Regulatory Guide 10.4

Guide for the Preparation of Applications for Licenses to Process Source Material

ML13350A215
Person / Time
Issue date:	07/30/1976
From:	NRC/OSD
To:
References
RG-10.004
Download: ML13350A215 (10)

r!U.S. NUCLEAR REGULATORY

COMMISSION

REGULATORY

GUIDE OFFICE OF STANDARDS

DEVELOPMENT

REGULATORY

GUIDE 10.4 GUIDE FOR THE PREPARATION

OF APPLICATIONS

FOR LICENSES TO PROCESS SOURCE MATERIAL July 1976

1. INTRODUCTION

1.1 Purpose of Guide This ouide describes the information needed to hexafluoride production, are not within the scope of this guide.1.4 As Low As Is Reasonably Achievable (ALARA)evaluate an application for a specific license to process Paragraph

20.1(c) of 10 CFR Part.20 states that source materials.

Examples of such processing activities

"... persons cngak,:d in activities under licenses issued are manufacture of depleted uranium and thorium, by the Nuclear Regulatory Commssion pursuant to the magnesium alloy products;

shaping, grinding, and Atomic Energy Act of l954."as:amn nded, and the polishing of lenses containing thorium: and the manurac- Energy Reorganization'Act of 1974 should, in addition ture and distribution of other products containing to complying with the i'equirenicnts set foiti in this source material.

part,make every reasoriable effort to maintain radiation exposures,.

and.,,. elescs-0f radioactive materials in 1.2 Applicable Regulations effluents to' unretricted areas, as low as is reasonably

'.Regulatory Guide 8.10, "Operating Philo-The Commission's rules and regulations concerning sophy for Maintaining Occupational Radiation Ex-licensing of source material are contained in Title 10, ..posuraisAs LOW; As Is Reasonably Achievable," provides Code of Federal Regulations, Part 40, "Licensing of 'ih, NRC :staff position on this important subject.Source Material." Source material means (1) uranium or 'ALacineniapplicants should give consideration to the thorium, or any Combination thereof, in any physical ,1Ai. philosophy, as described in Regulatory Guide chemical form or (2) ores that contain by weight 1/20 of "'-8. 10, in thie development of plans for work with licensed one percent (0.05%) or more of uranium, tltoriutný.or

,ý'radioactive inaterials.

any combination thereof. Source materit:dbes not'include special nuclear material.

OthetI, regulations

1.5 General Licens.e-.

pertaining to source material licenses are':found.li

10 CFR Part 19, "Notices, Instructions and'Rep&rts to Although this guide pertains to the filing of applica.Workers, Inspections;" 10 CFR Part 20, "Standards for tions for specific licenses, the applicant should be aware Protection Against Radiation, 10 CFR Part 71, of the existence of general licenses.

General licenses are"Packaging of Radioacti

airi for Transport and effective without the filing of an application or the Transportation of Radioac'

Under Certain issuance of specific documents. (Specific licenses require Conditions;" and 10- & rPaRt4,70, "Fees for Facilities filing of an application and the Issuance of licensing and Materials Licetes Un'Zr th; Atomic Energy Act of documents to specific persons.)1954, as Amoddedi".=The

,4plicant should study care-fully the rsgula&d'o id this guide and submit all information tiu sted. 1.5.1 General License to Receive Tide to Source'" Material 1.3 Items Requirinrg Separate Applications Activities that are related to the reactor fuel cycle, such as uranium and thorium milling and uranium A general license to receive title, only, to source material is provided by §40.2 1. 10 CFR Part 40. Under this general license, materials may be owned without USNRC REGULATORY

GUIDES Comments thould be $*en to the Sacetety at She Comm'rissin.

U5 Nu.clear Regulatory Conimiton.m Washington.

OC ',SW. Aglontion Docket~ing en~d Regulatory Guides Old $Stued to describe and make available go the Public 5,,,ics, Sectiou.melthods acceptable I* She PdRC staff Of im~~meniling

• Pacific Petit at the Corymrossiones tegulat.ono.

to delineate techniques used be the $left on tvli The gwidots#reissued in I%& following ton broaddie'.oons

lang specific problems a or S'tulated accidenits, ofto provide guidance to appl.drift Regulaetory Ouid*% are not subtiluest tot togulationt.

and comnplianice I Pows# Reactors 6 Products wvivh theme i not le4,.red Methods end soltuions different from those set out.in patriarch end Test Rsterlts 7 T.raep@tiot.iof the guiotdoe *,t be ACCeptable if they provide a basis tor the findings req.,isaol to Fueus and Material&

Facilities

4 OeCUPSIAMIHal Ietth the issuance Ot ort-wntei*

ofta oeitnit or license by She Commnission

4 (uosil~nmontet end $,long 0 Antotoust Review Commiventsf arnd suiggeettlonsl ot ,improvements

,1n thet guidds ate, encouraged

5 MeAer,.41 slid Plant protection

10 General'teitnos,, and guides -.lt be to-sted, as appropriate.

to accomimodate coin monglo nd to ;calle" neRw Informatlion Of ..Poioancoo However. comnments on Copies of published qurid*& may be obta~ined by writtent request &inidcatin~g the this gude. .1 0ec..eed Ailh.,, about two months &flat its issuance, will be psi divsieonsl dolited to the U.S Nucleet Regulatory Commission.

