cook, flatt & strobel engineers, p.a., missouri nuclear

8
CFS ENGINEERS cfse.com 2930 SW Woodside Dr. Topeka, Kansas 66614 (78 5) 272-4706 (785) 272-4736 Fax www.cfse .com Other Offices: Kansas City, Missouri Lawrence, Kansas Kansas City, Kansas Manhattan, Kansas Wichita, Kansas Kenneth M. Blair, P .E. Chairman a/the Board Robert S. Chambers, P.E. President- Treasurer Sabin A. Yanez, P.E. Sr. Vice President. Secretary Kevin K. Holland, P.E. Vice President Daniel W. Holloway, P.E. Vice President Charles C. lePage, P.E. Vice President Lance W. Scott, P .E. Vice President Melvin D. Chapman, P.E. Consultant October 10, 2012 Jennifer Bishop Materials Licensing Branch U.S. Nuclear Regulatory Commission Region III 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4351 Re: Missouri Nuclear Licensing Control Number 579076 Dear Ms. Bishop: In reference to your conversation with Bill Bender on September 27,2012, we are enclosing Appendix B with answers for questions 5 through 11. If additional infonnation is needed contact our Radiation Safety Officer, Bill Bender at 785-554-8967. Enclosures RECEiVEO OC116101'l

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Page 1: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

CFS ENGINEERS

cfsecom

2930 SW Woodside Dr Topeka Kansas 66614

(785) 272-4706 (785) 272-4736 Fax

wwwcfsecom

Other Offices Kansas City Missouri

Lawrence Kansas Kansas City Kansas Manhattan Kansas

Wichita Kansas

Kenneth M Blair PE Chairman athe Board

Robert S Chambers PE President-Treasurer

Sabin A Yanez PE Sr Vice President Secretary

Kevin K Holland PE Vice President

Daniel W Holloway PE Vice President

Charles C lePage PE Vice President

Lance W Scott PE Vice President

Melvin D Chapman PE Consultant

October 10 2012

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

Re Missouri Nuclear Licensing Control Number 579076

Dear Ms Bishop

In reference to your conversation with Bill Bender on September 272012 we are enclosing Appendix B with answers for questions 5 through 11

If additional infonnation is needed contact our Radiation Safety Officer Bill Bender at 785-554-8967

Enclosures

RECEiVEO OC116101l

Appendix B

Suggested Format for Providing Information Requested in Items 5

through 11

APPElTDIX B

ITEMS 5 AND 6 MATERIALS TO BE POSSESSED AND PROPOSED USES

Yes No Radioisotope

Cesium-137

Americiumshy241

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Troxler 3430

Device manufactJr~~9r distributor and model number

Troxler 3430 3440

Sealed source manufacturer or distributor and model number

Troxler 3430 3440

Device manufacturer or distributor and model number

Troxler 3430 3440

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Not to exceed either the maxImum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed on SSD

Certificate

Yes~

Specific descliption of the gauge use

Yes il

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

B-1 NUREG - 1556 Vol 1 Rev 1

APPENDIXB

No RadioisotopeYes

Californiumshy252

Other Isotope (Specify)

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certi ficate

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed onSSD

Certificate

Yes 0

Specific descliption of the gauge use

Yes 0

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

51 Not applicable

o Uses are

(Submit safety analysis supporting safe use)

~Not applicable

o Uses are

(Submit safety analysis supporting safe use)

Financial Assurance Required and Evidence ofFinancial Assurance Provided

NUREG - 1556 Vol 1 Rev 1 B-2

APPENDIXB

ITEMS 7 THROUGH 11 TRAINING AND EXPERIENCE FACILITIES AND EQUIPMENT RADIATION SAFETY PROGRAM AND WASTE DISPOSAL

Item No And Title

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND EXPERIENCE shyRADIATION SAFETY OFFICER

