ML20031F544
| ML20031F544 | |
| Person / Time | |
|---|---|
| Site: | 07000124 |
| Issue date: | 09/26/1981 |
| From: | Crow W, Soong A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20031F539 | List: |
| References | |
| NUDOCS 8110200085 | |
| Download: ML20031F544 (8) | |
Text
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SEP 2 6 g FCUP r/f ALSoong LTyson WTCrow JBlaylock RErickson DOCKET NO: 70-124 JRobertson LICENSEE:
Teledyne Isotopes (TI) i FACILITir:
Westwood, New Jersey
SUBJECT:
REQUEST FOR LICENSE RENEWAL (SNM-107)
===1.
Background===
Teledyne Isotopes' Materials License No. SNM-107 was first issued in 1957 to authorize possession and up of 1 mg of plutonium for preparing standard sources. The license was subsequently renewed in 1962,1965,1968, and 1973. The current license authorizes the possession and use of 4 grams of plutonium and 440 grams'of U-235 for use in research and development purposes.
Since Deceber 31, 1978,' the license has remained in effect in pursuant to the timely renewal provisions subsection 70.33(b) of 10 CFR 70 (NRC letter dated January 26,1979). During the period of this license, a total of eleven amendments were issued. They were: 9 amendment applications concerning changes in possession limits; one amendment application requestin9 exemption from the requiement of Section 70.24 of 10 CFR Part 70 for installing a criticality monitoring systera; and one amendment application in 1962 regarding a change of the licensee's name from Isotopes, Inc., to Teledyne Isotopes, Incorporated. The licensee's renewal application requests the possession and use of less than 350 grams of special nuclear material for analyzing the radionuclide composition of radioactive samples. The licensee provides this type of service to a number of nuclear industrial companies in this country.
~
II. Scope of Review The safety review of Teledyne Isotopes' renewal application included a review of their application dated November 27, 1980, and a revision sub-mitted April 15, 1981, prepared as a result of a visit. to the licensee's facility by the staff on March 26,- 1981 (see Enclosure 1. Trip Report).
In addition, the review also included a review of the compliance history of the license using reports of inspections made by Region I Office of Inspection and Enforcement personnel.
III. Summary of Review _
Teledyne Isotopes' revised, renewal application has demonstrated that they howe'the necessary technical staff with the qualifications to ad-minister an effective and safe radiological program. The following sections contain a description of the licensee's organization and radiological saf Pty program for handling that licensed material, along dth a66TM0f!Ei
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J 2-SEP 2 61981 III-1. Management Organization TI has established a Radiation Safety Committee to formulate company policy on the uses of and to approve the user of the source of ionizting radiation. The Committee is responsible directly to the President of TI and is composed of management level personnel, including the manager of the Radiological Service Department (RSD).
It is the responsibility of the Radiological Service Department to implement the Radiation Safety Program which is established by the Radiation Safety Committee.
After reviewing the licensee's administrative procedures section of the renewal application for handling licensed material, two de-ficiencies were found in the section. These deficiencies are corrected by the following two license conditions which shall be incorporated in the renewed license. They read:
Condition 11. -Notwithstanding radiation safety procedures in Section II of the Radiation Safety Code and Quality Control Manual of the application, the licensee shall prepare and follow the approved written procedures any time licensed material is handled.
Condition 12. Notwithstanding the statement on general safety rules in Section 3.7.1 of the Radiation Safety Code and Quality Control Manual of the application, the licensee shall fulfill all rules specified in the section.
III-2. Minimum Technical Qualifications Minimum technical qualifications have been established for the safety related staff positions:
Company Health Physicist - B.S. degree in Health Physics or related field and 4 years' practical health physics experience.
He must be certified by the American Board of Health Physics or have 8-10 years' practical experience.
Radiation Safety Officer - College degree in Health Physics or related field and 3-5 years' practical health physics experience.
III-3. Radiation Safety TheRadiationSafetyOfficer(RS0)is,undertheguidanceofthe
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- SEP 2 61981 The responsibilities of the RSO include the following:
a.
Control of personal exposure from radiation.
b.
Control of surface coitamination.
c.