Washinuton.

D C titularly utetutf in avlele~uai St.. need For en ejsiS, revition 2

6. AttentionS

Director, Office of Standards Developmeft regard to quantity but may not be physically possessed or used in any manner.1.S.2 General License for Possession of Small Quan-tities Section 40.22. 10 CFR Par, 40, provides a general license for the use and transfer by certain persons for certain uses of up to 15 pounds of source material it any one time provided that no more than 150 pounds of source material arc received in any caletndar year. Note that the 15 pounds and 150 pounds of source material refer to contained source material.

For exdmple. 375 pounds of thorium-magnesium alloy containing

4%thorium could be transferred and used at any one time under the general license.1.5.3 General Licenses to Export The export of source material in certain forms and quantities is authorized by a number of general license provisions in §40.23. 10 CFR Part 40. If it is desired to export forms or quantities of source material that are not provided for in the general licenses of §40.23, it will be necessary to file an application for a specific license pursuant to § §40.31 and 40.33.above do not meet the applicant's needs, an application should be filed on Form NRC-2. All items of the applica-tion form should be completed In sufficient detail for the NRC to determine that the applicant's equipment, facilities, and radiation protection program are adequate to protect health and ninimize danger to life and property.Since the space provided un the application form is limited, the applicant should append additional sheets to provide complete information.

Each separate sheet or document submitted with the application should be identified as to its purpose, e.g., response to an item of the application form, radtation safety instructions, etc.Five copies of the application should be completed.

The original and three copies should be mailed to: Radioisotopes Licensing Branch, Division of Fuel Cycle and Material Safety, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Corn.mission, Washington, D.C. 20555. One copy should be retained by the applicant since the license will require, as a condition, that the institution follow the statements and representations set forth i. the application and any supplement to it.1.6 Exemptions

3.2 Proprietary Information Paragraphs

40.13(a) and (b) provide certain exemp-tions from Commisson rules and regulations and requirements for licensing.

If the concentration by weight of source material in the materials being processed does not exceed 1/20th of one percent (0.05%) at any time during processing and use, such processing and use are cexempt from licensing.

The receipt, possession, use, and transfer and the import of"unrefined and unprocessed" ore a:. also exempt from licensing.

2. LICENSE FEES An application fee is required for most types of licenses.

The applicant should refer to §170.31,"Schedule of Fees for Materials Licenses," of 10 CFR Part 170 to determine the amount of the fee that must accompany the application.

Review of the application will not begin until the proper fee is received by the NRC.3. FILING AN APPLICATION

3.1 Application Form NRC-2*When the exemptions or general licenses described"Form NRC-2 was fotmefly designated Form AEC.2. Existing copies of Form AEC-2 may still be used. See Appendix to this guide.The applicant should not submit proprietary inform-ation unless it cannot be avoided in giving a complete description of the applicant's equipment, facilities, and radiation protection program. If the use of proprietary information cannot be avoided, the proprietary informa-tion should be separated from the rest of the application, and an application for withholding from public inspection should be submitted in conformance with the requirements of § 2.790 of 10 CFR Part 2.3.3 Environmental Information A formal environmental report is not specifically required for the type of activities included in the scope of this document.

However, the Commission has a responsibility to determine if the "conduct of any other activity" will significantly affect the quality of the environment when issuing new licenses or amendments and renewals of existing licenses.

Certain large-scale processing operations and associated waste storage and disposal activities may require evaluation pursuant to 10 CFR Part 51, "Licensing and Regulatory Policy and Procedures for Environmental Protection," unless the information submitted clearly shows no significant impact on the environment from the proposed opera-tions. The information concerning effluents submitted to show lack of impact should cover all aspects of the operation and include the technical basis and rationale that support the evaluation of potential environmental effects.10.4.2

3.4 Safeguards No safeguard information is required in an initial application for licenses covered by this guide.The Commission uses an electronic data processing procedure to record certain types of information concerning source material.

Tiis sytem uses a three-letter Reporting Identification Symbol (RIS) to identify licensees who must submit material transfer reports and periodic material status reports in accordance with§40.64. 10 CFR Part 40. Applicants will be assigned a Reporting Identification Symbol and will be informed how it is to be used following issuance of the license.This information will be forwarded under separate cover fullinwing issuance of a license or license amendment authorizing greater than 1,000 kilograms of source material, 4. CONTENTS OF AN APPLICATION

Many itenis on Form NRC-2 are self-explanatory.

The following comments apply to the indicated items on Form NRC.2.Item 4. Each site of use or storage should be given.Each site should be identified by street address. city, and state.Item 7. A brief narrative description of services or products in which the source material will be used should be submitted.

