ML20136F064

Forwards Results of Radiation Surveys & Decontamination of Fast Spectrum Cell at Linac Facility in San Diego,Ca.Wipe Survey Showed That Cell Clean

ML20136F064
Person / Time
Site:	07001359
Issue date:	08/07/1985
From:	Maschka P IRT CORP.
To:	Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20136F055	List: ML20136F050 ML20136F064
References
NUDOCS 8511220019
Download: ML20136F064 (40)

Text

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IRT Corporation 3030 Callan Road. San Diego. Cahfomia 92121 619/450-4343. Telex: 69-5412 August 7,1985 Mr. Robert Thomas U.S. NRC Region V 1450 Maria Lane Suite 210 Walnut Creek, CA 94596

Reference:

U.S. NRC License No. SNM-1405, and phone conversation on August 7,1985.

In response to your request during our phone conversation on Wednesday, August 7,1985, I am enclosing the results of our radiation surveys and decontamination of the Fast Spectrum Cell (FSC) located at our Linac Facility at 10955 John Jay Hopkins Drive, San Diege, CA 92121. This cell was monitored and all radioactive areas were decontaminated until the surveys showed that the radioactivity had been reduced below the levels specified in

" Guidelines for the Release of Facilities for Unrestricted Use".

The instruments used for the direct surveys were an Eberline PAC-ISA with a detector area of 72 sq cm and a Ludlum Model 12 ratemeter equipped with a thin window pancake GM with a detector area of 20 sq cm. The readings have been corrected to 100 sq cm.

Figure i shows the location of the wipes and meter readings for the cell and the fuel storage bins. Table I contains the results of the first meter and wipe survey taken in the cell; and it shows that the cell was clean.

Table 2 contains the results of the first wipe survey taken of the storage bins. Table 3 shows the results of the wipe and meter survey taken of the storage bins af ter several cleanings. These final results show that the storage bins are well within the " Guidelines".

If you need any further information or have any questions, please call me at (619) 450-4343.

Yours truly,

) wfA I

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Paul R. Maschka Radiation Safety Officer 12g g Q 10 9 PRM:krl Enclosures j

l Maihng Address:

l PO. Box 85317. San Diego. Cahfomia 92138 1

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8 10 A^vv Ns, M W l A4 l 11 12 7 I l C3 l 1B3 l l A4 l I c2 l ! a2 I l A2 l 14 13 W l B1 l l Al l 17 6 i FUEL STORAGE BINS 16 3

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FSC CELL FIGURE 1. FSC CELL AND FUEL STORAGE BINS

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I IRT Corporation i

TABLE 1.

Meter and Wipe Survey of the FSC Cell WIPE SLRVEY RESULTS DIRILT SLRVEY RESULTS IOSTICN BETA _dgn ALRM_dpn BETA /G % %

ALHM 1

<30

<5 500 BOD 2

<30

<5 3

<30

<5 4

<30

<5 5

<30

<5 6

<30

<5 a

7

<30

<5 8

<30

<5 9

<30

<5 10

<30

<5 11

< 30

<5 12

<30

<5 13

<30

<5 a

14

<30

<5 15

<30

<5 a

16

<30

<5 17

<30

<5 a

18

<30

<5 19

<30

<5 20

<30

<5 21

<30

<5 22

<30

<5 All numbers were corrected to 100 cm sq Survey Taken April 18, 1985

r orporation TABLE 2.

Fuel Bin Wipe Survey WIPE RESlLTS.dpn RJEL BIN BETA ALRM Al

<30 7

A2

<;30 34 A3

<30 140 A4

<30 35 B1

<30 7

B2

<30 24 B3

<30 104 B4 40 128 C1

<30 5

C2

<30 5

C3

<30 5

C4

<30 21 Survey taken 4/23/85 A direct meter survey was taken of the fuel bins on April 29, 1985, and the readings were 1000 to 2000 dpm Alpha per 100 cm sq.

The fuel bins were decontaminated further.

TABLE 3.

4 Final Meter and Wipe Survey of Fuel Bins i

WIPE RESULTS-dpn DIRECT ALRM FUEL BIN BETA ALRR dpn/100 en sq Al

<30

<5.

200 A2

<30 17 950 A3

<30 27 100 A4

<30 12 270 B1

<30

<5 BG B2

<30

<5 480 B3

<30

<5 200 B4

<30 7

350 C1

<30

<5 BG C2

<30

<5 BG C3

<30

<5 130 C4

<30

<5 200 Wipes taken 4/30/85 Meter survey taken 8/7/85 i

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O CoaTE TS 1.

IDENTIFICATIONsOF APPLICANT I

7 2.

LOCATIONS WHERE SPECIAL NUCLEAR MATERIAL WILL BE USED 3

3.

POSSESSION LIM ITS................................................

5 3.1 Total Lice nse Li mit............................................

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

6 3.3 Limitations and Exemptions.....................................

7 3.3.1 Specific Limitations for Areas Not Equippsd With Criticality Monitors 7

3.3.2 Specific Limitations for the 8221 Arjons Road Facili tie s.........................................

8 1

3.3.3 Exemption from Requirements Set Forth in 10 C F R 7 0.2 4.......................................... 8A 1

3.3.4 Exemption for the Arjons Warehouse Facility............... 8B 4.

PROPO' SED USES 9

4.1 Development of Nondestructive Inspection and Assay Equipment.....

9 i

4.1.1 Nuclear Fuel Quality Control Equipment...................

9 4.1.2 Waste Management Equipment 10 4.1.3 Safeguards Equipment...................................

