ML20059B379

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Application for Renewal of License SNM-1405,indicating That Licensee Will Only Possess & Store Snm.Answers to Ws Pennington Included
ML20059B379
Person / Time
Site: 07001359
Issue date: 09/30/1988
From: Maschka P
IRT CORP.
To:
Shared Package
ML20059B367 List:
References
NUDOCS 9008290048
Download: ML20059B379 (91)


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IRT 4171-013 -

APPLICATION FOR RENEWAL

.OF SPECIAL-NUCLEAR.

MATERIAL LICENSE SNM-1405 d

Submitted to UNITED STATES 3

1 NUCLEAR REGULATORY COMMISSION

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By

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IRT CORPORATION

'i San Diego, California IRTCORPORATION September 30,1988 3030 Canan Road. P.O Box 85317

_( 9008290048 F91014 San Diego. Cahfornia 92138

! PDR ADOCK 070013S9 619/450 4343

  • Telex. 69 5412 l,C PDC h.5'i 9

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OCTOBER 17,1988 ANSWERS TO QUESTIONS CONTAINED IN W.S. PENNINGTON'S LETTER DATED NOV. 9,1987 0.1 IRT does not intend to use SNM in dispersable form.

Refer: p.5 Section 3.1 and p.6 Section 5.2.

Q.2 We request this license to be in effect for five years.

Refer: p.2 Q3 Refer to the new listing on p.5 Section 3.1 1

Q.4 Each item is separate.

Refer: p.5 Section 3.1 4

i Q.5 Not applicable to this revised license application.

Q.6 xtsonnel employed in other safety-related positions are selected the manager of the Human Resources Department and the Manager of the Radiation afety Office with the Q

advice and consent of tie Radiation Safety Committee.

Refer: p.25 Section 53 3

Q.7 Minimum requirements for waiving formal training are prior completion of a radiation safety course and at least three years of active use of SNM.

Refer: p.22 Section 5.1.2 #1 Q.8 All personnel working with radioactive materials or in areas where they may be exposed to i

radiation, will receive a radiation safety refresher course each year.

Refer: p.45 Section 7.2

>i O.9 The reference should have read "Section 5.8.2".

i Refer: p.29 Section 5.8.1 0.10 A third coy of the RWA will'be posted la ' : work area by the RSO.

Refer: p.2:. Section 5.1.1 1

0.11 The Radiation Safety Officer shall review and write an annual audit of the Radiation Safety and Criticality programs and submit the audit to the RSC for their consideration. The RSC shall forward the audit to the appropriate Divisional Vice Presidents and to the President of the Company along with their comments and recommendations.

Refer: p.25 Section-5.5 last paragraph

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Q.12 Program records are maintained for a period of 3 years.

Refer: p35 Section 5.9 h

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Page 2 OCTOBER 17,1988 ANSWERS TO. QUESTIONS CONTAINED IN W.S. PENNINGTON'S LETTER DATED NOV. 9, Q.13 Scaled sources are tested for leakage semi annually by either a wipe test of an immersion test.

Refer: p.66 Section 8.5.5 Q.14 Not applicable to this renewal.

' O 15 Since IRT does not possess any special nuclear material in powdered or liquid form, disposing or moving the material, decontamination and surveying the facility will not take

-l more than six (6) man-days.

The material will be packaged for waste disposal or for transfer to another licensed facility.-

This should take no more than two (2) man days, considering the small amount of material

, that we have.

The areas where the material was used will be wipe and meter surveyed. If any contaminted areas are found they will be cleaned with a vacuum cleaner equipt with a HEPA filter or they will be cleaned with soap and water. Another survey will be taken. This will take no more than two man days.

A report of the results of the surveys and a request to release the facility will be sent the the NRC Washington, D.C. and to NRC Region V. This will take no more than two man days.

3 No liquids containing special nuclear materials were ever poured down the drains at the g Callan Road facility and no dusts or liquids were released through the ventillation system.

The only liquid and powdered materials that we yssessed were several samples of Uranal nitrate with less than one gram of U 235, some ;iquids containing nanocurie quantities of Plutonium and a couple of uranium standards in powdered form. However, these materials were all sent to the burial site in Hanford about five years ago.

The cost of disposal is calculated at:

Labor:

48 manhours at $50.00/hr

= $ 2400.00 Materials:

1 waste drum containing 48 gm U-235

= $ 1000.00 including: site burial permit, the drum, tranportation, Uranium surcharge, and burial fees.

TOTAL

= $ 3400.00 Q.16 As part ofIRT's Radiation Safety Course there is a section " Chapter 10" entitled " Rules for Safety" which contains instructions for " Safety and Handling Considerations For Scaled Sources and Uncontained Radioisotopes". In that section personnel who might work with SNM in dispersable form are instructed to check themselves for contamination immediately upon leaving the work area. After removing any protective clothing, they are instructed to check their face, head, hands, feet, and clothing using a portable Alpha counter and/or a aancake GM detector, as is appropriate. If they detect any readings greater than twice 3ackground, they are instructed to remain in the area ar.d call Health Physics for assistance.

Refer: p.39 Section 6.2.1 last paragraph.

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OCTOBER 17,1988 ANSWERS TO QUESTIONS CONTAINED IN W.S. PENNINGTON'S LETTER DATED NOV. 9,1987 Q.17 G M Survey meters shall be calibrated semi annually.

Refer: p.63 Section 8.5.2 Q.18 Assay e uipment is calibrated weekly. The minimum detection limit is 30 dpm Beta and 5 dpm Al ha.

Refer: p.64 Section 8.5.3 and p.65 Sccion 8.5.3 #4 Q.19 Self-reading pocket dosimeters and air sampler gas flow meters are calibrated on a yearly basis.

Refer: p.63 Section 9.5.1 and p.65 8.5.4 Q.20 Not applicable to this license tenewal.

Q.21 EMERGENCY PROCEDURES -

Fire is no real danger because the vault is made of concrete and there are no combustible materials inside the room and all materials are stored in metal containers.

There is very little possibility of release of loss of material because all we possess are sealed or solid materials, so none of it can evaporate or be poured down the drain. At this time and on into the forseeable future only two people will be authorized access to the vault room, The RSO and the Alternate RSO.14 x rial could only be lost in case of theft.The alarmed vault room will tend to deter anv h: u most dedicated thief, and the alarm system should bring response forces' N m:...e s!d gain entry to the room and remove the material.

Contamination of personnel will be prevented by proper training of personnel and by the fact that all of our material is in the form of sealed sources and non dispersible solids.

The only hazardous materials used at the Arjons Facility is some small containers (one quart of less) of solvents used for cleaning in the machine shop. These will pose no hazard to the material stored inside metal containers in the concrete vault room.

Refer: p.73 Chapter 10 If you h9ve any questions or need further information, please call me at (619) 450-4343.

c Thank You.

Yours Truly:

IRT Corporatinn fdk l1WG. @YY Paul R. Maschka Radiation Safety Officer o

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4 t s' sJ' CONTENTS I

1.

IDENTIFICATION OF APPLICANT....................................

2.

LOCATIONS WHERE SPECIAL NUCLEAR MATERIAL WILL BE USED 3-

-3.

PO SSESS!O N LI MITS.................................................

5 3.1 To ta l License Li mit.............................................

-5 3.2 For m of Licensed Material.......................................

6 3.3 Exemption f rom Requirements Set Forth in 10 CFR 70.24............

6 4.-

R ADI ATION S AFETY ORG ANIZ ATION.................................

7 5.

AD MINISTR ATIVE PROCEDURES.....................................

21 5.1 Project Authorization Procedures.................................

21 5.1.1 Radiation Work Authorization Request Procedures........... 21 5.1.2

. Radiation Safety Officer Review Procedures................ 22 5.1.3 Radiation Safety Committee Review Procedures.............

23 5.2 Project Changes and Renewals...................................

25 5.3 Selection Criteria for Health Physics Staff and Radiation Sa f e ty Co m m itt ee..............................................

25 5.4 Operations of the Radiation Safety Officer and He al th P hy sici s t................................................ 26 5.5 Internal Inspection and Review...................................

26 5.6 Operations of the Radiation Safety Committee.....................

27 5.7 Control and Accountability of Special Nuclear Material.............. - 28 5.7.1 Organization for Control, Safeguarding, and Accountability of SN M.....................................

28 5.8 Storage of Snacial Nuclear Materlats.............................. 28 28 5.8.1 3030 Callan Road Storage Vault 5.8.2 - Storage Crite ria......................................... 29 5.8.3 Arjons Facility Storage................................... 31 5.8.4

~ General Procedures for Use of Special Nuclear Material......

34 5.9 Pr og r a m R e cor d s.....................................,........

35 37 6.

RADIATION PROTECTION PROCEDURES 6.1 Radiation Protection Manual.....................................

37 38 6.2 Personnel Monitoring 38 6.2.1 Film Badges 40 6.2.2 Bloassay g,h 6.2.3 Whole-Body Monito ring................................... 41 1

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6.3 Limits of Radiation in Controlled and Uncontrolled Areas............ 41:

6.3.1 Controlled Area......................................... 41 '

6.3.2 Uncontrolled Areas...................................... - 42 6.3.3-Contamination Contr ol................................... 43 44 6.3.4 - Radiological Survey......................................

45 7.

INSTRU CTION OF PERSONN EL............................,..........

45 7.1 Formal Training for New Users...................................

45' 7.2 Per iodic Re tr aining.............................................

47 8.

TECHNIC AL C AP ABILITIES..........................................

47-8.1 General Purpose of Use.........................................

8.2 Organizational Structure........................................

47 49 8.3 - Technical Personnel............................................

8.4 Fa cili t ie s...................................................... 56 8.4.1 3 0 30 Callan Road........................................

56 -

8.4.2 82 21 Ar jons Road........................................ - 6 2 '

62~

8.5 In st ru me nt a t ion................................................

8.5.1 Personnel Monitoring Devices............................. 62' 8.5.2 Radiation Monitoring and Survey Instruments................ 63 g

8.5.3 Radioactive Material Assay...............................

64 W

65 8.5.4 Air Samples............................................

8.5.5 Source Leak Checking....................................

66 69-9.

W A ST E D IS PO S AL.. l................................................

69' 9.1 Solid W aste Disposal............................................

'9.1.1 Work Area Waste Receptacles............................. 69 9.1.2 Collection of Waste......................................

69 9.1.3 Monitoring............................................. 70 70 9.1.4 Waste Collection and Storage Area 70 9.1.5 Packaging of Shipping Drums............................. ;

70 9.1.6 Monitoring Shipping Drums...............................

71 9.1.7 Disposal o f Solid Waste...................................

71 9.2 Liquid Waste Disposal...........................................

9.2.1 Work Area Liquid Waste Receptacles.......................

71 71 9.2.2 Monitoring and Collection of Liquid Waste..................

73 10.

EMERG ENCY P ROCED U RES.........................................

73 10.1 Fire-..........................................................

10.2 Release of Loss of Mater ial......................................

73 9 i

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' 10.3 L Contamination of Personnel......................................

7.1 10.4 Other Hazardous Materials.......................................

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C E R TIFIC AT E...................................................... 7 5 -

' APPENDIX 1: - RADIATION WORK AUTHORIZATION FORM.............. ' 77 -

. APPENDIX II: OUTLINE--IRT R5D10 LOGIC AL S AFETY COURSE ~.'........

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l. IDENTIFICATION OF APPL 3 CANT This license renewal. spplication is made by IRT Corporation and authorizes activities which require licensing of operations involving the use of radioactive materials.

The headquarters of IRT Corporation are located in San Diego, California'at the following address:

1.

Name of Applicant

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IRT Corporation i

2.

Malling Address:

P.O. Box 85317 San Diego, California 92138-5317 3.

Telephone Number, Radiation Safety Office:

Area Code: 619 Number: 450-4343 1RT Corporation, formerly Intelcom Rad Tech, came into being in April '1973.

Prior to that date, all of the operating components and facilities of IRT comprised the Radiation Technology Division of General Atomic Company in San Diego, California.

Prior to 1967, the components of General Atomic comprised the General Atomic Division of General Dynamics Corporation.

Within various internal organizational structures, the components of Rad Tech had bes:.llcensed and operating effectively and safely for nearly 25 years. For the past 14 years, since the Company's separation from General Atomic, IRT has operated under State of California Radioactive Materials Licenses 2468-59 and 2468-80, and U. S.

Nuclear'. Regulatory License SNM 1405.

IRT Corporation is financially quallfled to conduct the operations requested to be licensed and is financially qualified to be responsible for any cleanup and decontamina-tion required if any of its licensed operations are terminated and facilities opened for O

8e"erei#se-September 30,1988 Pagei i

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The applicant, IRT Corporation, is a corporation which was incorporated in the g

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i state of Delaware. The applicant has no known control or ownership by any allen, foreign corporation, or foreign government.-

--We request this license renewal be in effect for a period of five years.

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2. LOCATONS WHERE SPECIAL NUCLEAR MATERIAL WILL BE USED i

. This license application requests authorization to store special nuclear materials at the following site:

1.

Manufacturing facilities located at 8221_ Arjons Road,- San Diego, California 92126.-

3 2.

Laboratories and facilities located at 3030 Callan Road, San Diego, t

CA 92121.

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3. POSSESSION LIMITS 3.1 ' TOTAL LICENSE LIMIT i

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8. Limit
6. b y lal
7. Form -

(grams)

A.

Pu (enriched to 98%

A.

Scaled sources -

1 Pu-239)

B.