Item 8. The physical form specification (Item 8(c))should include percent by weight of source material.This is necessary to determine the amount of source material to be covered by the license. For example, 2.000 pounds of monazite ore containing

5% natural thorium would contain 0.05 x 2,000 = 100 pounds of source material.

In this case, "5%- should be entered in Item 8(c) and "100 pounds" in 8(d). Percent specifica.

tions may be given as a range. but the "Maximum Amount" (Item 8(d)) should be based on the upper limit. The maximum total quantity to be on hand (item 8(e)) should include all source materials, i.e., raw materials, materials in process and storage, scrap materi-als, and wastes. The possession limit requested should be commensurate with the applicant's needs and facilities for safe handling and disposal.Item 9. An evaluation of the potential external and Internal radiation and uranium chemical*

hazards to workers and the public should be submitted.

Applicants are expected to utilize all practicable means for reducing radiation levels and concentrations of radioactive

• For soluble mixtures of U 238, U.234. and U-235 in air, chemical toxicity may be the limiting factor. See Footnote 3 to Appendix B. 10 CFR Part 20.materials in ambient air and water and in effluents by employing modern process. containment, and ventilation engineering to avoid unnecessary exposures.

The limits in 10 CFR Part 20 are not to be considered as design limits. The analysis should include a narrative d',-:rip-tion of the proposed possession and tise of sour:e materials from the time of receipt of raw materials to ultimate disposition of products and wastes. The chemical and physical form. percent by weight. and total batch size for each step in a processing operation should be estimated.

A sampling program may be required for raw materials and when changing or initiating

!,ew procedures to determine concentrations and quantities of source materials at each stage of a process. Each stacze of a process should be con.i~dered in evaluating potential hazards. For example. the processing of uranium may produce dust in the processing rea., release radon daughter products.

result in loose contamination iroin spills during transfers, and result in releases of dusts to the environment from ventilatii

' system exhausts.Written radiation safety procedures and instructions covering all operations should be submitted.

These should cover potential external radiation exposures to personnel;

the possible production of gas. vapor. dust. or other airborne radioactivity:

generation of liquids containing suspended or dissolved materials:

and the generation of solids as fines, scrap, slav. etc.. according to the process involved.Item 10. A description of the training and experience of each person who will directly supervise the use of imaterial or who will have responsibilities for radiological or uranium chemical safety should be submitted.

The description should include the type (on-the.job or formal course work). location, duration, and nature (subject.

depth, scope. etc.) of the training.

Training should cover (a) principles and practices of radiation protection. (b) radioactivity measurements, stanu'ardiza- tion. and monitoring techniques and instruments. (c)mathematics and calculations basic to the use and measurement of radioactivity, (d) biological effects of radiation, and (c) principles and practices of protection against the chemical toxicity of source materials.

The description of the personal use of radioactive materials or equivalent experience should include the specific isotopes handled, the quantities of materials handled, the chemical and physical form of materials handled, where rthe experience was gained, the duration of experience, and the type of use. Personnel qualifica- tions should be commensurate with the use of the materials as proposed in the application.

Item 11. The equipment, facilities, and instrument:a- tion for each site of use soiould be described in detail.The proposed equipment and facilities for each opera-tion must be adequate to protect health and minimize 10.4-3

3.4 Safeguards No safeguard information is required in an initial application for licenses covered by this guide.The Comnmission uses an electronic data processing procedure to record certain types of information concerning source material.

This sytem uses a three.letter Reporting Identification Symbol (RIS) to identify licensees who must submit material transfer reports and periodic material status reports in accordance with§40.64, 10 CFR Part 40. Applicants will be assigned a Reporting Identification Symbol and will be informed how it is to be used followving issuance of the license.This information will be forwardc-d under separate cover following issuance of a license or license amendment authorizing greater than 1 ,000 kilograms of source material.4. CONTENTS OF AN APPLICATION

Many items on Form NRC.2 are self.explanatory.

The following comments apply to the indicated items on Form NRC.2.Item 4. Each site of use or storage should be given.Each site should be identified by street address, city, and state.Itcn 7. A brief narrative description of services or products in which the source material will be used should be submitted.

Item 8. The physical form specification (Item 8(c))should include percent by weight of source material.This is necessary to determine the amount of source material to be covered by the license. For example, 2.000 pounds of monazite ore containing

57e natural thorium would contain 0.05 x 2,000 = 100 pounds of source material.

In this case, "5%" should be entered in Item 8(c) and "100 pounds" in 8(d). Percent specifica.

tions may be given as a range. but the "Maximum Amount" (Item 8(d)) should be based on the upper limit. The maximum total quantity to be on hand (Item 8(e)) should include all source materials, i.e., raw materials, materials in process and storage, scrap materi-als, and wastes. The possession limit requested should be commensurate with the applicant's needs and facilities for safe handling and disposal.Item 9. An evaluation of the potential external and intemal radiation and uranium chemical$

hazards to workers and the public should be submitted.