10 4.1.4 Research and Development Programs 10 5.

R ADIATION SAFETY ORG ANIZ ATION................................

11 5

6.

A D M INISTR ATIV E PR OC E D U R ES.................................... 27 1

6.1 Project Authorization Procedures................................ 27 j

6.1.1 Radiation Work Authorization Request Procedures.......... 27 6.1.2 Radiation Safety Of ficer Review Procedures............... 28 6.1.3 Radiation Safety Committee Review Procedures............ 29 6.2 Project Changes and Renewals 31 6.3 Selection Criteria for Health Physics Staff and Radiation Sa fety Com mit tee............................................. 31 6.4 Operations of the Radiation Safety Officer and Health Physicist..... 32 6.5 Internal Inspection and Review.................................. 33 6.6 Operations of the Radiation Safety Committee.................... 33 6.7 Control and Accountability of Special Nuclear Material............. 34 6.7.1 Organization for Control, Safeguarding and Accountability of SNM 34 6.7.2 Storage of Special Nuclear Materials...................... 35

..e

,. - - _. _ - _. - _ _, _ ~. -, -,

i h

6.8 Program R ecords.............................................. 41 7.

RADiAr10N eROTECTiON eROCeDUReS 43 7.1 Radiation Protection Manual.................................... 43 7.2 Personnel Monitoring 44 7.2.1 Film Badges 44 7.2.2 Bloassay 45 7.2.3 Whole-Body Monitoring.................................. 47 7.3 Limits of Radiation in Controlled and Uncontrolled Areas........... 47 7.3.1 Co nt rolled A rea........................................ 47 7.3.2 Un co n trolle d Areas..................................... 48 7.3.3 Contamination Control.................................. 49 7.3.4 Radiological Survey..................................... 50 7.3.5 Of f-Site Operations..................................... 50 8.

INSTR UCTION OF PERSO NNEL......................................

53 8.1 Formal Training for New Users..................................

53 8.2 Pe riodic Re training............................................

54 9.

TEC H NIC A L C A P ABILITIES.........................................

55 9.1 General Purposes of Use........................................

55 9.2 Organizational S tructure.......................................

55 9.3 Technical Personnel 57 9.4 F a ci li t i e s..................................................... 69 9.4.1 3 03 0 Callan Road....................................... 69 9.4.2 Linear Accelerator Facility..............................

76

/

9.4.3 8221 Arjons Road 79 9.5 Effluent Control

.............................................. 81 9.5.1 Air................................................... 81 9.5.2 Liquid

................................................ 81 9.6 Ins t ru m e n ta t ion............................................... 81 9.6.1 Personnel Monitoring Devices............................ 81 9.6.2 Radiation Monitoring and Survey Instruments............... 82 9.6.3 Radioactive Material Assay.............................. 82 9.6.4 Air Samples

........................................... 84 10.

MANUFACTURING AND QUALITY ASSURANCE PROCEDURES......... 85 11.

W A S T E D IS POS A L..................................................

87 g

11.1 Solid Waste Disposal........................................... 87 IV

1 O

ii.i.i Werw ^rea Waste Receptacies............................ 87 11.1.2 Collection of Waste.....................................

87 88

{

11.1.3 Monitoring 11.1.4 Waste Collection and Storage Area 88 11.1.5 Packaging of Shipping Drums.............................

88 11.1.6 Monitoring Shipping Drums 88 1

11.1.7 Disposal of Solid Waste.................................. _89 11.2 Liquid Waste Disposal.......................................... 89 l

11.2.1 Work Area Liquid Waste Receptacles...................... 89 11.2.2 Monitoring and Collection of Liquid Waste.................

89 12.

C E RTIFIC ATE..................................................... 91 APPENDIX I:

SUPPLEMENTAL INFORMATION CONCERNING PROPOSED USES 93 3

APPENDIX II: RADIATION WORK AUTHORIZATION FORM............ 97 APPENDIX III: WORKPLACES FOR UNSEALED RADIONUCLIDES......

101 APPENDIX IV: OUTLINE - IRT RADIOLOGICAL SAFETY COURSE IRT RADIOLOGICAL M AN,UAL IRT 4141-012...........

111 APPENDIX V: LINAC FUNDAMENTAL RADIOLOGICAL SAFETY O

R U L ES.............................................

1 1 7 APPENDIX VI: SUPPLEMENTAL INFORMATION FOR THE USE OF j

UNSEALED SOLID MATERIAL IN NONDISPERSIBLE FORM 121 i

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O FIGURP.S Figure 1

Fuel storage array depicting aspect area............................

37 2

IRT Corporation organization chart 56 3

ist Floor North 70 4

1 s t F loo r So u th..................................................

71 5

2nd Flo o r No r th.................................................

72 6

2nd F loo r Sou th.................................................

73 7

3 rd Flo o r No r t h.................................................

74 4 8

3rd Floor South

................................................. 75 9

G A Technologies, Inc., Torrey Pines Site............................ 77 10 Linear Accelerator (Linac) Facility 78 7 6 9 5 Fo r mu la P lace Fa cility......................................

