ML20127E277
| ML20127E277 | |
| Person / Time | |
|---|---|
| Site: | 07002872 |
| Issue date: | 12/21/1984 |
| From: | Palko G REUTER-STOKES, INC. |
| To: | Holt B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20127E198 | List: |
| References | |
| 23365, NUDOCS 8505200019 | |
| Download: ML20127E277 (11) | |
Text
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reuter @ stokes 18530 South Miles Parkway, Claveland, Ohio 44128 U.S.A.
- Telephone (216) 581-9400, Telex 98-5253 December 21, 1984 USNRC Region III Materials Licensing Branch 799 Roosevelt Road Glen'Ellyn, Illinois 60137 Attention:
B. J. Holt
Reference:
Control Number 23365 Reuter-Stokes Special Nuclear Material License SNM-1826 Reuter-Stokes Renewal Application Dated May 30, 1983 Gentlemen:
As requested in your letter of October 26, 1984, we are submitting the following information:
1.
Materials A.
Manufacturer, model number and plutonium quantity of PuBe sources:
- 1) Monsanto MRC-N-SS-W-PUBE-43 80 grams
- 2) Monsanto MRC-PU8BE-323 0.013 grams
- 3) Monsanto MRC-PU8BE-373 0.048 grams
- 4) NUMEC 320B-14 32 grams B.
The 300 micrograms of plutonium would potentially be used as several alpha standards.
C.
The 250 micrograms of uranium-233 would have been used for research and development projects that have now become obsolete.
There is no intent to use uranium-233 in the near future.
We request that you delete uranium-233 from our license renewal application.
2.
Users John Zilka will shortly be reassigned to duties that will not require that he be listed as a supervisor in the use of special nuclear materi al.
When using PuBe sealed sources, he will under the direct supervision of one of the other supervisors listed tion 4 of our renewal application.
O[
gIVE 3.
Operations - Precautions Q
A.
Receipt of radioactive material, including spe c
material and the applicable precautions are described i chment 6 of our renewal application which is titled, RS-SOP-88
, RECEIVING RADI0 ACTIVE MATERIALS.
Special nuclear material is received in 50 or 100 grams lots in granular form, (U 0, or U0 ).
2 8505200019 850501 REG 3 LIC70 SNM-1826 PDR
3 i
reuter ' stokes i
18530 South Mdes Parkway g
Cteveland, Ohio 44128
.ii USNRC Region III December 21, 1984
=
Attention:
B. J. Holt Page 2 B.
After the special nuclear material package has been checked accord-ing to the procedure, it is transferred to the responsibility of the Chemist / Supervisor, who stores the material, still in its original container, in a security container, (Mosler safe), which is located in a controlled access area until such time as it is processed further.
This controlled access area is described in
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Figure 1 of our renewal application.
Material already processed into a liquid form is often stored in the some security container.
3 Additional information and descriptions are g'ven in Attachment 10 of our renewal application which is titled, REUTER-ST0KES, INC.
RS-SOP-880.0, PHYSICAL SECURITY PLAN AND PROCEDURE FOR THE PROTEC-TION OF SPECIAL NUCLEAR MATERIAL OF LOW STRATEGIC SIGNIFICANCE.
7 C.
Transfer of material in the granular form is performed in the
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radioisotope fume hood described in Figure 3 of our renewal application.
Smaller quantities, nominally 20 grams, are weighed i
in an enclosed microbalance.
During any transfer of material in
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the granular form, the person handling the material is monitored with a portable lapel air sampler, (MSA Model S), for the entire
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period.
A typical respirator mask, 3M Model 8710 for dusts, is optional.
Appropriate protective clothing such as gloves is also used.
D.
The material in granular form is dissolved in an acid solution, i
and mixed with the appropriate vehicles to make a liquid solution suitable for electroplating.
This work is done under a radio-5 isotope fume hood, shown in Figure 3 of our renewal application.
