ML18295A336

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Jackson Community College - Conversation Record and Request for Additional Information
ML18295A336
Person / Time
Site: 07001228
Issue date: 10/18/2018
From: Foster S
NRC/RGN-III
To: Demarco C
Jackson Community College
References
609205
Download: ML18295A336 (9)
v • d • e


Text

NRC FORM6~9 (11*2017)

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U.S. NUCLEAR REGULATORY COMMISSION 1

CONVERSATION RECORD

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  • NAME OF PERSON(S)/TITLE CONTACTED OR IN CONTACT WITH YOU DATE OF CONTACT TYPE OF CONVERSATION Chris J. DeMarco 10/18/2018 DE-MAIL Radiation Safety Officer & Professor, Physics Dept.

E-MAIL ADDRESS - TELEPHONE NUMBER I;/ !TELEPHONE DINCOMING demarcochrisj@jccmi.edu (517) 796--8583 I;/ I OUTGOING ORGANIZATION DOCKET NUMBER($)

Jackson Community College 070-01228 2111 Emmons Rd., Jackson, Ml 49203 LICENSE NAME AND NUMBER(S) MAIL CONTROL NUMBER(S)

SNM-1171 609205 SUBJECT Additional Information Request concerning the licensee's request to renew the referenced U.S. NRC radioactive materials license, including to allow continued possession of a cobalt-60 sealed source, where thesource has not been used for principal activities in more than 2 years, and principal activities have ceased.

SUMMARY

AND ACTION REQUIRED (IF ANY)

This record concerns the licensee's June 27, 2018 application (NRC Accession No. ML18178A420) requesting renewal of the above-listed radioactive materials license, where all principal activities have ceased and the licensee's. only authorization is a cobalt-60 sealed source, for possession and storage only with intent to dispose.

Upon review, we have noted that the application omits information requested in the NRC's NU REG 1556 Vol.

7, rev. 1, "Program-Specific Guidance About Academic, Research and Development, and Other Licenses of Limited Scope, Including Electron Capture Devices and X-Ray Fluorescence Analyzers," guidance volume.

As discussed, please see attached for information needed to complete our review of your request.

As agreed during our phone call, please provide the requested information within 28 days of this message (on or before November 15, 2018). Include a signed and dated cover letter transmitting your response. Submission of your response as a pdf file attached to an email or via facsimile to 630-515-1078 will allow for the quickest processing. Please call or email me with any questions you may have, or if you are unable to respond by the date suggested above. Thank you for your prompt attention to this matteL NAME OF PERSON DOCUMENTING CONVERSATION Sara A. Forster, M.S., Health Physicist, Materials Licensing Branch, DNMS, RIii office; sara.forster@nrc.gov SIGNATURE DA TE OF SIGNATURE 10/18/2018

"' _ / ttlr NRC Form 699 (11-2017) Page 1 of 't

NRC FORM699 U.S. NUCLEAR REGULATORY COMMISSION (11*2017)

CONVERSATION RECORD {continued)

LICENSE NAME AND NUMBER{$) MAIL CONTROL NUMBER($}

SNM-1171 609205

SUMMARY

AND ACTION REQUIRED (IF ANY) (Continued)

ADDITIONAL INFORMATION NEEDED FOR CONTINUED REVIEW I. For general resubmission of the renewal application:

(1) Please resubmit the NRC Form 313, signed and dated by a Senior Managment official from Jackson Community College, or other individual designated to sign on that official's behalf; (2) Please include the licensee's mailing address as submitted in the June 27, 2018 application; (3) Please confirm that the licensee's sole address where materials will be used or stored is 2111 Emmons Rd., Jackson, Ml 49203.

(4) Please either (a) confirm that the Department and Building where materials will be used or stored is consistent with the location of use listed in Condition No. 10 to your most recent amendment (Corrected Copy to Amendment No. 12, dated September 21, 2017); or (b) provide final closeout information for the location of use currently listed on the license, as applicable.

II. For the authorization for possession of cobalt*60 for storage only, with intent to dispose:

(1) Please confirm that the only requested radionuclide is cobalt-60, with a requested form of a sealed source; (2) For each sealed source requested, please provide the manufacturer, model number, serial number, isotope, initial activity (and date of assay), activity at time source was received (and receipt date),

current estimated activity, date of last leak test, and confirmation that the sealed source is not leaking; and (3) Please confirm that the licensee's sole purpose of use is limited to possession, pending disposal.

