ML20135F004

Forwards Six Copies of Response to RAI Re License Renewal. Revised Version of Text for Matls License Document Encl

ML20135F004
Person / Time
Site:	07000398
Issue date:	02/28/1997
From:	Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL
To:	Soong S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9703110114
Download: ML20135F004 (46)

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UNITE ~) STATE] DEPARTMENT OF COMMERCE b.y National Institute of Standards and Technology g%h/y Gaithersburg, Maryland 208990001 70~ b February 28,1997 Dr. Sean Soong License No. SNM-362 Licensing Branch Docket: 70-398 U. S. Nuclear Regulatory Commission Mail Stop T 8-D-14 Washington, D.C. 20555-0001

Dear Dr. Soong:

Six copies of our response to'your request for additional information, dated January 28,1997, are enclosed. We include a revised version of the text for the Materials License Document and our responses to your specific comments. The attachments to the Document remain the same as previously submitted; please add the enclosed environmental monitor locator map to those attachments.

If you need additional information, please contact Mr. T. G. Hobbs at the National Institute of Standards and Technology, Room C125, Building 245, Gaithersburg, MARYLAND,20899. His telephone number is 301-975-5800; his FAX is 301-975-4893, and his e-mail address is thomas.hobbs@nist. gov.

Sincerely, F

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an E. Pevey, Chief Occupational Health and Sa Disision (Materials License Manager) enclosure f0 l

9703110114 970228 I

PDR ADOCK 07000398 C

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l RESPONSES TO 01/28/97 CO51MENTS FOR NIST SNM-362 LICENSE RENEWAL APPLICATION l

l-CITED PAGE RESPONSE TO COMMENTS I-1-2 The second and third sentences in the definition of " radioactive waste", Section 1.6, have been deleted.

1-1 3 Item e on decay-in-storage in Section 1.8 has been deleted.

I-3-1 The primary indicator for unacceptable filter loading is by a decrease in the air flow rate at the hood face to the prescribed performance level specified in Section 3.2.2. A preliminary indicator, i.e., prior to unacceptable decrease in air flow, is a drop in pressure across the filter. Thus, the justification for the work stoppage on drop in pressure is that a more conservative indicator has been implemented.

1-3 2 The last sentence in Section 3.2.3 has been revised to indicate that calibration will be performed for a survey instrument whenever it is repaired or semiannually.

I-3-3 Section 3.2.4 has been revised to specify bioassay data evaluation techniques and conducting workplace air sampling.

J I-4-1 Section 4.1 has been revised to reflect requirements given in 10CFR20.2001(a)(2) and 10CFR35.92.

11-1 0-3 Wastes treated by " decay-in-storage" are described in Section 10.4.2, reflecting i

commitments given in Section 4.1.

11-1 2-2 Section 3.2.4 and Section 12.1 have been revised to indicate that safety approval follows safety review and that the review establishes surveillance protocols, including monitoring frequency, and that the start of a project follows the safety approval.

3 11-1 2-5 The technical justifications for "C and H trigger levels in Table 11-12-1 are based on 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in a week for an exposure of 100 mrem. A conservative resuspension factor of 10 m, proposed by Brodsky in Health Physics, vol. 39(6), pp 9992-1000 and a 4

concentration criterion of 2% DAC, with DAC from 10CFR20, App. B, Table 1, Col.

3, the surface contamination level leads to (DAC x 2 x 102) / (104) pCi m 2. Thus, the table below shows the calculated values for C, the surface contamination level, for the nuclides of interest. The values in Table 11.12-1 represent a standard of cleanliness well beyond those values calculated.

nuclide DAC (uCiem 3)

C (uCiem.2)

C (dome (100 cm yi) 2 5

11 20 4 x 10 9 x 10' 3

4 8

"C 1

2 x 10 4 x 10 02/97...1

RESPONSES TO 01/28/97 COMMENTS FOR NIST SNM-362 LICENSE RENEWAL APPLICATION, CONT'D CITED PAGE RESPONSE TO COMMENTS Il-12-6 ICRP uses a factor of 30% of the appropriate limit for administrative action criteria.

4 The referenced 25% of the regulatory limit in Table II.12-2 is a similarly conservative a

application for initiating an action. Table II.12-2 has been modified to indicate that internal dose for occupational limits, rather than air concentrations, are the applicable action evoking determinant.

i uncited A locator map for environmental monitor stations has been attached to the Materials License Document, uncited Below are tables of solid, liquid, and gaseous waste discharges for 1991-1995:

l SOLID LOW LEVEL RADIOACTIVE WASTE 3

har Volume (m )

Activity (Ci) 1991 37.6 0.1 1992 99.4 141.0 1993 6.8

.0.3 1994 230.7 179.5 i

1995 39.0 1.2 LIQUID LOW LEVEL RADIOACTIVE WASTE 4

3 Year Volume (kt)

H (Ci)

B-y(Ci) 1991 660 0.7 0.0016 1992 428 1.5 0.0004 1993 4500 1.6 0.0002 1994 862 2.7 0.0008 1995 682 1.3 0.0001 GASEOUS LOW LEVEL RADIOACTIVE WASTE Year d' Ar (Ci) 3H (Ci) 1991 971 251 1992 665 351 1993 879 425 1994 469 637 1995 267 209 02/97...2

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4 MATERIALS LICENSE l

DOCUMENT i

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United States Department of Commerce i

National Institute of Standards and Technology Gaithersburg MARYLAND 20899 1

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TABLE OF CONTENTS INTRODUCTION PART I - LICENSE CONDITIONS CHAPTER l - STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1.1 N a m e...................................................

1 1 l.2 Loca ti on.................................................

1-1 1 1

1.3 Renewing License Number..................................... I 1 -1 1.4 Possession Limits............................................ I-1-1 1.5 Location Where Material Will Be Used...........................

1-1-1 1.6 Definitions...............................................

1-1-2 1.7 Authorized Activities......................................... I-1 -2 1.8 Exemptions and Special Authorizations............................ 1-1-3 Incorporated by

Reference:

Guidelines for Decontamination CHAPTER 2 - GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 2.1 National Institute of Standards and Technology Policy................. I-2-1 2.2 Organizational Responsibilities and Authority........................ I-2-1 2.3 Ionizing Radiation Safety Committee............................. I-2-1 2.4 Approval Authority for Personnel Selection........................ I-2-2 2.5 Personnel Education and Experience Requirements.................... I-2-2 2.6 Training.................................................. I-2 -2 2.7 Operating Procedures........................................ I-2-3 2.8 Audits and Inspections........................................ I-2-3 2.9 Investigations and Reporting of Off-Normal Occurrences................ I-2-3 2.10 Records................................................. I-2-4 2.11 Fire Protection......

............ I-2 -4 CHAPTER 3 - RADIATION PROTECTION 3.1 Special Administrative Requirements 3.1.1 Radiation Work Permit Procedures......,...................... I-3-1 3.1.2 ALARA Commitment........................

............ I-3-1 3.2 Technical Requirements 3.2.1 Access Control.......................................... I 1 3.2.2 Ventilation Requirements

...................................I-3-1 3.2.3 Instrumentation......................................... I-3-1 3.2.4 Internal and External Exposure............................... I-3-2 3.2.5 Local Emergency Actions.................................. I-3-3 3.2.6 Sealed Source Control..................................... I-3-3

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PART I cont'd.

T CHAPTER 4 - ENVIRONMENTAL PROTECTION 4.1 Effluent Control Systems...................................... I-4-1 4.2 Environmental Monitoring...................................... I-4-1 4.3 Nonradiological Hazards...................................... I-4-1 1

CHAPTER 5 - SPECIAL PROCESS COMMITMENTS 5.1 Special Nuclear Material Accounting and Control..................... I-5-1 5.2 Alpha Chemistry Operations.................................... I-5-1 i

CHAPTER 6 - NUCLEAR CRITICALITY SAFETY.....................

1-6-7-1 CHAPTER 7 - DECOMMISSIONING PLAN..........................

1-6-7-1 CHAPTER 8 - ACCIDENT EVALUATION........................... I-8-1 PART II - SAFETY DEMONSTRATION CHAPTER 9 - OVERVIEW OF OPERATION 9.1 Corporate Information

........................................II-9-1 9.2 M iss ion................................................... II 1 9.3 Site Description............................................ II 1 9.4 Maps, Buildings, and Site Information......

......... II-9-2 9.5 Lic ense History............................................. II-9-2 9.6 Changes in Procedures, Facilities, and Equipment..................... II 3 9.7 Examples of Operations That Might Be Conducted...................

11-9-3 CHAPTER 10 - FACILITY DESCRIPTION 10.1 Layout

..... II-10-1 10.2 Utilities, Including Electrical Power.............................

1I-10-1 10.3 Heating, Ventilation, and Air Conditioning........................ II 1 10.4 Waste Handling 10.4.1 Liquid Wastes.............

. II-10-1 10.4.2 S olid Wastes........................................... II-10-2 10.5 Chemical Systems

..........................................II-10-2 10.6 Fire Protec tion............................................. II-10-3 CHAPTER 11 - ORGANIZATION AND PERSONNEL 11.1 Unit Functions 11.1.1 Ionizing Radiation Safety Committee 11 - 1 1 - 1 11.1.2 Chief, Occupational Health and Safety Division................... II-l1-1 11.1.3 Chief, Health Physics........

11-11-1 11.1.4 Division Chiefs

..... I1-11-2 11.1.5 Staff......

11-11-2 11-11-2 11.2 Organization

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PART II cont'd.

CHAPTER 12 - RADIATION PROTECTION PROCEDURES AND EQUIPMENT 12.1 Procedures...............................................

11 1 12.2 Posting and Labeling I1-12-1 12.3 Personnel Monitoring........................................ II 1 12.4 S urv eys.................................................. II-12 -2 12.5 Reports and Records......................................... II-12-2 12.6 Instruments.............................................. II-12 2 l

12.7 Sealed Source Leak Testing..................................

11-12-3 j

12.8 Protective Clothing.......................................... II-12-3 12.9 Administrative Control Levels.

...... II-12-3 12.10 Respiratory Protection......................................

11-12-4 CHAPTER 13 - OCCUPATIONAL RADIATION EXPOSURES 4

13.1 Occupational Exposure Analysis................................. II-13-1 13 2 Measures Taken to Implement ALARA 11-13-1 13.3 Bioassay Program...................................

11-13-1 l

13.4 Air Sampling Program

.......................... II 1 13.5 Surface Contamination....................................... II-13-2 13.6 Shipping and Receiving...................................... I I-1 3 -2 1

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ATTACHMENTS NIST: Site Plan View, Topographic View, Building Floor Plans, Environmental Monitor Locations Forms Used in Radiation Safety Control Program

INTRODUCTION This document is intended to serve as information as required by the Code of Federal Regulations for the licensing of operations involving byproduct materials, source materials, and special nuclear materials. In no manner, express or implied, does the information in this document apply to the license issued to the National Institute of Standards and Technology for operating the NIST Reactor.

