ML20141L847
| ML20141L847 | |
| Person / Time | |
|---|---|
| Site: | 07002930 |
| Issue date: | 06/30/1983 |
| From: | Stewart R FIVE FOUR THREE CO., INC. |
| To: | Guinn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20141J561 | List:
|
| References | |
| 22123, NUDOCS 8602270492 | |
| Download: ML20141L847 (6) | |
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e4g company m Rt 6, Son 220E, Morg.ntown, WV 26505 304 292 0729 U
af C ml June 30, 1983 8
Materiala Radiation Protection Section Division of Emergency Preparedness h
\\g( 4 and Materials Safety Programa U.S. Nuclear Regulatory Commision Washington, DC 20555 g
ATTENTION:
PAUL R. GUINN Q
SUBJECT:
Additional Information Concerning Material Licenao Uteforence: 22123: 070-02930)
Gentlemon:
In responao to your request for additional information concerning amendment of Licanoo No. SNM-1872 to authorize the installation and corvicing of Wultex devices requented by letter of Juno 14, 1983, wo submit the following:
1.
Poanoaalon of licenced material.
The licenced material l
to be posacacod in Fivo, Four, Throo Company facilition in "for use and/or pococacion incident to":
1.
Insta116 tion into or removal from Guncon Sortex Company, Ltd., Aah Monitors and Wultex U.S. Inc. In-Lino Ash Motora.
2.
Installation, relocation, repair, testing, performance of radiation aurvoya on and servicing of the ash monitora.
3.
Picking up, packing, and transfer of scaled courcea roccived from customora for tranafor to authorized recipiento.
4.
Instruction of individuala in the uao of the ash monitor.
5.
Pocoonaion incident to the performanco of wipo tonting of customor courcoa.
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Thus, it will be necoccary to maintain the existing storage vault and two-room Radioisotope Laboratory at the Main East Roacarch Center (MERC), Route 8, Morgantown, Vest Virginia, previously described.
In addition, licensed material will be pocacased for
) calibration of curvey metera and wipe testing instrumento, (
waste materials from the performance of wipe testing, and (
packaging, holding and transfer of scaled sources incident to relocation of ash motoro, training of customer personnel and replacement of cealed soureco.
The reaclling of an ash meter or uale of an entiro coal preparation plant or company is an event which will require removal of courcco to 543 Company facilitico pending relicensing and retraining of personnel.
The current depressed otate of the coal industry has resulted in closed planta and discontin-untion of operations with decommionion of ash metera and pick up, holding, and transfer of cources to authorized recipienta...
Therefore, it is necessary to anticipate futuro requiremento and to maintain facilltion and licensing to hold at 543 Company facilitica the capability of handling the following courcoat 6.
Byproduct Sourco
- 7. Chemical or
- 8. Maximum Amount Physical Form A.
Plutonium 238 A.
Scaled Sources A. 2 Sources not to (Amercham Model exceed 10 mC1 cach PPCl)
B.
Curium 244 B.
Scaled Sourcoa B.
18 Sourcos not
( Amercham Model to exceed 20 CLCl) mci cach C.
Scaled Sourcea C.
10 Sourcea not (Amoraham Code to exceed 50 AMC.66) mci cach D.
Any byproduct D.
Analytical D.
10 Sources not material and
.Samplco to exceed 10
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2.
Distribution of licensed matorial.
It will be nococcary to distributo and pick up acaled courcon betwoon the 543 company and Wultex U.S. Inc., Pittaburgh and customer planta through-out the United States.
Sources will be shipped from Amoraham to the 543 Company for inopoetion, leak tooting and calibration at the Wultex plant in Pittaburgh, PA.
Initially, the first courco will be unod for training in nourco handling with concurrent uno of dummy courcoa at the 543 Company.
Each courco must reflect radiation to a count of 67.1 to 67.5 percent (ooo Operating Proceduroa, page 26).
All courcou outsido thin opecification munt be raturned to Amoraham for replasement.
The proper phyoical fit of the courco in the courco holder will bo determined with minimum poroonnel exposuro (calculated to be 1000 than 5 mr).
The courco hvidor containing the cource will bo tranuported for Wultex device calibration at the Pittuburgh plant, como 60 milon north of tho 543 Company.
All oourco transportation after
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delivery by the Amersham Corp. will bo in cource holder in the specially locked 543 Company vehicle, attended by 543 Company personnel at all times.
Tranaport to and from a customer plant will be by the onmo proceduro.
