ML20053E468
| ML20053E468 | |
| Person / Time | |
|---|---|
| Site: | 07001359 |
| Issue date: | 05/28/1982 |
| From: | Crow W, Kosla B NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20053E461 | List: |
| References | |
| NUDOCS 8206080196 | |
| Download: ML20053E468 (8) | |
Text
{{#Wiki_filter:" m DISTRIBUTION: ~ .e - Docket File 70-1359 NAY 2 81982 $S rf FCUP rf' t l BMKosla LTyson WTCrow JBlaylock RErickson DOCKET NO: 70-1359 JRobertson Region V LICENSEE: IRT Corporation
SUBJECT:
SAFETY EVALUATION REPORT I.
Background
Materials License No. SNM-1405 was issued August 31, 1973, to Intelcom Iredustries, Inc. (III) for possession and use of approximately 1300 grams of uranium and plutonium in encapsulated form. The authorized material, used for testing detection systems manufactured by III, was increased by amendment in 1974, when III initiated construction of a subcritical assembly, the Cf-250 Multiplier (CFX). Subsequently, the licensee was authorized to construct the CFX with keff of 0.99 and to change the name on the license to IRT Corporation. License No. SNM-1405 was amended to reflect these changes, and currently, IRT is authorized to use SNM for development of nondestructive inspection and assay equipment, and for research and development. SNM is used at three sites, the laboratories at 7650 and 7070 Convoy Court, San Diego, where the quantities of SNM are limited to less than a critical mass and are exempt from the require-ments of 10 CFR 70.24, and at the Linear Accelerator Facility which is in a structure occupied jointly by IRT and General Atomic Company on John J. Hopkins Drive, San Diego, California. The licensee submitted an application dated October 20, 1981, requesting renewal; accordingly, the license remains effective, pursuant to the timely renewal provisions of subsection 70.33(b)of10CFR70. The renewal application requests authorization to possess and use the following material: Byproduct, source, Chemical and/or Maximum amount and/or special physical form that licensee nuclear material may possess at any one time under this license (grams) U-233 Sealed sources 25 U-235 Sealed sources <5000 Any <300 Pu-236 Any 10 x 10-9 Pu-238(PuSe) Neutron sources 2 Pu>75% Pu-239 Sealed sources 500 l Any 1 Pu(PuBe) Neutron sources 100 Mp-237 Ar.y 10 omct >. 8206080196 820528 summt >- PDR ADOCK 07001359 out> C PD ...........p.............R....;................... NRC FORM 318 (10-80) NRCM 024o OFFICIAL R_ECORD COPY _ _ _ _ _ _
MAY 2 8 1982 II. Scope of Review The safety review of IRT's application for renewal included an examination of previous applications and amendments, a review of the application dated October 20, 1981, and addenda dated January 12, 1982, a review of the compliance history, a site visit on April 13, 1982, and discussion with Region V staff. The findings are discussed below. III. Discussion of Review The quantity and quality of information contained in the IRT renewal application demonstrates that the technical staff is qualified and sufficient in number to administer an effective and safe radiological protection program. The following sections contain a description of IRT's organization and radiological safety program, along with additional conditions developed by the staff. A. Organization and Administration 1. The IRT President and staff' advisers who administer the radiation safety program have been a part of the organization for the life of the SNM license. The Radiation and Criticality Safety group reports directly to the President, as do the Managers of the operating divisions. Line managers have responsibility for the establishment and administration of safe operations, and they are aided by review comittees appointed by the President. Radiation and Criticality Safety are managed by the Radiation Safety Officer (RS0), who is also a member of the Radiation Safety Committee. The Health Physics staff reports to the RSO. 2. The Radiation Safety Comittee, composed of at least five qualified members, is guided by a policy of commitment to ALARA. The policy commitment to ALARA is achieved through audit and inspection, review of procedures, and critical review of all radiation related work within the company. 3. The Radiation Safety Officer (RS0) is responsible for the review and inspection of procedures and new activities in all aspects 4 of radiation safety in the plant operation. In addition, the R30 must maintain a file of required records, investigate design criteria, and take charge of all radiological emergencies, and subsequent remedial action. The minimum education and experience requirements for the RSO include an accredited college degree in physics, the biological sciences, engineering,or other relevant fields and four years of applicable experience involving radioactive materials, radiation sources, special nuclear material, and radiation safety,or a minimum of eight years of applicable experience involving radio-active materials, radiation machines, special nuclear material, radiation safety and administrative practices in the radiation safety field. l
