ML20035F914
| ML20035F914 | |
| Person / Time | |
|---|---|
| Site: | 07001703 |
| Issue date: | 04/21/1993 |
| From: | Klasy M, Soong S, Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20035F910 | List: |
| References | |
| NUDOCS 9304230052 | |
| Download: ML20035F914 (6) | |
Text
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[
'o UNITED STATES
{
g NUCLEAR REGULATORY COMMISSION l
e WASHINGTON, D. C. 20555 l
l
.s i
APR 211333 r
DOCKET:
70-1703 LICENSEE:
Eastman Kodak Company (EKC) i Rochester, New York
SUBJECT:
SAFETY EVALUATION REPORT, AFPLICATION DATED APRIL 27, 1992, AND SUPPLEMENTS DATED SEPTEMBER 22, 1992, AND MARCH 25, 1993, RE LICENSE RENEWAL BACKGROUND i
By letter dated April 27, 1992, Eastman Kodak Company (EKC) filed a renewal application for License SNM-1513.
By letter dated August 12, 1992, the staff requested additional information. On September 22, 1992, EKC submitted a revised application. Additional information was provi.ded by a letter dated i
March 25, 1993. The license was last renewed in April 1987 with an expiration i
date of May 31,.1992. During this period, one amendment was issued concerning a change in personnel.
EKC's license was originally issued by the Commission in 1975 to authorize possession and use of 1,582.6 grams'of U-235 in a Californium Neutron Flux Multiplier (CFX). The licensed material is in the form of uranium-aluminum alloy clad in aluminum. The CFX was manufactured by the NRC-licensed Intelcom Rad Tech (Docket No. 70-1359).
EKC uses the CFX for i
neutron activation analysis and for neutron radiography.
I SCOPE OF REVIEW
(
The safety review of the licensee's request included an evaluation of their i
application dated April 27, 1992, and supplements dated September 22, 1992, and March 25, 1993, and a discussion with Mr. J. Roth, Region 1 Inspector.
DISCUSSION l
A.
Possession limits The applicant has requested tl ? following licensed material:
l Material Form Ouantity Uranium enriched to Uranium-aluminum Up to 1,582.6 grams
< 93.4% in the U-235 alloy clad in of U-235 located isotope aluminum in the Californium Neutron Flux Multiplier (CFK) i I
9304230052 930421 PDR ADOCK 07001703 C
APR 211993 2
B.
Authorized Activities and Place of Use The applicant has requested authorizhtion to use the material in the CFX for neutron activation analyses and neutron radiography for testing film material s.
The experiments will be conducted at the Research Laboratories, Building 82. Accordingly, the following license conditions are recommended:
Authorized use:
For use in accordance with statements, i
representations, and conditions specified in the licensee's application dated April 27, 1992, and supplements dated September 22, 1992, and March 25, 1993.
Authorized place of use: The licensee's Research Laboratories, Building 82, in Rochester, New York, as described in the above application.
C.
Manaaement Oraanization EKC's Health and Environment Laboratories (HAEL). are responsible for administering the radiation safety program. The HAEL provides technical support to Kodak Plants on health-related matters, including industrial hygiene and health physics. The radiation safety program is managed by the Occupational Health Laboratory (OHL) of HAEL.
The. Radiation Safety Officer (RS0) of OHL is responsible for approving purchases of radioactive material i
and licensing activities and is the consultant to the radioactive material user for radiation protection.
In the area where the CFX is used, a Radiation Safety Supervisor (RSS) is assigned responsibility for radiation safety. The i
RSS is responsible for routine radiation monitoring and record retention and serves as the liaison for the Radi:tien Protection Committee. The RSS is appointed by the Area Division Manager and is approved by the RSO.
EKC's Analytical Technical Division has the administrative responsibility for the CFX. The Group Leader, Atomic Spectroscopy Unit, is responsible for i
neutron activation analysis work and safe operation of the CFX.
EKC has established a Radiation Protection Committee (RPC) comprised of the Director of Occupational Health Laboratory and the Radiation Safety Officer.