This document and succeeding versions of this document, including corrections, amendments, and updates, and consequential conditions imposed on the National Institute of l

Standards and Technology by the U. S. Nuclear Regulatory Commission constitute a full and complete set of operational descriptions for licensable material receipt, acquisition, ownership, l

possession, use, and transfer, other than for the NIST Reactor.

This document is in two parts. Part I contains the license conditions that are fixed and cannot be modified without specific permission from the U. S. Nuclear Regulatory Commission. Part II contains the safety demonstration information that may be changed as necessary to support and confirm full compliance with the conditions of the license. This manual will be reviewed and updated as required to reflect changing standards and regulations. A current copy of this document will be maintained in the NIST Health Physics office.

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PART I - LICENSE CONDITIONS l

CHAPTER 1 -

STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS l

1.1. Name The agency is the National Institute of Standards and Technology.

1.2 Location The mailing address is National Institute of Standards and Technology, Attn: Chief, Occupational Health and Safety Division, Room B124, Building 301, Gaithersburg, MD,20899.

The facility location and the shipping address are National Institute of Standards and Technology, Route '1270 & Quince Orchard Road, Gaithersburg, MD 20899.

1.3 Renewing License Number Renewal is requested for Materials License Number SNM-362.

1.4 Possession Limits j

4 Information on the qualities and quantities of radioactive materials for which this application requests licensing is given in Table I.1-1(a), where activities are in curies unless otherwise noted.

1.5 Locations Where Materials Are Used It is possible that any location within the NIST perimeters could be authorized by Health Physics for radioactivity controlled under the materials license. The probability that radioactivity operations might be authorized.in a given location varies. Permanent authorizations exist for facilities within Buildings 235 and 245. It is highly probable that authorizations could exist for laboratories within Buildings 220,221,222,223,224,225, and 226, i.e., the designated general purpose laboratory buildings. It is likely that authorizations could exist for rooms in Buildings J

101 and 231. There is a low, but not zero, probability, that authorizations could exist for specific uses within Buildings 102,202,205,206,230,233,236,237,238,301,302,303,304,306,307, 309,310, and 411. There is also a reasonable possibility that an authorization could be granted for operations utilizing sealed sources on the NIST grounds, outside a building, for example, for calibrating environmental monitors.

Major material uses are in Buildings 235 and 245. In Building 235, Rooms B119 through B154 and Rooms C001 and C002 are used for radiochemistry, normally associated with irradiated samples from the NIST Reactor. Building 235's Cold Neutron Facility Guide Hall and the E and the A wings might be used for storage of radioactive materials or for small source or activated equipment use. Also associated with Building 235, Room H100, the Radioactive Waste Annex, is dedicated to receiving, processing (such as solidifying liquids or compacting certain solids),

packaging, and delivering to disposal agents the low-level radioactive wastes from NIST. In Building 245, incidental radiochemistry, such as the separation of bulk materials into aliquots for small source preparation, is conducted in Rooms B44 through B53, B146 through B157, Cl1, Cl3, C15, E103, E105, and E106. Source receiving and storage are conducted in Rooms B131, 02/97 I11

B132, and B133. Rooms B141 through B145 are used for sealed source receiving and i

measurements. Sealed source operations are conducted in Rooms B05 through 825, and in Rooms.

l-B013 through B043, and in Rooms B143, B034, B036, and F101.

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1.6 Definitions l

The following definitions, italicized, are given to provide a precise reference for the use i

of the defined words and terms in Parts I and II of this Materials License Document. The j

definitions given here will apply unless specifically noted otherwise at use.

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frequency-Any technique applicable to the radiological safety program, including surveillance '

j or calibrations, and that is scheduled at regular intervals is subject to the following limits on the j

scheduled interval:

L a......

biennial means not to exceed thirty months.

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b.... annual means not to exceed fifteen months.

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semiannual means not to exceed eight months.

j d......

quarterly means not to exceed four months.

e..... monthly means not to exceed one and one-half months.

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biweekly means not to exceed twenty working days.

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g...... weekly means not to exceed ten working. days.

Radiation (or Radiological Ha:ard) Control Area - Any area to which access is controlled for purposes of radiation protection.

radioactive waste - All materials to be dealt with under this document as radioactive waste are classified as low level radioactive waste, i.e., not high-level radioactive waste as defined in 10CFR60.2.

safety approval-After a safety review, a Supervisory Health Physicist or a person with the same qualifications may approve a radiation project proposal.

safety review - A radiation project proposal is reviewed by Health Physics, subject to further review by the Ionizing Radiation Safety Committee. The Ionizing Radiation Safety Committee will review proposals that could credibly lead to a whole body deep dose equivalent greater than 1.25 rem.

sealed source - Radioactive material encased in a capsule or bonded cover designed to prevent leakage or escape of the material under the conditions of use for which the source is intended, including normal wear and tear.

1.7 Authorized Activities No provision exists at NIST as part of this license for very high level activity, i.e.,

kilocurie, work that requires a " hot cell" or an equivalent containment mechanism. There is no process or production line type of operation at NIST: all are batched mode, i.e., of finite duration, even though the duration may be of some length, perhaps years, in completing a research project or in completing a contracted or regulated obligation, or, for functions such as instrument characterization projects, intermittent tasks with work required on demand by customers or clients. There are no critical assemblies and no live animal exposures.

Among the types of activities that may be authorized, the following topical list illustrates typical projects that may exist. Also listed are building designations for those buildings that 02/97 11-2

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would most probably be involved in a particular type of activity. The designations are of I

functional origin and include ADM for administrative buildings; SRL for special radiological l

laboratories, i.e., Buildings 235 and 245; SPL for special purpose laboratories other than l

radiological; and GPL for general purpose laboratories, i.e., Buildings 220 through 226.

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materials and equipment irradiations - SRL f

a source preparations - SRL, SPL, GPL a

source calibrations - SRL, SPL, GPL m

instrument calibrations - SRL, SPL, GPL l

e sample assays - SRL, SPL, GPL a

source characterizations - SRL i

e instrument and device characterizations - SRL, SPL, GPL j

u reference or counting source uses - ADM, SRL, SPL, GPL l

u radiochemistry - SRL, SPL, GPL i

e general research and development - ADM, SRL, SPL, GPL a

sources incorporated into devices or equipment - ADM, SRL, SPL, GPL

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m miscellaneous, e.g., static elimination - ADM, SRL, SPL, GPL i

1.8 Exemptions and Special Authorizations a.

We request exemption from the requirement to maintain criticality monitors or conduct j-criticality reviews because all SNM except for PuBe sealed sources are controlled to maintain i

a minimum separation of three feet between each 300 grams of plutonium or U-233 or uranium enriched in the U-235 isotope or combination of these. Each room or area involving SNM operations is the responsibility of a single person who controls the movement of materials for that area according to written procedures to insure that the material quantity limits are maintained.

b.

We request that radioactive material use may be authorized for an off-site location subject to the following provisions:

the proposal is reviewed and approved by Health Physics and, if required, by the a

Ionizing Radiation Safety Committee.

the radioactive material is controlled by an authorized individual, who possesses a

written operating instructions while engaged in the project.

the radioactive material is an integral part of a measurement instrument or a a

contained source, such as a check or reference source.

lead-in-paint detectors may not exceed 100 millicuries of cadmium-109 or a

americium-241 as sealed sources in each device, otherwise the total quantity of radioactive material for a single authorized use may not exceed ten times the activity listed in 10CFR20, Appendix C, or, for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity.

c.

We request authority to release contaminated equipment to uncontrolled areas in accordance with the USNRC's August,1987 " Guidelines for decontamination of facilities and i

equipment prior to release for unrestricted use or termination oflicenses for byproduct, source, I

or special nuclear material." A copy of the guidelines is incorporated by reference in this i

chapter, j

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TABLE L1-1 NIST RADIOACTIVE MATERIALS LICENSE LIMITS NUCLIDE CHEM / PHYS FORM POSSESSION LIMIT A.

Uranium enriched to less than 20 -

Any 30 grams of U-235 wt% in the U-235 isotope B.

Uranium enriched to or greater than Any 230 grams of U-235 20 wt% in the U 235 isotope C.

Uranium-233 Any 6 grams of U-233 D.

Plutonium, except Pu-238 Any 40 grams E.

Plutoniuta Scaled sources 800 grams of plutonium F.

Plutonium enriched to more than 80%

Any 0.1 grams i

in the Pu 238 isotope i

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Natural uranium Any insoluble form 150 kilograms l

Any soluble form 9 kilograms i

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Thorium Any 69 kilograms 1

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Uranium depleted in the U-235 Any insoluble form 42 kilograms j

isotope Any soluble form 4 kilograms l

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Co-60 Scaled sources 58,000 curies K.

Cs-137 Sealed sourcee 9,000 curies l

L.

Po-210 Sealed sources 20 curies M.

Am-241 Scaled sources 40 curies N.

Cf-252 Scaled sources 10 curies O.

Sr-90 Sealed sources 3 curies l

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Byproduct material Any 4,000 curies total 0

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any nuclide of half-life less

1. 4 curies i

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than 30 days i

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any nuclide of half life more

2. I curie, except for the j

than 30 days except for the following nuclides:

following nuclides:

i H-3 2,000 curies Au-198 300 curies Kr-85 35 curies Cs-137, Mo-99, Tc-99m, and Xe-133

- 20 curies each 4

C-14 and Co-60 5 curies each 1

Ac-227 25 millicuries l

Am-241. -242m, and.243 25 millicuries each Bk-247 25 millicuries i

Cf-249, -250, -251, -252, and -254 25 millicuries mch l

Cm-242, 243. -244. -245, -246, 25 millicuries each 247, 248, and -250 Np-236 and -237 25 millicuries each Sm-146 and -147 25 millicuries each i

Q.

Any byproduct material with Atomic Neutron irradiated 1,100 curies total except for 4

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Number 3 to 83 except for the samples or containers the following nuclides:

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' following nuclides:

Curies i

Ag-108m 800 Eu-152 and -154 800 Nb-94 800 Tb-158 800

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Be 10 500 P-32 400 i

Os-194 350 j

Cd-l13m 200

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Cl-36 200 l

I-130 200 4

4 Hf-178m and -182 100

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Bi-210m 30 l-125 20 Sm-146 3

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Irradiated Fuel Four pellets 0.25 grams of U-235*

• storage only, awaiting disposition l

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CHAPTER 2 -

GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 2.1 National Institute of Standards and Technology Policy -

The policy of the National Institute of Standards and Technology is to maintain radiation exposures and releases of radioactive materials in unrestricted areas to magnitudes as low as reasonably achievable (ALARA).