Pu (enriched to 80%

B.

PuBe neutron sources 1

Pu-238)

C.

Pu (enriched to 75%

C.

Mixed oxide fuel rods 365 Pu-239) as sealed sources D.

.U-235 (enriched to 10%)

D.

Mixed oxide fuel rods 277 as sealed sources E.

U-235 (enriched to 20%)

E.

Sealed sources 35 F.

U-235 (enriched to 10%)

F. Non-dispersible solid W,

sintered fuel fuel pellets 9

The total quantity of SNM does not exceed the amount specified in 10 CFR 73.2 (y),"Special Nuclear Material of Low Strategic Significance."

9a.

Authorized Use All items are to be used for storage, for preparation for transfer to another i

' licensed entity, and for disposal as waste.

9b.

Authorized Place of Use

- All items will be stored at the Manufacturing Facility located at 8221 ArJons Road, Suite F San Diego, California 92126.

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3.2 PORM OF LICENSED MATERIAL.

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, The SNM specified in the possession limits is in the form of sealed sources, sealed

. fuel rods, sintered oxide fuel pellets, and encapsulated folls.

i 3J EXEMPTION PROM REQUREMENTS SET PORTH IN 10 CPR 70.24 -

The' mass limitation given in Section 3.1-for 235U when coupled to the' maximum tweighted mass of Pu (weighting factor of 2.5) is below critical mass for homogenized-systems of various enrichments with optimum moderation and full reflection as given in lt Figure 13 of TID-7028.

The materials are not in a form to be homogenized and there are no massive moderators or reflectors of beryllium, heavy water or graphite present in the storage areas.

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4. RADIATION SAFETY ORGANIZATION

_i The IRT radiation safety organization consists of a Radiation Safety Officer'

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(RSO) who also serves as the Criticality Safety Officer (CSO), the Radiation and Criticality Safety Committee (RSC), and the Health Physics Staff.

The RSC is j

n composed of not less than five quallfled members, including the RSO. The committee represents both management and operating groups. The duties and functions of this committee are taken from American National Standard " Administrative Practices for Nuclear Criticality Safety," ANSI /ANS-8.19-1984.

The purpose of the radiation safety organization is to assure compliance with I

license requirements regarding the use of !! censed materials and equipment; to assure-compliance with established radiological safety standards and the nuclear Criticality Safety Program; to _ administer SNM safe-guards and accountability; and to provide license administration. This organization estab!1shes policles necessary for safety of l

radiation operations and publishes them in guides and manuals; provides various services such as personnel monitoring, dose rate measurement, radioactive material detection and assay, air and water sampling, environ =catel monitoring, and instructional and training programs. It provides inter-pretation of licenses, prepration and processing of license app!! cations, dissemination of license requirements, and maintenance of master -

license records. -

j The RSC acts in both a review function and an audit function. It'is responsible for-the critical review of all radiation-related work within the Company and must give authorization for all such activities. The Committee also audits all work involving licensed materials and radiation-producing machines for conformance to and effective-ness of all applicable procedures and practices and regulations. These functions are carried out through the review of plans and equipment, and are conducted I

to assure that license conditions are satisfied and that all reasonable precautions are taken to avoid accidental criticality in the handling and storage of SNM.

It is the policy of the radiation safety organization to assure that all approved operations are conducted in such a manner so as to keep personnel exposures, radiation September 30, 1988 Page 7

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levels, and the ' release of airborne' and liquid effluents to a level that is' as low as is - g-reasonably achievable. The goal is to maintrin personnel exposures and the release of efiluents to a value less than 25 percent of those specified. In 10 CFR 20.'

Where monitoring programs indicate that these levels are routinely being exceeded,~ the operation will be reviewed to determine if it is prac?lcal to reduce the levels.' At no time will the limits specified in 10 CFR 20 be exceeded.

Committee members are selected in accordance with Section 6.3. At least two.

members are selected for their experience and famillarity with nuclear criticality..

[

A listing of -.the members of the RSC -and statsments of their' training and-experience, Form RH 2050 A, follows.

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Radiation

-h Safety Officer Linac Facility and Chief '.

Manager '

P. R. Maschka Health Physicist

- 3. C. Young Radiation Safety Title Radiation Safety.

Title Officer =

Committee, Chairman l

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Nuclear Radiography Principal Engineer -

K. L. Crotble Engineer G. 3. Goss Groep q

Alternate Radiation Title -

Radiation Safety Title Safety Officer Committee, Member.

Radiation Safety l

Committee i

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l Assembly 1

3. D.' Gehringer Supervisor Radiation Safety

= Title i

Committee, Member t

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1-Member

Title:

Member -

Title i

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.em 7as P sees Sasemene. Co 8pm.s easia -

Department of Hestth STATEMENT OF TRAINING AND EXPERIENCE (Um additional sheets as necesary)

Instruction: Every individual propeang to um radioacave meterial is required to submit a Statement of Training and Experwnce in dupliente to the addres given above.

Physicians should request Form j

RH 2000 when applying for human use authorisanons Radiation Safety Officer

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and Chief 1.

Nanw of propowd user Paul R. Maschka Position title: Health Physicist h

Addres: 2111 Weatherby Avenue City: Escondido Zip:E7 j

To be included on Lic. No. 2468 80 in name of IRT cornaraeion 2.-

Description of proposed um Research and developmenti neutron radiography, gauging and assaying systems, instruc :

tion and demonstration 3.

Training j

a.

High School Gradussei Ye:1 No creiahton university. Omaha. Nebraska b.

-College or University: Name and locasion 2

peyee nana Couns of study Yers completed Education specifically applicable te use of radianotive material c.

U. S. Army Nuclear Power Plant Training Course (48 weeks)

Ft. Belvoir. Virginia General Atomic Raolelogical Safety Ccurse - passed l

4, Experience -

a. ' List exponence with radiosenvity bepanas with most recent l

present (1) Dates: From May 1973 to Health Physicist, retoonsible for administration and all onerational Title and duties:

radiation safetv' for IRT Employer. IRT corocration Addresi P.O. Box 80817. San Diano. CA 92138 Aoril 1973 I

(2) Deers: From Dec. 1963 to Health ohvsics survevor monitored radio-chem lab. hot cell, Title and duoss:

reactor facility, and linear accelerator -

E Employers canaral Atnaic Addres:- San Diego, CA

[.-

(3) Dnies: From Jan. 1960 to - Dec. 1963 Healthpnysicstech.andreactoroperator(SM*i[.ygtrPower Title and dutws:

Plant, Ft. Selvoir, Va., & PM 3A Nuclear Power Plant at McMurdo. Antarcica 1

U. S. Air Force -

Address; ' Ft. Belvoir, VA Employer:

i 8188 MA (701 O'

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l LO Radioacuve materials prev %1y used. Citt typical radioisotopes in appropnate box and key to -

b.

Part 4.a abovei Quantities Handled -

Microcurm

, Wilicuries

,, CurisA, -

Kilocunes -

so N

Gs"'0 g,N1 Go,g. G r' ~,

Go~'

D

  • k Sealed sources Co"230 Cs**239 10 eg,,

eg u

pu y235. Th232 235.p,239 235 235 233 Unsealed alpha' y

U 24l,yg,237 Th 2M 2M enuriers U

9 g

Unsealed beta-Sr". Cs#

MFP & MAP Kr P '

MFP 109 22 133 Cd ggp pausa enatters g ih Pute. Pole Neutron sources PoLt. Cf-252 Cf.252 Cf-252 Describe procedures suailer to those propoord in Part 2 with which you have had experience.

c.

Indisses months or years for each and hay to Pan 4.a above.

Research and development 44 (1) - May 19'1 to present 4a (2). Dec 1963 to April 1973 O

d.

ladicase which types of facilities you have used and key to Port 4.a.

(X) Orthaery Chemicallaboratories 44 1,2,3

-(X) "Contreibed Arse" (Type B) laborssories 4a-2,3 (X) Glove bones

-44 1,2 (X) Sheridad glove bones 44 2 (X) Caves with commes measpeksors 44 2 (X) Field opusecas with parable eqmpeant 4a 1,2,3

5. - Carafiene I baseby ammfy that an isfonnamos conmined in the Statement is true and correct.

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Department of Hastth-y E

STATEMENT OF TRAINING AND EXPERIENCE g

(Um additional sheets as necessary)-

Instruenons Every individual ang to use radioactve matenal is required to submit a Statement of -

(

Training and Experwnce in icate to the addres gwen above.

Physicans should request Form Alternate RH 2000 when applying for human use authoriannons.

Radiation 1.

Name of propowd user: Kay L. Crosbia Position title: Safet/ Off f cer

_ Address: 5002 Northaven Avenue city: San Ofeoo Zip:,R119 To be included on 1.ic. No 2asa.a0 in name of 1RT carnoration l

Description of proposed use 2.

Research and Development as defined in CRCR Section 30175(j) a.

Nondestructive' testing, radiography, gauging and assay systems, and b.

c.

Instruction and demonttration, y

1 3.

Trainagi High School Gradusse: Yes XX No '

Pratt Inst.. Brooklyn. M.Y.;

s.

Univ. of VA. Charlottesville, VA b.

College or University: Name and location met Cours of study Chemical EnGenG; Nuclear Enorng.

Years completed 6 Degree Education specifically applicable to us of radioactive maseCal c.

Experimental Nuclear Ergineering Lab.

Radiation Shielding and biological effects of radiation at University of Virginia 4.

Experience 1.ist exponence with radioscovity beginning with mos reent a.

(1) Dates From April 1973

' to present Radiation safety officer, principal physicist.. responsible for radiatici and du Titpeggep]: gsics, itcensing anc wwi accounnou nty; Mau witn suocrincal g

P.O. Box 80817, San Diego, CA 92138 Employer. IRT Corocration Address:

April 1973

-l (2) -Dases: From Sect. 1963 to Staff Encineer.. experimental researcht supervisor of accelerator Title and dunes pulsed reactori R&D with linear accelerator and nondestructive testing Employer: Gulf Red Tech Addres: P.O. Box 81608. San Diego. CA Sept. 1%3

-(3) Dates: From Sect. 1961 to Title and dunes: Staff membert pulsed reactor supervisor..respo%1ble for i 4ctor operations and safety-Employer: Sandia enenaratinn Address: alk" ~

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Rashonenve rnaterials previously und. Cite typical radioisotopes in appropnate box and key to Part 4.a above Quantities Handled Miaocurws Millieuries Curies Kilocurws

44. 1,2
44. 1,2,3
44. 1,2,3 -

Sealed sourms ut e.

Mite. A co-60 Mite. A co 60 Co 60 y

t)nsealed alpha 4a. 1,2,3

44. 1,2,3 4a. 1,2,3

.U.Np,Pu Th U-235. 0-238 U-235 & U-238 enursers am Th

'** l

      • l'3
      • l'3 Misc.'Z& MAP Mi,sc. & MFP,.

.F M bem-pen statars ggp gg MFP & M i

44. 1,z sa. 1.g.J os. 1,U'J br-a Neutron sourms Cf-252 Cf 252 Pe8e. Anse 3

c.

Describe procedures similar to those d in Part 2 with whie you have had experience.

Indiese man's a part for each key to hrt 4.2 above.

2a - c l years, 44 1,2 & 3 2b - 12 years, 44 1,2 2c - 9 years, 4e.1.2 LO d.

Indicase which types of facilities you beve used and hay to Part 4.a.

(X) Orchnary Chemical laboratories 4a 1,2 (X) " Controlled Area" (Type B) laboratorms 44 2 (X) Glove boxes 4a 1.2

-!'w>

() Shielded gion bonus i

() Cave with temose manipulasors L

(X) Field opersoons with portabir equipsarne de 1 5.

Csentissai I hewby carofy that allinformanon conmined in this samment is true and cornet.

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Department of Health '

seereinenes, causernes sesia -

STM EMENT OF TRAINING AND EXPERIENCE -

(Um additional sheets as necessary),

~

instruction. E,ery individual sing to um radioactive materialis required to submit a Statement of Training and Expenence in inte to the addres giwn abewe.

Physicians should request Form

-(

RH 2000 when - applying for human use authonssoons.

1.

Name of propowd user: Jack C. Youno posioon titlei Linac Facility Nnager' Addres: 1937 Rockhoff Lane Cityi Escondido zip:-92D26i

[

To be included on 1.ic. No 2468 80 in name of IRT corocration 2.

Descnption of proposed use'

'esearch and development

3.. Tramag:

a.

High School Graduate: Yes X No' b College et Universty: Name and locanon No. Texas State Univ..' Denton. Texas Years completed 5

Degree M A-Cours of sawiy Phv81cs c.

Education specifically applicable to um of radioecem mesenal 1.

Masters thesis utilized a Cockcroft.Walton accelerator 2.

Several courses in nuclear and atomic physics f

1 L

4 Exponence:

a. ' Ust exponenae with radioscovity beginning with mos recent

-(t) Dates: From 1973 to present TitJe and duties:' Princioal scientist.-ennerimental ohysical usina a linear accelerator 252Cf sources and Co " sources Employer. IRT cornaration Addresa P.O. Box 80817. San'Diano. CF.

92138 f

(2) Dates: From 1963-to 1973-Title and duties: Staff r..annerimental ohysics usina a linear accelerator, subcritical assemblies, and critical arsemblies.

1 Employer. Gulf General Atomic Addres: Sat' Disco. CA

' ~

(3) Dates: From to Title and duoss:

j Employer:

Address:

aa nsu in=

1 O\\

l September 30,1988 Page 14 l

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.)