Name Bill Bender

8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS

9 FACILITIES AND EQUIPMENT

10 RADIATION SAFETY PROGRAM - AUDIT PROGRAM

10 RADIATION SAFETY PROGRAMshyTERMINATION OF ACTIVITIES

Suggested Response

Before obtaining licensed materials the proposed RSO will have successfully completed one of the training courses described in Cl1teria in the section entitled Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer in NUREG-1556 Vol 1 Rev 1 dated November 2001

Before using licensed materials authorized users will have successfully completed one of the training course described in Criteria in the section entitled Training for Individuals Working In or Frequenting Restricted Areas in lTUREG-1556 Vol 1 Rev I dated November 2001

No information needs to be subInitted in response to this item key issues are addressed under Radiation Safety Program - Public Dose and Radiation Safety Program shyOperating and Emergency Procedures

The applicant is not required to and should not submit its audit program to NRC for review during the licensing phase

The applicant is not required to submit a response to the termination of activities section during the initial application However when the license expires when the licensee ceases operation NRC Form 314 must be submitted

Yes Alternative Procedures Attached

Drishy

0~

Separate Item 9 Response

Need Not Be Submitted With Application

Need Not Be Submitted With Application

Need Not Be Submitted With Application

10 RADIATION SAFETY We will either possess and use or have access ~ 0 PROGRAM shy SURVEY to and use a radiation survey meter that meets INSTRUMENTS the Criteria in the section entitled Radiation

Safety Program -Instruments in NUREG-1556 Vol 1 Rev 1 dated November 2001

B-3 NUREG - 1556 Vol 1 Rev 1

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 2: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

Appendix B

Suggested Format for Providing Information Requested in Items 5

through 11

APPElTDIX B

ITEMS 5 AND 6 MATERIALS TO BE POSSESSED AND PROPOSED USES

Yes No Radioisotope

Cesium-137

Americiumshy241

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Troxler 3430

Device manufactJr~~9r distributor and model number

Troxler 3430 3440

Sealed source manufacturer or distributor and model number

Troxler 3430 3440

Device manufacturer or distributor and model number

Troxler 3430 3440

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Not to exceed either the maxImum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed on SSD

Certificate

Yes~

Specific descliption of the gauge use

Yes il

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

B-1 NUREG - 1556 Vol 1 Rev 1

APPENDIXB

No RadioisotopeYes

Californiumshy252

Other Isotope (Specify)

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certi ficate

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed onSSD

Certificate

Yes 0

Specific descliption of the gauge use

Yes 0

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

51 Not applicable

o Uses are

(Submit safety analysis supporting safe use)

~Not applicable

o Uses are

(Submit safety analysis supporting safe use)

Financial Assurance Required and Evidence ofFinancial Assurance Provided

NUREG - 1556 Vol 1 Rev 1 B-2

APPENDIXB

ITEMS 7 THROUGH 11 TRAINING AND EXPERIENCE FACILITIES AND EQUIPMENT RADIATION SAFETY PROGRAM AND WASTE DISPOSAL

Item No And Title

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND EXPERIENCE shyRADIATION SAFETY OFFICER

Name Bill Bender

8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS

9 FACILITIES AND EQUIPMENT

10 RADIATION SAFETY PROGRAM - AUDIT PROGRAM

10 RADIATION SAFETY PROGRAMshyTERMINATION OF ACTIVITIES

Suggested Response

Before obtaining licensed materials the proposed RSO will have successfully completed one of the training courses described in Cl1teria in the section entitled Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer in NUREG-1556 Vol 1 Rev 1 dated November 2001

Before using licensed materials authorized users will have successfully completed one of the training course described in Criteria in the section entitled Training for Individuals Working In or Frequenting Restricted Areas in lTUREG-1556 Vol 1 Rev I dated November 2001

No information needs to be subInitted in response to this item key issues are addressed under Radiation Safety Program - Public Dose and Radiation Safety Program shyOperating and Emergency Procedures

The applicant is not required to and should not submit its audit program to NRC for review during the licensing phase

The applicant is not required to submit a response to the termination of activities section during the initial application However when the license expires when the licensee ceases operation NRC Form 314 must be submitted