Applicants are expected to utilize all practicable means for reducing radiation levels and concentrations of radioactive

• For sluble mixtures of U 238, U-234, and U-235 in air chemical toxicity may be the limriting factor. See Footnote 3 to Appendix B. 10 CFR Part 20.materials in arbient air and water and in effluents by employing modern process. containment, and ventilatton engineering to avoid unnecessary exposures.

Tihe limits in 10 CFR Part 20 arc not to be considered as desipi limits. The analysis should include a narrative d'.,crip-tion of the proposed possession and use of sourxe materials from the time of receipt of raw mnateriab, to ultimate disposition of products and waste-. The chemical arid physical form. percent by weight. arid total batch size for each step in a processing operation should be estimated.

A sampling program may be required for raw materials and when changing or initiating new procedures to determine concentrations and quantitics of source materials at each stage of a process. Each stage of a process should be con.idered in evaluating potential hazards. For example. the processing of uranium may produce dust in the processing area, release radon daughter products, result in loose contamination trotm spills during transfers, and result in releases of dusts to the environment from ventilatiL

i system exhausts.Written radiation safety procedures and instructions covering all operations should be submitted.

These should cover potential external radiation exposures to personnel;

the possible production of gas. vapor. dust. or other airborne radioactivity:

generation of liquids containing suspended or dissolved materials:

and th'>generation of solids as fines. scrap. slag. etc.. according to the process involved.Item 10. A description of the training and experience of each person who will directly supervise the use of ntaterial or who will have responsibilities for radiological or uranium chenical safety should be submitted.

The description should include the type (on-the-job or formal course work), location, duration.

and nature (subject, depth, scope. etc.) of the training.

Training should cover (a) principles and practices of radiation protection, (b) radioactivity niasurencents.

standardiza- tion, and monitoring techniques and instruments. (c)mathematics and calculations basic to the use and measurement of radioactivity. (d) biological effects of radiation, and (e) principles and practices of protection against the chemical toxicity of source materials.

The description of the personal use of radioactive materials or equivalent experience should include the specific isotopes handled, the quantities of materials handled, the chemical and physical form of materials handled, where the experience was gained, the duration of experience, and the type of use. Personnel qualifica- tions should be commensurate with the use of the materials as proposed in the application.

Item 11. The equipment.

facilities, and instrumenta- tion for each site of use should be described in detail.The proposed equipment and facilities for each opera-tion must be adequate to protect health and minimime 10.4-3 danger to life and property.

In describing equipment and facilities, the following information should be included: a. Description of site. A description of the area surrounding each facility should be submitted estab.lishing distances to, and the use of, neighboring buildings and facilities.

A general site description should include storage, processing, and waste holding areas. Restricted areas and methods for controlling access to such areas should be described.

Diagrams of the plant layout depicting process areas, storage areas, laboratories, clothing change areas, offices, etc.. should be submitted.

Explanatory sketches, drawings, and process flow diagrams should be appended to the application, as appropriate.

b. Description of storage facilities.

Consideration of shielding, containment, and security of material should be included.c. Description of general safety equipment.

A description of protective clothing, general and personal air sampling equipment, fume hoods, waste receptacles, auxiliary shielding, "veste holding tanks, firefighting and fire prevention equipment, vacuum systems, safety showers, and any other equipment that would contrib.ute to safe- use of materials should be described as appropriate.

d. Description of ventilation and containment systems, filters, dust collection devices, scrubbers.

and discharge stacks and vents. Ventilation and containment equipment should be described as it relates to the phase or type, of processing of source material involved.Criteria and procedures for evaluating the performance of the equipment should be specified.

e. Description of respiratory protection program.Applicants are expected to consider means for reducing concentrations of airborne radioactive materials by employing modern process, containment, and ventilation engineering controls whenever possible.

The use of respiratory equipment will not be considered an adequate substitute for a well.planned safety program for reduction of potential airborne contamination.

Section 20.103, 10 CFR Part 20, currently requires applicants to obtain specific approval before making allowance for the protection afforded by use of respira.tory protective devices. However, Commission require-ments concerning respirators and associated protection factors are not meant to discourage their use as an additional precaution in routine operations, In emergency situations, or in cases where protection from respiratory hazards other than airborne radioactive material is needed.A formal respiratory protection program may be established and approved pursuant to Section 20.103(c)of 10 CFR Part 20.0 Specification of a respiratory protection program should include the following information: (I) A written management policy statement.

Subjects to be covered by the policy statement include the ;tse of practicable engineering controls instead of respirt.'ors;

the use of respirators in routine, nonroutine, and emergency situations:

and limits on periods of respirator use and relief from respirator use.(2) Specification of respiratory equipment and rationale for selection.

Equipment approved under appropriate approval schedules in 30 CFR Part I I of the U.S. Bureau of Mines -National Institute for Occupa.tional Safety and Health (NIOSH) should be used.(3) Written operating procedures to cover training of personnel and fitting, use, testing, cleaning, dczontamination, inspection, repair, and storage of respiratory protection equipment.