80 9

vi

1 GV

2. LOCATIONS WHERE SPECIAL NUCLEAR MATERIAL WILL BE USED This license application requests authorization to use special nuclear materials at the following sites:

1.

Laboratories and facilities at the IRT headquarters located at 3030 Callan Road, San Diego, California 92121.

2.

Manufacturing and warehouse facilities located at 8221 Arjons Road, San Diego, California 92126.

3.

Temporary job sites of the licensee anywhere in the United States where the Nuclear Regulatory Commission maintains jurisdiction.

4.

Specified laboratories and facilities at the site occupied jointly by IRT

O Corgeration and cenerai Atomic Companx at 10,55 aohn 2. segwin, Drive.

l San Diego, California.

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October 4,1985 Page 3 1

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October 4,1985 Page 4 e

3. POSSESSION LIMITS 3.1 TOTAL LICENSE LIMIT 6.

Material (Enrichment)

7. Form

8. Limit (grams)

A.

Plutonium-239 (75%)

Scaled sources 30 B.

Plutonium-239 (75%)

Mixed oxide fuel rods 365 as sealed sources C.

Plutonium-239 (75%)

Any 1

D.

Plutonium-239 (75%)

PuBe Neutron Sources 33 E.

Plutonium-238 (80%)

PuBe Neutron Sources 2

F.

Plutonium-236 Any 10 x 10-9 G.

Plutonium-242 Any 5 x 10-4

-b H.

Uranium-235 (>20%)

Scaled Sources 200 I.

Uranium-235 (>20%)

Any 5

3.

Uranium-235 (10%-20%)

Scaled Sources 200 K.

Uranium-235 (10%-20%)

Any 5

1..

Uranium-235 (< 10%)

Mixed oxide fuel rods 284 as sealed sources M.

Urr.61um-235 (< 10%)

Scaled Sources 1400 N.

Uranium-235 (< 10%)

Non-Dispersable solid 300*

O.

Uranium-235 (< 10%)

Any 10

• This 300 grams of non-diapersable solid inaterial is included as a part of the 1400 gram limit for the <10% enr. U-235.

The quantity of unsealed U-235 and Pu and any mixture thereof shall be less than g '

the valbs set forth in 10 CFR 150.11.

\\

Excluding the Pu/U mixed oxide fuel rods that are possessed for storage only, the total quantity of SNM at any one time shall not exceed the amount specified in g' ',

10 CFR 73.2 (y).

October 4,1985 Page5 i

r e

9a.

Authorized Use Items A, C, D, E,,F, G, H, I,3, K, M, N, and O are to be used for the development and testing of nondestructive detection, assay, and inspection equipment; for development and testing of nuclear fuel, waste management, and safeguards equipment; and for research and development; in accordance with the statements, representations, and conditions specified in the licensee's application and addenda dated September 21, 1983, November 2,1983, January 31,1984, and October 4,1985.

Items B and L are to be used for storage only.

9b.

Authorized Places of Use Items A, C, D, E, F, G, H,1, 3, K, M, N, and O will be used at 3030 Callan Road San Diego, California 92121.

Items H,3, and M (within the limitations specified in paragraph 3.3.2) will be used at the Manufacturing Facility located at 8221 Arjons Road, Suite F San Diego, California 92126.

Itemr. B and L will be stored at the Warehouse Facility located at 8221 Arjons Road, Suite E San Diego, California 92126.

3.2 FORM OF LICENSED MATERIAL The SNM specified in the possession limits takes a variety of physical and chemical forms. These include, but are not limited to:

Metal plates and rods Metal foils Alloys Oxide and carbide pellets Oxide Powders Graphite-coated particles Mixed oxide fuel rods Uranium / aluminum alloy fuel plates Assorted containers with small quantities of SNM Liquids containing microcurie quantities of SNM.

l The majority of the SNM will be in the form of sealed sources, i.e., fuel rods, fuel plates and sealed metal or plastic containers.

October 4,1985 Page 6

O 3.3 LIMITATIONS AND 8XEMPTIONS 3.3.1 Specific Limitations for Areas Not Equipped With Criticality Monitors The following limitations shall be established as the maximum inventory of SNM allowed in each facility or area that is not equipped with criticality monitors. All transfers of SNM into or out of each area shall be under the control of the Radiation Safety (Accountability) Office.

These limitations shall also be the inventory limits for the 3030 Callan Road Facility.

Material (Enrichment)

Form Limit (grams)

Plutonium-239 (75%)

Sealed Sources 30 Plutonium-239 (75%)

Any 1

Plutonium-239 (75%)

PuBe Neutron Sources 33 Plutonium-238 (80%)

PuBe Neutron Sources 2

Plutonium-236 Any 10 x 10-9 O

eiotonium-242 any 5 x 10-4 Uranium-235

(>20%)

Sealed Sources 200 Uranium-235

( > 20%)

Any 5

Uranium-235 (10 to 20%)

Sealed Sources 200 Uranium-235 (10 to 20%)

Any 5

Uranium-235

( < 10%)

Scaled Sources 1400 Uranium-235

( < 10%)

Non-Dispersable solid 300*

Uranium-235

(< 10%)

Any 10

• This 300 grams of nondispersable solid material is included as a part of the 1400 gram limit for the < 10% enr. U-235.