Yes Alternative Procedures Attached

Drishy

0~

Separate Item 9 Response

Need Not Be Submitted With Application

Need Not Be Submitted With Application

Need Not Be Submitted With Application

10 RADIATION SAFETY We will either possess and use or have access ~ 0 PROGRAM shy SURVEY to and use a radiation survey meter that meets INSTRUMENTS the Criteria in the section entitled Radiation

Safety Program -Instruments in NUREG-1556 Vol 1 Rev 1 dated November 2001

B-3 NUREG - 1556 Vol 1 Rev 1

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 3: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

APPElTDIX B

ITEMS 5 AND 6 MATERIALS TO BE POSSESSED AND PROPOSED USES

Yes No Radioisotope

Cesium-137

Americiumshy241

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Troxler 3430

Device manufactJr~~9r distributor and model number

Troxler 3430 3440

Sealed source manufacturer or distributor and model number

Troxler 3430 3440

Device manufacturer or distributor and model number

Troxler 3430 3440

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Not to exceed either the maxImum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed on SSD

Certificate

Yes~

Specific descliption of the gauge use

Yes il

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

ONot applicable

o Uses are

(Submit safety analysis supporting safe use)

B-1 NUREG - 1556 Vol 1 Rev 1

APPENDIXB

No RadioisotopeYes

Californiumshy252

Other Isotope (Specify)

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certi ficate

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed onSSD

Certificate

Yes 0

Specific descliption of the gauge use

Yes 0

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

51 Not applicable

o Uses are

(Submit safety analysis supporting safe use)

~Not applicable

o Uses are

(Submit safety analysis supporting safe use)

Financial Assurance Required and Evidence ofFinancial Assurance Provided

NUREG - 1556 Vol 1 Rev 1 B-2

APPENDIXB

ITEMS 7 THROUGH 11 TRAINING AND EXPERIENCE FACILITIES AND EQUIPMENT RADIATION SAFETY PROGRAM AND WASTE DISPOSAL

Item No And Title

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND EXPERIENCE shyRADIATION SAFETY OFFICER

Name Bill Bender

8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS

9 FACILITIES AND EQUIPMENT

10 RADIATION SAFETY PROGRAM - AUDIT PROGRAM

10 RADIATION SAFETY PROGRAMshyTERMINATION OF ACTIVITIES

Suggested Response

Before obtaining licensed materials the proposed RSO will have successfully completed one of the training courses described in Cl1teria in the section entitled Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer in NUREG-1556 Vol 1 Rev 1 dated November 2001

Before using licensed materials authorized users will have successfully completed one of the training course described in Criteria in the section entitled Training for Individuals Working In or Frequenting Restricted Areas in lTUREG-1556 Vol 1 Rev I dated November 2001

No information needs to be subInitted in response to this item key issues are addressed under Radiation Safety Program - Public Dose and Radiation Safety Program shyOperating and Emergency Procedures

The applicant is not required to and should not submit its audit program to NRC for review during the licensing phase

The applicant is not required to submit a response to the termination of activities section during the initial application However when the license expires when the licensee ceases operation NRC Form 314 must be submitted

Yes Alternative Procedures Attached

Drishy

0~

Separate Item 9 Response

Need Not Be Submitted With Application

Need Not Be Submitted With Application

Need Not Be Submitted With Application

10 RADIATION SAFETY We will either possess and use or have access ~ 0 PROGRAM shy SURVEY to and use a radiation survey meter that meets INSTRUMENTS the Criteria in the section entitled Radiation

Safety Program -Instruments in NUREG-1556 Vol 1 Rev 1 dated November 2001

B-3 NUREG - 1556 Vol 1 Rev 1

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 4: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

APPENDIXB

No RadioisotopeYes

Californiumshy252

Other Isotope (Specify)

Manufacturer or Distributor Model No

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Sealed source manufacturer or distributor and model number

Device manufacturer or distributor and model number

Quantity

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certi ficate

Not to exceed either the maximum activity per source or maximum activity per device as specified in Sealed Source and Device Registration Certificate