Ill. For a renewal, where the licensee has permanently ceased licensed operations:

(1) Please describe all efforts made to dispose of the licensed material, including telephone calls, letters, facsimiles, personal contacts, etc.;

(2) Please indicate the date by which the licensee intends to dispose of licensed material; (3) Please confirm that the licensee will continue to take all actions within its ability to dispose of licensed material; and (4) Please confirm that the licensee will notify the NRC within 30 days of any final disposal and disposition of licensed material described above, including to submit a License Termination application using an NRC Form 314, "Certificate of Disposition of Materials."

NRC Form 699 (11-2017} Page 2 of 'i

NRC FORM699 U.S. NUCLEAR REGULA TORY COMMISSION (11-2017)

CONVERSATION RECORD (continued)

LICENSE NAME AND NUMBER(S) MAIL CONTROL NUMBER($)

SNM-1171 609205

SUMMARY

AND ACTION REQUIRED (IF ANY) (Continued)

IV. For listing lndividual{s) Responsible for Radiation Safety Program and their Training and Experience:

(1) Please confirm that the Radiation Safety Officer (RSO) for this license is Chris J. DeMarco, or otherwise list the name and experience of the RSO to be listed on the license. Sample RSO training criteria may be found in NRC's NUREG 1556 Vol. 7, rev. 1, Section 8.7.1, pp. 8-13 to 8-16.

(2) Please provide a copy of a Memorandum of Understanding/Delegation of Authority (MOU/DOA) document, signed and dated by both the licensee's Management Representative and the RSO. At a minimum, the MOU/DOA should indicate the RSO's responsibilities and authority for the licensed*

program and that RSO's acceptance of those duties. Sample RSO duties together with a sample MOU/DOA form may be found in NRC's NUREG 1556 Vol. 7, rev. 1, Appendix E, pp. E-1 to E-3. A copy of this appendix is attached for your reference.

(3) Please confirm that the sole Authorized User (AU) for this license is Chris J. DeMarco, or otherwise list the name and experience of the AU to be listed on the license. Sample AU training criteria may be found in NRC's NUREG 1556 Vol. 7, rev. 1, Section 8.7.2, pp. 8-16 to 8-18.

V. For authorizing storage of byproduct material at the Jackson Community College location:

(1) Please provide a description for the area where licensed material will be used or stored in accordance with NRC's NUREG 1556 Vol. 7, rev. 1, (a) Section 8.9, pp. 8-19 to 8-21, (b) Appendix C, Item 9, pp. C-2 to C-3, and/or (c) Appendix G, pp. G-1 to G-3, as applicable; (2) Your response should include a diagram of the area where the material will be used or stored, showing street address, room number, any physical barriers (doors, walls, windows, etc.), and scale of the area (i.e. 100 sq. ft.) highlighted in the submitted facility diagrams; (3) Your response should also list specific locations of the stored sealed source, within the area shown; (4) Please describe how the area is secured (key, keycard, code, etc.), with a description of individuals (Radiation Safety Officer (RSO}, Authorized Users (AUs), housekeeping, etc.) who will be able to access, or who will routinely access, the requested area; and (5) Finally, please describe any safety features (handling equipment, spill containment, etc.) available location where radioactive material will be stored.

VI. For Updates to your Radiation Safety program, in accordance with guidance provided in NUREG 1556, Vol. 7, rev. 1, Items 8.10.2 through 8.10.7, pp. 8-22 through 8-45:

(1) As discussed, please clearly state any change that is being requested, In the alternative, please confirm that - other than the expiration date - no changes to your radiation safety program are being requested.

NRC Form 699 (11-2017) Page 3 of1

NRC FORM 699 U.S. NUCLEAR REGULATORY COMMISSION (11-2017)

CONVERSATION RECORD (continued)

LICENSE NAME AND NUMBER(S) MAIL CONTROL NUMBER(S)

SNM-1171 609205

SUMMARY

AND ACTION ~EQUIRED {IF ANY) {Continued)

VI. For Updates to your Radiation Safety program, in accordance with guidance provided in NUREG 1556, Vol. 7, rev.1, Items 8.10.2 through 8.10.7, pp. 8-22 through 8-45 (continued):

(2) Concerning Item 8.10.2 - Radiation Monitoring Instruments:

(a) Please describe instrumentation that will be used to perform required surveys.

(b) Concerning surveys, please confirm the statement:

"We will use instruments that meet the radiation monitoring instrument specifications published in Appendix I in NUREG-1556, Volume 7, Revision 1, 'Program-Specific Guidance _. about Academic, Research and Development, and Other Licenses of Limited Scape.' We reserve the right to upgrade our survey instruments as necessary."

(c) Please confirm that instruments required for the program will be calibrated before first use, at least annually thereafter, and after any repair, by a vendor that the NRC or an Agreement State has licensed to perform instrument calibration.