All record kooping of roccipt and transportation will be made by R. F. Stewart, of the 543 Company.
3.
Personnel Monitoring.
In accordance with 20.202 all personnel entering a restricted area above 2 mr/hr will be provided with film badges and dosimetera.
In all casco within the 543 Company, it has been practical to limit exposures to lesa than 10 percent of permissible exposurce (ace NRC forma 5 for exposure in prior years) and this policy will be continued.
Handling of the 50 mCiAm241 cources for the Wultex ach motor are planned to reault in leaa than 10 mr exposurca verified by uno of dosimeters recorded before and after cach activity (maxi-mum daily).
Film badges by Scarles Analytic Inc., are developed monthly or at leanor timon when dosimetera show abnormal or drift readings.
Both finger ring and wrist badges have been used and found to be loca accurato than an attended survey probe used ahead of hand placement.
Personnel exposurca above 10 porcent of permionible will not bo permitted except in recorded emergencica.
4.
Individual uncro.
To maintain control and responsibility for the uno of liconood materiale, Mr. Robert F. Stewart will be phyoically prosent during all servicing operations involving the Gunaon Sortex and/or Wultex gaugen.
Ho will be anointed by Maria R. Stowart with training doacribed previoualy except that she haa now natiofactorily completed the Radiation Safety Isotope Usage Course by Dr. Slack at Went Virginia Univoraity, in May 1983 (copy enclosed).
Her namo chould now be listed no Technician-in-Training.
5.
Training of Individual Unora.
Terry Duxton, Sr. Vice Prooi-dont of Wultex U.S. Inc., in the manufacturer'a instructor, having been trained in England in the uno of the Wultex in Dritish coal planta.
Upon NRC liconoing and cource procuremont, he will instruct R.F. Stewart no a radiological instructor for the Wultex, using Mr. Stewart's years of experienco with Sortox and Condrox nah motora.
Together they will train customer paraonnel in routino uno of the Wultex, and they will train Maria R. Stewart in non-routino uno of the Wultex.
Non-routino operations (e.g., innta11ation, relocation, removal from acryice, etc..) will remain the responsibility of Terry Duxton and R.F.
Stewart and no training will bo given to cuatomer peraonnel in non-routino operationa nor will non-routino operationa be permitted by customer poroonnol.
Training will bo provided to R.F. Stowart and Maria R. Stewart for cach apacific nervico ontheWultoxdevicewithemphaoloonthe" lock-out"procedurco.
An described in Terry Duxton a lottor of May 4,1903, thin includoo in the plexiglano ahutter nnd housing, a acif-locking device with key rotnined by Duxton or by Stowart.
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6.
Calibration of instrumento.
Leak toot camplea are analycod by calibrated instrumento aa,doocribed in detail by letter of July 22, 1980, which includes uno of a Molochem Inc.,
Model 30 Low Lovel Counter, Sorial No. 178, calibrated with an NBS referenced Standard Source of Am241 of 0.006 microcurios reading 243 counto por minuto plus or minua one aigma counting statistico.
With a swab planchlet, the counter hao a conoiti-vity of 1.2% of 0.005 microcurica contamination.
Backup instrument ayatomo of 1000 canoitivity are listed in the 543 Company Instrument Inventory.
Your comment concerning reporting of resulto to greater accuracy than "1000 than 0.005 microcurica" lo quito apt, auch no 0.00110.0003.
But the question of oignificant level leading to potential leakage 10 not catabliohod, any 5% or 25%, but is u nder experimental atudy.
Actually, moot cources do have a few removable counto, yet rarely do they become worno.
We have noted that Am241 courco rupture can becomo exponoivo: IE Information Notico No. 83-32, May 26, 1983.
7.
Training of customer employoon.
The training of customer or plant employoon la by a preacheduled mooting betwoon manufacturer and customer at the timo of courco installation.
The customer employoon includes the plant foroman, area cloc-trician, chift operators and any plant employoon working in the aron of the ash motor.
They are addrocood by R.F. Stewart and Terry Buxton concerning:
1 Introduction and description of the Wultox In-Line Ach Motor.
2.
The specific radioactivity involved and a brief health physical roview of radiation dangora.
3.
The health protection featuros of the Wultox ash motor and the purpocos and functiona of protectivo chielding.
4.
Review of the posted NRO form 3 and operating proceduroa.
5.
Instructions on reporting any condition that may lead to liconao violation or personnel exposuro.