The person doing this work is also monitored with the portable air sampler, and appropriate clothing is also used.
The liquid solution in stored in non-glass, non-breakable containers.
j E.
The electroplating of electrodes for our products is accomplished with fixtures placed into the plating solution. All electroplating is done under a fume hood.
The electroplating process chemically bonds the uranium oxide to the metal electrodes forming an adherent
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coating.
Electrodes with non-adherent coatings are rejected.
Uranium coating thickness varies with the specific product, ranging from micrograms per square centimeter to two milligrams per square centimeter.
Coated area ranges from a fraction of a square centimeter to several thousand square centimeters per electrode.
Total uranium by weight likewise varies with the specific product.
ranging from a few micrograms to five grams per assembly.
- Thus, total weight is directly dependent upon the thickness of the coating and the plated area of the electrodes. Plating procedures such as RS-50P-630.1, URANIUM PLATING, include the appropriate precuations to be taken when working with uranium.
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reuter $ stokes j
18530 South Miles Parkway Cleveland. Ohio 44128 USNRC Region III December 21, 1984 5
Attention: B. J. Holt Page 3 Z
F.
The inventory of uranium plated electrodes is under the control of
)
the Chemist / Supervisor, and is kept in the controlled access area.
Small plated electrodes may also be kept in the security container 2
described above.
At no time are plated electrodes stored with the a
coating exposed.
Each is stored in its own sealed container, or wrapped in an appropriate cover to prevent any inadvertent handling of exposed uranium.
G.
The assembly of uranium coated electrodes into the final product 3
is done in the controlled access area.
This assembly is limited to only those technicians who have been trained in the handling of uranium plated parts.
Gloves and other protective clothing are used during assembly.
Air samples are taken and evaluated during peak assembly periods.
Coated electrodes for our products are always assembled into sealed outer containers.
These containers, i
usually the outer body of the fission counter or chamber, are hermetically sealed by welding or brazing.
The final assembly is then checked on a mass spectrometer helium leak detector to make sure we have a gas tight envelope.
Before leaving the controlled acc.ess area for further processing, all assemblies are checked for surface contamination.
If any removable contamination above back-ground is found, it is cleaned before being released for further processing.
After assembly into the outer envelope, the coated electrodes pose no hazard since the material is physically con-tained and the thickness of the metal outer envelope is more than sufficient to contain any ionizing radiation.
Each assembly is labeled as containing special nuclear material, the amount, and the date.
No more than 15 grams of special nuclear material in assemblies are outside a controlled access area at any one time.
H.
The finished products are tested in a controlled access area using a moderated PuBe neutron source.
Operating characteristics are established and from the neutron sensitivity of the finished unit the total amount of uranium is verified.
I.
Wastes generated as a result of the plating process are reduced to a solid form and stored in a 35/55 gallon drum until such time as arrangements are made for disposal as low level waste. Solidifica-tion of the residual scrap plating solution is effected by evapora-tion, distillation, precipitation, or simply mixing with cement.
5 Nominally no more than 15 grams of uranium is disposed of in any one drum.
Solidification of the waste, filling of the drums, and preparation for disposal are all done under the supervision of the Chemist / Supervisor in the controlled access area.
The drums are 1
S
reuter@ stokes 18530 South Mdes Parkway Cleveland. Ohio 44128 USNRC Region III December 21, 1984 Attention:
B. J. Holt Page 4 checked for external contamination prior to release to a common carrier.
All shipments and packaging are prepared according to the applicable sections of 10CFR71 PACKAGING AND TRANSPORTATION OF RADI0 ACTIVE MATERIAL.
Sections of 49CFR TRANSPORTATION, such as, but not limited to 49CFR172.310, marking, 49CFR172.403, labeling, and 49CFR172.203, shipping documents, are also used in shipment preparation.
J.
As in the case of waste materials shipments explained above,
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products containing special nuclear material are packaged, labeled, i
and shipped according to the applicable section of 10CFR71 and 49CFR - TRANSPORTATION.