2.2 Organizational Responsibilities and Authority The Chief, Occupational Health and Safety Division, reporting through the Director of Administration to the Director of NIST, who is the ultimately responsible official, serves as Materials License Manager, representing NIST in all matters relating to this license, and as the director of the radiological safety program at NIST. Health Physics is a unit of the Occupational l

Health and Safety Division, with a Chief and Supervisory Health Physicists directing a staff of l

professional and _sub-professional health physics personnel. The Chief of Health Physics administers the radiological safety program, allocates resources determined by NIST management, and reviews and determines approval or disapproval for major safety issues as presented by the l

Supervisory Health Physicists. The Supervisory Health Physicists apply NIST and regulatory policy and rules to day-to-day administration of the radiological safety program, review and determine action on non-routine issues, and submit major issues to the Chief of Health Physics for policy decisions. A Supervisory Health Physicist or higher management level has the authority to shut down an operation that he or she believes threatens the health and safety of the employees or the public or poses a potential for violation of applicable regulations, license conditions, or implementing procedures.

l 2.3 Ionizing Radiation Safety Committee The NIST Ionizing Radiation Safety Committee reports to the NIST Deputy Director.

Fields of expertise represented on the Committee include physics, chemistry, health physics, l

materials science, industrial safety, and nuclear research reactors. The Committee meets at least l

once annually, providing oversight for the NIST radiological safety program, reviewing radiological safety related matters, advising the Chief, Occupational Health and Safety Division on operations, and recommending corrective actions when necessary. The Committee serves as the ALARA review committee. The Chief of Health Physics or a Supervisory Health Physicist is a member and serves as a qualified expert for the Committee. Minutes of the Committee meetings are maintained in the Chairperson's file. An annual report from the Committee to the Deputy Director of NIST summarizes the following information:

trend analysis of data from personnel dosimetry, including internal exposures, environmental monitoring, and effluent surveillance; ALARA reviews and decisions; results of reviews of resource allocations for the radiological safety program; and required program audits and inspections conducted during the previous year.

There is no fire protection review committee as such. However, any proposed laboratory or facility construction or modification must be reviewed by and have the approval of such management interests as the head of the Safety Office, the Chief of the Fire Protection Services, 02/97 I-2-1

and the Chief of the Plant Division or his designated representative.

2.4 Approval Authority for Personnel Selection The Chief, Occupationa! Health and Safety Division, is responsible for Health Physics staff selections. The NIST Deputy Director appoints Ionizing Radiation Safety Committee members.

2.5 Personnel Education and Experience Requirements The Chief of the Occupational Health and Safety Division must have a B.S. in science or engineering and at least five years of professional safety-and health-related experience. The Chief of Health Physics, as a minimum, must be certified in Health Physics by the American Board of Health Physics, or must have a bachelor's degree in a science or enginee-ing field and at least five years of professional level radiological safety experience. Supervisorf Health Physicists must have bachelor's degrees in science or engineering and two years of experience in applied health physics. A fully qualified Health Physics technician must have completed training as required by the Supervisory Health Physicist and have at least one full year of service in typical Health Physics technician assignments. Members of the Ionizing Radiation Safety Committee must have a degree or equivalent professional experience in their respective fields of expertise, and at'least five years of pertinent experience.

2.6 Training Prior to receiving authorization to work independently with radioactive materials or radiation, workers receive training in topics such as these:

storage, uansfer, or use of radioactive materials at their workplaces; health protection problems associated with exposure to radioactive materials or radiations; precautions or procedures to minimize exposure; purposes and functions of protective devices employed; agency and other rules and regulations and conditions of licenses, and responsibilities for observing and complying with these to the extent under the worker's control; requirements for reporting to supervisors any condition that may lead to or cause a violation of the rules, regulations, or conditions of licenses or an unnecessary exposure to radiation or radioactive materials; appropriate responses to warnings given in the event of any unusual occurrence or malfunction that may result in or involve excessive radiation or radioactive material exposure; availabilhy of radiation exposure reports that may be requested; and fire safety and the use of portable fire extinguishers.

The extent of these instructions is commensurate with potential radiological health protection issues associated with the workplaces involved. New radiation workers must receive the training before permission to perform unsupervised operations is given. A Health Physics review of prior work experience and training in radiological safety may show that such training or experience can be substituted for all or any part of the training described above. Evaluations 02/97 1-2-2

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b-of trainee understanding is by performance observations, dosimetry reviews, personal interviews, prior work experience, or similar evaluation methods. Should safety-related changes by made in operations, or should any employee be reassigned or return after extended absence, the Division Chief determines the need for retraining.

Health Physics technicians are trained in fundamentals of radiological safety commensurate with their levels of responsibilities. Topics for this training might include the following:

basic principles; 5

particle and photon properties; dosimetry concepts and practices; shielding; 1

biological effects of radiation; 4

protection standards; l

instrumentation and equipment concepts and practices; and i

operations for which specific responsibilities are assigned, such as radioactive j

materials, and personnel or environmental dosirnetry.

i All individuals who work with radioactive materials and the Health Physics technicians are required to participate in biennial radiological safety training. The Chief of Health Physics 1

assures that training programs are available as required.

L 2.7 Operating Procedures Written operating, maintenance, and test procedures for work with licensed radioactive materials are developed and followed. Those generated by the prospective radioactive material user are reviewed by Health Physics. Following the review and upon agreement on the safety practices to be observed, a Supervisory Health Physicist or a person with the same qualifications

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approves the proposal, subject to review if necessary by the Ionizing Radiation Safety Committee.

l Similarly, proposals for radiological safety-related changes in existing procedures, equipment, or facilities also require Health Physics review and approval, subject to Ionizing Radiation Safety Committee review if necessary, Health Physics review addresses compliance with regulatory requirements and limits, ALARA commitments, monitoring concerns, emergency planning, and training needs. Any required Health Physics surveillance and observations of i

procedures, including frequencies, are specified. Health Physics surveillance of radiation and radioactive material control during operations indicates if there is a need for any procedural l

updating and review.

Health Physics operating procedures and major changes proposed for those procedures are d

reviewed and approved by the Chief of Health Physics. Health Physics procedures will be i

observed and followed.

2.8 Audits and Reviews 3

Ionizing Radiation Safety Committee representatives other than Health Physics staff annually audit the performance quality of operations that provide radiological safety assurance, reporting to the Committee and indicating necessary actions and follow-up audits. At least i

annually, Health Physics staff members review surveillance techniques and results to assure i

compliance with applicable protocols, documenting results and follow-up actions and results.

02/97 123 t

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Supervisory Health Physicists or persons with qualifications equivalent to those of a 4

Supervisory Health Physicist conduct radiation workplace safety observation tours at least quarterly for those workplaces that posnignificant potential for radiation exposures or releases j

of radioactive materials, following written plans. Results of the tours are documented and corrective action needs found during the tours are transmitted to workplace supervisors in a timely fashion.

2.9 Investigations and Reporting of Off-Normal Occurrences Health Physics, based on reports from Division Chiefs or workers, or on results of 4

monitoring or surveillance, investigates suspected off-normal occurrences. The Chief, 1

i Occupational Health and Safety Division, reports these conditions to authorities and to management, as required by applicable regulations, procedures, and license conditions.

i 2.10 Records j

Health Physics maintains documentation on the results of required monitoring and surveillance, the results of approved proposal reviews, off-normal occurrence investigations, and other rad.ological safety program information, sufficient to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee documents and retains information on audits and provides reports to management as required. Retention times for

[

documents are as required by regulations or for at least two years.

2.11 Fire Protection A Fire Protection Services grcup in the Facilities Services Division provides a trained fire l

and emergency response organization. Any proposed laboratory or facility construction or i

modification must be reviewed by and have the approval of such management interests as the head of the Safety Office, the Chief of the Fire Protection Services, and the Chief of the Plant Division or his designated representative. Members of the staff of the Fire Protection Services i

group are trained to the equivalent of Fire Fighter III level. Maintenance of fire fighting equipment is conducted according to written procedures. Extensive pre-fire plans exist, with information on locations of radioactive materials, fiammable materials, and other hazardous t

materials, and includes fire fighting protocols for those areas. The plans include locations of water supplies, storage areas, and other appropriate information. Fire Protection Services 4

maintains extensive documentation on maintenance and deployment of equipment, pre-fire planning, facility characteristics, training, results of actual occurrences, etc.

4 4

4 9

4 J

7 1

1 02/97 l-2-4 i

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l CHAPTER 3 -

RADIOLOGICAL PROTECTION 3.1 Special Administrative Requirements 3.l~1 Radiation Work Permit Procedures For special tasks, i.e., when a task could result in significant exposure or contamination, or as determined necessary by Health Physics, Form NIST-362, Radiation Work Permit, or equivalent is prepared to provide radiation safety control, if a standing procedure does not exist.

Following a review, including a review of industrial safety considerations, a Supervisory Health '

Physicist or a person with the same qualifications approves the proposal, subject to review if necessary by the Ionizing Radiation Safety Committee. A previously approved proposal may be approved and reissued by a Health Physics Technician, j

i l

3.1.2 AL. ARA Commitment The NIST commitment to the As Low As Reasonably Achievable (ALARA) concept is stated in section 2.1 of this manual. Health Physics reviews the dosimetry reports, contamination survey results, external radiation level survey data, and other radiological safety program information for ALARA purposes. The Ionizing Radiation Safety Committee, as a part of its annual audit, inspe:ts Health Physics documentation of these reviews and analyzes other safety and operations info 0 nation for ALARA purposes.

3.2 Technical Requirements 3.2.1 Access Control Health Physics establishes and monitors the control features of certain areas as required in 10CFR20. Signs, monitors, protection facilities, and other necessary provisions are specified at the time the area is established. Workers are required to perform personal contamination monitoring as they leave a designated contamination monitoring area.

3.2.2 Ventilation Requirements Based on quarterly tests of hood face air velocities, Health Physics causes work to stop for an air flow ofless than 75 linear feet per minute at any measured hood face location, if the approved work proposal requires the work to be done in a hood.

If approved work proposals require high-efficiency particulate filters (HEPA) for hoods or glove boxes at the workplace, Health Physics requires acceptance testing by the dioctyi phthalate (DOP) aerosol or equivalent method. Testing is performed using written operating procedures derived from accepted standards and guidance and results 'of the testing is documented. Quarterly magnahelic or equivalent pressure drop indicator observations demonstrate HEPA filter loading; work requiring HEPA filters is suspended if readings or indications show the equivalent of four times the reading for clean or freshly installed filters.

