ML20132G001
| ML20132G001 | |
| Person / Time | |
|---|---|
| Issue date: | 11/18/1996 |
| From: | Mattsen C NRC |
| To: | Bolling L NRC |
| Shared Package | |
| ML20132F972 | List: |
| References | |
| NUDOCS 9612260153 | |
| Download: ML20132G001 (2) | |
Text
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- . J7 From: Catherin'e Mattsen To:. WND1.WNP9. LAB-
.Date: 11/18/96.10:38am
Subject:
Response to Aub{ey Ggdwin on questions concerning Ni-Th a'loy
'..- This is to inform you of. DRA/RES concurrence on your memo responding to
< Aubrey Godwin's questions concerning the recycle of aircraft engine parts containing nickel-thoria alloy.. The division concurs in the draft response as transmitted to us on November 14.
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96'12560153 961217 PDR STPRG ESGAZ PDR
Aubrey V. Godwin, Director
- Arizona Radiation Regulatory Agency 4814 South 40th Street Phoenix, Arizona 85040
Dear Mr. Godwin:
I am responding to your e-mail questions on the andling of finished aircraft engine parts ,
containing nickel-thoria alloy in accordance with he exemption in 10 CFR,40.13(c)(8) on t unimportant quantities of source material.
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A review of the original notice (32 FR 15872) pubished on Novembe 18,'1967 and -*
effective on December 18,1967, indicates that th re are no restrictions on the receipt, i possession, use or transfer of this material (see En losbre 1). This exemption remains in- ' I offect and includes the receipt of aircraft engines b the rework company, and transfer to the recycler for melting and/or other modifications. As noted, in the document referenced above, an analysis of the potential health hazards s owed that it is highly unlikely that the l small number of workers carrying out such operatio s will be exposed to radiation in , i excess of the limits recommended (at that time) by tg international Commission on s )
Radiological Protection for individuals in the general public when averaged over s' period of 1 year.
Responses to your specific questions are provided in nelosure 2.
Since ly, Paul H. Lohaus, Deputy Director Office .f State Programs
Enclosures:
As stated Distnbution-DlR RF (6S-199) BMorris, RES RBangart DCool, IMNS/NMSS PLohaus FCameron, OGC SDroggitis LBolling Arizona File DCD (SPO3)
PDR YES_X_, NO DOCURENT NARE: G: \. LAB \THALLOY #2p n . .see.e .me m yahm cm .m w m e .na r -cm .m w .na = -w.
OFFICE fA,0SP l OS$d KM D:IMNS l OGC ] RES l OSP:D l PHLoSyJ' RLBangart NAME Ctiolling:kk DCool FCameron i BMorris DATE 11/ 7 /96 11/a//96 11/ /96 11/ /96 t 11/ /96 11/ /96 l OSP FILE C0)E: SP-AG-2 I
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p* 4 UNITED STATES h*
g j NUCLEAR REGULATORY COMMISSION l o, ! WASHINGTON, D.C. 20566-0(m b ,,,,, # October 17, 1996 MEMORANDUM T0: Paul H. Lohaus., Deputy Dire tor Office of State Programs !
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FROM: Donald Cool Direct r Division of Indust al and .
Medical Nuclear Sa ett MS$;
SUBJECT:
ARIZONA QUESTIONS ON THORJA-ALLOY We concur in the October 4.'1996, draft response to Arizona provided the '
attached changes (strikeout / underlined areas) are incorporated. We ;
recommended deletion of specific statements regarding conclusions on Part 40 '
exemptions at this time since both the preliminary and final assessments and outcome on Part 40 exemptions are currently being reviewed.
A copy of the attachment is also beirig provided electronically to Mr. Lloyd Bolling.
Attachment:
As stated k
Contact:
Patricia A. Santiago NMSS.
(301) 415-7269 i
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l Aubrey V. Godwin, Director i Arizona Radiation Regulatory Agency 4814 South 40th Street
- Phoenix, Arizona 85040
Dear Mr. Godwin:
I am responding to your e-mail questions on the handling of finished aircraft engine ) arts containing nickel-thoria alloy in accordance with the exemption in 10 C:R 40.13(c)(8) on unimportant quantities of source material (Enclosure 1).
In response to your first 2 questions, a review of the original notice (32 FR 15872) published on November 18, 1967, and effective on December 18, 1967 (Enclosure 2), indicates that the Commission specifically stated:
"The exemption adopted permits the conduct of activities such as repair of finished aircraft engine parts containing nickel-thoria alloy, and the handling and processing of nickel-thoria scrap by scrap dealers and scrap processors. An analysis of the potential health hazards shows that it is highly unlikely that the small number of workers carrying out such operations involving nickel-thoria alloys will be exposed to radiation or airborne concentrations of radioactive material in excess of limits recommended by the International Commission of Radiological Protection for individuals in the general public when averaged over a period of 1 year."
