ML20125D937
| ML20125D937 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 05/16/1985 |
| From: | Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25264, NUDOCS 8506120523 | |
| Download: ML20125D937 (3) | |
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e UNITETTATED DEPARTMENT OF COMME ACE National Bureau of Standards
- p Gathornburg M 099
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)k May 16, 1985 7
LECEP!ED k U. S. Nuclear Regulatory Commission Attn:
W. T. Crow, Acting Chier ' I
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3 13 > d J%35 Uranium Fuel Lice.nsing Branch.u m r ap t )J Division of Fuel Cycle andt \\s n-ci Docugr/
h ent 70-398 Ay [Tyq{j.V Material Safety, NHSS wi Washington, DC 20555 u ' C' Libonse SNH-362
,7 Gentlemen:
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Annex A to our Materials License No. SNH-362, issued May 2, 1985, requires leak testing for sealed sources with certain specific exceptions.
We request an amendment to the license to exempt certain other sources from leak test requirements.
NDS possesses and uses numerous transuranic radionuclide sources in physical forms that could be considered sealed sources, and with relatively small activities, i.e.,
below ten (10) microcuries.
For example, Radioactivity Standard Reference Haterial (SRH) Number 421 ip an americium-241 source with a nominal activity of 3 x 10 g -' (about ten microcuries).
s Each of these SRH's is Am-241 electroplated onto a 0.010-cm thick platinum foil which is covered with 0.005-cm thick aluminum foil; this assembly is sealed between two layers of 0.036-cm thick polyurethane-film tape and mounted on an aluminum annulus.
These SRH's are distributed to customers and are also used in NBS work as point gamma ray standards.
Others include commercially avail-able sources of transuranic materials contained in a variety of containments to be used as check sources, as spectroscopy standards, in product evaluation tests, and the like.
We estimate that perhaps one hundred such sources are currently in use.
Each of the sources in question is tested for activity containment integrity on receipt at NDS or at production time for NBS-constructed sources.
The extremely rigorous requ' ements on NBS operations to produce results and products with the best precision and accuracy possitle dictate that the user of such sources ensure that three containment integrity conditions are met:
(1) No loss of source activity to cause data to devinte from the calibrated value.
P) No transfer of a source's activity to cause deviation of Q,A(M,/j '
o transfer from another source's activity to cause another source's data from its calibrated value.
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/f/ gyma viation of the activity of a source in use from its ma a ibrated value.
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2 These conditions force source users to maintain conditions of cleanliness that preclude technical contamination, much less conditions of cleanliness that are cited as of radiation safety intarest, as in the license's Annex A action levels.
Therefore, we request an amendment to SNM-362 that will exempt sealed sources of transuranic radionuclides with activities less than ten (10) microcuries from leak testing.
Health Physics laboratory surveys, including contamination measurements, radiation level determinations, or air sampling tests, as appropriate, will provide adequate assurance that laboratory cleanliness and source containment are maintained.
l Thank you for your attention to this request.
If you have questions about this, please contact T. Hobbs or L. Slaback at 921-2247.
Sincerely, W
L. E. Pevey(
Chier, Occupational llealth and Safety Division Materials License Manager i
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