3.2.3 Instrumentation l

Table I.3-1 describes typical radiation detecting instruments commonly available for use in the radiological safety program at NIST, and their characteristics. Substitutions are acceptable i

l 02/97 13-1 w

-+m wr y-r-

ur y

e-y

.e 1

as long as there is no degradation of the radiation safety surveillance program. For instruments i

used for dose assessment, calibration for routinely used ranges is done semiannually or after repairs that could affect response, with sources traceable to national standards. For instruments used in a qualitative survey mode, responses are checked semiannually or after such repairs, 1

TABLE I.3-1 i

l TYPICAL HEALTH PHYSICS INSTRUMENTS j

INSTRUMENT TYPE NUMBER RANGE j.

liquid scintillator 1

counts per time, integrating smear counter I

counts per time, integrating alpha survey meter 1

0 to 50,000 dpm beta / gamma survey meter 4

0 to 50,000 dpm 1

i gamma survey meter 1

0 to 1,000 renVh gamma survey meter 3

0 to 50 rem /h L

neutron survey meter 1

0 to 20 rem /h i

{

area gamma monitor 1

0 to I rem /h particulate air sampler I

not applicable i

3.2.4 Internal and External Exposure l

Health' Physics conducts weekly radiation and contamination surveys for operations involving radioactive materials and for which the safety review and approval conditions include that surveillance. Removable surface contamination action levels are as follows:

l o

alpha above 200 dpm/100 sq. cm; i

o unknown beta and known beta other than H or "C, above 0.005 mrad /h or 2000 3

dpm/100 sq. cm; and 3

200,000 dpm/100 sq. cm. for H, or 20,000 dpm/100 sq. cm. for "C.

o The action to be taken for contamination on work surfaces in excess of an action level is to initiate decontamination efforts promptly after discovery, unless Health Physics determines j

that an alternative action is more feasible, such as area isolation for a period to permit decay of a short-lived nuclide. Any action taken is documented with the results of follow-up surveys.

i For skin contamination, any level of detected radiological contamination is cause for prompt decontamination attempts. A Supervisory Health Physicist must approve the. departure i

from the controlled area of any individual who is found to be contaminated above background levels.

4 I

i i

02/97 l-3-2 4

i Health Physics determines the need for external and internal personal radiation monitoring, reviewing external dose assignments upon receipt of processor results and internal dose assignments monthly, or as results of monitoring or bioassay become available. Health Physics assigns TLD's, pocket dosimeters, or other devices or other techniques for personal dose monitoring as appropriate. Health Physics assures that any device or devices, or techniques, used for these purposes is acceptable according to appropriate standards and regulations.

Almost any nuclide could be proposed for a project. Almost all projects are batch type and not ongoing operations. Operational experience has demonstrated negligible potential for inhaled or ingested intakes of radioactivity in operations. The safety review would include the level of activity involved and the potential for airbome activity suspension or activity release from containment. If the potential indicates that an internal exposure of a worker could result in doses greater than 10% of regulatory limits, then bioassays would be required. Bioassay frequencies and duration would be specified, using guidance such as found in NCRP Report No.

87. If there is a potential for levels of airborne activity exceeding 10% of those in Appendix B to Part 20, Table 1, Column 3, then air sampling would be required. Sampling types and frequencies would be chosen as appropriate to the process duration, the probability of release of airborne contaminants at any process step, and other factors, using guidance such as found in NCRP Report No. 87 and using professional judgment and experience.

3.2.5 Local Emergency Actions Emergency evacuation is required for unexpected or inadvertent situations that could cause radiation doses in excess of the applicable whole-body radiation exposure limits and that cannot be controlled with prompt and appropriate actions. Health Physics review is required for such situations to determine work times for necessary actions.

3.2.6 Scaled Source Control A. 1. Each sealed source containing more than 100 microcuries of beta and/or gamma emitting material or more than 10 microcuries of alpha emitting material, other than Hydrogen-3, with a halflife greater than 30 days and in any form other than gas, shall be tested for leakage and/or the contamination at intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that a test has been made within 6 months prior to the transfer, a sealed source received from another person shall not be put into use until tested.

2. The peri,dic leak test required by this section does not apply to sealed sources that are i

stored and not being used. Prior to any use or transfer to another person, the source shall be leak tested within 6 months prior to the date of use or transfer.

B.

The test shall be capable of detecting the presence of 0.005 microcuries of radioactive material on the test sample. The sample shall be taken from the sealed source oc appropriate accessible surfaces of the container or from the device where the sealed source is mounted or stored in which one might expect contamination to accumulate. Records ofleak test results shall be kept in units of microcuries and maintained for inspection by the USNRC.

If the test reveals the following:

1.

The presence of 0.005 microcuries or more of removable contamination from the sealed sources other than described below, or 02/97 f.3 3

2.

The presence of 0.05 microcuries or more of removable contamination from the teletherapy sealed source, or 3.

An indication that the irradiator sealed source which is stored in the water pool for shielding purposes is leaking, then NIST shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed ofin accordance with USNRC regulations.

l Within 5 days after determining that any source has leaked, NIsT shall file a report with i

the Division of Industrial and Medical Nuclear Safety, USNRC, Washington, D. C. 20555, l

describing the source, test results, extent of contamination, apparent or suspected cause of source I

failure, and corrective action taken. A' copy of the report shall be sent to the Administrator of the NRC Regional Office for Region I.

i l

02/97 I.3-4

i CHAPTER 4 -

ENVIRONMENTAL PROTECTION i

i 4.1 Effluent Control Systems 4

For operations involving uncontained activities greater than 10 ALI, Health Physics i

monitors airborne radiological effluents to provide an assessment of radioactivity concentrations at the discharge point at least once in each quarter for continuing operations or at least once for.

short-term operations, to establish that releases are less than 10% of the concentration given in 2

10CFR20, Appendix B, Table 2, Col.1. averaged over a calendar quarter. Should the concentration exceed that value, continuous monitoring will be initiated. Where effluent l

monitoring is required, air sampling arrangements shall be designed to assure that air samples i

taken will be representative of the actual release for the sampling period. Measurement of air I

sampling media will be with a lower limit of detection of no greater than 10% of the j

concentration given in 10CFR20, Appendix B, Table 2, Col.1, for the major radionuclide(s) involved in the process being monitored.

No liquid releases from NIST are permitted under this license that could exceed regulatory limits. Based on safety reviews, liquid wastes might be either drained to tanks for discharge to.

the sanitary sewer with appropriate dilution or collected in specially marked containers for solidification and disposal as solid waste. Building 235 waste holdup tanks are equipped with remote readout level monitors, and Health Physics inspects the level monitors for the Building 245 holdup tanks quarterly, documenting the inspection. Health Physics assays the contents of f

the tanks for radioactivity concentrations prior to discharge.

l Health Physics collects solid radioactive wastes from the laboratories and prepares them for transfer to disposal agents normally acting by contracted service or for decay-in-storage

~

treatment. A solid waste compactor may be used for reducing the volume of solid waste in a package. Disposal of decay-in-storage waste, as provided in 10CFR20.2001(a)(2), is in accord ~

with conditions given in 10CFR35.92.

}

4,2 Environmental Monitoring Health Physics maintains a listing of the locations of environmental monitoring stations and the specific monitoring techniques used at those sites, e.g., the numbers and locations of j

thermoluminescent dosimeters on the fence and on the buildings on site or the on-site grass plots i

used for vegetation sampling.

Quarterly changes of thermoluminescent dosimeters or equivalent integrating monitors j

about the site and off-site provide measurements of ambient radiation levels. These are maintained under the Health Physics quality assurance program. Quarterly sampling of vegetation or soil, seasonally dependent, and of surface water, and assays under the Health Physics quality

[

assurance program demonstrate radioactive material control. Sampling locations include on-site and off-site stations so that potential NIST contributions to the environment can be evaluated.

4.3 Nonradiological Hazards

{'

Nonradiological hazards are the responsibility of the Safety Office of the Occupational Health and Safety Division. Regulatory oversight by agencies such as OSHA, EPA, and the state Department of the Environment assure that toxic material control is adequate for regulatory 1

compliance. Each laboratory or work area is equipped with an appropriate fire extinguisher if I

necessary and with either combination rate-of-rise / fixed temperature or smoke detectors that i

provide signals to 'a central fire response facility.

02/97 I-41 4

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._ _ _ ~. _ __.

CHAPTER 5 -

SPECIAL PROCESS COMMITMENTS 5.1 Special Nuclear Material Accounting and Control Accounting and control of special nuclear materials to prevent and detect unauthorized diversions of material quantities are conducted according to provisions of 10CFR70. Health Physics maintains the SNM accountability office for NIST and administers the accountability program.

l 5.2 Alpha-Emitting Nuclide Chemistry Operations j

The activities of alpha-emitting nuclides in dispersable form in any one laboratory operation are controlled as described in Table I.5-1. Health Physics may approve limits above those shown in the table or may approve variances to the conditions shown for lower toxicity l

nuclides or if the proposing user can demonstrate adequate provision for safety, such as training, equipment, or other considerations. Radiochemistry hoods are provided with local indicators for l

air flow and operators are instructed to observe them. Should an air flow system for any hood l

in use fail, the operator is to suspend operations in that hood and notify Health' Physics immediately. Health Physics reviews the situation and determines the need for and the type of further action. Should gloves break or other operat!ve defect appear for a glove box, any processes being conducted in the box are to be suspended and Health Physics notified immediately so that corrective action may be planned.

.l TABLE I.5-1 ALPHA CHEMISTRY LABORATORY LIMITS AND RULES FOR HIGH-TOXICITY

• MATERIALS AND URANIUM TYPE OF OPERATION LIMIT (lesser of)

CONDITIONS simple storage 100 mci or 10 g in closed containers simple wet chemistry, e.g., aliquot extraction 10 mci or 1 g within hoods normal chemistry, e.g., analysis i mci or 0.1 g in HEPA filtered hoods complex wet chemistry, e.g., complex apparatus 0.1 mci or 0.01 g in HEPA filtered hoods simple dry operations 0.1 mci or 0.01 g in HEPA filtered hoods dry and dusty operations. e.g., grinding 0.01 mci or 0.001 g in glove boxes

• see, e.g., IAEA Safety Series No. 38, Radiation Protection Procedures NOTE: Plutonium in solution will be limited to less than 10 millicuries at any one location or in any one process.

l 02/97 15-1

-, =

CHAPTER 6 -

NUCLEAR CRITICALITY SAFETY No accumulations of special nuclear materials exceeding 300 grams are permitted in any one area or room, with the exception of plutonium sealed sources. Thus, no criticality program is necessary.

l l

l CHAPTER 7 -

DECOMMISSIONING PLAN As a Federal agency, the National Institute of Standards and Technology will generate and implement a decommissioning plan at the time that operations are to be terminated and in l

accordance with Federal rules and regulations in effect at that time.

l l

l I

(

l 02/97 1-6-7 1

l-l CHAPTER 8 -

ACCIDENT EVALUATION This accident evaluation presents a worst case scenario that considers the majority of the license possession limits being engulfed in a fire. It assumes that 100% of the possession limits for license line items A, B, C, D, F, G, H, I, and R are involved in the fire, and that -

10% of the total for license line items P and Q are involved in the fire. Line items P and Q allow a mixture of byproduct material nuclides up to a total of 4,000 curies and 1,100 curies, respectively.. Historically, NIST has maintained less than a nominal 10% of the limits for nuclides from line items P and Q. This byproduct material is utilized in four separate buildings and approximately 33 separate laboratories at NIST. The quantities approximate the distributed nature of byproduct material in a university type setting. The 10% level is considered to be realistic because a fire sensor is located in each laboratory and an on-site fire l

department b available to respond immediately to an emergency. The other license items are for usage programs that typically center around a single lah-satory or storage area and i

therefore 100% of the possession limit is assumed to be in the fire. License items E, J, K, L, l

M, N, and Q are sealed sources which would not cause a release even in case of a fire.