Use As Listed onSSD

Certificate

Yes 0

Specific descliption of the gauge use

Yes 0

Specific description of the gauge use

Specify Other Uses Not

Listed on SSD Certificate

51 Not applicable

o Uses are

(Submit safety analysis supporting safe use)

~Not applicable

o Uses are

(Submit safety analysis supporting safe use)

Financial Assurance Required and Evidence ofFinancial Assurance Provided

NUREG - 1556 Vol 1 Rev 1 B-2

APPENDIXB

ITEMS 7 THROUGH 11 TRAINING AND EXPERIENCE FACILITIES AND EQUIPMENT RADIATION SAFETY PROGRAM AND WASTE DISPOSAL

Item No And Title

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND EXPERIENCE shyRADIATION SAFETY OFFICER

Name Bill Bender

8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS

9 FACILITIES AND EQUIPMENT

10 RADIATION SAFETY PROGRAM - AUDIT PROGRAM

10 RADIATION SAFETY PROGRAMshyTERMINATION OF ACTIVITIES

Suggested Response

Before obtaining licensed materials the proposed RSO will have successfully completed one of the training courses described in Cl1teria in the section entitled Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer in NUREG-1556 Vol 1 Rev 1 dated November 2001

Before using licensed materials authorized users will have successfully completed one of the training course described in Criteria in the section entitled Training for Individuals Working In or Frequenting Restricted Areas in lTUREG-1556 Vol 1 Rev I dated November 2001

No information needs to be subInitted in response to this item key issues are addressed under Radiation Safety Program - Public Dose and Radiation Safety Program shyOperating and Emergency Procedures

The applicant is not required to and should not submit its audit program to NRC for review during the licensing phase

The applicant is not required to submit a response to the termination of activities section during the initial application However when the license expires when the licensee ceases operation NRC Form 314 must be submitted

Yes Alternative Procedures Attached

Drishy

0~

Separate Item 9 Response

Need Not Be Submitted With Application

Need Not Be Submitted With Application

Need Not Be Submitted With Application

10 RADIATION SAFETY We will either possess and use or have access ~ 0 PROGRAM shy SURVEY to and use a radiation survey meter that meets INSTRUMENTS the Criteria in the section entitled Radiation

Safety Program -Instruments in NUREG-1556 Vol 1 Rev 1 dated November 2001

B-3 NUREG - 1556 Vol 1 Rev 1

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 5: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

APPENDIXB

ITEMS 7 THROUGH 11 TRAINING AND EXPERIENCE FACILITIES AND EQUIPMENT RADIATION SAFETY PROGRAM AND WASTE DISPOSAL

Item No And Title

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND EXPERIENCE shyRADIATION SAFETY OFFICER

Name Bill Bender

8 TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS

9 FACILITIES AND EQUIPMENT

10 RADIATION SAFETY PROGRAM - AUDIT PROGRAM

10 RADIATION SAFETY PROGRAMshyTERMINATION OF ACTIVITIES

Suggested Response

Before obtaining licensed materials the proposed RSO will have successfully completed one of the training courses described in Cl1teria in the section entitled Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer in NUREG-1556 Vol 1 Rev 1 dated November 2001

Before using licensed materials authorized users will have successfully completed one of the training course described in Criteria in the section entitled Training for Individuals Working In or Frequenting Restricted Areas in lTUREG-1556 Vol 1 Rev I dated November 2001

No information needs to be subInitted in response to this item key issues are addressed under Radiation Safety Program - Public Dose and Radiation Safety Program shyOperating and Emergency Procedures

The applicant is not required to and should not submit its audit program to NRC for review during the licensing phase

The applicant is not required to submit a response to the termination of activities section during the initial application However when the license expires when the licensee ceases operation NRC Form 314 must be submitted

