ML20024H307
| ML20024H307 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 05/28/1991 |
| From: | Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| To: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9105310172 | |
| Download: ML20024H307 (8) | |
Text
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/,,e'o'c UNITED DTATED DEPARTMENT OF COMMERCE f p\\/
Natio. int Institute of Stonder de and Toohnology
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May 28,1991 George 11. Ilidinger, Section Leader Ref: Dacket No. 70 398 Uranium Fuel Section License No SNM 362 Fuel Cycle Safety llranch Division of Industrial and Medical Nuclear Safety, NMSS United States Nuclear Regulatory Commission Washington, D. C. 20555 l
Dear Mr. Ilidinger:
l Enclosed are copies of the changes to the text of the NIST Materials License Document for License Number SNM 362, with the pages dated 05/28/91. We developed this following discussions with Dr. Soong of your office. Please replace the text from the earlier submission with the enclosed replacement pages.
We hope this submission is satisfactory for your review needs. Should you have further questions, please contact Mr. T. Ilobbs, Chief of the NIST IIcalth Physics office, on 975 5800, or Mr. L. Slaback, Supervisonj IIcalth Physicist, on 975 5810.
Sincerely, 6
C h L. E. Pevey, Chief Occupational IIcalth and Safety Division
(' Materials License Manager) enclosures I
/
l l
9105310172 910528 PDR ADOCV 0700039::
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L 1
general purpose laboratories, i.e., Buildings 220 through 226.
materials and equipment irradiations SRL source preparations SRL SPL, GPL source calibrations SRL SPL, GPL instrument calibrations SRL, SPL GPL
=
sample assays - SRL, SPL, GPL source characterizations SRL
=
instrument and device characterizations SRL, SPL, GPL
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reference or counting source uses ADhi, SRL, SPL, GPL
=
radiochemistry SRL, SPL GPL
=
general research and development ADhi, SRL, SPL GPL
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sources incorporated into devices or equipment ADhi, SRL, SPL, GPL
=
miscellaneous, e.g., static elimination ADht, SRL, SPL, GPL 13 Exemptions and Special Authorizations We request exemption from the requirement to maintain criticality monitors or conduct a.
criticality reviews because all SNh1 except for PuBe sealed sources are controlled to maintain a minimum separation of three feet between each 300 grams of plutonium or U 233 or uranium containing greater than 20% U 235 or combination of these. Each room or area involving SNhi operations is the responsibility of a single person who controls the movement of materials for that area according to written procedures to insure that the material quantity limits are maintained.
b.
We request that radioactive material use may be authorized for an off-site location subject to the following provisions:
the proposal is reviewed and approved by Health Physics and, if required, by the Radiation Safety Committee.
the radioactive material is controlled by an authorized individual, who possesses written operating instructions while engaged in the project.
the radioactive material is an integral part of a measurement instrument or a contained source, such as a check or reference source.
the total quantity of radioactive material for a single authorized use may not exceed ten times the activity listed in 10CFR20, Appendix C, or, for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity.
c.
We request permission to dispose of radioactive materials as ordinary trash when the conditions specified in 10CFR35.92 are met. Short lived radioactive material with long-lived daughter radioactive nuclides will not be considered for this disposal mechani::m.
d.
We request authority to release contaminated equipment to uncontialled areas in accordance with the USNRC's 1987 " Guidelines for decontamination of facilities and equipment prior to release for unrestricted use or termination of licenses for byproduct, source, or special nuclear material." A copy of the guidelines is attached to this chapter.
5/28/91 1-1 3
9 to be followed, including participants, frequency and type of bioassay measurements and dose assessments, and actions levels and actions to be taken. Bioassay programs will be established similar to those described in Regulatory Guide 8.11 for uranium, Regulatory Guide 8.20 for iodine, Regulatory Guide 8.26 for fission and activation products, and the HPSSC draft standard for plutonium.
3.2.5 Local Emergency Actions Emergency evacuation is required for unexpected or inadvertent situations that could cause radiation doses in excess of the applicable whole-body radiation exposure limits and that cannot be controlled with prompt and appropriate actions. Health Physics review is required for such situations to determine work times for necessary actions.
3.2.6 Sealed Source Control A. 1. Each sealed source containing more than 100 microcuries of beta and/or gamma emitting material or more than 10 microcuries of alpha emitting material, other than Hydrogen 3, with a halflife greater than 30 days and in any form other than gas, shall be tested for leakage and/or the contamination at intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that a test has been made within 6 months prior to the transfer, a sealed source received from another person shall not be put into use until tested.
2.