235 The quantity of 0 is restricted to an amount not to exceed that defined by the following formula:

Mass U-235 (>10%)

Mass U-235 (s10%)

31 400 1400 October 4,1985 Page 7

The limits described above will apply to each of the experimental areas provided that they are separate rooms and are isolated from adjoining use areas by one of the following criteria:

1.

Surface-to-surface separation of at least 12 feet.

2.

Separation by at least the nuclear equivalent of eight inches of concrete of a density of 140 pounds per cubic foot.

This isolation criteria was obtained from TID-7016, Revision 1, pages 26 and 27, and applies to those systems as described in Table IV with the stipulation that more reactive systems would require 12 inches of concrete. Considering the specified mars limits and their most reactive configuration as the minima in the critical mass curves in Figures 8, 34, and 27 of TID-7028 (H. C. Paxton, et al., " Critical Dimensions of Systems 235 Containing g,239Pu and 233 "), the mass safety factors for 235U,239Pu and U

233 U

are 1.6, 2.0 and 1.92, respectively. Those systems specified in Table IV (TID-7016) have mass safety factors of the order of 1.33,1.43 and 1.55, respectively. The specified mass limits for these areas clearly fall within the limits described in Table IV and the isolation criteria is therefore applicable.

G 3.3.2 Specific Limitations for the 8221 Arjons Road Facilities A.

Warehouse Facility The material in this facility is for STORAGE ONLY. The material that will be stored is contained in 13 mixed oxide Pu/U fuel rods.

Material (Enrichment)

Form Limit (grams)

Plutonium-239 (75%)

Sealed Sources 365 Mixed oxide fuel rods Uranium-235

(<10%)

Sealed Sources 284 Mixed oxide fuel rods October 4,1985 Page 8

B.

Manufacturing' Facility Material (Enrichment)

Form,

Limit (grams)

Uranium-235

(>20%)

Sealed Sources

<l5 Uranium-235 (10 to 20%)

Sealed Sources

< 15 Uranium-235

(<10%)

Sealed Sources

< 15 The total amount of Uranium will not exceed the following formula:

Mass U-235 (>20%) + Mass U-235 (10 to 20%) + Mass U-235 (<10%) < 1 15 15 15 3.3.3 Exemption from Requirements Set Forth in 10 CFR 70.24 235 The mass limitation given in Section 3.3.1 for U when coupled to the maximum

- i ht d m'== e' e

1. d "u (weighting factor of 2.5) is below criticai mass for O

8 homogenized systems of various enrichments with optimum moderation and full reflection as given in Figure 13 of TID-7028.

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

IRT, therefore, requests exemption from the requirements set forth in 10 CFR 70.24 for all areas not exceeding these mass limitations.

O October 4,1985 Page 8A

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,e 3.3.4 Exemption for the Arjons Warehouse Facility The total amount of material involved is:

365 grams of Plutonium, 277 grams of 2.1% enriched Uranium-235, and 1174 grams of depleted Uranium containing 7 grams of U-235.

This material will be stored in two boxes that will be placed end-to-end inside the storage container.

Box No. I will contain six rods with:

161.5 gm of Pu and 138.5 gm of U-235 (2.1% enr.).

Box No. 2 will contain seven rods with:

203.5 gm Pu, 138.5 gm U-235 (2.1% enr.), and 7.0 gm U-235 contained in 1174 gm dep-U.

The internal measurements of the boxes are 10.5 cm x 10.5 cm x 195 cm long.

The total internal volume of each box is 21,500 cubic centimeters or 21.5 liters. Box No. 2, which has the most Plutonium, will have a Pu concentration of 9.5 gm/ liter. If all of the SNM were plutonium, the concentration would be 16.2 gm/ liter. Referring to TID-7028 Figure 19, " Estimated Critical Diameters of Infinite Cylinders of Homogeneous Water-Moderated Plutonium," the graph shows that a water reflected metal-water mixture in a 4-inch (10 cm) diameter cylinder would require a concentration of 3.2 Kg/ liter to achieve a critical mass. From this we calculated that the Plutonium in storage will have a safety factor of 336, and the " total SNM" will have a safety factor of 197. The material is not in form to be homogenized, it is inside a steel container sealed with bolts and an "O" ring, and there are no massive moderators or reflectors in or around the storage cage or cask.

IRT, therefore, requests exemption from the requirements set forth in 10 CFR 70.24 for the Arjons Warehouse SNM Storage Facility.

October 4,1985 Page 8B l

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O b.

Radioactive matenals previously used. C.te typical radioisotopes in appropnate box and key to Part 4.a above:

Quantities Handled Microcurws Millicunes Curtes Kilocunes i

l Co60. CsI37 60 60 Scaled sources Co Co Unsealed alphs U235. Th#33 U235 Thl32, enurters 238 238 g

g Unsealed beta-32 gamma enetters P

gpp Cf-252 PuSe, i

, Neutron sources PuSe, Po8e Po8e I

c.

Desenbe procedures sunder to those proposed in Part 2 with which you have had expenence.

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

Research and development 44 1 - 4 years 4a 2 - 14 years O

d.

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

(X) Onhaary Chemical laboratories 44 2 (X) " Controlled Area" (Type B) laboratories 44 1, 2 (X) Glove boxes 4a 1, 2 (X) Shielded giove bones 4a 1, 2

() Caves with remoe --

(X) Field opersoons with parable equipent'st 44 1, 2 '

s.