(d) In the alternative, if the licensee will be performing its own instrument calibrations for instruments used in required surveys, please either (i) confirm the statement:

"We will implement the model radiation survey meter calibration program published in Appendix I in NUREG 1556, Volume 7, Revision 1, 'Program-Specific Guidance about Academic, Research and Development, and Other Licenses of Limited Scope."' or (ii} Submit equivalent procedures for instrument calibration.

(3) Concerning Item 8.10.3 - Material Receipt and Accountability:

(a) Please confirm the statement:

"We will develop, implement, and maintain procedures for ensuring accountability of licensed materials at all times."

NRC Form 699 (11-2017) Page 4.(of oil

NRC FORM699 U.S. NUCLEAR REGULATORY COMMISSION (11-2017)

CONVERSATION RECORD {continued)

LICENSE NAME AND NUMBER($) MAIL CONTROL NUMBER{S)

SNM-1171 609205

SUMMARY

AND ACTION REQUIRED (IF ANY) (Continued)

VI. For Updates to your Radiation Safety program, in accordance with guidance provided in NUREG 1556, Vol. 7, rev.1, Items 8.10.2 through 8.10.7, pp. 8-22 through 8-45 (continued):

(b) Please either (i) confirm the statement:

"Physical inventories will be conducted at intervals not to exceed 6 months, to account for all sealed sources and devices received and possessed under the license. Records of inventory will be maintained for a period of 5 years from the date of each inventory, and will include the radionuclides, quantities, manufacturer's name and model numbers, and the date.of the inventory."' or (ii) Provide a description of the procedures for ensuring that no sealed sources have been lost, stolen, or misplaced.

(4) Concerning Item 8.10.4 - Radiation Monitoring Instruments - please confirm the statement:

"We will maintain, for inspection by the NRC, documentation demonstrating that unmonitored individuals are not likely to receive a radiation dose in excess of the limits in 10 CFR 20. 1502."

(5) Concerning Item 8.10.6 - Safe Use of Radionuclides, Security, and emergency procedures - please either:

{a) Confirm the statement:

"We will develop, implement, and maintain procedures for safe use, security and emergencies." or (b) Confirm the statement "We will adopt the procedures for the safe use of radionucfides, security and emergencies as published in Appendix Lin NUREG-1556, Volume 7, Revision 1, 'Program-Specific Guidance about Academic, Research and Development, and Other Licenses of Limited Scope."

(5) Concerning Item 8.10.7 - Surveys and Leak Tests:

either:

{a) Concerning leak tests, please confirm the statement:

"Leak tests will be performed at the inteNals approved by the NRC or an Agreement State and specified in the SSD registration certificate."

NRC Form 699 (11-2017)

NRC FORM699 U.S. NUCLEAR REGULATORY COMMISSION (11-2017)

CONVERSATION RECORD (continued)

LICENSE NAME AND NUMBER(S} MAIL CONTROL NUMBER{S)

SNM-1171 609205

SUMMARY

AND ACTION REQUIRED (IF ANY} (Continued}

VI. For Updates to your Radiation Safety program, in accordance with guidance provided in NUREG 1556, Vol. 7, rev. 1, Items 8.10.2 through 8.10.7, pp. 8-22 through 8-45 (continued):

(b) Concerning analysis of leak tests, if leak tests will be ana1yze4'by an outside entity, please confirm the statement:

"Leak tests will be analyzed by an organization authorized by the NRG or an Agreement State to provide leak testing services to other licensees. Leak tests may be collected by the licensee, using the instructions from the manufacturer (or distributor) of the sealed source or plated foil and the leak test kit supplier. Such leak test kits will be supplied by an organization authorized by the NRG or an Agreement State to provide leak testing services."

VII. For Updates to your waste management program, in accordance with guidance provided in NUREG 1556, Vol. 7, rev. 1, Item 8.11, pp. 8-48 through 8-54:

(1) If needed, please request authorization for extended interim storage of waste. and (2) Please confirm the statement:

"We will use the model waste procedures published in Appendix Pin NUREG 1556, vol. 7, rev. 1, NUREG-1556, Vol. 7, rev. 1, 'Program-Specific Guidance about Academic, Research and Development, and Other Licenses of Limited Scope.'

NRC Form 699 (11-2017) Paget, oflJ!

