ML20058P241
| ML20058P241 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 10/18/1993 |
| From: | Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| To: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9310220176 | |
| Download: ML20058P241 (6) | |
Text
,
,l.c(,
. ~.-
p.
g-i UNITED CTATE3 D pARTM3NT 012 COMM3RCH i
'p o'cg% '
V/
National Institute of Standmede and Technology
-fjg Gau.orwwg. Muywd eonas
+
m 1
\\ y...).,/
October 18,1993-I U S NUCLEAR REGULATORY COMMISSION-Docket Number 70-398 ATTN MICHAEL TOKAR SECTION LEADER License Number SNM-362 MAIL STOP 4E4 LICENSING SECTION NUMBER 2 LICENSING BRANCH DIVISION OF FUEL CYCLE SAFETY AND SAFEGUARDS NMSS l
WASHINGTON DC.20555 Gentlemen:
Please abandon our license amendment request of September 22 regarding the lead-in-paint devices and consider, in its place, the following amendment request.
We request amendment to License No. SNM-362 to permit the use of lead-in-paint detectors off site. This change is required for a project that is projected to begin shortly after January,1994.
and to last no longer than about 2 years. A proposed revised page 1-1-3 for the Materials License.
l Document is enclosed, with the requested change shown in shadowed print style. Please note that all other conditions of Section 1-1-8 Exemptions and Special Authorizations, paragraph b. will remain-as they were. Since the project is to start shortly, we appreciate your prompt attention to this request.
Each device will contain no more than 100 millicuries of cadmium-109 or americium-241.
The nuclides will be sealed sources, integral parts of the devices..We anticipate that 5 or 6 devices '
,1 will be received from clients, tested, and returned to the clients. While in use off site, the devices will be constantly attended by authorized persons,- trained for radiation safety purposes. Locations for use of the devices will depend on identifying suitable candidate structures for testing, but we anticipate that the locations will be in areas near our Gaithersburg laboratories or in the District of
-)
Columbia.
Surveys have been conducted on devices loaded with cobalt-57, an unlicensed alternative -
source for lead-in-paint detection. A copy of the results of those surveys is enclosed. " The emitted photon energy from "Co is about 122 kev, substantially more than the 88 kev from '*Cd or the 2
60 kev from Am, so the exposure rates shown should adequately demonstrate operational
- c(mditions from the ""Cd or Am loaded devices, given the half-lives and source intensities -
2
' involved.
Sincerely,
'O gg L. E. Pevey, Ch ef j
OccupationalM/alth and Safety Division jj (Materials License Manager) i enclosures I
9310220176 931018 D
['
'l PDR ADOCK-07000398 b
C pyg g
1
)
1 general purpose laboratories, i.e., Buildings 220 through 226.
materials and equipment irradiations - SRL a
source preparations - SRL, SPL, GPL a
=
source calibrations - SRL, SPL, GPL instrument calibrations - SRL, SPL, GPL
=
sample assays - SRL, SPL, GPL m
m source characterizations - SRL instrument and device characterizations - SRL, SPL, GPL j
m u
reference or counting source uses - ADM, SRL, SPL, GPL l
radiochemistry - SRL, SPL, GPL m
general research and development - ADM, SRL, SPL, GPL a
sources incorporated into devices or equipment - ADM, SRL, SPL, GPL a
miscellaneous, e.g., static elimination - ADM, SRL, SPL, GPL
=
j 1.8 Exemptions and Special Authorizations a.
We request exemption from the requirement to maintain criticality monitors or conduct criticality l
reviews because all SNM 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 enriched in the U-235 isotope l
1 or combination of these. Each room or area involving SNM 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 l
tbliowing provisions:
the proposal is reviewed and approved by Health Physics and, if required, by the a
i Radiation Safety Committee.
the radioactive material is controlled by an authorized individual, who possesses written a
operating instructions while engaged in the project.
the radioactive material is an integral part of a measurement instrument or a contained l
a source, such as a check or reference source.
lead Intaint deteers any not sitceed 100 maincurses (Mi.1109 et ri cA41 m
as saaled soerces in enA dev4ce, tt A the total quantity of radioactive material for a single authorized use may not exceed ten times the activity listed in 10CFR20, t
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 l
- [
specified in 10CFR35.92 are met. Short-lived radioactive material with long-lived daughter radioactive l
nuclides will not be considered for this disposal mechanism.
l d.
We request authority to release contaminated equipment to uncontrolled areas in accordance with l
the USNRC's August,1987 " Guidelines for decontamination of facilities and equipment prior to release j
for unrestricted use or termination oflicenses for byproduct, source, or special nuclear material." A copy I
t of the guidelines is attached to this chapter.
l We request an extension to the requirement for submission of an emergency response plan l
e.
according to 10CFR70.22(i)(1). We are developing a plan but have not completed our work, and need l-i more time.
We will submit the required infbrmation and.will be in full compliance with
-l 10CFR70.22(i)(1) on or before nine (9) months from the issue date of the renewal of this license.
l f.