Yes Alternative Procedures Attached

Drishy

0~

Separate Item 9 Response

Need Not Be Submitted With Application

Need Not Be Submitted With Application

Need Not Be Submitted With Application

10 RADIATION SAFETY We will either possess and use or have access ~ 0 PROGRAM shy SURVEY to and use a radiation survey meter that meets INSTRUMENTS the Criteria in the section entitled Radiation

Safety Program -Instruments in NUREG-1556 Vol 1 Rev 1 dated November 2001

B-3 NUREG - 1556 Vol 1 Rev 1

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 6: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

APPENDlXB

Item No And Title Suggested Response Yes Alternative Procedures

Attached

Physical inventories will be conducted at ~ 0 PROGRAM - MATERIAL

10 RADIATION SAFETY intervals not to exceed 6 months to account

RECEIPT AND for all sealed sources and devices received ACCOUNTABILITY and possessed under the license

Either we will maintain for inspection by10 RADIATION SAFETY 0 PROGRAMshy

~ NRC documentation demonstrating that

OCCUPATIONAL unmonitored individuals are not likely to DOSIMETRY receive a radiation dose in excess of

10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by an NVLAP-approved processor that is exchanged at a frequency recommended by the processor

The applicant is not required to submit a 10 RADIATION SAFETY Need Not Be Submitted PROGRAM - PUBLIC response to the public dose section during the With Application DOSE licensing phase This matter will be examined

during an inspection

We will implement and maintain the operating ~ 0 PROGRAMshy

10 RADIATION SAFETY and emergency procedures in Appendix H of

OPERATING AND NUREG-1556 Vol I Rev I dated EMERGENCY November 2001 and provide copies of these PROCEDURES procedures to all gauge users and at each job

site

OR

Operating and emergency procedures will be 0 developed implemented and maintained and will meet the criteria in the section entitled Radiation Safety Program - Operating and Emergency Procedures in NUREG-1556 Vol 1 Rev I dated November 2001

Leak tests will be performed at intervals 0 PROGRAM- LEAK lEST

10 RADIATION SAFETY ~ approved by NRC or an Agreement Sate and

Thespecified in the Sealed Source and Device

information inRegistration Sheet Leak tests will be

Appendix Jperformed by an organization authorized by

supporting aNRC or an Agreement State to provide leak

request totesting services for other licensees or using a

perform leakleak test kit supplied by an organization

testing andauthorized by NRC or an Agreement State to

sampleprovide leak test kits to other licensees and

analysis isaccording to the kit suppliers instructions

attached

NUREG - 1556 Vol I Rev 1 B-4

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 7: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

APPENDIXB

Item No And Title Suggested Response Yes Alternative Procedures Attached

Routine Cleaning and Lubrication 10 RADIATION SAFETY PROGRAM-

We will implement and maintain procedures 0~ MAINTENANCE for routine maintenance of our gauges according to each manufacturers recommendations and instructions

Non-Routine Maintenance

We will send the gauge to the manufacturer or 0 other person authorized by NRC or an

il The

Agreement State to pelform non-routine information

maintenance or repair operations that require listed in

the removal of the source or source rod from Appendix G

the gauge supporting a request to perform non-routine maintenance in-house is attached

The applicant is not required to submit its 10RADIATION SAFETY Need Not Be Submitted PROGRAM- response to transportation during the licensing With Application

TRANSPORTATION process However this issue will be reviewed during inspection

The applicant is not required to submit a 11 WASTE MANAGEl1ENTshy Need Not Be Submitted GAUGE DISPOSAL AND response to waste management during the With Application TRANSFER licensing process However the licensee

should develop implement and maintain gauge transfer and disposal procedures in its radiation protection program

B-5 NUREG - 1556 Vol 1 Rev 1

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I

Page 8: Cook, Flatt & Strobel Engineers, P.A., Missouri Nuclear

CFS ENGINEERS 2930 SW Woodside Drive

Topeka Kansas 66614

Jennifer Bishop Materials Licensing Branch US Nuclear Regulatory Commission Re gion III 2443 Warrenville Road Suite 210 Lisle Illinois 60532-4351

1111 1i IIII IImiddot I II I 111 Ill II 11 11111I