Ceroficam:

I hereby carnfy that allinfonnsoon conmined in this Statement is true and correct.

l C. J - -i L + 1u I94 I p

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September 21,1983 Page 25

m of CalHamie Rac e m m 7as a seen l

Dagetmut of Hesith sessmem, cassume saatag STATEMENT OF TRAINING AND EXPERIENCE (Use additional sheets as necesary)

Instruence Every individual propoeng to um radioscdve maamalis required to abmit a Statement of Traannag and Exponence in duptienee to the addres given above.

Phyacians should request Form RM 2000 when applyng for human use authonsanoes.

1.

Name d proposed user: Daniel E. Keesling posidos drie: Health Physics Tecn.

3 Addren:

8707 Priant Street c! y: San Diego Zip: 92126 1

To be incinded on [Jc Na 2468-80 in name d IRT Cornoration i

2.

Desespoom d proposed um Research and development 3.

Tramag:

a, High Schmet Gradusse: Ym1 No_

i h.

Couage or thniversty: Name and locanos Ball State University, Muncie, Indiana Years completed 5

Deyee B.s.

Cowse d sandy Bioloav: Natural Resources Education speedicaDr applicable to um W radioacsive matenal h

c.

Radiation Safety course at Scripps Clinic & at IRT Corporation, two quarters Inorganic Chemistry, one quarter Organic Chemistry G

Exponence:

I.ist expenance with radiosenvity bepamag with mes recent a.

(1) Deses: From 6/24/85 Present g,

Title and denies:

Health Physics Tech. - Personnel monitoring, area monitoring, isotony control, shipping & receiving rad. materials Employer. IRT Cornaration m. 3030 Callan Road, San Diego 921r.

(2) Desem From 2/15/80 to 6/21/85 Title and daies: Radiation Safety Tech. - Receiving rad. isotopes & delivering to la::s, rad. monitoring personnel monitoring. area monitoring, chemicals & their proper s ura;e EM.' UNn!'EIidie g.Reemarch " "M710688 a

N. Torrey Pines Road. La Jol'a (3) Dame: From to Title and duties:

i Employer:

Address:

l October 4, 1985 Page 26 4

b.

Radmacuve materials pitvtously used. C.te :ypical radioisotopes m appropnace box and key :o l

Part 4.a abow:

O

-- m,*d Miaocuries Millicuries Curies Kilocunes 192 60 60 Sealed sourms Ir Co Co M alphs 238 ena rters U

.05 gC:

k. c. **'. 5. *!

k. **',.5. '. ". 't.

tJamaled bem-si rw.

tas,c st e,w,e,s?

,,l {,. e*ase;,zi,,132. gjit, r,w, gi2 tzs t

pass enters Neutros sourcM 252 Cf Daseibe proemdures maalar to those proposed in Part 2 with whid you hme had experience.

c.

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

R&D Radiotherapy O

d.

ladicate which types of facilities you hsw used and key to Parr

( y) Ordinary Chemicallaboratories j

(4 " Controlled Assa" (Type 3) laborsaaries

() Glow base

() Shneided glow boxes

() Cases wish runoen semipaissors (y) Field opussions with parable espapsent 5.

Caruflese:

I hereby cumfy ther aR information cosained in this Stamment is arme and corisct.

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9-25-8S m.e o er m.

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October 4, 1985 Page 26a

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6. ADMINISTRATIVE PROCEDURES 6.1 PROJECT AUTHORIZATION PROCEDURES Any IRT operating department or individual desiring to initiate a program utilizing radioactive material or SNM must first obtain the proper authorization. The following procedure describes the proper course of action.

6.1.1 Radiation Work Authorization Request Procedures The responsible person directing the program, or his appointee, must prepare a Radiation Work Authorization (RWA) request form (see Appendix II) describing the operations to be performed, and the necessary procedures, equipment features, process characteristics, and planned precautions which assure radiological safety. The RWA O

rorm i#ci#aes the a -es e#a sisa t#res of >> verse #s 1 voived i= the gre8r - e#a identifies those persons responsible for the radioactive material or sources specified.

The request should be reviewed with the Health Physicist before it is submitted to the RSO. This step is optional but is beneficial to the requestor.

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

Criticality safety review is necessary if:

1.

The RWA involves the use of 200 grams of SNM.

2.

The amount of SNM used raises the inventory of a single Controlled Access Area (CAA) to 200 grams.

3.

The estimated annual throughput for a single CAA exceeds 2,000 grams.

Except as specifically approved by this license, the limits of approval for the 235 Committee shall be 200 grams of U (enriched > 20 percent), and 30 grams of plutonium, or 200 grams of combined SNM for laboratory-type operations with materials in any form.

October 5,1985 Page 27 l

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The approval limit for use of discrete sealed sources with enrichments up to 5 percent shall be limited to 43 percent of the safe mass limit and 67 percent of dimension limits described in DP-1014 " Critical and Safe Masses and Dimensions of Lattices of U and UO Rods in Water." Where other types of SNM are combined or used 2

in these operations, their mass values will be weighted by a factor of 2.5 and the overall computed enrichment will be used to determine the limiting values.

1 RWA's requiring criticality review will be directed to the Nuclear Systems Division Chief Scientist for additional review prior to submission to the RSC.

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

The RSC will review the RWA request and indicate approval or disapproval based upon specifications given in subparagraph 6.1.3 below.