)

. b. - Radioecnve materials previously und. Cite typical radminotopes in appropnate box and key to Part 4.a abovei Quantities Handled Microcures Millicunes Curies Kilocunes Sealed sourah Co60. CsI37

'Co60-60 Co U335. Th333 Unsealed alpha yZ33. Th333 enunen 238 238 U

U Unsealed beta-32 penma eminers P

gyp Cf 252. PuSe,

, Neutron sources -

PuSe.' Pole Po64 '

Describe procedue i sunder to those proposed in Part 2 with which you have had experience.-

c.

ladiese months a years for each and key to Part 4.s above.

Research and development 44 1 4 years 44 2 14 years D

. d.

Indicase which types of facilities you have used and' key to Part 4.a.

(X). Ordinary Chemical laboratories 4a 2 (X) " Controlled Area" Crype B) labora'.sries 4411, 2 (x) Glove bones 44 1. 2 (x) Shinidad glove bones 44 1. 2

-() Caets with ressess manipulosors (X) Field operamons with ponable equipment 44 1. 2 5.

Cerufleace I hereby earnfy that all informasion conmined ;n this Staerment is true and cortect.

%, c. 4 -. -1 L A JU 195I w

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Q September 30,1988 Page 15

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nesteeseis Mese session Sasse of Calpends 744 P Soest samunenes, caissemia gesta Dep rem set of H a m g

STATfJWENT OF TRAINING AND EXPERIENCE (Um additional sheets as necessary)

Instruction: Every individual poposing to um radioactive material is required to submit a Statement of-Training and Experience in cluolicate to the addres giwn above.

Physicians should request Form RH 2000 when applying for human use authorisations.

j 1

JOSEPH CEHRINGER Position title:ASSISIANT SUPERVIS01 1.

Name of propowd user; 8294 TLANDERS DRIVE #44 City:

SAN DIEGO Zips 92126 Address:

To be included on Uc. No. SW 1405 in name of IRT Corporation i

j 2.

Description of proposed um

)

Research and development l

A Training:

High School Graduate: Yes x No a.

b.

Colley or University: Name and locasion

^

Years completed Degree Ccaw of study Education specifically applicable to use of radioactive material c.

IRT RADIATION SAFETY COURSE

/

l l

l.

.I 4.

Experience:

Ust experience with radioactivity beginning with most recent l

a.

APRIL 1982 1988 (PRESENT)

(1) Dates: From to Title and duties:

FIELD SERVICE ENGINEER / TECH.

AND MANUFACTifRINd/ARRFMRf.Y Tr eif l

IRT CORPORATION Addreg.

8221 ARJONS, SUITE Ft S.D., CA. 92 Employer.

(2) Dates: From to Title and duties:

Employer!

Addres:

g (3) Dates: From to Title a.d duties:

Employer:

. Address:

September 30,1988 N!A

Ra6ssedvs assadals.a.:=y used. Cite typical radioisotopes in appropriam box and key to b.

r Part 4.s above:

O' Waroeunes MiBicurie Curies Kilocunes CO-60. U-235 C0-57 5ealed souress Cs-137 AH-241 PU-239 Umssaled alpha eminars unsealed bear ganuma emiteurs

? C g2 CF-252 gggg gggggg Describe procedures similst to those propoed in Part 2 with whid you base had experience..

c.

ladieste months or years for each and key to Part 4.s abow.

O d.

todicase which types of facilities you hsw used and key to Part

() Ordinary Chenaicallaboratories (x) "Connolled Area" (Typs B) laborssories

() Glove boxa

() Shielded glow boxes

() Cens with retnote manipulasors (x) Fiski operations with portable equipment Certificate I hereby certify that all informados contained in this Stateinant is true and correct.

Gw h 00 lfE8 b ei 0

$* v --

September 30,191 Page1 j

l l

gases of CaWomis masteessis sessen semien 7as P seest ospytnant of Hashh samamenes, ca6asemis ses STATEMENT OF TRAINING AND EXPERIENCE (Use additional sheets as necessary) 1 -

Instructions Every individual poposing to use radioactive material is required to submit a Statement of l

Training and Experience in cluplicate to the addres giwn above.

Physicians should request Form RH 2000 when applying for human use authorizations.

NUCLEAR RADIOGRAPHY i.

1.

Name of proposed user:

CEORGE J. COSS Position tith:

ENGINEER gj, ]l SAN DIEGO Addres:

3030 CALLAN ROAD City:

p, To be included on Lic, No.

- um in name of IRT Corocration 1

2.

Daseiption of proposed use Research and develapment 30 Training:

a.

High School Graduate: Yes x

No SAN DIEGO b.

College or University: Name and location UNIVERSITY OF CALIFORNIA 3+

Years completed Degree Course of study PHYSICS c.

Educ; tion speciScally applicable to use of radioactiw material GENERAL PHYSICS COURSES ASSOCIATED WITH NUCLEAR INTERACTIONS AND SPECTROSCOPICAL PHYSICS.,

IRT CORPORATION RADIATION SATETY TRAINING COURSES.

4.

Experience:

List experience with radioactivity beginning with most recent a.

(1) Dates: From FEBRUARY 1985 to PRESENT l

Tith and duties:

RADIOGRAPHER / APPLICATIONS ENGINEER.

DESIGN AND OPERATION.0F EQUIPMENT FOR USE IN RADIOGRAPHIC APPLICATIONS.

IRT CORPORATION Addres:

3030 CALLAN ROAD S.D. CA. 92121 Employer.

(2) Dates: From to Title and duties:

Employers Address (3) Dates: From to Title and duties:

Employer:

Address:

September 30,1988 Preg,13

p-

~

3 4

b.

Radioacaw asserials pseviously und. Cite typical radioisot: pes in approprian box and key to Part 4.s abow Miaocunes Millicuries curies Kilocuries TI-204 Co-60. Ir-192 r

Sealed sources Cs-137 Cs-137 Unsealed alpha emitters IJassaled beta.

THORIUM THORIUM e n tters RADIUM RADIUM Neutron sources Cf-252 Cf-252 Ct-s52 I

Dessibe preesdures similar to those propowd in Part 2 with which you bme had experience.

c.

Indicase months or years for each and key to Part 4.a above.

  • PRIMARY FUNCTION WITH ELECTRONIC X-RAY SOURCES IN THE 2Kv - 6MeV RANCE.

(USE AT MOST TIME

  • PEPIODIC USE OF RADIOISOTOPES FOR PENETRATING RADIATION IMAGING AND SAMPLE COMPONENT GUAGIN (PERIODICALLY)
  • WORK WITH 250KW TRIGA REACTOR FOR N-RAYRADIOGRAPHY USE (MARCH / APRIL '87)
  • CONDUCT SAMPLE EXPERIMENTS WITH A ELEC7PL LINEAR ACCELERATOR (16MeV MAX) (PERIODICALLY) d.

Indicane which types of facilities you beve used and key to Part (X) Ordinary Chemical laboratories (9 " controlled Area" (Type 3) laboraeories

() Glove boxe

() Shielded giove boxes

() Caves whb rences Wim (x) Field operations with portable equipment 5.

Certificam:

4 l

1 hereby certify that all infonnation conmined in this Statement is true and correct.

O sv.-. -

September 30,1988 Page 19

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September 30,1988 Page 20

1 I

I

  • O 4
5. ADMINISTRATTVE PROCEDURES 5.1 PRO 3ECT AUTHORIZATION PROCEDURES The only operation with SNM authorized by this license is storage or preparation f

l for shipmer.t to another licensee or for waste disposal.

l 3.1.1 Radiation Work Authorization Request Procedures i

The responsible person directing the program, or his appointee, must prepare a Radiation Work Authorization (RWA) request form (see Appendix I) describing the operations to be performed, and the necessary procedures, equipment features, process l

characteristics, and planned precautions which assure radiological and criticality

- i safety. The RWA form includes the names and signatures of all persons involved in the

(

l program and identifies those persons responsible for the material specified.

The request should be reviewed with the Health Physicist before it is submitted to the RSO.

l This step is optional but is beneficial to the requestor.

The request is then reviewed in detall by the Radiation Safety Officer who will document his analysis of the project, make recommendations, if necessary, and indicate his approval or disapproval, and if criticality safety review is app!! cable.

With the approval of the RSO, the RWA is then presented to the RSC by the RSO.

The RSC will review the RWA request and Indicate approval or disapproval based upon specifications given in subparagraph 5.1.3 below.

The RSC may approve the RWA with certain conditions or changes attached which the Committee feels is necessary for safer operation.

If approved by the RSC, the RWA will be valid for a period of one year from the month of approval and copies will be distributed by the RSO as follows:

Original Copy: To requestor First Copy Radiation Safety Of ficer l

Second Copy: RWA Flie

!O Taird Conv eosted ia work area.

Se,,em,e,30,iss, Page 21 1

l*

i

.q l

if disapproved, the RWA request will be retumed to the initiator with the reason j

for rejection stated and recommendations for modification.

g 5.1.2 Radiation Safety Officer Review Procedures j

i It is the responsibility of the RSO to establish that 1.

The applicant and all personnel listed in the RWA request are Authorized l

Individuals:

each person named on an RWA must have on file with the Radiation Safety Officer a resume of his previous experience with radio-active material and/or radiation sources, training and other quellfications, to indicate competence in dealing safely with radiation and radioactive mate-rials.

In addition, it is necessary that the individual has successfully completed an approved course in Radiological Safety, including a written examination on radiological safety principles and policles as applied to IRT I

activities, in some cases, due to past training and experience, a walver of this course requirement may be granted by the Radiation Safety Committee.

Minimum requirements for walving formal training are prior completion of a l

radiation safety course and at least three years active use of SNM.

" Authorized Per onne!" does not necessarily mean capable and competent to g handle any or all radioactive materials. It merely means that these persons l

are authorized to be named on an RWA and either have paswd a training course or have been granted a waiver.

2.

Experiments which could result in an airborne concentration of radioactive material which, when averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in one week, exceed the limits set forth in 10 CPR Part 20, Appendix B, Tables I and II, shall require the use of a suitable glove box or hooded facility with a filtered ventilation 'and, if j

necessary, require exposure time limitations or, in the case of emergencies, L

require the use of protective respiratory equipment.

l 3.

Contaminated materials or experiments which could result in contamination levels greater than twice background levels must be' handled in contamination control zones, glove boxes, etc., using adequate protective clothing.

In l-reviewing the adequacy of the f acilities specified for the operation, the report entitled "Workplaces for Unsealed Radionuclides" authored by o

D. A. Pickler is used as a guide. Deviations from this guide are allowed if alternatives are acceptable according to the considered judgment of the RSO g and RSC.

September 30,1988 Page 22

Experiments involving radioactive materials with radiation levels of a magni-4.

lO tude esi couid reseit in ex,-e ie-is ia - uncontroned area oft (a) 2 mrem in one hour; (b) 100 mrem in one week; or (c) 0.5 rem in one year as specified in 10 CFR 20.105 shall be done in adequately shielded cells. For controlled areas. adequate shielding and time limitations must be specified to prevent exposures in excess of those given in 10 CFR 20.101.

5.

The procedures es speelfled in the request are presented !n appropriate detall and are proper and adequate to assure safe operation.

6.

All license requirements are satisfied.

7.

The personnel involved and d!recting the program are competent to perform the Indicated work, and have the necessary training and experience to safely use the radioactive materials authorized by this RWA.

5.1.5 Radiatlan Safety Committee Review Procedures in their review of the RWA request, the RSC must consider the following.

1.

The adequacy of the engineering controls for the proposed project.

2.

The conditions under which operations must be performed sub}ect to the following criteria.

The equipment to be used as speelfled in the request is adequate to a.

assure safe operation, b.

The required facilities have been specified and are adequate to assure safety, including the use of glove boxes, hoods with proper ventilation systems, inert gas boxes, storage areas, containers, and shielding (experi-mental cells, structures, etc.) as appropriate.

The procedures, as specified in the request, are presented in appropriate c.

detall and are proper and adequate to assure safe operation.

d.

The personnel involved and directing the program are competent to perform the indicated work, and have the necessary training and experience to safely use the radioactive materials authorized by this RWA.

For RWAs involving the use of SNM, the RSC will evaluate the proposed e.

operation to assure that all reasonable precautions are taken to prevent September 30.1988 Page 23 l..

ll l

l

.i i

any accidental criticality. To assist in this evaluation, the Committee j

has available the following publications g

" Administrative Practices for Nuclear Criticality Safety," ANSI /ANS-8.19-1984,

" Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors," ANSl/ANS-8.1-1983, and

" Guide for Nuclear Criticality Safety in the Storage of Fissile Materials,"

ANSt.ANS-8.7-1982.

l The Committee's review of the RWA shallincludet j

(1) Reliability of any engineered safeguards against criticality.

(2) Familiarity of requestor with the factors related to the occurrence of criticality.

]

(3) Potential Interaction of the proposed SNM usage with any other.

SNM used in the same CAA.

(4) Adequacy of procedures established to prevent operational losses of SNM.

(5) Adequacy of procedures to safeguard SNM.

(6) Adherence of the proposed operation with the mquirements of all app!! cable regulations.

Approvals of work authorizations and other actions by the Committee will be documented and kept on file for a period of one year following termination of authorization.

in addition to the review of proposed programs, the RSC must review policies and criteria estabIlshed by the Radiation Safety Organization and review operations covered i

by these criteria. The Committee must also audit all work subject to this license for conformance to and effectiveness of all applicable procedures and practices.