MAY 2 81982 , The resumes presented by the applicant amply demonstrate the licensee's criteria to fill the position of RSO and membership in the RSC with highly qualified individuals. B. Training Training of personnel is through IRT's " Radiological Safety Orientation Course," which is supplemented by handouts and is terminated by examination. The basic training is also supplemented for individuals specific to their area, such as special instruction for the Linear Accelerator Facility. Retraining is conducted on a two-year cycle. The course outlir.e supplied by the licensee demonstrates a comprehensive program covering a broad spectrum of radiation physics and safety. A passing grade of 70 is required upon completion of the course. C. Nuclear Safety The requested possession limit is 25 grams of U-233, 5350 grams of U-235, and 603 grams of Pu. Unsealed raaterial is limited to 350 grams of U-235 and 1 gram of Pu. The total SNM inventory is further limited to less than 5000 grams as computed by the foraula in 10 CFR 70.22(h). Approval of the' Radiation Safety Officer is required for all activities involving less than 200 grams of SNM. Criticality Safety Committee review is required for activities involving up to 500 grams U-235 (>5% enriched); 250 grams of U-233, Pu, or any SNil mixture; and, for sealed sources of U-235 (<5% enriched), 45% and 67% of the safe mass and volume limits of Dp-1014. " Critical and Safe Masses and Dimensions of Lattices of U and UO2 Rods in Water." liigher limits require NRC approval. Storage of material in the vault at Hopkins Drive is based on limited mass, limited volume, and forced separation of unmoderated SNat units foot Tor) moderated units.and on a. surface density and a maximum density per s (H/X < 2 In addition, boral is located between all units in storage. The criteria are adequate for safe storage of the proposed possession limit, and a criticality alarm system is maintained in this area. Laboratories (cells) in the Linear Accelerator Facility are each limited to not more than 500 grams of U-235 or 250 grams of U-233, Pu or an SNM mixture. Each cell is isolated by at least 12 inches of concrete and material movement between the vault and the cells 1s controlled by the RSO, via the Radiation Work Authorization. At the Convoy Court facilities, the licensee has limited the possession "'c'> " "" ' I DATEf
- '""C" OFFICIAL RECORD COPY
MAY gy ;997 , limits to 25 grams U-233, 32 grams Pu and to grans U-235 according to the equation: 9 U-235 (>4%)_ + 9 U-235 (<4%) < 1, 500 y 1400 where 500 g is a subcritical quantity of high-enriched uranitm and 1400 g is a subcritical quantity of low-enriched uranium. The quantities in the cells and in the Convoy Court facilities are insufficient to form a critical mass under optimum conditions of water moderation and reflection. The licensee has requested, pursuant to 70.24(d), an exemption from the requirements of 70.24. The staff has determined that granting the exemption will not endanger life or property or the common defense and security, and is in the public interest. This exemption is authorized pursuant to 10 CFR 70.14. Condition 10. The licensee is hereby exempted from the requirements of Section 70.24 10 CFR Part 70 insofar as this section applies to materials possessed under this license at the 7070 Convoy Court and the 7650 Convoy Court Facilities, and the cells at the John J. Ilopkins Facility. The applicant has requested continued authorization to use SWM at temporary job sites in the field. This use is subjected to administrativa control of the RSO and has not caused radiation safety problems; however, for radiation and criticality safety, the quantity authorized is limited by condition to not exceed 15 grams. The licensee agrees with