The dose conversion factors are derived from the Annual Limits for Intake, ALI, due to inhalation, contained in Table 1, Col. 2 of 10CFR20. Table I.8-1 shows the conditions for l

the evaluation calculations. The factors for iodine thyroid doses have been corrected to apply I

to a child. Table I 8-2 contains the results of the evaluation.

The projected doses and uranium intakes are less than the criteria contained in 10CFR30.32 and'10CFR70.22. There is no need to establish capability for off-site accident response for the SNM-362 license.

TABLE I.8-1 PRESUMED ACCIDENT CONDITIONS Distance to off-site location 550 meters Release Duration 30 minutes Wind Speed 1 meter per second Wind Direction constant, toward nearest neighbor Atmospheric Stability Class F X/Q (from Fig.1, NUREG-ll40) 3.7 x 10" s m

Breathing Rate 2.66 x 10" m's' i

0197 l-8-1

TABLE I.8-2 OFFSITE ACCIDENT DOSES / INTAKES FOR LICENSE SNM-362

(*: Scaled Sources have no accident release potential)

NUCLIDE CilEM/PilYS IORM POSSESSION LIMIT EFI ECTIVE TilYROID SOLUBLE URANIUM WilOLE BODY DOSE (rem)

INTAKE (mg)

DOSE (rem)

A. Uranium enr. to less than 20 wt% in U-235 Any 30 grams of U-235 3E-06 NA IE-02 B Uranium enr. to or greater than 20 wt% in U-235 Any 230 grams of U-235 2E-05 NA IE-01 C. Uranium-233 Any 6 grams 9E-04 NA 6E4%

D_ Plutonium except Pu-238 Any 40 grams 2E-01 NA NA E. Plutonium Scaled sources

• 800 grams F. Plutonium enr. in Pu-238 Any 0.1 grams 1E-01 NA NA G. Natural uranium Any insoluble form 150 kilograms 2E-03 NA OE+00 Natural Uranium Any soluble form 9 kilograms IE-04 NA 9E-01

11. Thorium Any 69 kilograms 2E-03 NA NA

1. Uranium dept. in U-235 Any insoluble form 42 kilograms 2E41 NA OE+00 Uranium dept. in U-235 Any soluble form 4 kilograms 2E-05 NA 4E-01 J. Co-60 Scaled sources

• 58,000 curies K. Cs-137 Scaled sources

• 9,000 curies L Po-210 Scaled sources

• 20 cuties M. Am-241 Scaled sources

• 40 curies N. Cf-252 Scaled sou ces*

10 curies O. Sr 90 Scaled sources

• 3 curies P. Byproduct material Any 4,000 curies total 3E-02 2E41 NA

1. any nuclide of half-life less than 30 days 4 curies

2. any nuclide of half-life nwre than 30 days I curie Q. Any byproduct material with Akunic No. 3 to 83 Neutron irradiated materials 1,100 curies total IE-01 3E-01 NA R. Inaliated fucI Four pellets 0.25 grams of U-235 9E-09 NA DE+00 t

Summed Totals 4.5E-01 5.lE-01 1.5E+00 02/97 I-8-2

l t

I PART II - SAFETY DEMONSTRATION CHAPTER 9 -OVERVIEW OF OPERATION 9.1 Corporate Information The National Institute of Standards and Technology is an agency of the United States Government, in the Department of Commerce. It is located in Gaithersburg, Montgomery County, Maryland, approximately 20 air miles northwest from the zero milestone in Washington, DC. The most prominent natural features are the Potomac River flowing to the west and south of the facility and Sugarloaf Mountain to the northwest. Attachment I has a locator map of the Gaithersburg site.

- 9.2 Mission Title 15 of the Code of Federal Regulations contains information on the functions and duties of NIST. With respect to radiological work, NIST provides services and sources to customers and conducts miscellaneous research and development activities.

9.3 Site Description NIST is located on a fenced site of about 575 acres. It is bounded by highways I-270, MD124, and Muddy Branch Road, by residential and commercial properties, and by parklands.

About 2,500 persons occupy the site on a normal workday. Table II.9-1 shows local populations from final census data for 1990. The values shown here are calculated by adding 2/3 of the population density for Montgomery Village,4,917.5 persons per square mile, and 1/3 of the population density for Montgomery County,1,530.6 persons' per square mile, fc,r each of the areas represented by circles of shown radii. Meteorology for the NIST site has been compared to that observed at Washington National Airport and, over many years, no significant differences j

have been found. There have been no unusual or particularly severe weather conditions that would affect radiological operations or safety. Hydrologic studies show topographic control over ground water movement. That movement is slow, about 0.3 foot per day, and dicected to the south and west. Attachment I has a topographic map of the Gaithersburg site. Seismic activity is low level, typical of the Piedmont Belt. NIST is located in an area that has experienced only a micor amount of earthquake activity.

TABLE II.9-1 1990 POPULATION DENSITIES AROUND NIST RADIUS (in miles)

POPULATION 0 to 1 12,000 0 to 3 108,000 0 to 5 300,000 0 to 10 1,200,000 02/97 I 9-1

i

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4 j

9.4 Maps, Buildings, and Site Information Attachment I contains a NIST site plan and a topographical representation, building locations on site, and floor plans for buildings. The site exhibits a gently rolling topography 3

l and contains both open and wooded areas. Buildings include a central complex of the main administration building and several general purpose buildings designed to contain laboratories j

that accommodate customary scientific research and development functions, buildings that house the support functions ranging from grounds management, heating and air conditioning, and the like, to procurement, and special purpose laboratory buildings that are dedicated to specific research and development functions. This last category includes the Reactor and the i

Radiation Physics Buildings, where the majority of the work involving radiation and radioactive materials is conducted.

i 9.5 License History l

Table 11.9-2 shows a chronological ordering oflicensing history at NIST for l

radioactive materials. This history tracks licenses to the most recent renewal. In some cases, e.g., for 08-00566-05, the byproduct material license, a full history would extend to more than -

2 l

thirty years with many amendments and renewals. In 1980 a Materials License Manager was.

named to bear responsibility for licensing other than for the NIST Reactor. In 1985, five major licenses were consolidated into the single SNM-362 license.

TABLE !!.9-2 NisT MATERIALS LICENsINo

SUMMARY

YEAR LICENSE ACTION (identifier) l 1990-1994 sNM-362 amendments 1 - 4 1985 1990 sNM-362 amendments 1 4 l

1985 08 00566-05,08-00566 l0,08-0056612. sMB.

consolidation. incorporation into License No.

405, sNM 362 sNM 362 1983 080056645 Class I irradiator request 1982 all lonizing Radiation safety Committee 08-00566-05 change in limits (byproducts) j all perscnal dosimetry technique 1981 sNM 362 filter process (sNM) sNM-362 change in limits 08-00566-10 renewal (teletherapy) t 1980 -

sMB-405 license manager named (source) 1979 sNM-362 renewal 08 00566-05 change in limits 1978 sMB-405 renewal 4

i 08 00566-12 renewal (irradiator) 1977 08-00566-05 renewal 1

02/97 I-9-2 4

1 1

9.6 Changes in Procedures, Facilities, and Equipment NIST employees and other individuals working on the NIST site are responsible for obtaining authorizations from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiological safety, or for disposition of radiation sources. Division Chiefs are responsible for ensuring that staff members comply with radiological safety rules and that staff members are aware of radiological safety procedures. The Chief, Occupational Health and Safety Division, is charged with managing the radiological safety program and with representing the National Institute of Standards and Technology in all matters relating to materials licensing. The Chief, Health Physics, is charged with administering the radiation safety program at NIST, including maintaining documentation to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee is responsible for reviewing major radiation facility proposals and significant proposals for use of radiation, including modifications to existing facilities, and for assuring the performance quality of operations that provide radiological safety assurance.

9.7 Examples of Operations That Might Be Conducted As an example of the miscellany of types of work done at NIST, consider NCRP Report No. 58, A handbook ofradioactivity measurements procedures, second edition. Of the fifteen consultants listed in the preface to the first edition, ten were from one working group within NIST (then NBS), as well as the chairman of the scientific committee. The preface to the second edition names twenty-four persons who made contributions to that edition. Of those, fifteen were NIST (then NBS) personnel, including Health Physics staff members. The wide variety of operational activities and of radionuclides described in the publication, essentially the product of only one of the groups at NIST, illustrates the extremely broad scope of work done at NIST.

For the specific nuclides listed in Table I.1-1, the following examples of research, development, and other activities will suggest the variety of operations involving radioactive materials at NIST. Uranium at any enrichment, from depleted through 99.9%

U, 233U, any 235 nuclide of plutonium, and thorium, might be used in metallurgical research, for beam transmission studies, in neutron beam research, for check sources, or as beam filters. Sealed sources of 23 Pu are used as thermal sources. PuBe, PuLi, and other sealed Pu-X sources are used in neutron research and are calibrated for customers. Sealed sources of"Co, 27Cs, 2iopo (sometimes as PoBe),2"Am 252Cf, or "Sr might be used in research requiring photon, neutron, or beta radiations, for instrument calibrations, in neutron physics research, medical device (implant seeds, eye irradiation applicators, etc.) calibrations and research, or basic nuclear chemistry and physics research such as half-life studies. Miscellaneous byproduct materials, including materials and containers irradiated in the NIST Reactor and brought out of the Reactor licensed area, might be used as check sources, in laboratory intercomparison

~

tests and studies, for light sources, for basic radiochemistry and nuclear physics research, for sample preparations for authorized customers, or in research for medical or other specific laboratory types.

l 02/97 l-94

e CHAPTER 10 -

FACILITY DESCRIPTION t

i 10,1 Layout i

. Attachment I shows building locations on the NIST site. The attachment also shows floor plans for those buildings, Buildings 235 and 245 are dedicated to uses of radioactivities l

and all of these two buildings will retain their authorizations for work with radioactivities until the buildings themselves are decommissioned. Of the remaining buildings, only a few I

laboratories in Bldg. 222 are currently authorized for unsealed radionuclide operations using i

activities greater than 10CFR20, Appendix C, quantities. The laboratories and the number of l-units of App. C activity quantities in each are: Room B207 with 10 units, Room B363 and Room A368 that share 88 units, and Room A242 with 13 units. These represent the facilities t

that will require substantial investments of time and attention when the authorization for radioactive materials work is terminated, i.e., that will require extensive decommissioning q

planning and implementation. Other facilities within NIST have authorizations for storage of radioactive materials with no open source work permitted, for sealed radioactive materials, 4

usually reference or calibration sources, tritium light sources, or other non-radiochemistry type sources. The decommissioning requirements on these other facilities will be at a lower i

intensity than for the higher-level, unsealed work type radionuclide laboratories.