The Committee will meet at least once each calendar quarter to review RWA l

requests and conduct other business. There must be a majority of members present to constitute a quorum.

One of these must be the Radiation Safety Officer or his designated appointee.

No RWA request may be approved or any official business transacted in the absence of a quorum.

O+

September 30,1988 Page 24 L

l.

l 3.2 PROECT CHANCES AND RENEWAL 5 RWA's are approved for a period of one year from the month of authorization and may be renewed by submittal of the RWA request 30 days prior to the termination date.

Renewal without repeating the formal review requires that the R50 and/or Chief Health Physicist inspect operations and make a recommendation for renewal on the RWA request. The R50 may approve RWA renewals without formal review by the RSC.

Changes in a project require the filing of an amendment to the existing RWA.

The R50 will determine the need for formal review by the R$C, based on the extent of changes since the previous review.

No changes are made or renewals granted without the approval of the R50. All changes concerning the amounts or use of SNM must be reviewed and approved by the R$C.

SJ SELECDON CRfTERIA POR HEALTM PHYSICS STAFF AND RADIAT90N SAFETY COMMITTEE The RSO shall have an accOJited college degree in physics, the biological sciences, engineering, or other relevant fields and a minimum of three years of applicable experience involving radioactive materials, radiatica, sources, special nuclear materials, and radiation safety, or a minimum of six years of applicable experience involving radioactive materials, radiation machines, special nuclear material, radiation sofety, and administrative practices in the radiation safety field.

The Health Physicist shall have a minimum of three years of applicable exper-lence involving radioactive materials, radiation-producing machines, special nuclear material and radiation safety.

Members of the Radiation Safety Committee shall have expertise in their fields of specialty. For technical members, an accredited college degree in a field appropriate to their specialty and a minimum of two years of related experience is required. For a nontechnical member, a minimum of five years of experience is required in an appropriate field.

The Radiation Safety Committee is appointed by the President of IRT and has a minimum of five members, including the R$O, a member representing IRT management, and a member representing experimental operations.

Personnel employed in other safety related positions are selected oy the Manager of the Human Resources Department and the Manager of the Radiation Safety Office h

with the advice and consent of the Radiation Safety Committee.

September 3 19g

5A OPERATIONS OF THE RADIATION SAFETY OPPICER AND HEALTM PHYSICIST in addition to the above-mentioned revonsibilities, it is the responsibility of the Radiation Safety Officer tot 1.

Review and inspect all operations at least yearly and more frequently if deemed necessary by the RSC.

2.

To inspect and assure proper operation of all'new installations affecting materials governed by this license before accepting them as workable and

usable, it is the responsibility of the Health Physicist to:

1.

Initially investigate all incidents involving radioactive materials, special nuclear matarlais and radiation sources to determine the causes and circum-stances and what corrective action is needed, and report findings to the RSO and RSC.

2.

Ensure that policies of the RSO and special requirements as speelflod in the license are being followed and to stop all operations that are violating these policies until the situation is remedied.

3.

See that radioactive waste material is handled properly, that the proper containers are available and being used, and that all waste material is being disposed of in a proper and timely manner, it is the joint responsibl!!ty of the Radiation Safety Officer and the Health Physicist to:

1.

Maintain a complete centrally located file of all records required by this i

license, 2.

Investigate the design criteria of all facilities and ensure that they are l-functional for their intended use and radiologically safe.

3.

Take charge of all radiological emergencies and institute remedial action as provided by the general emergency procedures.

5.5 INTERNAL INSPECTION AND REVIEW The Radiation Safety Officer is responsible for inspection and review of all activities involving materials subject to this license, to establish that all activities are September 30,1988 Page 26

authorized, that they are in compilance with this license, and that good radiological

_Q protection practices are being used. He is required to submit a written report of any discrepancies to the Radiation Safety Committee, the cognizant IRT Department l

Manager, and the President of IRT.

The Radiation Safety Officer shall review and write an annual audit of the Radiation Safety and Cr!ticality programs and submit the audit to the RSC for their consideration.

The RSC shall forward the audit to the appropriate Divisional Vice Presidents and to the President of the Company, along with their comments and recommendations.

S.6 OPERATIONS OF THE RADIATION 5AFETY COMMf7 TEE in addition to its authorizational duties described above, the Radiation Safety l

Committee must:

L 1.

Review and establish organizational policies and procedures concerning radiological matters and make recommendations to management for their implementation.

2.

Review and investigate all significant incidents and report to management O

with recommendations as to remedial action and policy or procedural changes If Indicated.

3.

Assure that all operational difficulties such as unsafe practices, noncompll-ance with license, safety hazards, etc., are corrected prior to continuance of program or procedures.

To assist in the safety evaluation of the uses authorized by this license, the Radiation -Safety Officer and the Radiation Safety Committee. have available. the following publications:

" Administrative Practices for Nuclear Criticality Safety," ANSI /ANS-8.19-1984.

" Nuclear Criticality Safety !n Operations with Fissionable Materials Outside f

Reactors," ANSI /ANS-8.1-1983, and

" Guide for Nuclear Criticality Safety in the Storage of Fissile Materlats,"

ANSI /ANS-8.7-1982.

1 O

September 30,1988

]

Page 27

1 5J CONTROL AND ACCOUNTABILITY OF SPECIAL NUCLEAR MATERIAL 5.7.1 Organksation for Centrol, Safeguarding, and Accountability of SNM g

i Inventory control of SNM will be accomplished through a system of Permanent and Temporary Controlled Access Areas (CAA's) which are designed to minimize interaction of separate uses and provide a basis for accountability. Each CAA will be a well-Identitled physical area with specified boundarles. Each CAA will have a Material Custodian and Alternate Material Custodian who will be responsible for accountability and adherence to license criteria.

The operating and review functions for material control, accountability, and prevention of criticality w' 1 be conducted by a Nuclear Materials Manager (NMM) and the Radiation and Criticality Safety Committee (RSC).

1.

Responsibilities of Nuclear Materials Manager The Radiation Safety Officer la the Nuclear Materials Manager (NMM). The NMM will have overall responsibility for operation of the Control and Accountability System. The resp %sibility includest Assurance that all receipts and shipments are within license !!mitations.

a.

b.

Maintain material control and accountability procedures.

g Report any losses as required by applicable regulations.

c.

d.

Mainta!n a file of material transfers and current inventory for each MBA.

Act as Material Custodian for the fuel storage areas and control access e.

to these areas, f.

Perform a physicalinvent.>ry of all C AA's annually.

5.8 STORAGE OP SPECIAL NUCLEAR MATERIALS 5.8.1 3030 cantan Road Storage Vault This vault-type room is located on the first floor, North wing of the new IRT Headquarters Building.

The walls and ceiling are made of 8-inch thick reinforced concrete block.

A metal door equipped with a combination-type security padlock provides entrance. The vault shall be equipped with an ultrasonic motion monitor ior security. The room measures 6 feet by 6 feet by 8 feet high.

O\\

September 30,1988 j

Page 28

" - - ~ - - - " - - ~ - ' - - ~

- - - - = - -. - - -

Inside the fault, immediately opposite the entrance, are two 4-inch diameter i

O eie 28 *

  • ad i' <
  • uad r th 9 rkias ta*

'8 9 9 = r 5 *a 7 <

  • uad rsrauad-5 The buried end is welded shut and the end in the vault is closed with a pipe cap. These ttbes will be used to store long reactor test rods. The other storage compartments will consist of metal cabinets measuring 18 inches deep by 36 inches wide and 72 inches

]

high. Storage bins shall be built on each shelf in order to comply with the Storage Criteria discussed in Section 5.8.2, which follows.

5.8.2 Storage Criteria The rules for storage. are governed by both density and area criterla with the

)

following rules goveming storage in the HTGR vault.

1.

Unmoderated SNM metal, alloy or compounds may be stored in closed 235 containers limited to 1.2 kg of U in a 3.6 liter volume,0.8 kg of plutonium 233 in a 2.4 liter volume, or 0.4 kg of U in a 1.3 liter volume.

2.

Moderated SNM (H/X greater than two) may be stored in isolated plane 235, 0.098 kg of plutentum, U

arrays not to exceed an average of 0.160 kg of 233 or 0.140 kg of U per foot square of aspect area. No foot square of the 235, 0.1% kg of plutonium, O

aspect area may contain more than 0.320 kg of U

or 0.280 kg of 233,g The " foot square of aspect area" means any foot square area as viewed. There are two, restrictions goveming the storage, (1) an average loading of i grams per square foot, and (2) 22 grams in any one square foot of aspect area. Uniform loading of x grams per square foot over an entire array satisfies the storage criteria--no more than i grams per foot square regardless of where the square foot area is selected. The array shown in Figure 1 also satisfies the storage criteria.

Some of the material is concentrated in a smaller areat however, no singitt aspect area is allowed an excess of 2 i grams of material. Referring to the figure if each box defines a foot square there can be i grams on the average in each square. You can also store i grams in adjacent corners so long as you do not exceed 2 i in any foot square of aspect area, shown here as the dashed foot square. Any material stored in the other two connecting squares must fall outside the dashed foot square.

The basic reference for critical dimensions of SNM-moderated systems is 235 TID-7028; H. C. Paxton, et al., " Critical Dimensions of Systems Containing U,

.239 233 Pu, and U," USAEC Report TID-7028, Los Alamos Scientific Laboratory and Oak September 30,1988 Page 29

R R

g 7_

. -. q

!R h

Y b

L_,,.

.J R

R R

R R

a Figure 1. Foot sqmre of aspect area Ridge National Laboratory, June 1%4. This document is an extensive cross comparison of many critical experiments on a common basis.

In addition to USAEC Report TID-7028, a second publication was used to check the storage criteria: ANSI standard N16.5-1975 (Reaffirmed May 13,1987) " Guide for I

Nuclear Criticality Safety in the Storage of Fissile Materials."

Rule (1) above is based on the critical parameter versus SNM density curves, Figures 8,9, 27,28,34, and 35 of TID-7028, with a safety factor of 2.3, which provides-double-batch protection under mass control and 1.33 in volume. These curves are for l

water-moderated SNM spheres. The metal-water mixture data have been used since these figures, in nuclear safety evaluation by the licensee, assume the SNM exists in the containment vessel as a fine particulate material and the vessel may become water I

flooded.

Reflectors, other than water, have been taken into account by use of Table 7 and Figure 44 of TID-7028.

The most effective moderator is Be, extrapolated from Figure 44 to be 7.5 kg for an infinite reflector. However, Be ir wt a common reflector and it is very unlikely that a storage situation would arise in which the entire container

[

would be reflected by Be. Using the data from Table 7 and Figure 44 of TfD-7028, reflectors other than water have been taken into account by further reducing the p

critical parameter versus SNM density curves using another safety factor. This safety f actor is determined by the ratio of the critical mass of an infinite beryllium reflector to the critical mass for an infinite water reflector for an unmoderated SNM sphere.

235 This safety factor is 0.33, and although it applies directly to U, it has been used for g 233 plutonium and U.

September 30,1988 Page 30

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-. - -- ~ - - -. _

~

)

1 i

The nuclear safety of this geometry is based on the fact that 1.2 kg of U is 233 235 h

safe in a spherical shape for all metal-moderator mixtures above 1.7 kg U per liter and 3.6 liters is a safe spherical volume for any metal-moderator mixture below 1.7 kg i

23b per liter.

233 A similar argument to that for U applies for plutonium and 0.8 kg of plutonium

)

is safe in a spherical shape for all metal-moderator mixtures above 1.4 kg plutonium per liter and 2.4 liters is a safe spherical' volume for any metal-moderator mixture below 1.9 kg plutonium per liter.

Moderators othe'r than water, such as carbon and bery!!!um, as a diluent, have less j

moderation ability, per atom, than hydrogen and the addition of carbon and beryllium result in a loss of reactivity.

Rule (1) is also based on Table IV and V of T!D-7016, Revision 1, for plane lattices of this type.

This is, therefore, based on a mlnlmum center-to-center spacing of 16 inches and surface-to-surface spacing of eight inches or greater.

l' Rule (2) is based on the slab geometry curves of TID-7028. The area-density concept is of frequent use in storing and handling SNMI this is usually expressed in kilograms of SNM per foot square of area. The working limits are arrived at by using water-reflected critical slab geometry curves of TID-7028, converting to equivalent c

O kiio rams,er foot seuare, angivin a safety factor of 2.3 for doubie-batch erotection.

and replotting versus the SNM density per liter of SNM-water mixture. The minimum 235, 0.098 kg of plutonium, and 0.140 kg U

of these curves are at values of 0.160 kg of 233 I

of U per foot square.

5.8J Arjans Pacility Storage A vault type room has been constructed at the Arjons Facility to store the Pu/U MOX ft al rods and the other SNM. The attached Figure 2 shows the location of the i

l vault and Figure 3 shows the estruction of tne Vault Type Room. The internal i

dimensions of the room are 36 inches deep,34 inches wide, and 84 inches high. The rear wall is a 4-inch thick reenforced concrete structural wall which is part of the existing building. The side and front walls are made of standard 8 x 8 x 16-inch hollow concrete blocks with the hollows filled with concrete during construction. The ceiling is made of 1/4-inch steel plate covered with 2 inches of concrete. The door is a steel door secured with a combination lock deadbult and key lock door handle.

The vault room is equipped with intrusion alarms consisting of alarm contracts on

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room. The alarm system will be "ON" at all times except when it is necessary to enter vault.