(4) A description of the air sampling program.(5) A description, of the bioassay program to monitor effectiveness of the respiratory protection program.(6) A descriptiori of the medical evaluation program. Workers should be evaluated by competent medical personnel to ensure that they are physically and mentally able to wear respirators.

These evaluations should be part of the employee's periodic physical examination.

f. Description of the radiation detection instruments to be used.(1) The manufacturer's name, Instrument model number, the number available, the type of radiation detected (alpha, beta, or gamma), the range (milliroent.

gens/hour, or counts/minute), the window thickness in mg/cm 2 , and type of use should be specified for each instrument.

The type of use would normally be monitoring, surveying, assaying, or measuring.

(2) The frequency and methods of calibration of instruments should be described, Daily or more frequent operational checks of survey instruments should be*A notice of proposed amendments to §20.103, 10 CFR Part 20, was published for public comment on August 21. 1974 (39 FR 30164). Guidance as to acceptable methods of implement.

4% the proposed rule changes, such as protection factors and references to acceptable equipment, would be set out in a regulatory guide, and related technical Information would be provided in an associated manual. The regulatory guide and the manual will be issued following the adoption of the proposed amendments to § 20.103.!i 10.4-4

0 supplemented periodically by a complete calibration of all ranges of each instrument.

If survey instruments will not be returned to the manufacti-'-

Fr calibration, a detailed de;cription of planned calibr-tion procedures should be submitted.

The description should include standard sources to be used, facilities to be used, pertinent experience of each individual who will perform the calibrations, and procedures to ensure safe and accurate calibrations.

g. Description of personnel monitoring equipment.

The type of equipment (film badges, TLD. pocket dosimeters)

to be used, the f-equency of evaluation, and whether the devices are used to evaluate whole body or extremity exposure should be specified.

A description of methods of calibrating and processing monitoring equip-ment or specification of the type of services to be obtained from a commercial supplier should be submitted.

Item 12 Radiological and uranium chremicall safety procedures should be developed regarding all aspects of the radiation and uranium chemical safety program.These procedures should be established to ensure compliance with the provisions of 10 CFR i.'t, 19."Notices, Instructions and Reports to Workers;Inspections," and 10 CFR Part 20, "Standards for Protection Against Radiation." The procedures should be specific to the activities for which a license is sough: and should cover all external and internal radiation hazards associated with these activities at all locations of use.Item 12[a). Safet, features and procedures.

Safety and fire prevention aipects of the program such as storage of flammable or caustic reagents apart from source materials, temperature controls on dryers, or use of inert atmospheres in thorium-magnesium machining should be described.

Item 12(b). Emergency and decontamination procedures.

A copy of emergency procedures to be posted in all laboratory or work areas where radioactive materials are used should be submitted.

These instruc-tions should describe immediate action to be taken in case of an emergency in order to prevent release of radioactive material or further contamination of work areas and personnel.

Examples of emergency procedures are turning off the ventilation systems, evacuation of the area, re-entry, procedures for containment of spills, etc.The instructions should specifically state the names and telephone numbers of responsible persons to be notified.*For gluble mixtures of U.238. U-234, and U-235 in air, chemical toxicity may be the limiting factor. See Footnote 3 to Appendix B, IOCFR Put 20.Item 12(c).a. Radiation Survey Program. A survey means an evaluation of the radiation hazards incident to produc-tion, use. release, disposal, or presence of radioactive materials under a specific set of conditions.

When appropriate, such evaluation in:ludes a physical sarvey of 'he location of materials and equipment and measure-ments of levels cf radiation or concentrations of materials present.A more extensive survey program may be needed for evaluation and verification of potential hazards associated with pilot studies and initial phases of a full-scale produat',n

,.peration than is needed for day.to-day operations within an established program. Provisions for evaluation

,,f all changes in operations should be made.The proposeJ survey program should he designed to monitor t!he adequacy of containment and control provi-sions for radiological safety purposes.

The areas of primary concern for source material operations are air sampling, monitoring releases to unrestricted areas.surveying for personnel contamination, and surveying to evaluate surface contamination.

Gamma surveys of processing and storage areas may be required for opera-tions involving concentrated or pure source materials.

The types, methods, and frequency of surveys should be described in detail as they relate to the type of progr:rm involved.(1) The survey program for evaluation of alpha contamination of personnel and plant surfaces should include provisions for monitoring protective clothing, hands, and feet of workers leaving restricted areas before breaks and at the end of shifts. Surveys of gloves and other protective clothing, equipment, or toots required during processing should be described.

The survey program associated with cleanup efforts where dust or loose materials may be involved should be described.

Reasonable efforts should be made to remove all residual contamination.

Surface contamination evaluation should include unrestricted areas such as lunch rooms, offices. etc.Acceptable limits of fixed and removable contamination for facilities and equipment should be established and submitted.