10.2 Utilities, Including Emergency Power j

Electrical power is provided to NIST by the Potomac Electric Power Company, using a site-resident substation. Each building is in turn supplied from that substation. No processes l

are permitted that require permanent application of utility protection services. Fail-safe

]

mechanisms are built into equipment such as automatic shutter closing for teletherapy-type devices so that loss of power cannot cause unsafe radiological conditions, i

10.3 Heating, Ventilation, and Air Conditioning Steam and chilled water are generated in Building 302 and distributed to the various buildings on site with underground conduits. These are combined in varying portions for heating and air conditioning. Filtered air is supplied for each building and laboratory spaces are maintained at negative pressure relative to corridors and office spaces. Exhausts from radioactivity hoods are equipped with velocity-controlled automatic dampers to insure positive air flows through the hoods. High-efficiency particulate (HEPA) filter systems are maintained so that no leakage paths can exist, so that magnahelic or equivalent pressure-drop gauges show no more than four times the clean or fresh reading, and so that hood face velocities are maintained at 100 linear feet per minute over the open area of the hood face. Any degradation in these limits causes review, by the Heating, Ventilation, and Air Conditioning Shop of the Plant Division for pressure-drop to determine remedial action. In some instances, too great an air flow can also be detrimental and must be corrected.

Health Physics performs a quarterly air flow test of hoods equipped with HEPA filters.

The open area of the hood work face is divided into a nine-cell grid and an air-flow measurement is made in the center of each cell. Should a cell be deliberately blocked by, for example, shielding material within the hood, the air flow through that cell is not measured.

Should any cell measurement fall below 75 Ifm, work in the hood is halted until the air flow 02S7 1101

1 reduction is corrected.

10.4 Waste Handling 10.4.1 Liquid Wastes All liquids from the B-and C-wing radiochemistry labs in Building 235 drain to a tank of approximately 19,000 liters that is located underground on the east side ~of the building. As the tank fills, Health Physics assays the contents and dumps the liquid to the j

sanitary sewer if the activity permits. All releases are less than applicable limits. Since 1

considerable liquid from the building drains through the tank, ten to thirty tank dumps each year are necessary, particularly in the summer, when the air conditioning condensate runoffis collected.

Radioactivity laboratories in Building 245 provide drains that lead to two tanks of.

approximately 19,000 liters each located in the subbasement in Room B045. Health Physics assays the contents and, if the activity concentration permits, dumps the contents to the sanitary sewer. All releases are less than applicable limits. As these tanks fill very slowly, an occasional dump, perhaps once in a year, is necessary.

' For other laboratories, and for any process in which liquid wastes with significant activity concentrations are expected, polyethylene or equivalent collectors are placed at the work station and instructions given to the operators to collect all effluent liquids in these bottles. When full or when the process is complete, the bottles and appropriate information on the contents are delivered to Health Physics for transfer to the waste handling facility in Building 235. Liquids are either solidified for disposal as solid radioactive waste or disposed of via the liquid waste tanks. To insure that the systems operate as described, various mechanisms are employed. A liquid level monitor with remote alarm warns that the tank at Building 235 is near full. Typically, monthly readings are taken of the sight glasses on the

~ tanks in Building 245 to assure that these are kept at manageable levels. Health Physics trains -

workers who generate liquid radioactive waste to assure that liquid waste collection containers are properly used.

10.4.2 Solid Wastes Each work station that can generate solid radioactive waste is provided with i

marked containers for low-level wastes. Health Physics trains workers who generate solid waste to assure collection of all solid waste materials that could contain activity. On request from the worker, Health Physics collects the wastes in polyethylene bags or equivalent containers and transports long-lived wastes to the radioactive waste facility in Building 235.

The materials normally deposited in the containers are residues from chemical operations, paper towels or wipers, glassware, and miscellaneous solid substances. Radioactive sources and other relatively high activity materials are treated individually, separately from the low-level wastes. The wastes are disposed of either by using a waste disposal contractor or by shipping directly to a licensed burial site. If a contractor is used, the waste is packaged according to their instructions. If the shipment is direct to the burial site then all applicable regulations and restrictions on packaging are followed. If possible, the wastes are compacted with a commercial trash compactor. Protective features incorporated into the compactor facility include a filtered ventilation system and regular air samples to identify potential releases of airborne radioactivity. Wastes that cannot be accommodated in drums are 02/97 1 10-2 l

e i-I packaged appropriately in boxes or other containers as specified by the contractor, Wastes with short half-lives are treated by decay-in-storage. Disposal of decay-in-storage waste, as provided in 10CFR20.200l(a)(2), is in accord with conditions given in 10CFR35.92, 10.5 Chemical Systems L

Nonradioactive chemical operations are the responsibility of the Environmental l

Compliance Group of the Occupational Health and Safety Division. Any facility or operation

]

involving toxic materials is reviewed to insure compliance with appropriate regulations.

L' 10.6 Fire Protection The buildings and facilities at NIST were constructed in accordance with applicable regulations for Federal facilities at the time of construction and are maintained under the fire protection auspices of Fire Protection Services of the Facilities Services Division. The

[

coverage by this trained fire and emergency response brigade includes around-the-clock fire and emergency medical response capabilities.

[

The Fire Protection Services Chief serves as the fire safety review person for plans for modification or construction of facilities. Complete facility plans, including locations of hydrants, sprinkler system layouts, access pathways, and other layout information related to fire fighting are maintained in the offices and workspaces of the Fire Protection Services work areas. Training of fire fighters is according to the National Fire Protection Association (NFPA) voluntary codes for such training; fire fighters are trained to the level equivalent to

[

Fire Fighter III. Materials and equipment available to the group include appropriate vehicular fire fighting units, water supply systems including hydrants and automatic sprinkler systems, portable fire extinguishers, protective clothing, and tools used in fighting fires. Maintenance and deployment of fire fighting equipment is in accord with standards such as the NFPA codes. Extensive pre-fire plans have been developed, incorporating information on locations of radioactive materials, flammable substances, and hazardous materials storage areas, and include fire fighting protocols for those areas. The plans include locations of water supplies, automatic fire fighting response mechanisms that might be employed, and other appropriate information. Fire Protection Services maintains extensive documentation on deployment and 1

maintenance of equipment, pre-fire planning, facility characteristics, training, results of actual occurrences, etc. Portable fire extinguishers are deployed according to NFPA 10; these are commonly dry chemical loaded. In addition, portable extinguishers are commonly located in i-each laboratory area with the type ofloading dependent on the primary fire hazard of that laboratory, Stairwells have standpipe connections and hydrants are located at various positions on the exterior of buildings. The loading dock in Bldg. 245 has a sprinkler system.

Laboratories are monitored with fixed temperature, rate-of-rise, or smoke detectors, the type dependent on the hazard expected from that area. Manual fire alarm boxes are located according to the NFPA code. These notify the central console when activated; local 3

evacuation wamings are manually activated from that console or, in the case of Bldg. 245, from an annunciator box in the lobby. The system is fail-safe, i.e., any failure causes a waming annunciation.

i 02/97 1104

_m,m

~

l i.

4

. CHAPTER 11 -

ORGANIZATION AND PERSONNEL

\\

l1.1 Unit Functions The functions of the various groups and individuals specifically involved in radiological safety at NIST are outlined below. Those functions designed especially to

- accommodate the requirements of 10CFR21 are marked with "a".

I1.1.1 Ionizing Radiation Safety Committee The Ionizing Radiation Safety Committee performs the following functions:

l a.

Review the past year's accomplishments, the current program status, and the i

long-range plans and needs for radiation safety; b.

Audit the performance quality of operations that provide radiation safety assurance; c.

Review major radiation facility proposals and significant proposals for use of radiation, including modifications to existing facilities (for matters related to the Reactor license, this function is carried out by the Safety Review and Audit Committee);

d.

Advise the Chief of the Occupational Health and Safety Division on matters pertaining to radiation safety; e.

Report to the Deputy Director on the status of radiation safety annually; and f.

Review incidents and compliance citations and recommend corrective actions where needed (for matters related to the Reactor license, this function is normally carried out by the Safety Evaluation Committee).

l 11.1.2 Chief, Occupational Health and Safety Division The Chief, Occupational Health and Safety Division, is responsible for the i

following:

{

a.

Establishing an effective radiation safety program; b.

Handling matters which involve the position of the Gaithersburg laboratories as i

a licensee of the NRC, except for matters dealing with the NIST Reactor license; and a

c.

Reporting to the NRC on defects and items of noncompliance with NRC j

regulations, except for matters dealing with the NIST Reactor.

11.1.3 Chief, Health Physics The Chief, Health Physics, is responsible for the following:

a.

Providing services to ensure compliance with regulatory requirements j.

pertaining to radiation safety; 2

a b.

Evaluating reports of substantial radiation safety hazards from division chiefs and reporting evaluation results that imply the existence of defects or noncompliance with NRC regulations promptly upon a report from a division chief to the Chief, OHSD; c.

Establishing and updating guidance, procedures, instructions, and other rules required to promote radiation safety and establishing adequate safeguards to see that these are observed; j

d.

Providing training and retraining in radiation safety for employees; and Maintaining documentation required to demonstrate the adequacy of the L

e.

p i

02/97 1111 4

v

radiation safety program.

11.1.4 Division Chiefs Each Division Chief managing radiation work is responsible for the following:

Ensuring that staff members comply with radiation safety mies in implementing a.

the NIST radiation safety policy; b.

Ensuring that staff members are aware of radiation safety procedures and receive training as required; e

c.

Reporting potential items of substantial safety hazard as defined in p

10CFR21.3(k) to the Chief, Health Physics, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence or i

discovery, except for items relating to the Reactor license which are to be handled according to that license; and 3

d.

