated fissile shipping containers. At that time, a physical security plan for shipment of SNM of low strategic significance will

ISU College of Science and Engineering, March 25, 2022 Page 23 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 be prepared in accordance the 10 CFR 70.22 (g) (1) and will be submitted to the NRC in an amendment request. Decommissioning is not expected in this 10-year renewal period.

At the time of final decommissioning of the facility, ISU will develop a decommissioning plan cons idering the guidance in NUREG-1757, Consolidated Decommissioning Guidance and NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual which will be sent to the NRC for approval in accordance with the requirements of 10 CFR 70.38(g). Following the remo val of the Department of Energy owned SNM, the facility will be surveyed in accordance with the RS-17, Decommissioning Survey Procedure.

Residual contamination is not expected to be present at the time of facility decommissioning. However, in the event contamination is found during the decommissioning survey it will be decontaminated to levels as low as reasonably achievable but not to exceed the acceptable screening values for building surface contamination as specified in the decommissioning plan. Any materials that cannot be decontaminated or are activated will be prepared for disposal.

Measurable activation activity is not expected because of the minimal neutron fluence produced by the sub -critical assembly and the infrequent use of the assembly. In the decommissioning plan, ISU will specify surveys of potentially activated materials with portable sodium iodide survey instruments to verify no detectable activation products are present. These surveys will include structural components of the sub-critical assembly and building construction materials. Measurements will be supplemented by gamma spectroscopy if potentially activated materials are detected. ISU will retain all records related to decommissioning activities, as required by 10 CFR 70.25(g)1-2, until the facility is released for unrestricted use. Such records include decommissioning survey results, records of spills or spread of contamination, historical review of the locations RAM was used or stored, as built drawings and modifications of structures and equipment where RAM was used or stored, and a list of any inaccessible areas that may contain residual contamination. These records are stored electronically on ISU's cloud storage server.

15.Environmental Protection

15. 1. Air Effluents ISU complies with the NRC constraint on air emissions specified in Regulatory Guide 4.20 to demonstrate that no member of the public receives a dose equivalent from air emissions greater than 10 mrem. Specifically, ISU follows the guidance of EPA-520/1 ISU College of Science and Engineering, March 25, 2022 Page 24 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022 002, A Guide for Determining Compliance with the Clean Air Act Standards for Radionuclide Emissions from NRC-licensed and non-DOE Federal Facilities to model air emissions using the COMPLY code. All of the materials used in the sub -critical assembly are sealed sources (fuel plates, fission foils, and neutron sources) and are not included in the emission source term based on the EPA source term guidance. Therefore, the air emissions from the sub-critical assembly are zero.

15.2. Liquid Effluents There are no liquid effluents from the sub-critical assembly. If the water used in the sub critical assembly becomes activated or contaminated it will be managed as radioactive waste and discharged to the sanitary sewer system or disposed by transfer to a licensed waste broker as described in the radioactive waste section 8.3

15.3. Radioactive Waste Radioactive waste is discussed in Section 8.3

15.4. Impact from Accidents 10 CFR 70 Subpart H does not apply to the sub -critical assembly because it does not involve enriched uranium processing, fabrication of uranium fuel or fuel assemblies, uranium enrichment, enriched uran ium hexafluoride conversion, plutonium processing, fabrication of mixed-oxide fuel or fuel assemblies, or scrap recovery of special nuclear material. Therefore, there is no evaluation of accident impacts on members of the general public.

16.Chemical Safety Chemical hazards associated with operation of the sub-critical assembly will be evaluated by appropriate personnel in the Environment Safety and Health (EHS)

Department in accordance with the ISU Chemical Hygiene Plan. The reactor administrator will evaluate all new and revised procedures to determine if they involve chemical hazards. If so, the reactor administrator will send the procedure to the Director of the EHS department for chemical safety review. Comments provided by the EHS department will be sent to the reactor safety committee for a complete record of the review and will then be incorporated in the applicable procedure.

ISU College of Science and Engineering, March 25, 2022 Page 25 of27 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

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ISU College of Science and Engineer ing, March 25, 2022 Pa ge 26 of2 7 Application for License Renewal Materials License No. SNM-1373 March 25, 2022

Figure 2: Basement of Lillibridge Engineering Building

ISU College of Science and Engineering, March 25, 2022 Page 27 of27 Application for License Renewal Materials License No. SNM-1373 March 25 2022

Figure 3: First Floor of Lillibridge Engineering Building

ISU College of Science and Engineer ing, March 25, 2022 Page 28 of2 7 Attachment I Idaho State University Roster of Officials for Materials License SNM-1373, Docket No. 1374 17.Attachment I: Idaho State University Roster of Officials

President of the University Kevin Satterlee, J.D.

264 Administration Building, Mail Stop 8310 Idaho State University Pocatello, ID 83209 - 83 10 Tel: {208) 282-3440 Email: kevinsatterlee@isu.edu

Vice President for Research Donna L. Lybecker, Ph.D.

106 Administration Building, Mail Stop 8130 Idaho State University Pocatello, ID 83209-8130 Tel: {208) 282 - 2592 Email: donnalybecker@isu.edu

Chair of the Department of Nuclear Engineering Chad Pope, Ph.D.

235 Lillibridge Engineering Building, Mail Stop 8060 Idaho State University Pocatello, ID 83209 - 8060 Tel: {208} 282 - 2875 chadpope@isu.edu

Chairperson of the Reactor Safety Committee Kermit Bunde, P.E.