The building has perimeter alarms on all of the entrances and there are infrared motion detectors throughout the inside of the building. This intrusion alarm system is "ON" at all times except when the building is occupied.

The Pu/U MOX fuel rods will be stored inside two three-inch diarmter steel pipes.

]

The ends of the pipes will be threaded and closeo with pipe caps. The pipes will stand on end, one in each rear corner of the room, and they will be secured to the wall with' two clamps. The other material will be stored in the same steel cabinet that they were stored in at the Callan Road facility. The cabinet will be positioned between the two

]

plutonium storage pipes.

5.8A General Procedures for Use of Special Nuclear Material Several general procedures apply to all users of SNM.

1.

The Criticality Safety Committee must approve all operations which fall within the limits on SNM specified in Section 5.1.1.

j O

2.

All transfers of SNM between CAA's must be recorded on a Material Transfer form. One copy must be given to the NMM and one retained by the Material Custodian.

3.

Each Material Custodian must maintain a log of transfers in and out of his CAA, showing a running inventory of the current amount in his possession.

4.

Unless speelfically exempted by the License, a criticality monitor which conforms to 10 CFR 70.24(a)(1) will be operating in each area where more j

233 235, 300 grams of Pu, or 300 grams of U

U than 500 grams of contained are present.

Special nuclear material operations are generally controlled by mass limits. The CAA is prevented from exceeding its limits by the Nuclear Material Manager controlling SNM issuance to the CAA. The CAA log book for the operation provides the means of enforcing and auditing adherence to these limits. The possession limit under each CAA is the mass limit authorized and pe-lodic audit ensures that the CAA books are properly maintained, that limits are not exceeded, and that operations are safely conducted.

O September 30,1988 Page 34

i l

1 In addition, the* entries leading into a CAA shall be conspicuously posted by a sign or signs. Such signs shallinclude the following informations a.

SNM limitation b.

Quantity of SNM currently in the CAA c.

Material Custodlan d.

Alternate Material Custodlan(s).

The quantity of SNM within the CAA will be updated whenever SNM is added or-removed.

When the Material Custodlan or alternate Material Custodian is not in the immedlete vicinity of the CAA, entries leading into the CAA will be controlled by locked doors, a watchman, or a security guard for authorized personnel entry.

Anyone who wilfully violates the above administrative controls will be subject to appropriate corrective action. Any future RWNs signed by the violator will have a notation beside his name as having " violated a good radiation safety practice." The cognizant manager of the violator will be notified in writing of the violation and a record of the violation will become part of the employee's radiation record.

In the event of repeated violations, the employee will be subject to disciplinary l

action such as dental of use of SNM, suspension or termination.

5.9 PROGRAM RECORDS Program records are maintained in a centralized file of the Radiation Safety Office for a period of at least three years. These files will include but not be limited to 1.

Radiation Work Authorizations that include location of use; names of personnel involved; description of the program, procedures, materials, and f acl!!tles; results or comments of reviewers, i

2.

A list of all authorized personnel.

3.

The results of all inspections and audits of the program, including survey and compilance data.

4.

SNM accountability records, including materlat transfers, physical inven-tories, and material status reports.

-O 3.

exnese,e end bioassay histeries of eti esers.

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Leak test and environmental survey records within and outside controlled O

areas.

7.

Histories of allincidents and unusual occurrences.

8.

A complete file of calibration data on allinstruments used for radiation level i

monitoring.

9.

Resume of each authorized person's training and experience with radioactive materials.

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6. RADIATION PROTECTION PROCEDURES l

6.1 RADIATION PROTECTION MANUAL The manual that is used for instruction of personnel in the principles of radiation safety and protection is the "!RT Corporation Radiological Safety Gulde" prepared by

]

P. R. Maschka and K. L. Crosble, as revised August 1986. In addition, the ic* lowing publications are available for use in the instruction programs:

1. " Introduction to Radiological Health," by Hanson Blatz, McGraw-Hill,1964.
2. " Accelerator Health Physics," by H. Wade Patterson and Ralph H. Thomas, Academic Press,1973.
3. " Radiological Safety Aspects of the Operation of Electron 1.lnear Accelera-(]

tors," by William P. Swanson, IAEA,1979.

4. " Atomic Radiation" Theory, Biological Hazards, Safety Measures, and Treat-ment of injury, published by RCA Service Company.
5. " Radiological Health Handbook," pub!!shed by the U. S. Department of Health and Human Services, Public Health Service,1970, in addition, we have a large number of reports, booklets, and pamphlets from the IAEA, NCRP, and NBS.

These documents are maintained by the Radiation Safety Office to provide current and concise source books covering radiological safety practices and procedures established by the licensee.

These books, in addition to describing the complete radiological safety program, cover the procedural needs for establishing an activity involving radioactive materials, the personnel work rules which must be employed, the p

kind of personnel monitoring which will be used, records requirements, etc.

These j.

manuals specify the need for special review of untried operations before commencing activities. They also identify various detection programs, such as the bloassay program designed to detect and measure radiation exposures from internally deposited radio.

O active materials. They are available to each individual who expects to utilize and be September 30,1988 Page 37

l l

.I t

i responsible for radioactive material or radiation-producing devices, and this individual hf is charged with the responsiblity of seeing that personnel working under his direction i

L abide by the rules and regulations. The individual user at all times is further charged j

not only with the responsibility of his own safety but also with the safety of others and a

the protection of equipment and facilities.

Changes to the IRT Radiological Safety Regulations can only be made by the l

Radiation Safety Officer, with the approval of the Radiation Safety Committee.

t 6.2 PERSONNEL MONITORING r

In order to fulfill responsibilities for evaluating and recording all exposures.+%t are actually incurred, personnel monitoring equipment is provided for each employee r

who may be subject to irradiation and any visitor who is permitted into a radiation area.

Appropriate personnel monitoring equipment shall be supplied to and be required for use by:

1.

Each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of.

23 percent of the applicable value specified in 10 CFR 20.101(a).

g I'

2.

Each Individual under 18 years of age who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of five percent of the app!! cable value speelfled in l

10 CFR 20.101(a).

3.

Each individual who enters a high radiation area.

6.2.1 Film Badges Film badges are used to measure external radiation dose for occupational l

personnel. The following table gives a summary of the typical characteristics of such j

devices. Self-reading pocket lonization chambers (dosimeters) are used in addition to film badges as determined by licensee to measure x-ray and gamma radiation, fast neutron radiation, and thermal-neutron radiation from a dose of I mrem to 600 rems.

l 9

September 30,1988 Page 38 l-

Film Badge Dose Ranges Radiation From To T pe (mrems)

(rems)

Energy X-ray and gamma 10 500 5 kev to 100 MeV (hly energy)

X-ray and gamma

  • 0 60 Low energies Beta 40 1000 400 kev to 30 MeV Thermal neutrons 10 300 0 to 3.5 eV Fast neutrons 15 10 5 kev to over 100 MeV The film badge and finger ring dostmetry service is provided by contract with the R. S. Landauer Company, a commercial supplier of this service.

Film badges and finger rings are processed monthly by the supplier, and pocket dosimeters are read weekly and more frequently if exoomare of the wearer is likely to exceed 100 mrem during the weekly period. Dosimeters are calibrated yearly.

Personnel-monitoring records are confidential Information, but each employee or his supervisor may review his exposure record upon request.

Doses in excess of 100 mrem / week are called to the attention of an Individual and.his supervisor immediately following the reading revealing such an exposure, and an inquiry is made regarding the cause with an explanation noted in the record, in addition to the personnel monitors, a bloassay program for employees working with unencapsulated radioactive materials is conducted, utilizing urinalysis, lung burden azay, and whole-body counting as appropriate to provide the company with a methW for acquiring records related to occupational radiation exposures. Bloassay services are contracted to United States Testing Company, Richland, Washington, while whole-body counting and lung burden assay services are available from the General Atomic Health Physics Department. The program is as described in Section 6.2.2.

Personnel who work with SNM in dispersable form are instructed to check themselves for contamination immediately upon leaving the work area. Af ter removing any protective clothing, they check their f ace, head, hands, feet and clothing. They use a portable Alpha counter and/or a pancake GM detector, as appropriate, if they detect any readings greater than twice background, they are instructed to remain in the area and call Health Physics for assistance.

September 30,1988 Page 39

.I i

O' 62.2 Blassay

,ys will be conducted in accordance with the guidelines contained in Guide 8.11.

u.

j innse Individuals working with ingestible radionuclides are required to routinely i

submit urine specimens for analysis. The analysis and interpretation of these bloassays i

are done according to ICRP Publication 10.

Each Individual working with ingestible radionuclides is assigned a hazard index number of one to five based on his own situation. The exposure hazard Indices for gross-alpha bloassay are shown !n the following table.

In regard to the sensitivity of the analysis, the present minimum sensitivity of the bloassay analysis is<1 percent of the maximum permissible body burden for a specimen vold internal of eight hours for uranium and tritium and 10 percent for other time intervals and materlats. For whole-body counting, the minimum sensitivity is less than f

1 percent maximum permissible body burden for each nuclide.

Exposure Hazard Indices for Gross Alpha Bloassay Exposure Hazard Sample Typical a

Index Frequency Situation W

i 5

Weekly Special schedule for individuals whose average bloassay results exceed 4.0 pCl/ day of alpha activity, or who worked in an area where the airborne activity is >25 percent of D AC.

4 Monthly Individuals working in areas where the quar-terly airborne alpha activity is >10 percent of DAC and <25 percent of DAC.

i 3

Semlannually Individuals working in areas where 'the quar-terly airborne alpha activity is <10 percent of DAC and the maximum used to obtain the average is <25 percent of D AC.

2 Annually Individuals working in areas where the quar-terly airborne alpha activity is >l percent of DAC and the maximum used to obtain the average is <10 percent of D AC.

1 As needed Individuals who work in potential alpha con-taminated areas or following an accidental release of airborne alpha emitters into the work area.

O September 30,1988 Page 40 A

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6.2J Whole-Body Manitorire Whole-body monitoring is routinely done on all individuals who may become internally contaminated with beta or gamma emitting radioactive materials. Each individual working directly with radioactive materials and each Individual who has a reasonable probability of becoming contaminated if an incident should occur is assigned a hazard index number of one to three based on his own situation. The exposum hazard Indices for whole-body monitoring are shown in the following table.

Expcoure Hazard Indices for Whole-Body Monitoring Exposure Hazard Sample Typical index Frequency Situation 3

2 or more Individuals who show continuing or recurring times a year evidence of internal contamination.

2 Annually Individuals who routinely work with more than 10 times the MPBB of any unsealed alpha emitter.

1 As needed All Individuals who work with uncontained SNM in an ingestible form Additions, deletions, and changes to these programs or proceoutes are made by the Health Physicist or the Radiation Safety Of ficer.

6J LIMITS OF RADIATION IN CONTROLLED AND UNCONTROLLED AREAS 6.3.1 CentroBed Area Controlled areas include any area, whether the property of IRT or temporary job sites, in which the company controls access for purposes of radiation safety. Access is controlled by means of fences, ropes, or other barriers which deter access by the general public. Areas which have radiation levels equal to or greater than that which will cause exposure of (a) 2 mrem in one hour, (b) 100 mrem in one week, or (c) 0.5 rem in one year or have smearable contamination levels greater t' an (a) 140 disintegrations 2

per minute per 100 cm above background, of beta-gamma enitters, or (b) 26 disinte-2 grations per minute per 100 cm above background of alpha emitters are classified as controlled areas.

September 30,1988 Page 41 l

j Areas with radiation levels of 5 mrem per hour are declared radiation areas and j

are monitored and posted with appropriate signs by the Health Physicist or the

(

individual responsible for the program.

Areas in which the airborne radioactivity exists in concentrations greater than those specified in 10 CFR 20.203, or which, averaged over the number of hours in any week during' which individuals are in the area, exceed 25 percent of the above concentrations, are declared airborne radioactive areas and are monitored and posted as such by the Health Physicist. Work in these areas is done only wit', appropriate clothing i

4 and respiratory protective devices.

Radioactive Work Permits (RWP) signed by the Health Physicist or the RSO are necessary for all work in controlled areas for personnel who are not covered by an RWA or who have not completed the Ra:'.ological Safety Course given by the cornpany and do not have on file with the RSO a resume of previous training and experience and/or a L

waver.

63.2 Uncantrolled Areas Uncontrolled areas are those areas wherein the company does not control access.

Radiation levels in these areas shall be as low as practicable, but will not result in h' exposure of more than (a) 2 mrem in one hour, (b) 100 mrem in one week, or (c) 0.5 rem I

in one year.at the boundary of the controlled area.

. lielease limits of effluents, either airborne or as liquids, are controlled to have an l

average.inual activity at the boundarles as far as practicable below the maximum permissible concentrations (MPC) for unrestricted areas as defined in 10 CFR 20. Any l

time the accumulated data indicate that a level of 50 percent of the MPC may be exceeded on an annual basis, corrective action is instituted.

The discharge of radioactive material into the sanitary sewer system will be in compliance with 10 CFR 20.303 and will not exceed 25 percent of the !!mits speelfled.

The release of decontaminated facilities and equipment shall be within the

- guidelines set forth in: ANNEX A "Guldelines for Decontamination of Facilitics and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special 1

i Nuclear Material."

In addition, every reasonable effort shall be made to reduce residual contamination levels to as low as practical.

g September 30,1988 Page 42 l

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6J.3 Contamination Control

]

Surface contamination -is controlled by containment.

Cross contamination is limited by ' employing ' practical handling techniques.