Reporting significant radiation safety matters to his or her~ supervisor.

11.1.5 Staff NIST employees and other individuals working on the NIST site are responsible for the following:

a.'

Observing approved radiation safety rules; 4

b.

Consulting with Health Physics early in the planning of operations that might involve radiation sources; c.

Obtaining authorization from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiation safety, or for disposition of radiation sources; d.

Notifying Health Physics of any occupational radiation exposure from work at facilities other thr.n NIST; e.

Immediately informing Health Physics upon discovery of loss or theft oGany radioactive materials; f.

Immediately informing their supervisors and Health Physics of accidents involving radiation or radiation sources; and 2

a g.

Informing their supervisors of defects that could create a substantial safety j

hazard.

11.2 Organization The Ionizing Radiation Safety Committee members' and altemates' names and pertinent resumes are listed below. The size and composition of the Committee are subject to change at the discretion of the Deputy Director.

(Chair) Dr. Chris E. Kuyatt, Executive Director, Visiting Committee, PhD, Physics, 1960, Nebraska Univ.; experience in electron, photon, and particle physics.

(Vice Chair) Dr. Hany L. Rook, Deputy Director, Materials Science and Engineering Laboratory, PhD, Nuclear Analytical Chemistry,1969, Texas A & M Univ.;

experience in nuclear chemistry.

4 Dr. Bert M. Coursey, Chief, Ionizing Radiation Division, PhD,1970, Radiochemistry, Univ. Georgia, applied radiation science.

j-Dr. Heather Chen-Mayer, Physicist, Analytical Chemistry Division, PhD (Physics) 1989, CUNY; neutron physics.

02/97 1-11-2 a

)

j Mr. Keith H. Eggert, Group Leader, Environmental Compliance Group, Occupational j

Health and Safety Division, B. S., Chemistry,1976, The American Univ.; B. S.

Chemical Engineering,1978, Univ. of MD; health physicist / radiological chemist / safety engineer, CSP, CHMM.

Mr. Thomas G. Hobbs, Chief, Health Physics, Occupational Health and Safety Division, M. S., Physics,1975, The American Univ.; applied health physics experience as Health Physicist / Supervisory Health Physicist / Chief of Health Physics, Certified l

Health Physicist.

Dr. Richard M. Lindstrom, Research Chemist, Inorganic Analytical Research Division, I

PhD (Chemistry) 1970, University of California, San Diego; nuclear analytical chemistry.

Mr. J. Franklin Mayo-Wells, Staff Assistant for Technical Coordination / Operations, 4

Electronics and Electrical Engineering Laboratory, B. S. Physics,1957, The Johns Hopkins Univ.; division and center safety representative, low-level monitoring training, l

non-ionizing radiations experience.

}

Dr. Santos Mayo, Physicist, Semiconductor Electronics Division, PhD,1955, Nat'l Univ, of LaPlata; accelerator and sealed source research, non-ionizing radiations.

Mr. Lyman E. Pevey, Chief, Occupational Health and Safety Division, B. S.

Engineering,1959, Lowell Technological Institute; MBA,1983, Frostburg State University; diversified safety engineering / safety and health management experience, Certified Safety Professional and Certified Hazard Control Manager.

Dr. Henry J. Prask, Research Physicist, Reactor Radiation Division, PhD, Nuclear Physics,1963, Univ. of Notre Dame; nuclear experience at Notre Dame and the NIST Reactor.

Dr. J. M. Rowe, Chief, Reactor Radiation Division, PhD, Physics,1966, McMaster Univ., Canada; nuclear experience at Chalk River, Argonne, and NIST.

Dr. Francis J. Schima, Physicist, Ionizing Radiation Division, PhD, Physics,1964, Univ. of Notre Dame; nuclear physics and radioactivity metrology experience.

Dr. David S. Simons, Group Leader, Analytical Microscopy Group, Surface and Microanalysis Science Division, PhD,1973, physics, Univ. Illinois, analytical chemistry and chemical microanalysis, including isotopic analysis.

Mr. Lester A. Slaback, Jr., Supervisory Health Physicist, Occupational Health and Safety Division, B. A., Physics and Mathematics,1962, San Jose State Coll.; applied health physics experience as Health Physicist / Radiological Safety Department Head / Supervisory Health Physicist, Certified Health Physicist.

Dr. Christopher G. Soares, Physicist, Ionizing Radiation Division, PhD, Physics,1976, Univ. of Florida; photon / electron spectroscopy, thermoluminescence dosimetry, calibration source development, measurement assurance, and electron source calibration experience.

02/97 1114

CHAPTER 12 -

RADIATION PROTECTION PROCEDURES AND EQUIPMENT 12.1 Procedures In a safety review, Health Physics makes an initial assessment of radiological protection needs for a task based on an appropriately completed Form NIST-364, Proposal to Acquire Radiation Source, or equivalent document. Usually, Health Physics compares the proposed task's characteristics to criteria such as those in IAEA Safety Series 38, Radiation Protection Procedures, for applying classifications of workplaces, radiotoxicities, and job types. Health Physics assigns an initial frequency and type of surveillance commensurate with anticipated hazards for the task. Personal monitoring, access controls, additional training, protective clothing, and facility design characteristics are chosen to meet required rules.

Changes or modifications to facilities, users, or source characterisucs require that Form NIST-365, Proposed Change in Utilization of Radiation Source, or an equivalent document be submitted for safety review. Should any review disclose that a whole body dose equivalent greater than 1.25 rem could credibly be generated, the proposal is submitted to the Ionizing Radiation Safety Committee for further review. Ionizing Radiation Safety Committee review may be requested for any proposal by the proposer, by Health Physics, or by the Committee.

Health Physics establishes the methods, frequencies, and plans for surveillance based on the review. Observation of operational techniques and performance results such as personnel dosimetry data yield information for ALARA compliance monitoring. Should any condition threaten to expose uncontrolled areas to excessive radiation levels, measures are implemented to restrict access to the areas and to control worker occupancy times. Scheduled, on demand, or intermittent surveys of external radiation levels, contamination levels, airborne activity concentration levels, or other measurement techniques can identify any need to impose more restrictive controls on access or occupancy. Health Physics designs plans and documents results for radiation field quality and level monitoring, as necessary.

Safety approval follows the safety review and permits the proposal to be implemented.

12.2 Posting and Labeling Table II.12-1 shows control mechanisms and action levels under which radioactivity operations are permitted. The contamination limits shown represent a departure from customary practice in that specific nuclide limits are provided for beta-emitting nuclides when the identity of the nuclide is known. As an ALARA precaution, Health Physics requests decontamination of areas in which any detectable contamination above normal background levels are found. Health Physics review may result in a determination that actions other than described in this table should be implemented. Such alternate actions are documented by Health Physics.

12.3 Personnel Monitoring Health Physics maintains a primary personnel dosimetry program that employs thermoluminescent dosimeters (TLD), or other devices such as direct-reading pocket dosimeters. Health Physics assures that any device used in the primary personnel dosimetry program meets quality assurance requirements equivalent to the dosimetry national voluntary laboratory accreditation program (NVLAP), either by performing suitable tests and checks on 02/97 1121

,e the devices or by requiring suppliers and processors to certify to quality assurance acceptability. Any worker who could be exposed to 25% or more of the regulated radiation limits is registered in the primary program upon approval of the applicable work proposal.

Such a registration causes the review of the applicant's work environment to assess potential for the worker to be listed as a " radiation worker". Usually, a radiation worker is assigned 1

one device, or for special circumstances, such as those with mixed-field radiations for which one device may not adequately measure the dose, more than one device. Those radiation workers who may be exposed to different work environments for which the radiation doses are to be separated, such as work with californium neutron sources and with reactor-generated radiations, may be issued one device or set of devices for one environment and another device or set for the other. In some instances, Health Physics may determine that a more immediate indication of exposure is necessary and issue personnel devices, such as direct-reading pocket dosimeters, that are not maintained according to a full NVLAP QA program but are checked to demonstrate a response to radiation. Primary personnel dosimeters are evaluated at least quarterly and the records reviewed for radiological safety control and for ALARA purposes.

Primary personnel dosimeters may be film, supplied by the Lexington Signal Depot, or TLD, supplied by either the Lexington Signal Depot or by the Naval Medical Command.

Alternative suppliers may be considered, if the appropriate quality assurance requirements are met.

Some workers, for whom registration as radiation workers is determined not to be l

necessary, but who could enter controlled areas, may be issued supplementary personnel dosimetry, such as film, TLD, or pocket dosimeters, at Health Physics discretion. Such supplementary dosimetry would be subject to internal supplementary quality assurance but need not be submitted to a NVLAP QA type program. Results from these devices would help to establish and support the provisions for personnel selections for the primary dosimetry program and would also help in the evaluation of radiation work for ALARA reviews.

12.4 Surveys Health Physics performs weekly routine surveys of a laboratory in which unsealed RAM is utilized when the initial proposal or subsequent evaluation of the work environment demonstrates that levels could exceed the levels at which posting is required, as shown in Table IL12-1. As specified by Health Physics, the surveys could include smear tests of surfaces, radiation level tests, radiation quality tests, air activity contamination tests, or combinations of these, and other radiation safety assurance procedures. For special situations, such as maintenance, similar surveys, time and motion studies, or practice sessions on mock-up assemblies are initiated to assure that operations are conducted with minimal exposures.

12.5 Reports and Records The Chief, Occupational Health and Safety Division, documents management and authority notifications resulting from reports from Health Physics on off-normal investigations. Health Physics maintains documentation on routine and special radiological surveys, personnel monitoring, licensing interactions with NRC, instrument calibrations, ALARA reviews and findings, employee training and familiarization, environmental monitoring, and source control. The Chairperson of the Ionizing Radiation Safety Committee 02/97 l-12 2

i 1

j maintains records of meetings of the Committee, Committee audits, and special reviews and 1

investigations by the Committee. Normal retention time for these records and documents is d

two years unless otherwise specified by regulations, l

j 12.6 Instruments j

Health Physics semiannually calibrates or response-checks each instrument or marks i

the calibration / check record with appropriate information, such as "not located" or i

" inoperative (reason)". Radiation calibrations for dose measuring portable survey meters are i

performed routinely with Cs-137 for photons or with Cf-252 for neutrons. Response checks are performed with Am-241 for alphas or Sr-90 for betas. Other sources, such as x-rays, Co-60, Pu-Be, U-nat, Pm-147, or Po-210 may be'used. Any radiation source used for calibrating

)

instruments is calibrated, itself, using techniques providing traceability to national standards.

i Radiation source calibrations are performed at points in the lower and the upper 25% of the normally used span. Intrascale calibrations are performed on at least two points on each normally used scale with electronic devices simulating radiation sources or with radiation sources. Electronic calibrations are done whenever possible to provide maximum accuracy and in the interest of minimizing radiation exposures to calibration personnel. Each source j

calibration is to within 20% of the true value, or *35% if correcting information such as charts or graphs are supplied with the instrument. Electronic calibration is to within *10% of j

the true value, or to within 20% of the true value if correcting information such as charts or j

graphs are supplied with the instruments. If the calibration criteria cannot be met, the -

j instrument failing to meet the calibration criteria is removed from service for radiation control j

purposes. Health Physics insures that beta and alpha portable survey instruments respond appropriately to radioactive materials. Those instruments are checked with a source on one l

range and the full response of the various ranges and the linearity are tested as described

~

above.

l Health Physics selects instruments for detecting or measuring surface contamination, l

radiation levels, particulate and gaseous airbome contamination, radiation levels, particulate

'j and gaseous airborne radioactivity concentrations, radiation qualities, etc., based on the requirements for assuring radiological safety as specified in action level commitments given in this manual and in the regulations as given in 10CFR20. Normally, a complement of twice the numbers of instruments of each type shown in Table I.3-1 is available and usable j

according to'the Health Physics instrument quality assurance program. This set of instruments is fully capable of providing instrument coverage for normal and any anticipated off-normal radiological safety situations. Instruments are normally stored at locations convenient to work places. Health Physics maintains a master list ofinstruments in the quality assurance program and the last known status of each instrument described.