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

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

Original Copy:

To requestor First Copy:

Radiation Safety Officer g

Second Copy:

RWA File If disapproved, the RWA request will be returned to the initiator with the reason for rejection stated and recommendations for modification.

6.1.2 Radiation Safety Officer Review Procedures It is the responsibility of the RSO to establish that:

1.

The applicant and all personnel listed in the RWA request are Authorized Individuals: each person named on an RWA must have on file with the Radiation Safety Officer a resume of his previous experience with radio-active material and/or radiation sources, training and other qualifications, to indicate competence in dealing safely with radiation and radioactive mate-rials.

In addition, it is necessary that the individual has successfully completed an approved course in Radiological Safety, including a written examination on radiological safety principles and policies as applied to IRT activities. In some cases, due to past training and experience, a waiver of this course requirement may be granted by the Radiation Safety Committee.

l September 21,1983 Page 28

O 6.7.2 Storage of Wi=1 Nuclear Materials 1.

HTGR Storage Vault vault-type room for storage of special nuclear material is located inside th 'iTGR assembly room. This vault-type room is 6 feet wide,18 feet long, and.

• feet high. The floor is 8-inch-thick reinforced concrete, two walls are 16 inch-thick reinforced concrete, the other two walls are 8-inch-thick reinforced concrete block, and the ceiling is 5-inch-thick reinforced con-crete. A metal door equ'pped with a combination-type security padlock i

provides entrance. The only other penetrations into the room are two metal ventilation grills that measure 7 by 18 inches mounted three feet below the ceiling in the assembly room wall. The vault is equipped with two separate criticality alarm systems that meet the criteria of 10 CFR 70.24(a)(1), two 150-watt flood lamps for lighting, and an ultrasonic motion monitor for security.

This vault-type room is the storage area for all SNM used at the Linear Accelerator Facility.

O The ssM stora8e racks are fastea d aien8 oth ien8 waiis. The racks are h

j made of steel frames to which is attached sheets of boral (boron-aluminum j

alloy) forming the base, the walls, and the door of the storage racks. Each rack is separated with boral plates into five storage compartments with each compartment being 8 inches wide, 8 inches deep, and 30 inches high.

Access to the area is limited to those personnel in the Security Departmt.nt, Radiation Safety Office, and the Health Physics Group who have d

need to enter and who are authorized. The Radiation Safety Officer (RSO) and the Health Physicist (HP) are the SNM Material Custodians for the material in the vault.

2.

3030 Callan Road Storage Vault This vault-type room is located on the first ficor, North wing of the new IRT Headquarters Building.

The walls and ceiling are made of 8-inch thick reinforced concrete block. A metal door equipped with a combination-type j

security padlock provides entrance. The vault shall be equipped with an ultrasonic motion monitor for security. The room measures 6 feet by 6 feet by 8 feet high.

October 4,1985 j

Page 35 i

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Immediately opposite the entrance are two 4-inch diameter pipes that extend 16 feet under the parking lot. The pipes are 6 to 7 feet underground.

The buried end is welded shut and the end in the vault is closed with a pipe cap. These tubes will be used to store long reactor test rods. The other storage compartments will consist of metal cabinets measuring 18 inches deep by 36 inches wide and 72 inches high. Storage bins shall be built on each shelf in order to comply with the Storage Criteria discussed in Item 3, which follows.

3.

Storage Criteria The rules for storage are governed by both density and area criteria with the following rules governing storage in the HTGR vault.

a.

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

b.

Moderated SNM (H/X greater than two) may be stored in isolated plane 235 arrays not to exceed an average of 0.160 kg of U, 0.098 kg of 233 plutonium, or 0.140 kg of U per foot square of aspect area. No foot square of the aspect area may contain more than 0.320 kg of 235,

U 0.196 kg of plutonium, or 0.280 kg of 233U The " foot square of aspect area" means any foot square area as viewed. There are two restrictions governing the storage, (1) an average loading of x grams per square foot, and (2) 2x grams in any one square foot of aspect area. Uniform loading of i grams per square foot over an entire array satisfies the storage criteria--no more than x grams per foot square regardless of where the square foot area is selected. The array shown in Figure 1 also satisfies the storage criteria. Some of the material is concentrated in a smaller area; however, no single aspect area is allowed an excess of 2 x grams of material. Referring to the figure if each box defines a foot square there can be x grams on the average in each square. You can also store x grams in adjacent corners so long as you do not exceed 2 x in any foot square of aspect area, shown here as the dashed foot square. Any material stored in the other two connecting squares mest fall outside the dashed foot square.

September 21: 1983 Page 36

"r 235 Q

The minimum of these curves are at values of 0.160 kg of U,0.098 kg 233 of plutonium, and 0.140 kg of 0 per foot square.

4. ARJON Warehouse Storage An NRC approved shipping container will be utilized as the storage container for the Plutonium-Uranium test rods.

The container is:

Certificate of Compliance No. 6581, Model 51032-1. The rods will be placed inside two wooden inner containers, then inside the shipping container, and finally the shipping container will be inside a locked cage made of heavy duty security-fencing.

The wooden boxes are made of 1-inch stair tread stock that is glued and nailed together, except for the top which is fastened on with 2-inch wood screws. The inside dimensions of the box are 4.125" x 4.125" x 76.75". See Figure la.