I
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The RPC is responsible for formulating company policy on the use of the licensed material and dealing with unusual radiation problems, such as approval of changes to procedures which could increase experimental radiation levels. The RPC meets at least twice a year.
D.
Technical Qualifications The licensee has established the minimum qualifications for the positions of the Chairman of the Radiation Protection Committee, Radiation Safety Officer, Health Physicist, and Group Leader. These positions require a bachelor's degree in science or engineering, in addition, the licensee has set forth the 3
following minimum qualifications-
i APR 21 1993 3
The chairman of the Radiation Comittee shall have at least 5 years' experience in management, including 2 years working with radiation.
The Radiation Safety Officer shall have at least 2 years' work experience in radiation safety.
The Health Physicist shall have at least 2 years' experience in applied health physics.
The Group Leader shall have at least 2 years' experience with ionizing radiation.
E.
Administrative Procedures Written Procedures The applicant has comitted that the CFX operation will be conducted in accordance with written procedures.
These procedures will be approved by the Radiation Protection Comittee. The applicant did not comit to written health physics procedures. Accordingly, the staff recomends the following license condition:
The licensee shall establish, maintain, and follow written procedures for carrying out the health physics activities. The procedures shall be approved and updated every 2 years' by the Radiation Safety Officer.
j Insoection The applicant has comitted to periodic inspections by safety personnel.
These inspections are performed quarterly by the RSO at all work areas. These l
inspections are conducted in accordance with written procedures. The findings of these inspections, with associated corrective actions, are transmitted to the supervisor of the inspected area and the Radiation Protection Comittee.
Trainina l'
The Radiation Safety Supervisor and Group Leader jointly provide inhouse i
training to each new worker and conduct retraining of operators in radiation safety. The retraining of operators will be conducted every 14 months. This is consistent with NUREG-ll27, " Radiation Protection Training at Uranium Hexafluoride and Fuel Fabrication Plants."
F.
Radiation Safety The CFX, which contains 1,582.6 grams of U-235, is housed in the underground radiation cavity of EKC's Butiding 82. The shielding provided for the cavity is adequate to assure that radiation exposure outside the cavity (control room) is less than regulatory limits.
In addition, the following safety design features of the CFX and cavity prevent potential mishaps:
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l APR 21 1993 1
4 j
l a.
An interlock system prevents entry into the cavity when the CFX is on and the radiographic port is open. The system is routinely checked by the RSS to ensure it is operating properly.
b.
Ion chamber detectors, located in the device, automatically shutdown the I
device when the radiation level exceeds a preset level.
Radiation monitors in the cavity will trigger an alarm in the cavity and c.
control room when the radiation level exceeds 10 mr/hr.
Control of Personnel Exposure i
Each worker who uses the CFX is provided with a personnel radiation dosimeter and is required to wear it at all times in the restricted areas. The dosimeters are analyzed and evaluated monthly.
If any worker's monthly i
exposure is above 100 mrem, the RSS will immediately investigate the cause and will take action to prevent further exposures.
The maximum annual exposure of any worker reported by EKC for 1989, 1990, and 1991 was insignificant.
Control of Surface Contamination Since the licensed material is a contained source and installed inside the neutron multiplier device, the potential for surface contamination from the material is unlikely. The containment of the licensed material is checked (leak testing) every 6 months. To ensure that leak testing will be performed adequately, the staff recommends the following license condition:
The licensee shall comply with the attached " License Condition for Leak Testing Sealed Uranium Sources," April 1993.
The laboratories are checked monthly for surface contamination (primarily for i
radioactive material licensed under the Agreement State license).
EKC has established criteria (action levels) for cleanup, if contamination is detected.
Airborne Activity Due to the nature of the radioactive material being handled and the double aluminum housing in which the material is encapsulated, hazardous exposures to airborne radioactive material are unlikely.
Instrument Calibration Portable meters and area monitors are calibrated yearly by persons who have a license that authorizes calibrations of health physics instruments. This calibration frequency is consistent with Regulatory Guide 8.23, " Radiation Safety at Medical Institutions."