When routine contamination-control falls, decontamination _ procedures are used. A reading of twice background is readily detectable and is accepted as indicating positive contamination.

Surface contamination is detected and evaluated using (a) large area wipes checked with a l

survey meter; (b) direct survey; and (c) wipes measured in the IRT Health Physics Lab.

Airbornt contamination is controlled by containment in fume hoods, gleve boxes,'

facility ven%hra systems, chemistry hoods, and high-efficiency air filters.

The techniques used for contamination measurement are detailed below.

Filtered exhaust systems throughout this_ application imply a system containing high efficiency particulate filters (99.7 percent efficient in removing particles as small as 0.3 micron in_ diameter).

Typically these filters are preceded by Dust Stop a

pre-filters.

All work with special nuclear materials, in either dry or liquid form, which could create airborne radioactivity will be done in a glove box or chemistry hood equipped i

with high-efficiency filtered exhaust systems and a means for collecting any liquid h

I waste material.

The pre-filters in the chemistry hoods and glove boxes will be changed when there E

has been a throughput of 1 kg of unsealed SNM through the particular device.

j Minimum air flow velocity at hood faces and opened glove boxes Is 150 cubic feet per minute.

The air flow velocities shall be. measured quarterly.

The maximum differeatlat pressure across HEPA filters is six inches of water.

The exhaust streams of these systems,- when in use for special nuclear material, will be continuously sampled by portable air semplers located downstream of the high-efficiency filters. The sampler head is centrally located within the exhaust stream just prior to the exit such that the air stream is sampled as it enters the atmosphere. The portable air sampler utilizes a Gast Model 0521-V3 or equivalent Carbon Vane, constant volume, vacuum pump with a Rockwell 310 or equivalent gas flowmeter.

Air samplers have their filters changed each work day. The filters are counted and evaluated by the IRT Health Physicist. The samples are routinely counted and 4

evaluated at least twice. The first count takes place as soon as possible af ter the sample is collected. This gross count gives an indication of the immediate condition in tha f acility. The second delayed count and, in some cases, a third delayed count enable a more quantitative measurement of the long-lived nuclides present in the sample. Any September 30,1988 Page 43

+

. time the accumulated data indicates t at a evel of 20 percent-of MPC may be h

l exceeded on a weekly basis, corrective action shnll be instituted.-

More frequent sample changes are accomplished and other analysis rout;nes are -

Initiated as required during nonroutine operations or accident situations.

Internal personnel radiation exposure is evaluated through the bloassay program and total body counting.

Personnel who might work with SNM in dispersable form are instructed to check themselves for contamination immediately upon leaving the work area. Af ter removing-any protective clothing, they are instructed to check their face, head, hands, feet, and clothing using a portable Alpha counter and/or a pancake GM detector, as is appro-priate. If they detect any readings greater than twice background, they are instructed to remain in the area and call Health Physics for assistance.

6.3.4 Radiological Survey Radiological surveys will be conducted in order to determine the radiological

-hazards involved in new and untried operations and to ensure that operations in process remain urder proper controls. The frequency and type of surveys are determined by the Health Physicist, the RSO, principal investigators, and the RSC. The basis considered.g are type of operation, hazards involved, and experimental conditions. These surveys are made at various frequencies, depending upon the conditions. They may vary from as 31 times per shif t (every entry into a cell) for Linac experiments, to frequen once per ye : as with surveys of the office areas.

samples a-taken in each work area where unsealed SNM is used with the -

sampl % 3 po-

's near to the workers' breathing zone as is practicable. Using in Appendix III of this application, the work is conducted in d

the gu mx chen n-aa ve boxe, as is necessary. As a matter of general practice, all work A-er a or ? quid SNM which is in a readily ingestible or respirable form is done in eithe a qood or gh ve box. As a result of this policy, air samples taken in the work areas during previous c >erations have shown a quarterly average concentration of airborne radhactivity of:

1.1 x 10"I3 C1/cc for all areas, with 1.6 x 10-13 pC1/cc being the highest, and 3.8 x 10~I" C1/cc being the lowest concentration for individual areas.

O September 30,1988 Page 44

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7. INSTRUCTION OF PERSONNEL u

'7.I PORMA1, TRANING FOR NEW USERS I?? conden 'a program for instructing new personnel regarding health and safety rules end prdMems attendant e the use of sources of radiation.

The radiation protection nihm;aJ has been described in Section 7. An outline of the Radiological Safety Orientation Course based on the IRT Radiological Safety l

Manual, IRT 4171-009, is included as Appendix II. The ceu u is supplemented with study handouts and terminated with an' examination; a grade of 70. is required ~ for passing. All personnel currently. working for IRT, and who are also working unsuper-

)

vised with radioactive material, have passed the Radiological Safety Test or have been-i granted a walver. All new personrel who will work with radioactive material or within a controlled radiation area are required to take the Radiological Safety Orientation O.

i coe,..

l 7.2 PERIODIC RETRAINING i

Annual retraining will be given to all personnel working _with Special Nuclear Materials. _

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O September 30,1988 Page 45

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8. TECHNICAL CAPABILITIES l

8.1 GENERAL PURPOSE OF USE i

IRT. Corporation's programs which utilize radioactive materials and radiation producing machines cover three major categories--instrumentation, research. - and -

f

. technology. These are further subdivided into nuclear energy, non-destructive testing,

-i survivability, radiation effects, and radiation services. The programs range from basic-research to finished products.

Instrumentation programs cover four major areas:- (1) nuclear material measure-ment,- (2) nondestructive testing, and (3) data acquisition and analysis systems.

Instruments include fixed and portable neutron radiography systems, radiation gauges, 4

ordnance quality control systems, large-scale field experimental systems, automated j

X-ray Inspection Systems and laboratory data collection and reduction systems..

Technology development and transfer programs cover the broad areas of:

(1)-

l X-ray technology, (2) nuclear fuel cycle and alternate energy sources, (3) radiation '

processing, and (4) defense analysis. Programs involve test and evaluation, radiation and electromagnetic effects, process development, radiation sterilization, radiation -

enhancement, target camouflage, and nuclear survivability.

l 8.2 ORGANIZATIONAL STRUCTURE

)

IRT Corporation's organization chart is shown in Figure 4.

The division I

managers are responsible to the President of IRT for all matters relating to the l

[

technical excellence of work performed by their respective organizations.

They-establish business goals in their assigned technological areas and are responsible for the application of all resources and personnel necessary to accomplish those goals. The-engineering and production requirements of the company are satisfied by the Engineer-ing and Manufacturing organization. Project organizations are established for major projects cutting across disciplinary lines.

The projects draw from the technical organization for both project management and technical personnel. Projects involving O

the ese of radioactive meteri is eed/or redietion-9reeecins machimes are reviewed hv the Radiation Safety Officer and Radiation Safety Committee to assure adequate facilities, procedural requirements, and licensing authority are provided.

September 30,1988 l

Page 47

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BOARDI

' CHAIRM Ct CORPORATE COMMUNICATIONS A N O Brien PRESit OPERA 1

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AUTOMATION FINA SYSTE MS GROUP ADMih V

E Soron ycei

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General Manager (A; ting)

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FINANCE RAD f, KE ING HEALT J Dooley farFogel E Soron t

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PR

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Vee President

& Treasurer I.

1NGINEERING PRODUCT HUMAN ASSURANCE RESOURCES E Soron RI Fogel J.

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(Acting)

R Tambuffo t

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Figure 4. IRT Corporation Organization Chart September 30,1988 Page 48 e ;w

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I DIRECTORS '-

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f AND CEO:

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PNG OFFICER Battin -

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ELECTRONIC TR TI N SYSTEte$ GROUP

[7 Iet4ent & -

J W Batto O Secret sy (Actn0) l l

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' ELECTRONIC SYSTEMS

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CONTRACTS

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T u cag.n C e wm.ams

~ A Venoni r

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81 APERTURE CARD

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Aperture Card i

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o Support for the pro}ects is ' provided by - the other departments listed - on the' organizational chart. Matters pertaining to Security and Safety are directed through the Human Resources Department. Health Physics reports to the Radiation Safety Officer.

The function of the Indicated health and safety personnel and review committees have been discussed in an earlier section.- Within this structure, the responsibility for establishing and maintaining safe operations rests' directly with the

~ line management of the organization; and to amure the discharge of this responsibility,_

the President of IRT Corporation appoints review committees as appropriate. These committees are independent of management control in performing reviews and report Items requiring action to the appropriate level of management, if satisfactory action is not taken, as determined by subsequent audit, then higher levels of management are

- advised of the need for action. The final authority on the response of management to recommendations of the review committees rests with the President of IRT Corporation.

8.3 TECHNICAL PERSONNEL O.-

The technical staff members comprise approximately 101 of the 173 employees of the company. Of 1he 101 technicai staff member, and 31,e, cent hold coiiege deg,ees,.

and about 33 percent have associates degrees. The academic disciplines' represented by these degrees are predominantly physics and engineering. ' The technical staff members are grouped in organization levels as shown in the following table.

~

Organizational -

Level Title O

President, Vice President 1

Research Advisor 2

Principal Scientist Principal Engineer 3

Staff Scit.ntist Staff Engh.eer 4

Senior ScienVst Senior Enginet.e 5

Engineer Physicist Technical Specialist O

September 30, 1988 Page 49 i

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.R s c ii Personnel l'n organizational levels 1 and 2 are responsible for planning," managing- 'g research programs, managing manufacturing groups and generally have an advanced '

j degree with an ' average = experience of 15 years. Personnel in organization lev'el3

I through 5 have an average of 12 years experience. -

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' September 30,1988 Page 50 m

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I K. L. CROSBIE,~ P.E.'

i B.ChE., Chemical Engineering, Pratt institute; M.N.E., Nuclear Engineering, University of Virginia

.Mr. Crosble joined IRT in 1963. He was Radiation Safety Officer for IRT from April 1973 to May 1983 and was responsible for all aspects of the radiation safety programs, radioactive materials and special nuclear materials licensing, criticality-safety, and. special nuclear materials safeguards and accountability. In addition to these duties, Mr. Crosbie is a Principal Engineer in the Nuclear Systems Division and j

Principal Inves-tigator for programs involving the design, construction, operational testing and installa-tion of radiation gauging devices and radiation detection systems.-

Other responsi-bilities involved the design, construction, operational testing and installa-tion of Californium-252 based subcritical multiplier systems and physics and engineer-Ing investigation on programs related to in-depth heating studies in concrete using microwave and fission heat sources, nuclear instrumentation and radiation shielding.

Prior to this he was engaged in fast-neutron physics and fast-neutron detection systems employing time-of-filght techniques.

He was responsible for. the design, construction, licensing, and operation of Accelerator Pulsed Fast Assemblies (APFA-1, O-11, and III). As supervisor of these facilities, he has provided static and pulsed service irradiations for studies that ranged from effects of simulated nuclear detonations-to foil activation for fast neutron dosimetry.

Mr. Crosble attended the University of Virginia under an AEC fellowship program and conducted research and development work on a nuclear-powered plasma thermo-couple. From 1961 to 1963, he was with the Sandla Corporation as a reactor supervisor

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at the pulsed-reactor facility.' His main responsibilities included the supervision of pulsed-reactor operations, with primary concern for the safety of the reactor and personnel conducting experiments. He was also engaged in research on the penetration and activation of shielding materials by neutrons from the reactor pulse.

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PAUL R. MASCHKA Radiation Safety Officer Mr. Maschka was appointed Radiation Safety Officer for IRT Corporation in May.

1983. Prior to that date he was the Senior Health Physicist for IRT'since joining the company.in May 1973.

As Radiation Safety Officer he is responsible for licensing radioactive materials and special nuclear materials; registration of cabinet radiot;raphy systems; compilance with the various State and Federal Regulations; and all aspects of l

the radiation safety program. He has had extensive experience with X-ray equipment from the time that IRT started building X-Rays inspection devices in 1983. He assists l

in the design and shielding requirements for X-Ray rooms and X-Ray cabinets. As -

Nuclear Materials Manager, he is responsible for special nuclear materials safeguards and accountability and criticality safety. He assists in the planning for all radiation operations c,nd monitors the projects for compliance. He conducts the Radiological-t Safety Courses for IRT and customer personnel.

Prior to joining IRT Corporation, Mr. Maschka was a member of the Health Physics Department of G.A. Technologies Inc.

Since 1963 he has had extensive experience as' Health Physics Surveyor at various G.A. Facilities, including: the Hot h Cell; TRIG A R eac tor Facility; Radiation Research t aboratories, and teh Fuel Manuf acturing Facilities, in September,1970. He was made Senior Health Physicist for the Linear l

Accelerator Facility which is now owned by IRT Corp.

Mr. Maschka completed two years of higher education at Creighton University in Omaha, Nebraska. In 1955 he enlisted in the U.S. Air Force and served four years as an electronics tednician, in 1959 he was chosen to attend the U.S. Army's Nuclear Power Training Course at Ft. Belvoir, VA. He graduated from the 48 week course.

In March 1961, ~ specializing in Health Physics and Chemistry.

Mr. Maschka was a member of the Start Up Crew for the U.S. Navy's PM3A nuclear power plant in McMurdo, Antarctica.

At the PM3A he worked as Health Physicist, Reactor Opeartor, and eventually as Shift - Supervisor.

He received training in nuclear materials management and NMMSS reporting at a seminar conducted by the DOE in August 1980 and a workshop conducted for the NRC by Martin-Marietta Energy

' Systems in July 1985.

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T3ACK C. YOUNG, P.E.