Products are packaged in strong outside containers and are shipped via common carrier.
To the best of our knowledge, there has been no problem in the shipment of our products that contain special nuclear material in the 28 year history of our company.
4.
Monitoring Procedure A.
Air sampling of vents is performed on a quarterly basis in conjunc-tion with other surveys listed in section 13 of our renewal i
application.
Air sampling in the plating laboratory is done on a
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weekly basis if there is plating activity during that week. Air samples are also taken as described in section 3 above.
Our air monitors are run for a specific period of time, generally 15 to 30 minutes.
For the purposes of a sample calculation we will use 15 minutes.
The total quantity of air through the filter can be calculated from the specifications of the air monitor.
In the case of the portable MSA unit, the total quantity of air is 2,000 ml per minute times 15 minutes equals 30,000 ml.
The filter is then counted in the flow counter described in section 6.3.2 of our renewal application.
In this syste_m,1 cpm is equal to 2 dpm or 1 picocurie of alpha activity, (10 *pc).
Dividing the total alpha activity by the total air flow yields the uranium concentra-tion in air. Thus:
cpm x U Concentration =
p)g pa e
To detect the action level set forth in section 4. C, the calcula-tion would be:
cm 4(6 x 10 " pc/ml) g,g9 m/
)
15 min h [cl b d
=
/O'b cpm = 24 x 10 uc/ml x 3 x 10' ml 72
=
l 10' pc 2
I reuter@ stokes 18530 South Mdes Parkway Cleveland, Ohio 44128 USNRC Region III December 21, 1984 Attention:
B. J. Holt Page 5 Therefore a filter showing 72 cpm after it had been run in the MSA portable air monitor for 15 minutes would constitute an action 8
level of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> times the air concentrations shown in 10CFR20 Appendix B, Table 1, Column 1.
l B.
Tha lon~1st interval between whole body counts has been 24 months.
We have no justification for this longer frequency other than the unavailability of a whole body counter of sufficient sensitivity in our area, and the fact that our air monitoring and bioassay data over the past twenty or more years show our process generi-cally does not put radioactive particulates into the atmosphere.
We have investigated whole body counting more thoroughly and, since we are now a subsidiary of the General Electric Company, we are in the process of making arrangements to have all of our whole
-L, body counting done by the General Electric facility in Wilmington, North Carolina.
The frequency guidelines set forth in Regulatory Guide 8.11 will be followed.
The data analysis and reporting will be performed by R.M.C. Technical Services of Northbrook, Illinois.
C.
We will follow the bioassay action levels and proposed follow-up procedure recommended in Regulatory Guide 8.11.
Under normal working conditions, the weekly exposure of individuals working in the uranium plating laboratory should not exceed an amount that is equivalent to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> exposure to the maximum permissible concentra-tion (MPC) listed in 10CFR 20 Appendix B, Table 1, Column 1.
This is our action level for airborne concentrations of uranium.
This lower than required level is set in order to maintain the exposure of individuals to airborne radioactive materials at a level as low as reasonably achievable.
The follow-up to concentrations reaching action levels is:
- 1) Confirm results by taking additional air samples.
2)
Identify probable cause and correct or initiate additional control measures.
- 3) Perform an urinelysis as soon as possible, but no later than 2 days after notification that an action level was reached.
- 4) Take a whole body count for all persons in the affected area.
- 5) Determine whether others could have been exposed and perform bioassay measurements for them,
- 6) Restrict the work area until it has been determined that airborne concentrations of uranium are within acceptable levels.
reuter [ stokes 18530 South Mdes Parkway Cleveland, Ohio 44128 USNRC Region III December 21, 1984 Attention:
B. J. Holt Page 6 D.
The action level for decontaminating removable alpha contamination in uncontrolled areas is 20 dpm/100 sq. cm.
For controlled areas, the action level where notification of the Radiation Safety Officer or his assistant is necessary, is 500 dpm/100 sq. cm.