this limitation and the following condition is reconnended: 0 i Condition 11. Use of SNM at temporary IRT job sites shall be limited to less than 15 grams of SNM, and shall be subject to the radiation and criticality safety conditions of this license. l The applicant proposes to install a Californium Multiplier (CFX) System for the Arr.ly. Such installation should be done under the Army's license and has not been evaluated herein. D. Radiation Safety The IRT structure of review and inspection in the radiation safety office is an affirmation of their policy commituent to ALARA. The reviewer observed during the site visit that the work currently being done with SNM requires the use of small quantities of material due to the wphisi.ication end sensiti;iity of the dc,iices in-development, howewr, "'c4 .a.thorou2h..p.rogram.for.. rad Iat.ian.safaty. is..structur.ed and..jmp.1emgn.t#,.. as needed. A brief descri ) tion of the IRT program fol lows. => om> """"""""C" OFFICIAL RECORD COPY
. MAY 28 1992 i l 1. Personnel Monitoring a. Exposure, internal and external 1. The licensee is comitted to a bioassay program structured in accordance with Reg. Guide 8.11. In addition, the licensee has established an Exposure Hazard Index for each individual work situation which establishes a frequency of urinalysis and in vivo testing which is con-servative by S.11 standards. 2. Film badges, pocket dosimeters, and finger ring dosimetry are used for detection of external expowre. The film badges which measure x, gama, beta, and neutron exposure are changed on a monthly basis, and the badges and finger dosimeters are comercially processed and reported. The maximum exposure measured in the past year i was 1 rem, which was principally attributed to the Linac operation and not from SNM. 2. Dispersible Material a. Authorization All work done with dispersible SNM is controlled by Radiation Work Authorization (RWA). This process requires that all aspects of a job be described and that the radiation and nuclear safety components be subjected to critical review by the RSO - RSC dependent on the quantity of sterial to be used. Work done with dispersible SNM is performed in glove boxes or l fume hoods equipped with high efficiency filtered exhaust systems. i b. Air Monitoring i Air sampling is continuous and filters are changed and processed daily. Corrective action is taken at 10% of MPC. To demonstrate IRT's quality of containment for work with dispersible material, the licensee reported that the average concentration of activity measured in worker breathing zone testing was 1.1 x 10-ts pCi/cc, and the maximum measured was 1.6 x 10-18 pC1/cc, approximately 1% MPC limits listed in 10 CFR Part 20, "'c 4 ""^"'> i "Rc ' "" * ' * " ~ * * " " C "-. " - - OFFICIAL RECORD COPY
MAY 2 81982 Appendix B. c. Surface Contamination The application indicates that an action level of twice background is used to initiate decontamination procedures. In discussion, the licensee stated that surface surveys cre conducted both during and following an operation with dispersible material, with a frequency of at least once each day. He further stated that decontamination proceeds when beta and gan.la are detected at 66 dpm/100 cm2 and 2 alpha measures 13 dpm/100 cm. These are conservative practices and are acceptable to this reviewer. To verify survey frequency and for guidance in decontamination, the following conditions are reconnended: Condition 12. Surface contamination surveys shall be conducted at least once each day when the job involves dispersible SNM. I Condition 13. Release of equipment or material from IRT for unrestricted use shall be in accordance with the enclosed Annex A. "Guidalines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termi-nation of Licenses, for Byproduct, Source, or Special Nuclear Material," dated November 1976. 4. Sealed Sources Periodic leak testing of sealed sources is conducted by the Radiation Safety Office. The technique is not completely described; therefore, the following condition is included to provide direction for method, frequency and re porting procedures. Condition 14. The licensee shall comply with the enclosed Annex B, dated September 1980, " License Con-dition for Leak Testing Sealed Plutonium Sources." E. Effluent Control Air released when dispersible material is used i ntinuously
- ilterM eM m pled. Te eretrath : =surW'-1979-{ Test a