12.7_ Sealed Source Leak Testing i

Each sealed source containing more than 100 microcuries of beta-or gamma-emitting radioactive material or more than 10 microcuries of alpha-emitting radioactive material, other j

than hydrogen-3, gaseous sources, sources with half-lives of 30 days or less, or sources in storage, will be tested for leakage at least semiannually. Prior to use or transfer, a source that i

has not been leak tested within the past six months will be leak tested. The test will be k

02/97 1123 4

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capable of revealing the presence of 0.005 microcuries of removable contamination on the test sample. The sample will be taken from the source or from an associated surface where

- contamination might be expected to accumulate. Sources will be immediately withdrawn from use and action taken to repair or dispose of the source, and appropriate actions taken to notify the NRC, if the following limits are exceeded for removable contamination:

e any indication of leakage from the irradiator sealed source in the water shielding i

pool.

m 0.05 microcuries or more from a teletherapy-type sealed source.

e 0.005 microcuries or more from any other sealed source.

12.8 Protective Clothing Health Physics maintains a nominal supply of various protective clothing items, including gloves, shoe covers, coveralls, head covers, etc. These are freely available as needed for issue to laboratory workers using dispersable radioactive materials. For situations requiring protective clothing beyond the normal issue quantities, the requesting work unit may be asked to replenish the supply.

l 12.9 Administrative Control Levels Table II.12-2 describes the administrative action levels and the actions taken at those levels to control radiation and radioactive materials in specific situations and under specific conditions.

12.10 Respiratory Protection Health Physics may issue dust stop or similar particulate breathing masks for dusty work environments. At the conclusion of the job, Health Physics retrieves the masks and prepares them for reuse.

O t

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02/97 I.12-4 1

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TABLE II,12-1 CONTROLS AND ACTION LEVELS Radiation Level Action l

greater than the most restrictive of:

restrict occupancy for general public j

a. 500 mrem in a year

• j b,100 mrem in seven days

• l

c. 2 mrem in one hour

• f greater than 5 mrem in I hr**

post as " Radiation Area" i

greater than 100 mrem in I hr**

post as "High Radiation Area" 4

greater than 500 rads in I hr*"

post as "Very High Radiation Area" j

greater than derived air concentration (DAC), or post as " Airborne Radioactivity i

greater than 0.6% of the annual limit on intake Area" l

(ALI) or 12 DAC-hours greater than 10 tiraes an exempt quantity of post room or area with " Radioactive i

radioactive materia!

Material" sign greater than an exempt quantity of radioactive post unattended and otherwise material unmarked container with

" Radioactive Material" label, with information for alpha contaminants, greater than 200 dpm/100 post as " Contamination Control 2

cm.

Area" for unknown beta contaminants or for known beta post as " Contamination Control i

3 contaminants other than "C or H, greater than Area" 2

2,000 dpm/100 cm 4

2 for "C, greater than 20,000 dpm/cm post as " Contamination Control Area" 3

2 l

for H, greater than 200,000 dpm/cm post as " Contamination Control i

Area" NOTE:

Any dose or dose rate marked "*" means substantially whole body exposure or equivalent.

]

Any dose rate marked """ means the result of an individual receiving such an absorbed dose in excess of that rate at 30 centimeters from a radiation source or from any surface that the radiation penetrates.

Any dose rate marked "*"" means the result of an individual receiving such an absorbed dose in excess of that rate at 1 meter from a radiation source or from any surface that the radiation penetrates.

i 02/97 1125 1

4

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TABLE II 12-2 ADMINISTRATIVE ACTION LEVELS AND ACTIONS DOSE EQUIVALENT j

extemal, penetrating, wiiole 0.05 rem notify worker j

body 1

i external, non-penetrating, 0.5 rem review situation, extremity recommend actions 3

j internal 0.5 rem review situation, i

recommend actions i

i SKIN CONTAMINATION fixed or removable any level review situation, cleanse, Health Physics may release when 0.05 mrad /h achieved-AIR AND LIQUID EFFLUENT i

environmental air 25% environmental ALI locate source, suspend operations liquid for release 25% environmental ALI dilute before discharge

}

REMOVABLE SURFACE CONTAMINATION 2

i alpha 20 dpm/100cm review situation, restrict j

access i

2 unknown beta 200 dpm/100cm review situation, restrict access 3

2 l

known beta, other than H or 200 dpm/100cm review situation, restrict "C

access j

i

'!C 2,000 dpm/100cm review situation, restrict 2

i access 2

'H 20,000 dpm/100cm review situation, restrict access i

~

02S 7 1126 a

t

l CHAPTER 13 -

OCCUPATIONAL RADIATION EXPOSURES 13.1 Occupational Exposure Analysis For the period from 1990 through 1995, no monitored employee accumulated in any year a total external dose equivalent greater than 25% of the annual limit from external sources involved in materials licensed operations. Internal dose equivalents from these operations have been negligible. Measurements of radioactivity concentrations in air showed less than minimum detectable levels, i.e., less than at most 10% of ALI, demonstrating that -

. no radiation worker was exposed to significant air activity concentrations resulting from radiation work for 1990 through 1995.

No off-normal occurrence resulting in excessive exposure has been documented.

Bioassays of tritium workers, workers from gaseous iodine processes, and other potential internal dose contributing work have demonstrated extremely good control of dispersable radioactive materials.

13.2 Measures Taken to Implement ALARA Health Physics dosimetry programs have been centralized, with results reviewed by a single responsible individual, who ensures that ALARA concepts are observed in surveying dosimetry data. Environmental monitoring responsibility has also been assigned to a single individual, who reviews data for ALARA purposes. Information about the ALARA concept and the NIST ALARA program has been widely disseminated and workers are requested to inform Health Physics of any pertinent data or information that could affect this program.

13.3 Bioassay Program Workers involved in projects with a potential for significant internal dose, such as operations that could create significant airborne levels of tritium, iodine, or transuranics, may be required, at Health Physics discretion, to participate in a bioassay program. Appropriate techniques for bioassay are developed from available regulatory guidance, contracted assays may be utilized, or other acceptable bioassay mechanisms may be specified.

13.4 Air Sampling Program Table 11.12-1, Controls and Action Levels, and Table II.12-2, Administrative Action Levels and Actions, list the various levels at which certain actions would be implemented. In addition, should any measurement of air radioactivity concentration indicate that an applicable limit would be exceeded, the operation involved or the operation generating the activity concentration would be suspended unless the condition could be remedied by prompt corrective action.

Proposal reviews and analytical observations to determine actions for specific situations involving potential airbome radioactivity releases are approached using conservative techniques, for example, conservative resuspension factors or mass loading values would be assumed for extended operations. Health Physics evaluates a proposal to conduct processes that could release radioactive material to the effluent streams and considers the potential for such release. Material containment, resuspension probability, effluent stream access, filtration available, and other chemical and physical properties involved are part of the criteria used.

02M7 113-1

l i

Should the potential for a release be greater than 10% of the maximum permissible s

l concentrations as given in 10CFR20, Appendix B, Table 2, Col.1, then air sampling of the i

workplace will be initiated.

j 13.5 Surface Contamination Table 11.12-1, Controls and Action levels, and Table II.12 2, Administrative Action i

Levels and Actions, list controlling levels for surface contamination. Measurements for surface contamination checking and protective measures are described in sections 11-12.1, II-i 12.4, and 11-12.7 of this manual.

l Hand and shoe monitoring may be performed with conveniently placed equipment; resuspension factors for transforming surface contamination levels to airborne' activity concentrations are applied as described in section II-13.4 of this manual.

4 13.6 Shipping and Receiving All radioactive materials received at NIST and all radioactive materials shipped from j

NIST are controlled by Health Physics. Usually, incoming packages are brought to the Health Physics receiving area in Building 245, unless alternate provisions are made with the ultimate 1

recipient. In either case, surveys for compliance with transport regulations are made within time limits specified by the regulations. Health Physics and the recipient then survey the package and contents and determine if the shipment is acceptable for incorporation into the project for which the source is intended. Usually, outgoing packages are field in the NIST shipping area in Building 301 until Health Physics or a designated representative checks the package for compliance with transport regulations.

4 Type B shipments are made in accord with the provisions of the quality assurance program as detailed in a separately submitted document.

t If an incoming shipment shows contamination at any level of packaging, the package is held in the Health Physics or other designated storage area until a decision is made, jointly between Health Physics and the recipient, on returning the source, decontaminating the j

source, disposing of the materials, or establishing proper controls for safe use of the source.

1 4

02M7 113-2 s,-

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NIST MATERIALS LICENSE DOCUMENT ATTACHMENT NUMBER 1 Gaithersburg Site Plan and Building Descriptions for National Bureau of Standards (1964 Edition)

- Directions to NIST (1989 Edition)

Topographical Map of NIST Site (1989 Edition)

Building Descriptions for NIST Buildings Not included in 1964 Issue (1990 Edition)

NIST and surrounding area with environmental monitor locations noted (1996) i l

l

..e NIST MATERIALS LICENSE DOCUMENT ATTACHMENT NUMBER 2_

Form NIST-362.. Radiation Work Permit (typical procedural instructions)

Form NIST-364... Proposal to Acquire Radiation Source Form NIST-365... Proposed Change in Utilization of Radiation Source i

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BOUNDARY TLD STATION LOCATIONS 1

A 0FFSITE TLD STATION LOCATIONS THE NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY ENVIRONMENTAL MONITORING LOCATIONS,

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