We request a schedular exemption to the requirement for submission of a decommissioning j
funding plan according to 10CFR70.22(a)(9). We are developing a plan but have not completed our l
work, and need more time. We will submit the required information and will be in full compliance with l.
q 10CFR70.22(a)(9) on or before eighteen (18) months from the issue date of the renewal of this license.
l i
10/18/93 1-1-3 i
~
i 1
i 4 January,1991 1
^
Report of Radiation Survey From: Doug Eagleson
[
IIcalth Physicist, NIST
Background:
Manufacturers have developed portable detection devices to evaluate the lead contained in a painted surface. Scaled radioactive material sources are used in some of these designs with Cobalt-57 being a typical choice of radionuclide. Measurable ionizing radiation levels exist near some of these devices as a result.
i Survey Method: On June 2,1989 a radiation survey was performed in order to measure the radiation levels near three different models oflead detectors. He survey was conducted using Victoreen Inc. Model 450, serial number 407, radiation detector. His is an ionization style detector that was calibrated on April 10,1989 and has an accuracy of +/-15 percent. The radiation levels were measured at three different distances from the surfaces identified by number in stuvey figures 1,2, 5 and 8. Each model was evaluated in it's storage case, outside it's case with the source shutter closed, and shutter open with the detector face flush with a laboratory bench top. Survey results for the storage cases report the highest level found on the identified surface. The following devices were evaluated.
Manufacturer /Model Source #
Activity j
Map-FC2A 2952LC 40 rnCi (on 9/7/88)
Microlead-Warrington C-3809 10.4 mci (on 12/1/88)
Princeton Gamma-Tech C3896 10 mci (on 3/89)
Survey Results: Figure 1 shows the survey locations for the storage cases. This is an identical
{
scheme for all devices tested. Location number 1 is the case surface with the carrying handle.
i The background radiation level of 0.02 mR/hr has not been subtracted from these results.
p; storage Case Survey Locations I,
h D
i
/
O h
I
' Map-FCZA Fig.2 Map i ceA sur vey t ocations 10 9
7 4
(
Device Survey Results:
Fig 3
_ mew % % p t,(mns a g w %,p t,r,ng u locatiori ibntact 10 cm 30 cm
!stkm ihntact t 0 cm 30 cro 1
5.1 2.8 CAF i
1.94 0.51 0.11 2
64 1.72 OSI 2
1.38 0.37 0.06 3
8.I 2.6 0.62 3
1.39 0.33 0.13 4-72 ISS 0.56 4
f.60 035 0.11 5
9/A N/A N/A 5
3.1 0.32 0.11 L
6 0.40 0.61 0.32 6
024 0.17 0.09 7
0.38 0.56 0.32 7
022 0.14 0.10 8
0.56 0.64 0.41 8
021 0.10 0.08 9
0.50 0.73 050 9
0.19 0.10 0.08_ _
IO 0.35 020 0.14 10 0.17 0.10 0.13 N/A sneens Nat Acxm04e Storage case survey results:
Fig.4 l
Er wure Pate (mR/hr)
Intbn Fontet 15 m 30 cm 1
020 0.11 0.02 2
026 0.12 0.08 3
0.52 0.16 0.07 4
0.96 024 0.14 5
0.04 0.03 0.03 6
1.10 029 0.10
)
i
)
i j
j
.i
Microlead-Warrington Fig.5 1
Microtead-Vorrington Survey Locations 6
Device survey results:
Fig.6 Shutter opm Erpmure Rate (mR/br)
Shutter Omed uposure Rate (mR/hr) i Intion Pontact 10 cm 30 cm locatbn Fontact 10 cm (30cm I
4A 1.70 0.52 1
0.34 0.20 0.11 2
3.6 1.60 0.46 2
036 0.21 CA6 3
4.8 f.90 0.38 3
0,63 0.19 0.08 4
3.4 1.30 0.36 4
0.31 0.17 0.10 5
0.38 0.28 0.12 5
0.11 049 0.02 6
9/A N/A N/A 6
2.2 0.31 0.08
-N/A means Not Accessible i
Storage case survey results:
i Fig.7 Fx vnn Pate (mR/hr)
Intbn
~ontxt
'15 cm 30 cm 1
0.13 0.05 0.03 2
020 0.1I 0.03 3
033 0.10 0.03 4
0.10 0.04 0.03 I
5 049 0.03 0.02 6
0.15 0.06 -
0.02 f
+
- e, r
f
1 O
Princeton Gamma-Tech S'
Princton _ Gomma-Tech Survey Locations O
G G
g Device survey results:
Fig.9 a ggy 0;,,n %,p,9gma y agt, ag %, a,u (gy location
- bntact 10 m 30 cm lacetbo
- botact 10 en 30 cm -
1 031 022 0.11 1
0.30 0.07 0.03 2
0.18 0.06 0.05 2
0.23 0.15 0.04 3
1.0 t 0.30 0.06 3
1.33 025 0.14 4
0.88 035 0.14 4
0.40 025 0.04 5
0.43 020 0.12 5
038 0.18 0.10 6
0.40 028 0.10 6
0.33 0.10 0.11
- 7 0.13 0.08 0.03 7
0.23 0.08 0.04 8
0.17 0.13 0.06 8
0.17 0.14 0.03 9
1/A N/A N/A 9
23 0.43 0.12 10 VA N/A N/A lo 0.32 023 0.09
-N/A means Not AccessfLie Storage case survey results:
Fig.10 Er vrarre Rate (mR/hr) lexstion htact 15 cm 30 cm 1
0.05 0.05 0.02 2
031 0.24 0.06 3
0.15 0.07 0.04 4
0.12 0.06 0.04 5
0.10 0.06 0.02 6
0.34 0.12 0.08
?
F
- e, t
I
.