Contamina-7Kon levels greater than 5,000 dpm/100 sq. cm. should be cleaned as soon as possible, but no later than the following day, unless the contaminated surface is not readily accessible to personnel.
In this latter case, the limit is 10,000 dpm/100 sq. cm.
5.
Was'e Disposal To date, we have not received any specific recommendations from ORMUG regarding volume reduction of low level waste.
When recommendations are made, we will evaluate their applicability to our operation and contact the NRC to see if an amendment to our SNM license is necessary.
6.
Distribution The necessity to register radiation detectors containing special nuclear material is a new requirement not imposed on us in previous reviews.
It comes as a surprise since this type of detector, commonly referred to as a fission chamber, has been in extensive use in the nuclear power industry since its birth over twenty years ago.
We have been making and distributing fission chambers for almost as long.
Today almost every nuclear power plant in the United States has fission chambers in its core to monitor various core parameters.
In addition, reactors run by the Department of Energy and Department of Defense at various facilities such as Idaho Falls, Savannah River, Oak
- Ridge, and most of the National Laboratories, also use fission chambers, usually of a special design to meet the needs of the specific facility.
In some cases the end use of the fission chambers may even be classified.
We will answer your questions relative to registration to the best of our ability, however, it is our desire to meet with the appropriate reviewers, at their convenience, to discuss further how this new requirement impacts our operations.
A.
Attached are a number of information sheets on various fission chambers we presently make or have made in the past.
We cannot anticipate future designs except to say that they will probably fall within the range of physical size and uranium content pre-sented in the attachments.
Although it is technically possible, we do not make a fission counter that contains more than 4 grams of uranium.
The information sheets show that most fission chambers
reuter Q stokes 18530 South Mdes Parkway Cleveland. Ohio 44128 USNRC Region III December 21, 1984 Attention: B. J. Holt Page 7 contain milligram quantities of uranium.
We also do contract plating work for the National Labs.
The most recent such contract was for Oak Ridge National Lab to plate ORNL supplied electrodes with uranium to be used on a prototype high sensitivity fission chamber being built by ORNL.
B.
The specific method and instrumentation used to determine the exact quantity of uranium in each fission chamber is considered to be proprietary.
In general, an exact amount of uranium is weighed on a microbalance prior to incorporation into a
plating solution.
Determining the activity of the solution before and after the plating cycle determines the total quantity on the electrodes.
A further check on the uranium quantity is the final test to determine the neutron sensitivity of the fission chamber.
Neutron sensitivity is dependent upon the total coated area and the total amount of uranium.
C.
Electrodes are electroplated with a hard uranium coating.
The coating would have to be scratched, scraped, or purposely abraded in some manner before particulates could be released to the environment.
The plated electrodes are assembled into a metal outer envelope, usually stainless steel or aluminum.
This outer envelope is welded and brazed to hermetically seal the electrodes from the environment. Under normal conditions of use, the envelope is not breached to expose uranium plated surfaces.
If the coating should, for some unexplained reason, lose its adherent properties, the material would still be confined by the hermetically sealed outer envelope.
D.
Reuter-Stokes produces its products to formal quality control pro-cedures and has a Quality Assurance Manual. The Manual is a controlled document which we would not object sending to you if you stipulate that you will keep it proprietary.
In-core fission chambers for Boiling Water Reactors are manufactured to quality standards set forth in 10CFR50 Appendix B, and to the applicable sections of the ASME Boiler and Pressure Vessel Code.
Other fission chambers are manufac-tured to various rigid quality standards based upon the specific design and specific requirements imposed by our customers.
E.
In the attachments are several samples of standard labels that we use to mark fission chambers.
The label identifies the specific uranium isotope, total quantity in grams, the applicable date, and, when affixed to a tag, the total activity in millicuries.