The periodic leak test required by this section does not apply to sealed sources that are stored and not being used. Prior to any use or transfer to another person, the source shall be leak tested within 6 months prior to the date of use or transfer.
B.
The test shall be capable of detecting the presence of 0.005 microcuries of radioactive material on the test sample, The sample shall be taken from the sealed source or appropriate accessible surfaces of the comainer or from the device where the sealed source L
is mounted or stored in which one might expect contamination to accumulate. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the USNRC.
If the test reveals the following:
1.
The presence of 0.005 microcuries or more of removable contamination from the sealed l
sources other than described below, or 2.
The presence of 0.05 microcuries or more of removable contamination from the teletherapy sealed source, or 3.
- An indication that the irradiator sealed source which is stored in the water pool for shielding L
purposes is leaking, then NIST shall immediately withdraw the ' sealed source from use and shall can*e it to ' be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed of in accordance with USNRC regulations.
Within 5 days after determining that any source has leaked, NIST shall file a report with the l
Division of Industrial and Medical Nuclear Safety, USNRC, Washington, D. C. 20555, describing the source, test results. extent of contamination, apparent or suspected cause of source failure, and corrective action taken. A copy of the report shall be sent to the Administrator of the NRC Regional Office for Region I.
5/28/91 1-3 3
i CilAPTER 4 ENVIRONMENTAL PROTECTION 4.1 Elfluent Control Systems 11ealth Physics monitors airborne effluents to provide an assessment of radioactivity concentrations at the discharge point at least once in each quarter for continuing operations or at least once for short term operations, to establish that releases are less than 10% of the concentration given in 10CFR20, Appendix B. Table 11, averaged over a calendar quarter. Should the concentration exceed that value, continuous monitoring will be initiated. Where effluent monitoring is required air sampling arrangements shall be designed to insure that air samples taken will be representative of the actual release for the sampling period. Measurement of air sampling media will be with a lower limit of detection of no greater than 5% of the concentration given in 10CFR20, Appendix B. Table 11, for the major radionuclide involved in the process being monitored. If the IIealth Physics group determines that the proposed work requires air sampling, the airborne concentration of radioactivity in the worker's breathing zone air will be determined after each working day.
(also added criteria for selecting processes to be monitored in Part II) 5/28/91 1-4-1 l
l
l CHAPTER 5 -
SPECIAL PROCESS COhth11ThiENTS 5.1 Special Nuclear hiaterial Accounting and Control Accounting and control of special nuclear materials to prevent and detect unauthorized diversions of material quantities are conducted according to provisions of 10CFR70. llealth Physics maintains the SNh1 accountability office for NIST and administers the accountability program.
5.2 Alpha Emitting Nuclide Chemistry Operations The activities of alpha-emitting nuclides in dispersable form in any one laboratory operation are controlled as described in Table 1.51. Ilealth Physics may approve limits above those shown in the table or may approve variances to the conditions shown for lower toxicity nuclides or if the
_ proposing user can demonstrate adequate provision for safety, such as training, equipment, or other considerations. Radiochemistry hoods are provided with local indicators for air flow and operators are instructed to observe them. Should an air llow system for ay hood in use fail, the operator s to suspend operations in that hood and notify IIcalth Physics immediately. llealth Physics reviews the situation and determines the need for and the type of further action. Should gloves break or other operative defect appear for a glove box, any processes being conducted in the box are to be suspended and llealth Physics notified immediately so that corrective action may be planned.
TAllLE 1.5-1 ALPHA CIIEN11STRY LAllORATORY LastlTS AND RULES FOR lilGil TOXICITY' htATERIALS AND URANIUh1 TYPE OF OPERATION LIMIT (lesser of)
CONDITIONS simple storage 100 mci or 10 g in closed containers simple wet chemistry, e.g., aliquot extraction 10 mci or 1 g within hoods normal chemistry, e.g., analysis 1 mci or 0.1 g in llEPA fdtered hoods complex wet chemistry, e.g., complex apparatus 0.1 mci or 0.01 g in llEPA filtered hoods simple dry operations 0.1 mci or 0.01 g in llEPA filtered hoods dry and dusty operations, e.g., grinding 0.01 mci or 0.001 g in glove boxes
- see, e.g., IAEA Safety Series No. 38, Radiation Protection Procedures NOTE:
Plutonium in solution will be limited to less than 10 millieuries at any one location or in any one process.
5/28/91 I+1
I CllAPTER 6 -NUCI EAR CRITICALITY SAFETY No accumulations of special nuclear materials exceeding 300 grams are permitted in any one area or room, with the exception of plutonium sealed sources. Thus, no criticality program is necessary.