The shipping / storage container is a 43-inch diameter right cylinder 216 inches long fabricated of 3/8-inch steel. This vessel is fabricated in two sections, a base and a cover assembly. Continuous 2 x 2 x 1/4-inch closure flanges are welded to the base and cover assemblies. A 1/2-inch continuous rubber "O" ring gasket is fitted between the mating flanges.

The two halves of the containment vessel are mated and sealed together with fifty-eight 1/2-inch 13UNC-2A steel closure bolts; in addition, a padlock I

and a tamper indicating seal will be attached to each end of the cask. The complete assembly weighs about 4000 pounds. See Figure Ib.

The wire cage will be 5 ft. high,25 ft. long, and 9 f t, wide. The cage supports will be bolted to the concrete wall and floor. There will be a 6 ft. sliding door in the front of the cage. The entire top will be hinged at the wall so that the top can be tilted back

)

for access to the cask. The door and top will be locked and equipped with intrusion alarm contacts. The alarm system will be "ON" at all times except when it is necessary to enter, open the storage container and inspect the rods.

The warehouse has perimeter alarms on all of the entrances and there are infrared motion detectors throughout the inside of the building. One of the motion detectors monitors the SNM storage area. This intrusion alarm system is "ON" at all times,

. except when the building is occupied.

l I,

O j

October 4,1985 Page 39 t

I 4.

Temporary Storage of SNM in Use h

The temporary storage of SNM in active use will be accompli =hed by the use of locked metal cabinets located in the temporary CAA. Access will be controlled by keys in the possession of the Material Custodian of this CAA. Physical security will be in accordance with IRT Corporation's approved Physical Security Plan.

5.

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

a.

The Criticality Safety Committee must approve all operations which fall within the limits on SNM specified in Section 6.1.1.

b.

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

c.

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

g d.

Unless specifically exempted by the License, a criticality monitor which conforms to 10 CFR 70.24(a)(1) will be operating in each area where 235 more than 500 grams of contained U, 300 grarm of Pu, or 300 grams 233 of U are present.

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

In addition, the entries leading into a CAA shall be conspicuously posted by a sign or signs.

Such signs shall include the following l

information:

O October 4,1985 j

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(1) SNM limitation (2) Quantity of SNM currently in the CAA (3) Material Custodian (4) Alternate Material Custodian (s).

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

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

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

In the event of repeated violations, the employee will be subject to disciplinary action such as denial of use of SNM, suspension or termination.

6.8 PROGRAM RECORDS The following records are maintained in a centralized file of the Radiation Safety Office.

1.

Radiation Work Authorizations that include location of use; names of personnel involved; description of the program, procedures, materials, and facilities; results or comments of reviewers.

2.

A list of all authorized personnel.

3.

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

4.

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

5.

Exposure and bioassay histories of all users.

O l

October 4,1985 Page 41 1

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6.

Leak test and environmental survey records within and outside controlled areas.

7.

Histories of all incidents and unusual occurrences.

8.

A complete file of calibration data on all instruments used for radiation level monitoring.

9.

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

O i

i I

l O

October 4,1985 Page 42

O DANIEL E. KEESLING B.S., Fishery Resources and Biology, Ball State University Mr. Keesling joined the IRT Radiation Safety Staff in June,1985 where he is working as a Health Physics Technician. His duties include routine meter and wipe surveys of the laboratories and Linear Accelerator Facility, maintaining the personnel monitoring program, doing source leak tests and maintaining the source inventory, and monitoring shipments and receipts of radioactive materials and radioactive waste.

Prior to joining IRT, Mr. Keesling worked as a Health Physics Technician at Scripps Clinic & Research Foundation since February,1980. His duties there included:

monthly and weekly meter and wipe surveys of forty-eight' research labs and three hot labs; maintaining records of all incoming isotopes and delivering them after a thorough leak check; supervising the clean-up of lab spills and rooms where patients had undergone radiotherapy; distributing and collecting film badges, answering questions about radiation and radiation safety; and monitoring during operations involving the surgical implanting of radioisotopes. He also supervised and directed another radiation l

O safety technician workinS or Scripps Ciinic.

f Mr. Keesling graduated from high school in Muncie, Indiana and served for one I

year in the U.S. Navy before receiving a hardship separation and an honorable i

discharge. He attended Ball State University in Muncie, Indiana starting in 1969 and graduated with a B.S. degree in Fishery Resources and Biology in 1975. He worked for the EPA Region 6 in Anderson, Indiana for two and half years as a field biologist, then he worked for the Division of Water Quality in Muncie, Indiana as a fishery biologist i

until he moved to California and started working for Scripps Clinic.

O October 4,1985 Page 68A i

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O 9.4.2.2 HTGR Storage Vault.

The HTGR storage vault for special nuclear material is located in the HTGR assembly room. This facility is a secured concrete storage vault. This vault is 6 feet by 18 feet by 13 feet high with two walls of 16-inch thick reinforced concrete and two walls of eight-inch-thick reinforced concrete block.

l The ceiling is five-inch-thick reinforced concrete.

A metal door equipped with a combination security padlock provides entrance. This vault is equipped with a local and remote readout criticality alarm system, and a motion detector for security purposes.