(2) Acceptable limits of fixed and removable contamination for fa:iities and equipment to be released for unrestricted use should also be established and submitted.

For example, if, after reasonable efforts to remove all residual contamination, maximum alpha readings are 3,000 dpm/100 cm 2 or less and the average is 1,000 dpm/100 cm 2 , unrestricted use is permissible provided that removable alpha contamination does not exceed 200 dpm/100 cm 2.These guidelines apply to 10.4-5 natural thorium. For natural and depleted uranium, the levels may be a factor of 5 higher.(3) A description of an air sampling program should define the areas where samples will be taken, the frequency of sampling, and appropriate spatial relation-ship between sampling locations and workers' breathing Lones. The type (gross alpha, fluorimetric, etc.), justifi-cation for, and sensitivity of assays that will be performed to evaluate air samples should be described.

The methods used to relate sample results to actual personnel exposure should be described.

If air sampling instruments

%%ill not be returned to the manufacturer for calibration, the methods, frequency, and standards used for calibration should be specified.

(4) The effluent monitoring program for releases to unrestricted areas should encompass all airborne and liquid releases.

Calculational evaluations should be supplemented by stack monitoring, waste stream monitoring, water sampling, or other environmental m-,nitoring as appropriat, for the planned and potential releases of radioactive materials.

b. Specification of radiation safety responsibilities and duties. The responsibilities and duties of manage-ment, any radiation safety committees, radiation safety officers, and use of consultants should be established and clearly described.

Individuals having radiation safety responsibilities should be identified by name and each individual's pertinent training and experience described.

Assignment of duties should cover all aspects of the radiation safety program.c. Bioassay program. Regulatory Guide 8.11,"Applications of Bioassay for Uranium." outlines the information to be submitted concerning a bioassay program. Regulatory Guide 8.11 specifically deals with depleted, natural, and enriched uranium; however, some of the methods and concepts are applicable to thorium.d. Records management.

Provisions for keeping and reviewing records of surveys, material inventories, personnel exposures, and receipt, use, and disposal of materials should be described.

e. Materials control provisions.

Procedures for ordering materials, for notification of responsible persons upon receipt, and for safely opening packages should be submitted.

Section 20.205, 10 CFR Part 20, requires monitoring of certain packages upon receipt depending on the quantity of contained material and Its form. Monitoring of external package surfaces for contamination is required upon receipt of packages containing more than I millicurie of source materials (greater than 3.3 pounds of natural uranium).

If removable contamination in excess of 0.01 microcuries/l00

cm 2 is found on the external surfaces of the package, notification of the shipper and the Commission is required by §20.205, 10 CFR Part 20.f. Procedures for training personnel.

A description of the training programs for all personnel who arc involved in or associated with the use of materials should be submitted.

The description should include the form of training (formal course work, lectures, on-the-job instruction, written instruction, or manuals), duration of training, retraining provisions, and the subject matter to be included.

Copies of training procedures and manuals should be submitted.

Itent 13. The description of the waste disposal program should specify the quantities and types of radioactive waste products generated by all phases of operation.

Consideration should be given to the disposal of contaminated equipment such as filters, tools, process equipment.

scrap, fines, and any wastes generated from molding, grinding, or machining operations.

Airborne wastes released from processing facilities, ventilation systems, or dust collection systems, and liquids and solids from chemical processing and melting should be considered where such processes are involved.Wastes generated ps a result of operations involving source materials should be disposed of in a safe manner.Sections 20.301 through 20.305, 10 CFR Part 20, deal with waste disposal.

The applicant should specifically describe waste disposal methods and procedures.

Wastes which are soluble or readily dispersible in water may be disposed of in the sanitary sewer system subject to the concentration and the daily, monthly, and annual limits specified in § 20.303, 10 CFR Part 20. For example, up to one millicurie of natural uranium may be disposed of daily provided the concentration in sewage does not exceed 1 x 10-3 microcuries/ml when diluted by the licensee's average daily quantity of sewage. Sewer disposal of radioactive materials by a licensee Is limited to a total of one curie/year and average monthly concentrations not exceeding restricted area water concentrations.

Wastes may be buried in soil. Such burials are subject to the four-foot depth. six-foot separation, and 12-per-year limitations of §20.304, 10 CFR Part 20.The quantity per burial is limited to 100 rnmllicuries for source materials

(330 pounds of natural uranium).The most commonly used method of disposal is transfer to a commercial firm licensed to accept such wastes. Lists of such firms are available from the Commission upon request. In dealing with such firms, prior contact is recommended to determine specific services provided.If other methods of disposal are requested, the information specified in §20.302. 10 CFR Part 20, 10.4-6 should be submittcd.

The information should include the quantities and kind of materials, levels of radio-activity, a description of the manner and conditions of disposal, and evaluation of environmental effects, and control procedures.

Any long-range disposal plans for large volumes of low concentration source material waste should be described.

Applications for processing operations, such as rare earth extraction, that generate large volumes of wastes should include detailed specific plans for ultimate disposal of such materials.