B.A., Physics and Mathematics, North Texas State University M.A., Physics, North Texas State University SinceL joining IRT in 1958, Mr. Young has been engaged in many low-energy _

neutron physics problems, including work in studies of garnma-ray ' emission af ter uranium photofission, the measurement of the Fermi age to indium resonance in Beo, as r

well as numerous experiments in integral neutron thermalization. He was Physicist-in-Charge of the Critical Assembly which was used to investigate neutron spectra in various nonmultiplying and subcritical assembles in 1967, he worked on the design and construction of a thermionic critical facility. In 1%8, he was involved in making -

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spectrum measurements in fast subcritical assemb!!es, with relatively long dicaway times, to develop experimental and analytical techniques for time-of-flight measure-ments of fast neutron spectra. He was Program Manager and Principal Investigator on this program from 1969 to 1972.

Since 1973, Mr. Young has been involved in the management'of several integral.

measurements to test neutron scattering cross sections and gamma-ray production in.

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various shielding materials.

Mr. Young was prompted to Manager of the-linear acceimat-faciiity in 1986. In 181s capaciix he is resgoesisie for the operatioe, l

O-lz maintenance and modification to the accelerator.

Mr. Young has served as Program Manager and Principal Investigator on several DoD programs, meluding the development of a fully automated ordnance inspection system for the demilitarization of practice bombs via dual' Compton-scattering-methods, the fully automated precision measurement of components for SSPO via the Radiation Photometry Gauge (RPG-100), of which two systems were delivered, and several commercial systems, including the Active Fuel Rod Scanner (AFRS-Il0) which automatically measures the enrichment uniformity, total fissile content, rod and plenum length, fuel stack length, and other important parameters. Delayed gamma.

sensing of fissions caused by low-level neutron irradiation was utilized in this system.

In all of these systems Mr. Young was responsible for the overall system performance, cost and schedule, as well as system integration and day-to-day project management.

He has been very successful at taking R&D or conceptual designs to full-throughput, i

production-line inspection machines.

O September 30,1988 Page 53 1

JOSEPH D. GEHRINGER -

Assembly Stpervisor Mr. Gehringer joined IRT in 1982 as an assembly and testing technician for the Nuclear Systems Division. He assisted in the assembly.and testing of Portal Radiation Monitors (PRMs) and other IRT products.

He. was made' a Fleid Serviceman - and.

Representative in 1984 where he was responsible for the in'stallation and maintenance of IRT's gauges and radiation monitors.

Some of, the ' equipment he installed and -

repaired was. Portal Radiation. Monitors, Decontaminated Laundry Monitors, Letter Bomb isetectors, and Explosive Flash Tube Inspection Gauges.' In 1986 Mr. Gehringer.

was made Assembly Supervisor for IRT's X-Ray Cabinet Inspection devices. He assists in designing the systems, but his main responsibilities are assembly of the X-Ray cabinet and the X-Ray and imaging systems.

He is responsible for testing the equipment for proper operation and testing the cabinets for comp!!ance with the FDA regulations in accordance with 21 CFR 1020.40.

Prior to joining IRT, Mr. Gehringer spent six years (1973 to 1979)in the U.S. Navy as an Aviation Electronics Technician, where he maintained radar, sonar, navigation, and doppler systems on helicopters. Af ter leaving the Navy he worked for three years for Boatronics, Inc. as an electronics technician and lead installer. He installed and repaired radars, sonars, depth finders, auto pilots, and radios for both pleasure craft and the commercial shippnig industry.

He received his electronics training from Military Electronics School and his radiation training from IRT's Radiation Safety courses.

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O September 30,1988 Page 54

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' GEORGE 3. GOSS Manager, Applicatlans Development Laboratory '

George Goss has been working at IRT since January,1985. Since that time he has been ~1nvolved in research, development, and design of radioscopic. inspection systems;

- utilizing variable types of penetrating radiation. In addition, Mr. Goss has participated in studies for the determination of lonizing radiation effects on electronic related components 'and composite materials. This work involved radiation gauging and analysis-of the output characteristics of electronic x-ray sources. This in turn has led to the implementation of x-ray spectral modifications using elemental filter materials.

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-In Mr. Goss' current capacity, he performs investigations into the feasibility of

- applying x-ray and neutron imaging technology for the analysis of specific components.

i This Involves electronic x-ray sources, radio-isotopes, and nuclear reactors, in addition, he provides engineering and testing support for the development of advanced electronic x-ray sources for use in industrial radioscopy.

Augmenting this experience, Mr. Goss has studied the subnuclear aspects 'of physics at the University of California, San Diego.

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September 30,1988 Page 55 at m

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8A FACDJTIt!S L

At the present time IRT Corporation has two facilities for storage of special.

' nuclear materials, one located at 3030 Callan Road and the second located at-8221 l

ArJons Road. These facilities are described below.

L NOTE: As soon as this license is approved, all remaining special nuclear material presently stored at Callan Road will be moved to the new vault type room being built at the Arjans Facility.

At this time, September, _!988, IRT Corporation is in the process of selling its Electronics System Group to another company. Once the sale has been completed, we will vacate the Callan Road Facility and probably move to the Arjons Facility or to

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some building near the-Arjons Facility. The move will take place in the first half of 1989. As soon as this license is approved and all of the remaining SNM has been moved to the ArJons Storage Vault, we will request that the Callan Road Facility be inspected

. l and removed from the license as a place of use.

SA.1 3030 Callan Road

'The headquarters and main engineering and scientific building is located at 3030 Callan' Road in~ the Torrey Pines Science-Park. The building is a three-story, 86,500 square foot building with the main entrance on the second floor and truck access / loading on the first floor. The laboratories and shops are located on the first floor. No radioactive materials othei than small check sources used for instructional purposes shall be allowed on the upper floors.

Radioactive materials may be used throughout the entire - First Floor (see j

Figure 5). SNM will be used in Rooms 101,107,111,113,114,155, and 117. SNM will-be stored in the Vault Room 110, and byproduct material will be stored and used in Room 111. All use of radioacive material and SNM will be conducted in such a way that '

the second f.loor shall remain an unrestricted area with personnel exposures limited to the levels specified in 10 CFR 10.105. The floors, other than the support structure, are -

made of 3/4-inch plywood with an overlay of 1-1/2 inches of normal concrete. Since this thickness of wood and concrete offers very little in the way of shielding, all experiments and equipment will be designed in such a way that there will be a maximum amount of shielding on the top in order to keep second floor personnel exposures within the limits of 10 CFR 20.105 and ALARA.

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sunk'into the floor. This will be a storage well for highly radioactive sources. The "gl The byproduct material storage room has a 10 inch diameter by 10 foot deep pipe

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sources will be stored in Individual pipes that are fastened to a plate on top of the well. -

A movable shield cap of concrete 'and lead will be positioned over the well. Other

- sources will be stored in shipping / storage casks and a lead cave of adequate shielding to protect personnel on the second floor.

Storage of SNM will be as described previously in Section 6.8.

In order to. prevent exposure to the office. personnel on the upper floors, all movements and use of radioactive materials will be done in compliance with' 10 CFR 20.105. If it is calculated that a certain operation could result in an Individual-on an upper floor receiving a total dose of 2 millirems in any one hour, the following.

procedure will be followed.

It will be determined if the area on the second floor above the radiation work area can be clered of personnel during normal working hours; if not, the work will be done after normal working hours when fewer people are present. In either case, during or -

f af ter working hours, the procedure will be as follows.

1.

Clear the area of personnel.

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Warn the personnel in the adjacent areas, or at night, warn the meintenance

. personnel.

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Put up temporary barriers and warning signs around the area on the upper floor.

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Post an observer, if necessary, to warn people to stay out of the area. '

i 5.

At the end of the operation, remove the ropes and the signs and notify I

personnel that it is safe to return, if the source that has been installed in a device or if a radiation-producing machine ls to be operated, the area on the upper floor will be surveyed with the i

appropriate portable radiation survey meters in order to determine the dose rates in that area. If the survey indicates that the limits imposed by 10 CFR 20.105,might be j

exceeded, additional shielding material will be added to the device or machine to reduce the dose rates to acceptable levels. The radiation dose rates will be verified by additional surveys. Only then will step 5 above be taken.

Environmental and location badges shall be placed in normally occupied areas on the Second Floor above those areas where radioactive materials are used or stored on g the First Floor. The badges are placed in the following areas (refer to Figures 6 through 8h September 30,1988 Page 58

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i Room 200iAccounting Room 221 - Lobby

.i Room 234 - Pub!! cations and other areas as needed.

1 We have had three years of experience and film badge data. -The highest yearly exposure at any' one-location was 140 mrem.. Since personnel only. work about 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> a year (about one-fourth of the year), the maximum calculated personnel l

exposure is 35 mrem for the year.

8.4.2 8221 Arjans Road This facility is presently IRT's manufacturing facility, but in 1989 it may also be our main headquarters facility. The facility is located in an industrial area North of the Miramar Naval Air station at the north end of a long warehouse complex. Other companies occupy the rest of the building to the south of this facility. - The Building is made of tilt-up concrete sle'as 20 feet high. In part of the facility there is a drop _

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ceiling eight feet high, but in the rest of the building the ceiling is the full 20 feet high.

The facility measures 180 feet by 160 feet (see Figure 2).

At the ' present time the facility is used by the electronic assembly and engineering groups and used to manufacture X-Ray equipment and X-Ray inspection cabinets.

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The SNM will be stored in the Vault room as described previously in section 5.8.3.

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8.5 INSTRUMENTATION The. Radiation Safety Office has instrumentation 'availa'.!e to perform the

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' following functions in the detection and measurement of radiation.-

8.5.1 Personnel Monitoring Devices IRT uses photographic dosimetry for x-ray and gamma radiation in the. range

- 5 kev to 100 MeV covering dosages from 20 mrem to 500 rem for high energies, and dosages from 10 mrem to 60 rem for low energies; photographic dosimetry of beta radiation from 400 kev to 50 MeV covering dosages from 40 mrem to 1000 remi thermal j

and fast neutron photographic dosimetry in the ranges 0 to 3.5 eV covering dosages from 10 mrem to 300 rem, and 500 kev to over 100 MeV covering dosages from

f 15 mrem to 10 rem. Pocket lonization-chamber dosimeters which are the self-reading type that detect x-ray and gamma radiation from a dose of I mrem to 500 rem, and hf

' September 30,1988 Page 62 i

e self-reading fast neutron and thermal neutron dosimeters that measure dosages from l' mrem to 200 mrem are also used. Dosimeters are callbrated yearly. : LIF and CaF' TLD's are available to the Radiation Safety Office on loan from other IRT operating departments.

.i 8.5.2 Radiation Monitoring and Survey Instruments j

A list of -Instrumentation, detection limits, and frequency of calibration is provided below.

Minimum Detection Detection Calibration Type Limits Limits Frequency G.M. Survey Meter

.i Ludlum 14 A (3) 0-50,000 cpm 100 cpm Semlannually Ludlum 12 (1) 0-500,000 cpm or 2 x B.G.

Technical Associates (TBM-3) 0-50,000 cpm Alpha Survey Meter Eberline PAC-ISA (1) 0-2,000,000 cpm 100 cpm

. Quarterly.

Ludlum Model 12 (1) 0-500,000 cpm 150 cpm or 2 x B.G.

Neutron Survey Meter Snoopy, NP-1 and 0-2,000 mrem /hr 0.2 mrem /hr Quarterly NP-2 (3)-

Ionization Type Survey Meter Eberline' RO-2 (2) 0-5,000 mr/hr' 0.1 mr/hr Quarterly Victoreen 440 RF/C (1) 0-100 mr/hr -

' O.1 mr/hr Quarterly 3

- Eberline RC-2A 0-50,000 mr/hr 0.2 mr/hr

- Quarterly

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Victoreen 69:2 (1) 0-1,000 mr/hr 0.2 mr/hr Quarterly Victoreen 471 RF (1) 0-300 R/hr 0.02 mr/hr Quarterly Technical Associates CP6M (1) 0-1000 R/hr 0.1 mr/hr Quarterly i

Criticality Monitor GM Detectors 0-20 mr/hr 2 mr/hr Quarterly Eberline RM-12A (3)

O September 30,1988 Page 63

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8J.3 Radioactive Ma'terial Assay e!

The Instruments - and procedures described ' below are presently being _ used; however, if these instruments should stop operating due to 'old age, mechanical failure

.or e ec r ct i al failure, other instruments that have similar background counting rates and l

efficiencies will be substituted. - Instruments that might be: substituted could be Pancake G.M. counters, proportional counters or scintillation detectors, along with the appropriate scaler and power supply.

Any substitute would-be carefully tested for proper background and efficiency.

Assay equipment is calibrated at least weekly.

)

1.

An Eberline Model BC-4 Counter. This instrument is a complete system'-

consisting of a two-inch detector, high-voltage power supply, pulse amplifier, timer, and six-decade scaler. All circuits are solid state with extensive use I

of integrated circuits to enhance reliability. The detector is a pancake-type Geiger tube with a 1.75-inch diameter window which is 1.4 to 2.0 mg/cm

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2 thick. With the addition of a 0.002-inch mylar window the total' window 2

density is approximately 7 mg/cm. This mylar window is removable for IN decontamination or for counting low energy beta emitters such as C.

the detector is shielded on the top and side with 7/8 inch of lead. The detector background is generally 30 to 33 cpm. The efficiency for two pl geometry is generally 70 percent and for four pl the efficiency 'is 35 percent for 90Sr 90y, l

2.