9.4.3 8221 Arjons Road This new manufacturing and warehouse facility is located in an industrial area North of the Miramar Naval Air Station. These two facilities are located in a long warehouse complex, the manufacturing facility (Suite F) is at the north end of the building with the warehouse (Suite E) adjoining its south wall. Other companies occupy the rest of the building to the south of the warehouse. The building is made of tilt-up concrete slabs twenty feet high. In the manufacturing area there is a drop ceiling eight feet high but in the warehouse area the ceiling is the full twenty feet high. The manufacturing facility measures 180 feet by 160 feet and the warehouse measures 120 feet by 160 feet. (See Figures 11 and 12.) Only SNM contained in sealed sources will be used at these facilities. No materials with smearable contamination in excess of 66 dpm/100 cmsq Beta / Gamma or 12 dpm/100 cmsq Alpha will be allowed to be used at these facilities. both of these facilities are equipped with separate intrusion alarm systems.

Initially the manufacturing facility will be used to build Portal Radiation Monitors (PRMs), Portal Beta Monitors (PBMs), Automated Contamination Monitors (ACMs), and Component X-Ray Inspection Devices (CXIs). Later, however, this facility may also be used for R&D to design, build, and test new versions of the above devices and other devices such as:

letter bomb detectors, neutron monitors, scintillation detector systems, SNM monitoring and analyzing equipment, and other new types of devices that use SNM, radioactive sources, or radiation producing machines. The SNM will be used in the PRM and ACM Assembly and Test Areas. The material will be stored in the Scintillation room inside a locked cabinet, shielded as necessary to protect personnel from unnecessary radiation exposure.

O October 4,1985 Page 79

The warehouse facility will be used as the site for storage of the Pu/U mixed oxide fuel rods and as a possible area for expansion of the manufacturing facility. The rods will be stored in an NRC Certificate of Compliance shipping container, No. 6581, Model 51032-1. This storage container will be inside a security cage equipped with intrusion alarms. The storage location will be the northwest corner of the warehouse as shown in Figure 12. The wall at this location is made of concrete four inches thick.

9 October 4,1985 Page 79A

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9.5 EFFLUENT CONTROL Effluent is controlled within the regulations as required by 10 CFR 20 with the addi;ional requirements as previously stated.

9.5.1 Air Programs involving the use of radioactive material in a form that may become airborne are connected to or carried out within areas that have a filtered ventilation system.

1 9.5.2 Liquid s

3 Liquid effluent is controlled by storage until determined safe for disposal or is yfe within applicable regulations for release to a sanitary sewage system.

t Monitoring of effluents is accomplished by using portable air samplers and continuow air mordtors and performing analysis for long-lived alpha and beta radioac-

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tivity and by gross-alpha, gross-beta and gamma spectral analysis of liquid samples.

s 9.6 INSTRUMENTATION The Radiation Safety Office has instrumentation available to perform the following functions in the detection and measurement of radiation.

9.6.1 Personnel Monitoring Devices IRT uses photographic dosimetry for x-ray and gamma radiation in the range 5 kev to 100 MeV covering dosages from 20 mrem to 500 rem for high energies, and dosages from 10 mrem to 60 rem for low energies; photographic dosimetry of beta

. - radiation from 400 kev to 50 MeV covering dosages from 40 mrem to 1000 rem; thermal and fast neutron photographic dosimetry in the ranges 0 to 3.5 eV covering dosages from 10 mrem to 300 rem, and 500 kev to over 100 MeV covering dosages from

_ Qmrem to 10 rem. Pocket ionization-chamber dosimeters which are the self-reading type that detect x-ray and gamma radiation from a dose of 1 mrem to 500 rem, and g

h self-reading fast ileutron and thermal neutron dosimeters that measure dosages from I mrem to 200 mrem are also used. LiF and CaF TLD's are available to the Radiation Safety Office on loan from other IRT operating departments.

O October 4,1985 Page 81 s

1

9.6.2 Radiation Monitoring and Survey Instruments A list of instrumentation, detection limits, and frequency of calibration is provided in the table on the following page.

9.6.3 Radioactive Material Assay The Radiation Safety Office has the following Radioactive Material Assay instruments.

1.

An Eberline Model BC-4 Counter. This instrument is a complete system consisting of a two-inch detector, high-voltage power supply, pulse amplifier, timer, and six-decade scaler. All circuits are solid state with extensive use of integrated circuits to enhance reliability. The detector is a pancake-type Geiger tube with a 1.75-inch diameter window which is 1.4 to 2.0 mg/cm2 thick. With the addition of a 0.002-inch mylar window the total window density is approximately 7 mg/cm2 This mylar window is removable for decontamination or for counting low energy beta emitters such as I"C.

the detector is shielded on the top and side with 7/8 inch of lead. The detector background is generally 30 to 33 cpm. The efficiency for two pi geometry is generally 70 percent and for four pi the efficiency is 35 percent for 90Sr 90y, 2.

An Eberline Model SAC-4 Scintillation Alpha Counter. This instrument is a complete system consisting of a two-anch detector, high-voltage power supply, charge-sensitive input amplifier, timer, and six-decade readout. All circuits are solid state, except the detector, with extensive use of integrated l

circuits to enhance reliability. The detector is scintillation phosphor made of ZnS(Ag) powder plated on a plastic light pipe. The photomultiplier tube is a l

ten-stage, Sil-response, end window tube, two inches in diameter.

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background is generally 0.6 to 0.9 cpm. The efficiency for two pi geometry is generally 80 percent for a one-inch diameter Pu239 source, and for four pi geometry the efficiency is 40 percent for the above source.

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September 21,1985 Page 82