CilAPTER 7 -DECOMMISSIONING PI AN As a Federal agency, the National Institute of Standards and Technology will generate and implement a decommissioning plan at the time that operations are to be terminated and in accordance with Federal rules and regulations in effect at that time.
CilAPTER 8 -EMERGENCY PIAN NIST shall maintain and execute the response measures of the Radiological Contingencey Plan submitted to the NRC on Sept. 3,1982. NIST shall prepare and maintain implementing procedures for the Radiological Contingency Plan. NIST shall make no change in the Radiological Contingency Plan that would decrease the response ellectiveness of the Plan without prior NRC approval as evidenced by a license amendment. NIST may make changes to the Radiological Contingency Plan without prior NRC approval if the changes do not decrease the response effectiveness of the Plan.
NIST shall furnish the Chief, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS, USNRC, Washington, D. C. 20555 a report containing a description of each change within 6 months after the change is made.
5/28/91 1-5-2
CilAPTER 13 -
OCCUPATIONAL RADIATION EXPOSURES 13.1 Occupational Exposure Analysis For the period from 1985 through 1989 no monitored employee accumulated in any year a total externaldose equivalent greater than 25G of the annuallimit from external sources involved in materials licensed operations. Internal dose equivalents from these operations have been negligible. Measurements of radioactivity concentrations in air showed less than minimum detectable levels, i.e., less than at most 10% of MPC, demonstrating that no radiation woiker was exposed to significant air activity concentrations iesulting from radiation work for 1985 through 1989 The principal exposure-producing operation for materials licensed operations for some years has been the Cf 252 irradiation project. This is expected to continue into the foreseeable future. Measures to limit exposures to these sources have been and are being implemented by the work group. These measures include installing remote handling devices for source transfer, planning for relocation of the irradiation facility to a more isolated environment, and stricter administrative control for operations timing.
No off normal occurrence resulting in excessive exposure has been documented. Bioassays of tritium workers, workers from gaseous iodine processes, and other potential internal dose contributing work have demonstrated extremely good control of dispersable radioactive materials.
Between 1985 and 1991, 827 hood air flow measurements were performed; only two adjustments for low air flow resulted from this monitoring. For the same period,73 air samples indicated that, based on a beta MPC of 3 X 10* microcuries per milliter and an alpha MPC of 6 X 10 " microcuries per milliter, the beta exposure to any individual was 0.22 MPC-hours uhile the alpha exposure, subject to a great uncertainty from many false positives from the low count rates obtained at near background, was less than 33 MPC-hours. Again, for that same six year period, the bioassay results, these being from tritium urinalyses for workers in the Reactor and, therefore, under the Reactor license, showed that 41 persons showed a range of summed dose equivalents from 5 mrem to 475 mrem in the six years, with a total population dose equivalent of 6.24 person-rems.
13.2 Measures Taken to implement ALARA Health Physics dosimetry progrann have been centralized, with results reviewed by a single responsible individual, w ho ensures that ALARA concepts are observed in surveying dosimetry data.
Environmental monitoring responsibility has also been assigned to a single individual, who reviews data for ALARA purposes. Information about the ALARA concept and the NIST ALARA program has been widely disseminated and workers are requested to inform llealth Physics of any pertinent data or information that could affect this program.
13.3 Bioassay Program Workers involved in projects with a potential for significant internal dose, such as operations that could create significant airborne levels of tritium, iodine, or transuranics, may be required, at Health Physics discretion, to participate in a bioassay program. Appropriate techniques for bioassay are developed from available regulatory guidance, contracted assays may be utilized, or other acceptable bioassay mechanisms may be specified.
13.4 Air Sampling Program Table 11.121, Controls and Action Levels, and Table 11.12-2, Administrative Action Levels and Actions, list the various levels at which certain actions would be implemented. In addition, 5/28/01 11-13-1
should any measurement of air radioactivity concentration indicate that an applicable limit would be exceeded, the operation involved or the operation generating the activity concuitre. ion would be suspended unless the condition could be remedied by prompt corrective action.
Proposal reviews and analytical observations to determine actions for specific situations involving potential airborne radioactivity releases are approached using conservative techniques, for example, conservative resuspension factors or mass loading values would be assumed for extended operations. Ilealth Physics evaluates a proposal to conduct processes that could release radioactive material to the efiluent streams and considers the potential for such release. Material containment, resuspension probability, efiluent stream access, filtration available, and other chemical and physical properties involved are part of the criteria used. Should the potential for a release greater than 10% of the maximum permissible concentrations as given in 10CFR20, Appendix B, Table II, then air sampling of the workplace will be initiated.
5/28/91 11-13-2
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