US Depa rtment of Energy, Idaho Operations Office 1995 Fremont Street Idaho Falls, ID 83415 Tel: 208 - 526-5188 Email: bundeka@id.doe.gov

Radiation Safety Officer Mason Jaussi Idaho Accelerator Center Idaho State University Pocatello, ID 83209 - 8263

ISU Personnel Roster Page l of 2 Attachment I Idaho State University Roster of Officials for Materials License SNM-1373, Docket No. 1374 Tel: (208} 282 - 5652 Email: masonjaussi@isu.edu

Reactor Administrator and Reactor Supervisor Mary Lou Dunzik -Gougar, Ph.D.

Center for Advanced Energy Studies Idaho State University Pocatello, ID 83209-8060 Cell: (208} 569-9915 Email: mldg@isu.edu

Reactor Supervisor in Training Jonathan Scott Lillibridge Engineering Laboratory Mail Stop 8060 Idaho State University Pocatello, ID 83209-8060 Tel: (208} 282-1491 Cell: (573) 466 - 2792 Email: jonathanscott@isu.edu

ISU Personnel Roster Page 2 of2 Attachment II Drawings and Images of the Subcritical Facility for Materials License SNM-1373, Docket No. 1374

18.Attachment II: Drawings and Images of the Subcritical Facility

Attachment II - Drawings and Images of the Subcr itical Facility Page 1 of 4 Attachment II Drawings and Images of the Subcritical Facility for Materials License SNM-1373, Docket No. 1374

Figure 11-2: Details of the Fuel Plate Structure Attachment II - Drawings and Images of the Subcritical Facility Page 2 of 4 Attachment II Drawings and Images of the Subcritical Facility for Materials License SNM-1373, Docket No. 1374

Figure 11-3 : Wiring Diagram for Subcritical Assembly Attachment II - Drawings and Images of the Subcritical Facility Page 3 of 4 Attachment II Drawings and Images of the Subcritical Facility for Materials License SNM-1373, Docket No. 1374

Figure 11-4: Piping Diagram for Subcritical Assembly

Attachment II - Drawings and Images of the Subcritical Facility Page 4 of 4 Attachment Ill Specifications of Uranium-Aluminum Fuel Plates, Uranium-Aluminum Foils, and Fission Counter

19.Attachment Ill: Specifications of Uranium-Aluminum Fuel Plates, Uranium Aluminum Foils, and Fission Counter

SP CIAL CL MAT I -c ITICAL

(a) Ur niua-Alua nua tu

Th for

( ) Urn ua-Alu* nua o la:

Attachment Ill - Specifications of SNM Page I of 2 Attachment Ill Specifications of Uranium-Aluminum Fuel Plates, Uranium-Aluminu m Foils, and Fission Counter

(c) Fission counter:

The fission counter, manufactured by Westinghouse, model WA 7186, is designed to be used as a flux mapping probe. The active length of the counter is only 1.0" with an active diameter of O. 20". The counter, which contains ---- of uranium-235 is sealed into one end of a stainl ~ e 40 11 long and 0.25" in diameter. A BNC connector is attached to the other end of this tube for electrical connection. A detailed description of the counter is:

Active length of counter Active diameter Enrichment of U-235 isotope Uranium-235 mass Case material Operating voltage

Attachm ent Ill - Specifications of SNM Page 2 of 2 Attachment IV Qualifications of University Personnel Responsible for Materials License SNM-1373, Docket No. 1374 (also for R-110 Reactor License)

20.Attachment IV: Qualifications of University Personnel A) Responsible University Officer, currently the Vice President for Research

  • PhD or equivalent education
  • Senior Manager at ISU
  • At least 5 years of supervisory/administrative experience

B) Chair of the Department of Nuclear Engineering

  • PhD or equivalent education
  • At least 2 years of experience related to nuclear reactor operations (need not have power reactor experience)

C) Chairperson of Reactor Safety Committee

  • BS or higher in an engineering field or physical science field
  • At least 5 years of experience related to nuclear reactor operations (need not have power reactor experience)
  • A professional engineering license is desirable but not essential

D) Reactor Administrator

  • MS or PhD in an engineering or physical science field
  • At least 2 years of experience related to nuclear reactor operations (need not have power reactor experience)
  • A professional engineering license is desirable but not essential
  • Certification as a Health Physicist is desirable but not essential
  • Note: it is not necessary for the Reactor Administrator or the Assistant Reactor Administrator to have or retain certification as either a Reactor Operator or Senior Reactor Operator

Attachment IV - Minimum Qualifications of University Personnel Page l of2 Attachment IV Qualifications of University Personnel Responsible for Materials License SNM-1373, Docket No. 1374 (also for R-110 Reactor License)

E) Reactor Superv isor

  • BS in an engineering or physical science field
  • At least 2 years of experience related to nuclear reactor operations (need not have power reactor experience)
  • Pass the requirements, or equivalent, for having a Reactor Operator License, and obtain a Senior Reactor Operator License within one year of qualifying for the Reactor Operator License
  • Must ma intain certification as a Senior Reactor Operator

F) Rad iation Safety Officer

One of the follow ing are the minimum requirements for the Radiat ion Safety Officer

  • BS (or higher degree) in health phys ics, nuclear engineering, or closely related field, and five years of experience related to health physics/radiation protection
  • Certification by the American Academy of Health Physics or nominally equivalent relevant certification

Attachment IV - Minimum Qualifications of University Personnel Page 2 of2