. y..r di.spe..r.A'pp4'Ma, ' 'M'4H,"Mtfie"tbEa T"Ei"d6"y4Wr""" yea sible SNM was used) were loss than 10% MPC limits of omcep ........g g, DATEk . ~...... ~....... - ""C " ""'""C" OFFICIAL RECORD COPY
MAY 28 1937 was 3.6 x 10-s uti. There was no release of SNM in 1980 or 1981. Liquid waste as a result of decontamination or cleanup is disposed of into the sanitary system in accordance with 10 CFR 20.303. Since 1979, less than a milligram has been discharged into the system and none is anticipated for 1982. Solid waste is minimal and is packaged and shipped in accordance with DOT regulations to a licensed company for processing and disposal. There have been no shipments containing SNM in the past five years and the licensee currently has about I gram which is scheduled for disposal in 1982. The licensee anticipates a diminished use of SNM due to the sophistication and sensitivity of the monitoring equipment now in development. F. Environmental Impact The critical pathway of radiation dose to man from the licensee's operation is due to airborne effluent released into the environment. The effluent concentrations, as described above, are within 10 CFR 20 specifications, and further dilution due to dispersion will reduce them to insignificant levels before reaching the nearest individual. Therefore, the staff concludes that there is no significant environ-mental impact associated with the licensee's operation. Accordingly, the licensee's proposed renewal application is judged by the staff as non-substantive and insignificant from the standpoint of environ-mental impact, and pursuant to subparagraph 51.5(d)(3) of 10 CFR 51, no environmental impact appraisal need be prepared. IV. Compliance History and IE Comments A review of the Inspection and Enforcement record of the SNM license under examination was basically positive. The 1979,1980 and 1982 reports showed no items of non-compliance. In 1981, foer items of non-compliance were reported. They were of a procedural nature (missed retraining l schedule for three employees, non-calibration of a monitor at the llopkins facility, etc.) and did not constitute a safety hazard. They were corrected, and a routine has been established to prevent recurrences. Region V, in discussion February 26, 1982, expressed no objection to the issuance of the renewal license. V. Conclusion Upon completion of the radiation safety review and the compliance history, the staff concludes that the basis of the radiation safety prograin is sound. Confomance by IRT with their proposed conditions as well as those developed by the FCUF staff should insure a safe operation and quick detection of unfavorable trends or effects by IRT or Region V with prompt corrective action. '"C'>...............n.................. " "^55) une vor.u sie iio. o unca oz' OUKML REORD COW
MAY 2 81982 Based on the discussion above, it is therefore reconnended that the license be renewed for a five-year period in accordance with the application and subject to the following conditions: Condition 10. The licensee is hereby exempt from the requirements of Section 70.2410 CFR Part 70 insofar as this section applies to materials possessed under this license at the 7070 Convoy Court and the 7650 Convoy Court Facilities, and the cells at the John J. Hopkins Facility. Condition 11..Use of SNM at temporary IRT job sites shall be limited to less 15 grams of SNM, and shall be subject to the radiation and criticality safety conditions of this license. Condition 12. Surface contamination surveys shall be conducted at least once each day when the job involves dispersible SNM. Condition 13. Release of equipment from IRT for unrestricted use shall be in accordance with the enclosed Annex A, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unre-stricted Use or Termination of Licenses, for Byproduct, Source, or Special Nuclear Material," dated November 1976. Condition 14. The licensee shall comply with the enclosed Annex B, dated September 1980, " License Condition for Leak Testing Sealed Plutonium Sources." original signed by B. M. Kosla Bernice M. Kosla Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, fMSS Original Signed By t' Approved by: W. T. crow W. T. Crow, Section Leader
- "cr>. FCU.
..... F.CU F...JT.. .....E. CUR gf(. c"="*"'>..BN_@.s,1.a,;,rd.........LTy s.9.n.,,........NTGrpw... ................l
- >.51.20/82......
.... 5l... ?2....... NG.h. !.82... t une rom m oo.o sac" OUMR ECOR(gOW ,}}