When such wastes are to be held for significant periods of time on site in basins, etc., adequate provi-sions for containment, security, and long-term control should be made. Plans for any interim type of storage should be described in detail.Ihem 14. If distribution of products containing source material is planned, the detailed description of the products outlined in Item 14 of the application Form NRC-2 should be supplemented, as appropriate, with the following:

a. A description of the quality assurance program, including process control measures, sampling plans, product examination and testing, acceptance criteria.and testing and examination of prototype or production products, which establishes that the products will consistently have the radiation safety characteristics described to the Commission and that these charac-teristics will not be significantly degraded over the expected lifetime of each product.b. If appropriate, a description of labeling, including label materials, content, location on the product, and method of attachment.

c. Estimates of radiation doses to users of the products and others who 'may be exposed to radiation or radioactive materials from the products and the basis for these estimates.

5. AMENDMENTS

TO LICENSES Licensees are required to conduct their programs in accordance with statements, rcprescntationis, and procedures contained in the licenso application and supportive documents.

The license must therefore b.aniended if the licensee plans to make any changes in facilities, equipment (including monitoring and survey instruments), procedures, personnel, or source material to be used.Applications for license amendments may be filed either on the application form or in letter form. The application should identify the license by number and should clearly describe the exact nature of the changes.additions, or deletions.

References to previously submitted information and documents should be clear and specific and should identify the pertinent informa-tion by date, page, and paragraph.

6. RENEWAL OF A LICENSE An application for renewal of a license should be filed at least 30 days prior to the expiration date. This will ensure that the license does not expire until final action on the application has been taken by the NRC as provided for in paragraph

40.43(b) of 10 CFR Part 40.Renewal applications should be filed on the Form NRC-2, appropriately supplemented, and should contain complete and up-to-date information about the applicant's current program.In order to facilitate the review process, the applica-tion for renewal should be submitted without reference to previously submitted documents and information.

If such references cannot be avoided, they should be clear and specific and should identify the pertinent informa-tion by date, page. and paragraph.

10.4-7 APPENDIX fORM CC-2 FORM APPROVED (- OUREAU OF BUDOET NO 3-Ao002 UNITED STATES ATOMIC ENERGY COMMISSION

APPLICATION

FOR SOURCE MATERIAL LICENSE Pursuant to the regulations in Title 10, Code ot Federal Regulations, Chapter 1, Part 40, application is hereby made for a license to receive, possess, use, transfer, deliver or import into the United States, source material for the activity or activities described.

1. tCAch 2. N1AME OF APPLICANT 0 (a) New license C (b) Amendment to License No.

3. PRINCIPAL

auSINES.S

ADODESIS 3 (c) Renewal of License No.O (d) Previous License No.4 STATE THE ADDRESSIES)

AT WHICH SOURCE MATERIAL WILL oB POSSESSED

OR USED 5 BUSINESS OR OCCUPATION

&. (1 IF APP.ICANT

IS AN INDIVIDUAL.

STATE (b) AGE CITIsrs I 7 DESCRIBE

FOR WHICH SOURCE MATERIAL WILL BEr USED 0 %TATE THE TYPE OR TYPES. CHEMICAL FORM OR FORMS. AND QUANTITIES

OF SOURCE MATERIAL YOU PROPOSE TO 1RE1CCIVE.

POSSESS. USC. OR TRANSFER UNDER THE LICENSE (a) TYPE (b) CHEMICAL FORM (c) PHYSICAL FORM (Includin (cd) MAXIMUM AMOUNT AT% U or Th.) ANY ONE TIME (in pounds)NATUHAL URANIUM URANIUM DEPLETID IN THE U-235 ISOTOPE THORIUM tIsOrOPLi (a) MAXIMUM TOTAL QUANTITY OFr 6OUV4CE MATERIAL YOU WILL. HAVE ON HAND AT ANY TIME (.inpou~d.1

9 DESCRIBE THE CHEMICAL.

PHYSICAL.

METALLURGICAL.

OR NUCLEAR PROCESS OR PROCCISES

IN WHICH THE SOURCE MATIERIAL.WILL

BE USED. I NOICATING

THE MAXIMUM AMOUNT OF SOURCE MATERIAL INVOLVED IN EACH PROCESS AT ANY ONE TIME. AND PROVIDING A THOROUGH EVALUATION

Or THE POTENTIAL

RADIATION

HAZARDS ASSOCIATED

WITH EACH STEP OF THOSE PROCESSES.

10 OISCRcIIUE

THE MINIMUM TECHNICAL

OUALIFICATIONS

INCLUDING

TRAINING AND 1EXPERIENCE

THAT WILL BE RECUIRO OC" AP-PLICANT'S

SUPERVISORY

PERSONNEL

INCLUDING

PERSON RESPONSIBLE

FOR RADIATION

SAFcTy PROGRAM (OR OF APPLICANT

IF APPLICANT

IS AN INDIVIDUAL).