6.
Instructions of what to do in the event of accident or malfunction of the Wultex and on " lock-out" proceduroa.
7.
Advino of the radiation expoouro reporto that may b,o requested.
8.
The improbability of any actual radiation exposuro due to fire or accident.
9.
The posted namo and phono number of whom to notify in tho event of accident:
Wultex and tho 543 company.
8.
Radiation survey roculto.
Bofore and aftor each courco installation, courco removal or replacement or gaugo rolocation, a radiation ourvoy will bo made of all acconciblo
.ourfacon monoured in mr/hr with calibrated survey motor.
Noto that onco the plexiglaca chutter nnd housing are inatalled with
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7t-an activo source, total chiciding from any omission is achieved and no difference is found beforo and after cource installation, except for electronic reading by the recorder many foot away.
Thus, a radiation survey is negativo of itac1f and only the recordor reading is noted.
A copy of the negativo radiation survey is signed by R. F. Stewart and filed with the company or plant recordo.
Another copy la retained by the 543 Company in its leak toot filoa.
9.
Servicing Operations.
(a)
The specific device la a Wultex In-Line Ach Motor.
(b)
The apacific operations are:
1.
Source inatallation 2
Lock-out and reactivation 3.
Source removal (c1)
Operating proceduros for cource installation.
The apocific procedure is identical to the 21-atop procedure for dummy tooting, pages 25 and 26 of March 10, 1983 application, cocopt that an actual 50 mCiAm241 la unod instead of a dummy (practico) source.
Copico of those two pages are attached for reference.
Since the only possible poroonnel exposure occurs when the courco 10 removed from the cource container, stopa 7 through 11, exposure may be reduced by personnel monitoring of thoso specific atopo.
With an noaiatant to handle and maintain a curvey probo at the position of the fingera, otopa 7 through 11 are repoated, includ-ing a wipo toot, to monouro actual exponuro of the fingera during this proceduro.
If the resulta show total finger exposure abovo 10 mr. longer tonga, more chielding or improved handling will bo incorporated into the procedures.
Basically a aimilar proceduro used with two 20 mci courcea of Cm244 chow no monourable finger exposure.
(c2)
Lock-out and reactivation procedurc.
The previously doacribed "lockk-out" dovice in a plexiglano ahutter and housing with a acif-looking, key-operated cafety device.
The Wultex cource la looked out of corvice by manually pulling the metal rod, attached to the ahut-ter, from outside of the Expamot guard panol.
The acif-locking dovice provento roactivation of the sourco by opening the ahutter without, firot, removal of the Expamot guard panol, then incertion of the reatricted key and unlocking of the devico.
Reactivation of the lock-out devico in conducted only by Wultox or 543 Company poroonnel who have accoaa to the key.
Plant or customor poroonnel are not permitted to reactivato nor have accoco to the locking key.
Typical renoona for lock-out of the Wultox are Wultex malfunction, rolocation of the nuh motor or replacomont
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f of the conveyor belt.
No routine maintenance of the Wultex by plant personnel requires access inside the Expamet guard panels nor lock-out of the Wultex to prevent possible personnel exposure.
l (c3)
Source removal procedure.
The 50 mCiAm241 source in the Wultex source holder will be removed for wipe testing, for source replacement, for ash meter relocation or for recommission of the Wultex ash meter.
The procedures are the same as the 21-step Source Installation except that, for removal, the source is placed in an Amersham shipping container instead of a source holder, the radia-tion warning signs are voided and the record keeping reports state the exact status and location of the source or sources.
The shipping container will be immediately locked in the 543 Company vehicle and will not be held nor stored at the plant outside of the Wultex ash meter.
No other servicing operations require removal of the source from the Wultex source holder, All electronic and maintenance repairs inside the Expamet Cuard panels are conducted by qualified Wultex or 543 Company personnel.
In the ovunt of fire or accident, the Americium source is first secured by 543 Company personnel and removed as appropriate.
Continued review of the license application is requested and we believe the above information is adequate for evaluation.
Because of the urgency of this topic, we would like to visit your offices to supply any additional.information needed.
The proposed dates are in ordar of preference, July 6, July 8, or July 11.
We will phone to confirm a suitable time.
Sincerely,
<fb
$W F.. Stewart, President The Five Four Three Company
Enclosure:
Orade Report of WVU Pages 25-26 of procedures cc:
Terry Buxton, Wultex U.S. Inc.
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