Calibration of instrw.cnts, d.
Control of radioactive weste.
e.
Conduct of radiation safety training for the workers.
I II-3.1.
Control of Personnel-Exposure A.
External Exposure At TI, all personnel who work with licensed material are provided with personnel dosimeters for monitoring purposes. The dosimeters are evaluated on a quarterly basis. External exposure data of the workers submitted by the licensee for 1980 indicates a maximum of 25 mrem, which is less than 1% of the allowable exposure limit.
B.
Internal Exposure Protection of operating personnel from excessive internal exposure is provided by the use of:
1.
Protective clothing and gloves to minimize direct contact with the radioactive material.
2.
A ventilated and filtered hood or glove box for handling dispersible radioactive material. The ventilation at hood face and glove box openings is checked monthly for face velocity, which must keep at a speed of 100 ifpm. The filter will be replaced when the pressure drops across the filter exceeds 4 inches of water.
3.
Air sampling and analysis program for monitoring the concentration of radioactivity in the work area to detect the presence of elevated concentration.
Data on the concentration of airborne radioactivity provided by TI indicate an average of 0.5% of the MPC limit for the first quarter of 1981 and the maximum one week concentration detected during the quarter is 9.4% of MPC.
4.
A bioassay program to monitor and detect any signifi-cant deposition of radioactive material in the worker's body. The program includes routine taking of samples from personnel working with dispersible fom of licensed material and action points.
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. SEP 2 61981 III-3.2.
Control of Surface Contamination A contamination survey of a'.1 work areas is conducted by the RSD weekly.
When the measured contamination levels are found to exceed the preset action level, RSD will begin to decontaminate the area. The action levels for surface contamination used by T1 are equivalent to the levels of allowable contamination developed by NMSS staff for release of facilities for unrestricted use; therefore, they are acceptable to thi. reviewer. After reviewing the licensee's surface contamination e
control program, this reviewer has found two deficiencies in the licensee's program. They are:
a.
TI's surface contamination control program does not include the permissible contamination level for per-sonnel skin prior to his exiting from restricted area.
b.
TI does not have completed criteria for releasing the contaminated equipment and package from the facility for unrestricted use.
In order to correct the deficiencies described above, two license conditions have been added to the renewed license:
Condition 13. Notwithstanding the acceptable surface contamination levels given in Section 3.3.2, page III-2, of the Radiation Safety Code and Quality Control Manual, April 1981, submitted in the revised application dated April 15,1981, the licensee shall not allow an individual whose skin or personnel clothing is found contaminated above background levels to exit a restricted area with-out prior approval of the Company Health Physicist or the Radiation Safety Officer.
Condition 14.
Release of equipment or materials from Teledyne Isotopes for unrestricted use shall be in accordance with the enclosed Annex A," Guidelines for Decontamination of Facilities and Equipment Prior to Re-lease' for Unrestricted Use or Tennination of Licenses for Byproduct, Source or Special Nuclear Material," published by tiic USNRC Division of Fuel Cycle and Material Safety, dated November 1976.
III-3.2.
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111-3.4. Management of Radioactive Waste All radioactive waste materials are discarded in the container for radioactive wastes. When it is full, the Radiological Survey Department will crrange for shipment of the container to an approved burial sito.
Low level radiocctive liquid wastes generated in the laboratory, such as in the process of washing laboratory glassware, will be stored in i
a holding tank. They will be released to the unrestricted area in accordance with 10 CFR Part 20 limits.
Potentially contaminated air which was generated in the process of dispersibla material in the chemistry hood is exhausted through the HEPA filter and discharged through the stack. Stack effluent is continuously monitored for radioactivity to meet released concentration limits as specified in 10 CFR Part 20.
i III-3.5. Training Program -
All radiation workers are required to take the basic training course i
given by the Health Physics Office. The Office also gives refresher training to the worker on an annual basis to update and review each worker's knowledge in radiatic.n protection.
l III-4..Heclear.Taf.n l l
The total 346 grams of SNM possession limit is insufficient to achieve l
acddental criticality. The licensee is therefore excmpted from the l
requirement in Section 70.24 of 10 CFR Part 70 regarding criticality monitoring. Since the licensee possesses Byproduct and Export licenses issued by the Commission which could authorize the licensee to possess additional SNM material, the staff is recomending that the following condition be incorporated in the renewal license to ensure that the regulation is enforced:
Condition 15. The licensee is exempted from the require-ment of Section 70.24 of 10 CFR Part 70, insofar as this Section applies to the material covered by this license. The totiquantities of Special Nuclear Material in the laboratory facility shall contain less than 450 grams.