1
l APR 21 1933 i
5 Radioactive Waste Disposal Radioactive waste generated by the CFX consists of activated samples contained in sealed polyethylene capsules. These capsules are packaged for disposal according to the requirements of the Department of Trar.sportation and New York State. To ensure that contaminated equipment is released according to NRC guidelines, the staff recommends the following condition:
Release of equipment or material for unrestricted use shall be in accordance with the attached " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear i
Material," April 1993.
j G.
Nuclear Criticality Safety EK operates a CFX device for activation analysis and neutron radiography operations.
The CFX is a subcritical assembly that consists of a Cf-252 neutron source surrounded by 1,582.6 grams of enriched uranium (93% U-235).
This subcritical assembly serves as a multiplying medium to enhance the effect l
of the spontaneously fissioning Cf-252 source.
The device is optimally moderated and fully reflected by polyethylene. This design is such that the
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effective multiplication factor (K,,,) is.990.
The operation of this device is the subject of this criticality review.
To ensure that the CFX remains subtritical at all stages of operation, the device has been designed such that the effective multiplication factor cannot exceed 0.99 with the control rods fully withdrawn. This multiplication factor is based on experimental measurements that have been performed by the vendor, 4
who assembled the subcritical assembly in the EK facility. To ensure that the configuration is maintained, the licensee has impicmented a procedure that l
prohibits manipulation of the CFX aluminum fuel containers.
The CFX device is optimally moderated, with a hydrogen-to-uranium ratio,such that any change in the geometric arrangement of the fuel will result in a less reactive system, and fully reflected so that reactivity changes by additional reflectors are precluded.
In addition, the device is equipped with aluminum-encased cadmium plates as safety rods to provide for system shutdown and is equipped with a backup safety system similar to a reactor. The CFX device has an activation port to provide for neutron activation analysis. To ensure that no additional fuel is introduced into this port, the licensee is not authorized to possess any additional special nuclear material other than the 1,582.6 g authorized by this license. The insertion of materials, other than SNM, into the activation port was studied by both the licensee and the staff and found to introduce insufficient reactivity to cause the system to become critical.
6 APR 211333 The engineered-safety control features of the CFX device, in conjunction with EK's administrative controls, are sufficient to ensure that the configuration will remain subcritical. The licensee has requested an exemption from 10 CFR 70.24. Therefore, the staff recommends the following license condition:
The licensee is hereby exempt from the requirements of 10 CFR 70.24(d) insofar as the section applies to materials held under this license.
H.
Environmental Protection The licensing of the EKC activities is in accordance with 10 CFR 51.22(c)(14)(v), and therefore, neither an environmental impact statement nor an environmental assessment is warranted for this action.
I.
Decommissionino Due to the nature of the licensed material (encapsulated), a decommissioning funding plan is not required by 10 CFR 70.25.
J.
Emeroency Plan EKC is not required to have a nuclear criticality alarm and does not possess any uranium hexafluoride. Therefore, pursuant to 10 CFR 70.22(1)(1), an emergency plan is not required.
K.
Egaion I Comments On March 16, 1993, the staff discussed the renewal application with Mr. J. Roth, Region I Facility Inspector, and he foresaw no safety-related problems with the issuance of the renewed license, as conditioned.
CONCLUSION AND RECOMMENDATION Upon completion of the safety review of the licensee's application, the staff has concluded that licensed activities will not constitute an undue risk to the health and safety of the public or the environment.
Subject to the above conditions, it is recommended that the license be renewed for a 5-year period.
0nE;wJ Si 00d 8Y' E
42! Siped 9v-Sean Soong Marc Klasky Licensing Section 2 Licensing Section 2 Licensing Branch Licensing Branch Division of Fuel Cycle Safety Division of Fuel Cycle Safety and Safeguards, NMSS and Safeguards, NMSS Approved by:
U @n N* N Michael Tokar, Section Leader OFC FCLB_
FCLB f
FCL6 FCLB E
MK1ah SSoongI4 UT'harpe MTok M 7 NAME DATE 4/T/93 4/4/93 4/^6/93 4/A /93
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C = COVER E = COVER & ENCLOSURE N = NO COPY
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