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.fro,,., t'IU'4.£C.,. 155" J Vo(. 7 rev'. 1 Apf"E?n<!Li)CI £ Radiation Safety Officer Duties and Responsibilities .J The radiation safety officer's (RSO's) duties and responsibilities include ensuring radiological safety, security, and compliance with both U.S. Nuclear Regulatory Commission (NRC) and U.S. Department of Transportation (DOT) regulations and the conditions of the license (see Figure 8-5). Typically, these duties and responsibilities include the following:

  • Ensure that licensed material that the licensee possesses is limited to the types and quantities of byproduct material listed on the license.
  • Maintain documentation demonstrating that the dose to individual members of the public does not exceed the limit specified in Title 1O of the Code of Federal Regulations (10 CFR) 10 CFR 20.1301.
  • Ensure security of radioactive material.
  • Ensure that licensed material is transported in accordance with applicable NRC and DOT requirements.
  • Ensure that radiation exposures are"as low as is reasonably achievable" (ALARA).
  • Oversee all activities involving radioactive material, including monitoring and surveys of all areas in which radioactive material is used.
  • Act as liaison with the NRC and other regulatory authorities.
  • Provide necessary information on all aspects of radiation protection to personnel at all levels of responsibility, pursuant to 10 CFR Parts 19 and 20, and any other applicable regulations.
  • Oversee proper delivery, receipt, and conduct of radiation surveys for all shipments of radioactive material arriving at or leaving from the institution, as well as packaging and labeling all radioactive material leaving the institution.
  • Determine the need for personnel monitoring, distribute and collect personnel radiation monitoring devices, evaluate bioassays, monitor personnel radiation exposure and bioassay records for trends and high exposures, notify individuals and their supervisors of radiation exposures approaching the limits, and recommend appropriate remedial action.
  • Conduct training programs and otherwise instruct personnel in the proper procedures for handling radioactive material before use, at periodic intervals (refresher training), and as required by changes in procedures, equipment, regulations, etc.
  • Supervise and coordinate the radioactive waste disposal program, including effluent monitoring and recordkeeping of waste storage and disposal records.
  • Oversee the storage of radioactive material not in current use, including waste.

E-1

  • Perform or arrange for leak tests on all sealed sources and calibration of radiation survey instruments.
  • Maintain an inventory of all radionuclides possessed under the license, and limit the quantity to the amounts that the license authorizes.
  • Immediately terminate any unsafe condition or activity found to be a threat to public health and safety or property.
  • Supervise decontamination and recovery operations.
  • Maintain other records not specifically designated above, for example, records of receipts, transfers, and surveys as required by 10 CFR 30.51, "Records," and 10 CFR Part 20, Subpart L, "Records."
  • Hold periodic meetings with, and provide reports to, licensee management.
  • Ensure that all radioactive materials users are properly trained.
  • Perform periodic audits of the radiation safety program to ensure that the licensee is complying with all applicable NRC regulations and the terms and conditions of the license (e.g., leak tests; inventories; use limited to trained, approved users); the content and implementation of the radiation safety program to achieve occupational doses and doses to members of the public that are ALA RA, in accordance with 10 CFR 20.1101; and required records are maintained.
  • Ensure that the results of audits, identification of deficiencies, and recommendations for change, are documented (and maintained for at least 3 years) and provided to management for review; ensure that prompt action is taken to correct deficiencies.
  • Ensure that the audit results and corrective actions are communicated to all radiation workers, including ancillary personnel.
  • Ensure that all incidents, accidents, and personnel exposure to radiation in excess of ALARA or 10 CFR Part 20 limits are investigated and reported to the NRC and other appropriate a*uthorities, if required, within the required time limits.
  • Maintain understanding of and keep up-to-date copies of NRC regulations, the license, revised licensee procedures, and ensure that the license is amended whenever there are changes in licensed activities, responsible individuals, or information or commitments provided to NRC during the licensing process.
  • Develop, implement, maintain, and distribute, as appropriate, up-to-date operating, emergency, and security procedures.

E-2

Model Delegation of Authority for Radiation Safety Officer Memo To: Radiation Safety Officer From: Chief Executive Officer

Subject:

Delegation of Authority You, , have been appointed radiation safety officer and are responsible for ensuring the safe and secure use of radiation. You are responsible for managing the Radiation Protection Program, identifying radiation protection problems, initiating, recommending, or providing corrective actions, verifying implementation of corrective actions, stopping unsafe activities, and ensuring compliance with regulations. You are hereby delegated the authority necessary to meet those responsibilities, including prohibiting the use of byproduct material by employees who do not meet the necessary requirements and shutting down operations, when justified, to maintain radiation safety. You are required to notify management if staff does not cooperate and does not address radiation safety issues. In addition, you are free to raise issues with the U.S. Nuclear Regulatory Commission at any time. It is estimated that you will spend _ _ hours per week conducting radiation protection activities.

Signature of Management Representative Date I accept the above responsibilities, Signature of Radiation Safety Officer Date cc: Affected department heads E-3

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