This exemption remains in effect and includes the receipt of aircraft engines by the rework company, and transfer to the recycler for melting and/or other modi fications. A review of other technical assistance requests related to nickel-thoria aircraft engine parts provide additional information which may be of interest to you. The U.S. Air Force. 'in a letter dated April 6.1989, questioned disposal of nickel-thoria and indicated pursuant to 40.13(c)(8),
nickel-thoria which ~cannot be reused as scrap should be exempted from further regulatory control. ,A December 23. 1993 memorandum to D. Chamberlain. NRC Region IV advised that, the Commission was silent, in both the proposed and the final rule, on the disposal 'of finished nickel-thoria aircraft engine parts authorized under 10 CFR 40.13(c)(8) to other than a scrap dealer, therefore, any other dis)osal is prohibited (Enclosure 3). The memorandum
- also explained that 10 C R 40.13(c) allows the disposal of nickel-thoria alloy as scrap when the alloy meets the requirements of 10 CFR 40.13(c)(4).
In response to your third question, we are currently reviewing a draft report frc 03NL cn the radiclogical impact: to the public from Part 30 and Part 'O cxemptions. Even considering the revision of 10 CFR Part 20. which now cc binc; the internal and external dose to producc : TEDE. and the use of a
- 'ublic dc c limit cf 100 mrc
- /yr versu: the cld 500 mr=/yr it 1: nct ex^ccted that the conclusions regarding the 10 CFR 10.13(c)(8) exemptior 4+,
thE 1967 Federal Register Notice quoted abcyc will change. Furthcr. ccn=rn
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1 l Mr. Aubrey V. Godwin the oriainal Federal notice addressed similar concerns. was (OCC rcccarcnd; l
dc!ction of the fc!!cwing) raised in the car!y 1960: that stcc1 cupp!!c: might becanc cont minated with sourcc matcri:1 Citcnsive tect: conddcted by Dupont \
Chowcd that c::cntia!!y 311 of thc thorium introduccd into stain 1cs: stcc1 or '
l Inconc! mc! ting fbrnacc: ,::: scparated with th^ 1 g. Thc c The issues
! associated with typc cf iscucs (c.g. re-us'a of scrap metal will be addressed !
l in the planned recycle rulemaking effort which will be coordinated with the EPA.
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l In response to your fourth question based on the information that you have '
l provided it appears that the nickel-thoria aircraft engine parts are being transferred to scrap dealers and recyclers as authorized by 10 CFR 40.13(c)(8). Therefore, we do not see the need for any enforcement action at this time.
- Sincerely.
l Paul H. Lohaus. Deputy Director l
1 Office of State Programs ,
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Enclosures:
l As stated l
! 1 1
l DISTRIBUTION:
- DlR RF (6S-199) l RBangart .
PLohaus SDroggitis LBolling FCameron OGC BMorris. RES DCool. IMNS/NMSS DCD (SP03) i PDR YES / NO-l *See previous concurrence.
! DOCUMENT NAME: G:\TSK6S199. lab To receive e copy of thie document, indicate in the box: "C" = Copy without ettschment/ enclosure 'E" = Copy with attachment / enclosure "N" = No copy 0FFICE OSP lE OSP:DD lC OGC lC IMNS:D lC NAME LBolling:gd PLohaus FCameron DCool DATE 10/02/96* 10/03/96* / / / /
OFFICE RES C OSP:D NAME BMorris RLBangart DATE / / / / / / / /
05P CODE: SP-AG-2 l
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l . .. . 7 pt o e
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- ROUTING AND TRANSMITTAL SLIP DATE: OCTOBER 4, 1996 PARALLEL CONCURRENCE REQUESTED F. CAMERON, OGC
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B. MORRIS, RES l .D. COOL, IMNS ,
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LETTER T0: AUBREY V. GODWIN, DIRECT 6R
- FROM: PAUL H. LOHAUS, DEPUTY DIRECTOR OFFICE OF STATE PROGRANS
SUBJECT:
ARIZONA QUESTIONS THORIA-ALLOY YOUR CONCURRENCE IS REQUES17.0 BY C.O.B. OCTOBER 18. 1996.
l OSP CONTACT: LLOYD BOLLING (415-2327) i PLEASE CALL KATHALEEN KERR (415-3340) FOR PICK UP.
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a EXECUTIVE TASK MANAGEMENT SYSTEM
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<<< PRINT SCREEN UPDATE FORM >>> i i
, TASK
___._ #_ -'6S199 DATE- 08/08/96 MAIL CTRL. - 1996 TASK STARTED - 08/08/96 TASK DUE - / / TASK COMPLETED - / /
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TASK DESCRIPTION - 8/6 E-MAIL RE SCRAP METAL INVESTIGATION - MATERIAL
..__ ...__..-~~~ .,
DISCOVERED AT EMCO RECYCLING !
REQUESTING OFF....___...._____ REQUESTER AZ - A. GODWIN WITS - 0 FYP - N i
.......... .... __. 1 PROG.- LAB PERSON - STAFF LEAD - LAB PROG. AREA -
PROJECT STATUS - OSP DUE DATE:
i PLANNED ACC. -N '
LEVEL CODE - 1 l 1
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