The label is attached, as appropriate either to the outside of the fission chamber itself, or to the immediate packaging material, usually a polyethylene bag.
reuter Q stokes 18530 South Mdes Parkway Cleveland. Ohio 44128 USNRC Region III December 21, 1984 r
Attention:
B. J. Holt Page 8 E
Fission chambers are designed for use as neutron flux sensors and are typically used as a component in a complex electronic instrumentation f
system in a nuclear power plant.
We do not manufacture these systems and their details are generally not made available to us, so it is not possible to provide explicit instructions for their use.
However, the fission chamber information sheets provided as attachments do provide maximum ratings such as voltage, temperature, and pressure.
These ratings have been specified to preserve good operating characteristics i
and are well below those values which would result in physical damage to the metal envelope which contains the uranium plated electrodes.
Specification sheets containing maximum operating parameters are made 1
l available to our customers.
v r
F.
We follow the method described in 10CFR70.42(d) to verify that our I
customers are authorized by the NRC or an Agreement State to possess r
and use special nuclear material.
The procedure used is detailed in section 11 of RS-50P-880.0, PHYSICAL SECURITY PLAN FOR THE PROTECTION
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OF SPECIAL NUCLEAR MATERIAL 0F LOW STRATEGIC SIGNIFICANCE, an attach-ment to our renewal application.
In addition, all applicable shipments are accounted for and special nuclear material is transferred according
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to the instructions in 10CFR70.54.
We complete and distribute a h
Nuclear Material Transaction Report on DOE /NRC Form 741, in accordance r
with printed instructions.
I 1
g G.
Once shipped out of our plant, fission chambers cannot be serviced or I
g maintenance repaired.
Instructions for the disposal of fission i
chambers are not provided for the following reasons:
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- 1) Appropriate disposal procedures depend upon the total radiation i
flux level received and the history of the fission chamber. The y
procedures are usually reactor site specific. For example, fission I
chambers made for in-core monitoring in Boiling Water Reactor's I
are removed after several years of service and are highly radio-
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active due to internal fission products and the activation of the 6-fission chamber structural parts.
The reactor staff removes E
these fission chambers with special remote handling equipment and follows the plant technical specifications for storage and disposal.
Boiling Water Reactor-6 power plants, the latest General Electric design, have a specific Bottom Entry Disposal System i
(BEDS) to remove the prepare activated fission chambers for disposal.
E m
reuter Q stokes l
18530 South Mdes Parkway Cleveland, Ohio 44128 USNRC Region III December 21, 1984 Attention:
B. J. Holt Page 9
- 2) Since fission chambers are distributed only to users holding a valid special nuclear material license, such users are required by their license conditions to maintain both an accountability system and have an approved method of disposing of special nuclear material.
All shipments of fission chambers include certification by Reuter-Stokes of total special nuclear material content by name, physical form, and activity.
A sample certification is part of the attachments to this letter.
We will be contacting you within the next several weeks to set up an acceptable time to discuss Item 6 distribution questions.
If you need more information, please let us know.
Sincerely, REUTER-STOKES, INC.
/ p$
/ George Palko Vice-President, Operations Radiation Safety Officer I
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1 D(N4PLES OF LABCIE
o reuteristokes 18530 South Miles Parkway, Cleveland, Ohio 44128 U.S.A.
Telephone (216) 5819400, Telex 98-5253 SHIPPER'S CERTIFICATION EUR RADI0 ACTIVE MATERIALS We hereby certify that the nameo articles are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation, according to the applicable regulations of the Department of Transportation.
Model No.
Serial No.
AUTHORIZED SIGNATURE DATE RADIOACTIVE MATERIAL FORM, PHYSICAL & CHEMICAL ACTIVITY (C1)
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LABEL REQUIRED TRANSPORT INDEX PROPER SHIPPING NAME U.N. NLMBER DOSE RITE / CONTAINER SURFACE DOSE RATE /l METER FROM CONIAINER PACKAGE TYPE l
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RADIATION SAFETY OFFICER h
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