An Eberline Model SAC-4 Scintillation Alpha Counter. This insuument is a complete system consisting of a. two-inch ' detector, high-voltage power.

supply, charge-sensitive input amplifier, timer, and six-decade readout. All circuits are solid state, except the detector, with extensive use of integrated circuits to enhance reliability. The detector is scintillation phosphor made of ZnS(Ag) powder plated on a plastic light pipe. The photomultiplier tube is a ten-stage, Sil-response, end window tube,. two inches in diameter.

The background is generally 0.6 to 0.9 cpm. The efficiency for two pl geometry is 239 generally 80 percent for a one-inch diameter Pu source, and for four pl-geometry the efficiency is 40 percent for the above source.

3.

A Technical Associates windowless gas flow proportional counter for assaying fritium (3 ), Alpha, and Beta radiations. The system consists of a power H

supply, an automatic scaler, a timer, a scanning single-channel analyzer, and hI the windowless gas flow counter.

The detector is a two-inch diameter, September 30,1988 Page 64

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.two-pl.henilsphere with a precision collector. wire. The two-pi efficiency is normally 51 percent for alphas and 60 to 70 percent for betas.

The Radiation Safety ' Office - also. has free access - to the following!

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- equipment 'used by other groups at IRT.

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For sainple counting a Tennelec LB1000 Low Beta counter and.an:-

ORTEC 576 Alpha Spectrometer.

b.'

For sample assay and isotope Identification:

there are available a j

l number of Nal detectors and Ge(L1) detectors used with TMC or Nuclear Data 660 multichannel analyzers.

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Limits of Detection' g

a.

BC-4 Beta Counter. The average 95 percent confidence level for wipe.

.i samples with beta particle energies up to 0.546 MeV (90Sr, 30 ) g,

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y 10.7 cpm above background.

This is equivalent to 30 dpm or 14 pCl-(0.000014 microcuries) of activity.

The average 95 percent confidence level for wipe samples with. beta--

l particle' energies up to 0.292 MeV (DTc) 'is 10.7 cpm above background.

l' This is equivalent to 42.8 dpm or 19.3 pCl of activity. -

o b.

5AC-4 Alpha Counter. The average 95 percent confidence level for.

wipe samples with alpha particle energies up ts 5.16 MeV (239Pu) is 1.75 cpm - above background.

This is equivalent e 5 dpm ~or - 2 pCl

.(0.000002 microcuries) of activity.

The average 95 percent confidence level'for wipe samples.w'ith' alph particle energies up to 4.68 MeV (230Th) is 1.75 cpm above background. This is equivalent to 5 dpm or 2 pCl of activity.

8.5.4 Air Samples

- The Radiation Safety Office has portable particulate air samplers that can use various types of filter papers. Each of the air sarnplers includes a gas flow meter for the determination of the amount of air that flows through the filter. The filter papers are analyzed for alpha, beta, and gamma radiation. The gas flow meters are calibrated yearly.

O September 30,1988 Page 65

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8.5.5 Source Leak Checking -

Sealed source shall be_ tested at six-month intervals. = Unsealed plutonium or-uranium sources and sources covered with thin layers of material-shall be tested at three-month Intervals.

Two methods of testing sealed sources for leakage are used by the IRT Health

' Physics Group: wipe testing and immersion testing.

1.

Wipe Testing Whatman 41 filter papers,4.7 cm diameter, are used for the wipe test.

2.

Testing Radioactive Source Less than 500 4Cl Wer. ring ~ gloves, rub as much of the source area as possible with the filter paper. Use sufficient pressure to pick up any radioactive particles that may be present.

Count the wipe paper for alpha and beta / gamma-radiation.

3.

Testing Radicacho Source Greater than 500 gCl a.

Method 1.

Use' tongs to hold the wiper paper or tape the wipe paper to a rod. If possible, wipe the source in its container. -if the source must be-.g removed, place it in a metal or plastic container to prevent :ltL from getting lost.. Use an intervening shield if necessary to reduce personnel exposure. Rub as much of the source as possible with the wipe paper.

Return the source to its shield, b.

Method 2.

Tape the wipe paper to the bottom of an appropriate container. - Using tongs or some other hanF.ing device, remove the source from its shield. Again, using intervening shielding if riecessary, rub the -

source over the wipe paper. Return the source to its shield.

4.

Testing Sources Mounted in Equipment Sources that are integral parts of a device, and that are difficult or impossible to remove, are tested in the following manner.

Tape a wipe paper to a rod or using a cotton swab, wipe as much of the source as possible, if the source cannot be reached, wipe the area nearest -

the source.

Count the wipe paper for alpha and/or beta /gamnia radiation. To count the cotton swab, cut the cotton off the stick, spread it out and glue it onto a g

. September 30,1988 Page 66 x_-_--__--_______-

i piece of stiff ; cardboard.

Af ter the. glue dries, count - for alpha and l bett/ gamma radiation.

= 5.

Immersion Leak Testing in this method of leak testing,.the source is placed in a vial of alcohol that is__

inside an ultrasonic bath. ' Af ter the source:Is in the vial, the ultrasonic -

cleaner is tumed on for a few minutes. The source is then removed and the alcohol is poured into a planchette and slowly evaporated on a warm hot plate :

In a filtered hood. The residue in the planchette is then counted for, alpha:

- and/or beta / gamma radiation.

This. method is particularly useful for intense sources which can be

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remotely positioned, since the ultrasonic bath' can also be remotely cperated.

j This eliminates the need to be in close proximity.to the source to make the-1 I

test and minimize personnel exposure.

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9. WASTE DISPOSAL -

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t aste disposal service is on an as-needed basis with Thom-* Gray and Associates-l w

of Orange, California. Waste processing is not done by IRT Corporation; accumulated

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wastes, liquid and solid, are packaged and labeled in accordance with app!! cable DOT-'

y regulations and transferred to the Broker for ultimate processing and disposal.

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'(d 9.1 SOLID WASTE DISPOSAL' Very.little waste-1s: generated by the operations in which IRT Corporation is' presently _ involved.

However, all of-th'e material authorized by this license will:

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eventually be disposed of as waste.

9.1.1 Work Area Waste Receptacles j

Approved waste receptacles are metal trash cans equipped with a self-closing !!d-i

. or a metal drum with a full metal cover. A plastic bag s p aced inside each receptacle i

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't with the open end of the bag pulled down the outside of the can leaving the bottom of t

the bag sitting on the 'ottom of the receptacle. (This helps prevent contamination of the outside of the can.,

J., inventory sheet is attached to the can. When radioactive j

l waste is placed in the receptacle, the isotope and am'ount (lf.known) are noted on the inventory sheet. SNM-waste is segregated from byproduct material waste and collected in a separate receptacle.. If a number of different isotopes are used in the area, two

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waste receptacles are used, one for radioactive isotopes with half-fives less-than 30 days, and another for Isotopes with half-lives greater than 30 days.

9.1.2 Collection of Waste t

o The Waste Disposal Personnel are notifled when a waste receptacle is full or nearly full. The waste disposal personnel remove the bag by gathering up the open end of the bag and twisting it closed just above the mass of waste; the bag is taped shut, j

and then pulled out of the receptacle.

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9.1J Manitoring The bag is monitored with the appropriate radiation survey meter. Radiation I

readings are taken at the surface of the bag, at one foot, and at one meter from the bag, with the readings being noted on the inventory sheet. The radiation readings are used to calculate the amount of radioactive material in the bag in case the inventory sheet has not been properly updated. The bag is marked with radiation warning labels and is taken to the waste collection area.

9.1.4 Waste Conection and 5torage Area l

The normal waste collection and storage area will be Radioactive Material Storage Room at the Arjons Road facility. Only DOT 17E/17H drums are authorized fer shipment of Radioactive Waste. Both empty and filled drums are kept under some protective cover to prevent deterioraf on. Waste containing short-lived isotopes are stored until the radioactive isotopes have decayed to background levels as measured on a pancake G.M. detector, and then the waste is disposed of in the ordinary trash.

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9.1.5 Packaging of Shipping Drums g1 A plastic 55-gallon drum liner, at least four mil thick, is placed in the waste drum. The individual bags of waste are put into the drum and packed down loosely-taking care not to punctuu um"vidual bags or pack so tightly that entrapped air is i

forced out of the bags A note is made on the inventory sheet indicating the amount and identity of radioactive materials placed in each drum. The appropriate radioactive warning labels are app!!ed to each drum, i

9.1.6 Monitoring Shipping Drums When a drum is filled, the open end of the plastic bag is drawn up and twisted shut i

l just above the mass of waste and secured with a twist tie or tape. The lid is placed on the drum and secured by bolting the locking ring tightly in place. A portable radiation i

survey meter is used to scan completely a*ound the sides of each drum from top to bottom, and, the top and bottom.

The highest radiation readings at surface, at one foot, and at one meter are noted on the inventory sheet. At least two wipes are taken on each drum and counted according to standard wipe counting procedures. If a drum is contaminated on the outside it is immediately decontaminated to acceptable G' September 30,1988 Page 70

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i levels. The drum is leak checked by laying It on its side for 20 minutes and noting if

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liquid comes out around the locking ring. All leaking drums are opened and repackaged.

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The proper radiation warning labels are placed on the drum and the inventory sheet is j

taped to the top of the drum.

9.1.7 Disposal of SoBd Waste When six drums of waste have accumulated, the commercial hauler is contacted and arrangements are made for removal of the waste.

Each drum is classified in accordance with 10 CFR 61.55 and labeled with the appropriate DOT shipping labels. A

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Radioactive Materials Shipping Record is made out, along with any special papers the 2

hauler may require. A record of all radioactive materials shipped and copies of all papers are stored in the Radioactive Waste Disposal file in accordance with 10 CFR 20.

l 9.2 LIQUE WA5TE DISPOSAL Most !! quid wastes have been generated by decontamination and cleanup of 1

equipment and the accelerator facility. Some low-level concentrations of liquid waste has been generated by radiochemical operations, and in almost all cases this liquid met the requirements of 10 CFR 20.303 for disposalinto the sanitary sewer system.

j 9.2.1 Work A:ea Liquid Waste Receptacles Storage containers for collecting liquid waste are leak-proof, corrosion-resistant plastic bottles with screw caps ranging from one to five gallons in capacity.

An inventory sheet is maintained for each bottle. SNM, byproduct material, short half-!!!e and long half-life materials are collected in separate bottles.

9.2.2 Manitorire and Couectlan of Liquid Waste The waste disposal personnel are notified when a bottle is full. They cap the I

bottle tightly, agitate it vigorously, and extract a. one-liter sample. The water sample is assayed by the Health Physics Department using standard laboratory procedures; 1.e., the water sample is evaporated to dryness and the residue is counted for radioactivity, if it is determined that the liquid meets the requirements of 10 CFR 20.303, it is disposed of by release into the sanitary sewer system. If the hquid does not meet the requirements of 10 CFR 20.303, it is stored and disposed of by the current U.S. DOT and NRC regulations.

September 30,1988 Page 71

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10. EMERGENCY PROCEDURE 5 10.1 FIRE Fire is no real danger to the $NM because the vault is made of concrete and there

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are no combustible materials inside the room and all materials are stored in metal containers.

10.2 RELEAh6 OF LOSS OF MATERIAL There is very little possibility or release of loss of material becuase all we possess are sealed or solid materials, so none of it can evaporate or be poured down the draln.

At this time and on into the forseeable future only two people will be authorized access to the vault room, the R50 and the Alternate RSO. Material could only be lost in case l

l - O oftheit. The aiarmed vaeit room wiii tend to deter anx bet the most dedicated thief, and the alarm system should bring response forces before the thief could gain entry to the room and remove the material.

10.3 CONTAMINATION OF PERSONNEL Contamination of personnel will be prevented by proper training of personnel and by the fact that all of our material is in the form of sealed sources and non-dispersible solids.

10.4 OTHER HAZARDOUS MATERIALS The only hazardous materials used at the Arjons Facility is some small containers (one quart of less) of solvents used to clean metals in the machine shop. These will pose l-no hazard to the material stored inside metal containers in the concrete vault room, o

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September 30,1988 Page 74

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11. CERTFICATE The applicant and any official executing this certificate on behalf of the app!! cant i

named in item 1, certify that all information contained herein, including any supple-ments attached hereto, is true and correct.

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IRT Corporation Applicant Name in item 1 Date:

17 October 1988 By M[

b Vice President Title of Certifying Official l

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APPENDIX I l

RADIATION WORK AUTHORIZATION PORM O

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P September 30,1988 Page 78 t

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I RT Corporation RADLATlON WORK AUTHORIZATlON No..

1.

( ) New Request Date Submitted

( ) Renewal of RWA No.

Date Required 2.

Principal Investigator Material Custodian Alternate 3.

Work location 4.

Description of program (include methods, sketch of the apparatus and setup showing the shielding provided). Attach supplements referenced to this request,if necessary.

O 5.

QuantL.es of Radioactive Material involved in this operation:

Isotope Amount Material Description (Physical Form) 6.

If Airborne Radioactivity is created indicate major Isotopes, quantity and physical form.

Isotope Amount Gaseous or Particulate O

NONE 7.

Will a contamination control coundary be needed:

( ) Yes

( ) No

!! yes, describe. Attach supplements ref erenced to this request, if necessary.

N" 4

September 30,1988 g

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APPENDIX D OUTLINE--RT RADDLOGICAL SAFETY COURSE RT RADDLOGICAL MANUAL RT 4171409 O1 1

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