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l III-5.
Compliance H1 story and IE Comments
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.. spections made by Region I, IE. The period examined was from 1975 to 1980.
In this period, two safety inspections were made resulting in 7 items of non-compliance. These non-compliance items concerned l
proper posting of radiation signs, failure to keep appropriate records for radioactive wastes, failure to check survey meter for i
calibration prior to each use, and worker failure to survey him-self prior to his exiting from the laboratory. The record also indicated that TI has taken appropriate action to resolve the non-compliance items. None of the non-compliance items identified resulted in measurable adverse effects to the health of the workers, nor to the health and safety of the public. It is this reviewer's opinion that non-compliai, t items identified in this review do not reflect basic weaknesst.s.e licensee's radiation safety program.
On August 11, 1981, the staff discussed the renewal license with Mr. J. Roth, IE, Region I Inspector, and he foresaw no safety-related problems with renewing the license as proposed.
IV. Radiological Contingency Plan On February 11, 1981, the Comission issued an " Order to Modify License" to Teledyne Isotope; requesting them to develop and submit to the NRC a radiological contingency plan for its facility in accordance with the standard format and content as specified in the Order. The approved plan will be incorporated as a condition of the license; or the licensee may submit an application for license amendment to reduce the possession limits of licensed material below those specified in the Order, thereby eliminating the need for a radiological contingency plan.
Since the possession limits of licensed material requested by the licensee in the renewal are below those specified in the Order, TI is therefore not required to have a radiological contingency plan.
V.
Conclusion and _Recomendation Upon completion of the radiation safety review of the licensee's application and compliance history, the staff has concluded that TI has the necessary technical staff to administer an effective radio-logical safety program. Confonnance by TI to their proposed conditions, as well as to those developed by the FCUP staff, should ensure a safe operation and the quick detection of unfavorable trends or effects by TI or IE with prompt corrective action. Based on this analysis, it is concluded that the proposed renewal application is non-substantive and insignificant from the standpoint of environmental impact, and pursuant to subparagraph Sl.5(d)(3) of 10 CFR 51, no environmental impact state-ment, negative declaration, or environmental impact appraisal need be orenared.
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.... SEP 2 61981 Based on the discussion above, it is therefore.recomended that the license be renewed for a 5-year period in accordance with tlie' application and subject to the following conditions:
Condition 11. Notwithstanding radiation safety procedures in Section II of the Radia_ tion Safety Code and Quality Control Manual of the application, the licensee shall prepare and follow the approved written procedures anytime licensed material is handled.
Condition 12. Notwithstanding the statement on general safety rules in Section 3.7.1 of the Radiation Safety Code and Quality Control Manu'al-of th-application, the licensee shall fid'!il all rules specified in the sect &
Condition 13. Notwit. standing the acceptable surface contam*>ation levels given in Section 3.3.2, page III-2, of the Radiation Safety Code of Quality Control Manual April 1981, submitted as revised appli-cation dated April 15, 1981, the licensee shall not allow an individual whose skin or personnel clothing is found contaminated above background levels to exit a restricted area without prior approval of the Company Health Physicist or the Radiation Safety Officer.
Condition 14. Release of equipment or materials from Teledyne Isotopes for unrestricted use shall be in accordance with the enclosed
~ Annex A. " Guidelines for Decontamination of Facilitles and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Materials," published by the USNRC Division o' Fuel Cycle and Material Safety,
, dated November 1976.
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..* SEP 2 61981 Condition 15. The licensee is exempted from the requirement of Section 70.24 of 10 CFR Part 70, insofar as this Section applies to the material covered by this license.
The total quantities of Special fluclear Material in the laboratory facility shall contain less than 450 grams.
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