1l OfSCRIBE THE LOUIPMENT

AND FACILITIES

WHICH WILL 0E USED TO PROTECT HEALTH AND MINIMIZe OANGEIR TO LIFE OR PROPERTY AND RDELAfE 1 HE kjU.E OF THEN LOUIPM ENT ANOFACILITIES

TOTHE OPERATIONS

LISTEo IN ITEJM gINCLUODE(a)RAOIATtONPDETECTION

AND RELA T ED INTF1UMENTS

including badgln. dosdmctIn counters, lit sampling.

and other survey equtpmrriwt soappeovelate.

The d,.etiptlon o1 rtadltl-fi ICIftI~tPI

If~c t IA)lI Icilu*.lt the Inttrumnet characteristic*

ouch as type of radiation detectd. window Ihicbnfst, and the rgnsr(e) of each in.stUwme4flt).

(6) METHOD.

AND STANDARDS

USED IN CALIBRATING

INSTRUMENTS

LISTED IN (W) ABOVE. INCLUDING

AIR SAMPLINGI EQUIPMENT (for fim badges. sprtrfy method of casltahl and processing or amem

10.4.8 APPENDIX-Continued Page 2 1I(c). VENTILATION

ECQUIPMENT

WHICH WILL BE U!;rD IN OPERATIONS

WHICH PRoDUCc DUo?. rumes. OR GA5C:E. INCLUDING PLAN VIEW SHOWIN4G TYPE AND LOCATIONOF

HOOD0 ANDr ILTCES.MINIMUM

VELOCITIES

MAINTAINCOAT

H10 OPLSNI.G AND PRO.CEOURES FO)l TESTING SUCH EQUIPMENT It. DESCRIBE PROPOSED PROCEDURES

TO PROTECT HECALTH AND MINIMIZC DANGER TO LI4E A^NO PROPERTY AND RELATE PRO.CEDURES TO THE OPERATIONS

LISTED IN ITEM 9ý INCLUDE (e) SAFrTY FEATURES AND P4OCCDURnEs TU AVOID NONNUCLLA" AC"I.CENTS, SUCH AS FIRE. EXPLOSION.

ETC , IN sOURCC MATERIAL STORAGE AND PsG'oCcSsaG

AMFAI, 4b) EMERGENCY tb) ~ n ;;--, -MREC -V"N r~5.l*CLLL

JML- H HLLV NTO ACCIDENTý!""'C" MIGHT INVOLVE SOURCE MATERIAL (*) DETAILED DESCRIPTION

OF RAOIAl ION SURVrEY PROGRAM AND PROCEDURES.

1I. WASTE PRODUCTS:

If none will be gellerelted.

state "'None" opposite (a). below. It waste products will be dener.ated. check here 0 and esplain on a supplemental sheet: (a) Quantity and type or radioactive waste that will be generated.(b) Detailed procedures for waste disposal.I&. IF PRODUCTS FOR DISTRIBUTION

TO THE GENERAL PUBLIC UNDER AN EXEMPTION

CONTAINED

IN 10 CFR 40 ARE TO BE MANUFACTURED, USE A SUPPLEMENTAL

SHEET TO FURNISH A DETAILED DESCRIPTION

OF THE PRODUCT. INCLUDING: (a) PERCENT SOURCE MATERIAL IN THE PRODUCT AND ITS LOCATION IN THE PRODUCT.(b) PHYSICAL DESCRIPTION

OF THE PRODUCT INCLUDING

CHARACTERISTICS.

IF ANY. THAT WILL PREVENT INHALATION

OR INGESTION

OF SOURCE MATERIAL THAT MIGHT BE SEPARATED FROM THE PRODUCT.(c) BETA AND BETA PLUS GAMMA RADIATION

LEVELS (Specify instrument used. date of calibration and calibration technique used) AT THI SURFACE OF THE PRODUCT AND AT 12 INCHES.(d) METHOD OF ASSURING THAT SOURCE MATERIAL CANNOT BE DISASSOCIATED

FROM THE MAN.UFACTURED

PRODUCT.CERTIFICATE (This item must be completed by applicant)

is. The applicant, and any official executing this certificate on behalf of the applicant named in Item 2, certify that this application is prepared in conformity with Title 10, Code of Federal Regulations, Part 40, and that all information contained herein, including any supplements attached hereto, is true and correct to the beat of our knowledge and belief.Dated lApph~eant na~med In haem 3)BY: APrent of type name under u'ans lueir),Tart ut ..-II'Iwng 0MCe', .) ther,,ed'

ato anE behalf of Ahc applwatsC WAItNlN.%(:

1.11 II.S.I. Sreclioti

1001. Art iruni Jue'*V. 1918;t "1 Six(. 749; makmh ts haefrnmineal Ouinje to MakP a Will(Ully UNA' S ,IaC meni or rt'plrr~t~snticin lo an) departmenl t orallene of the' Unlied Slhiell 9410 anY Muller within Its JurisdIction.

it u's ovwma4l mIft pU Inoaal@10.4.9