ML20141M286
| ML20141M286 | |
| Person / Time | |
|---|---|
| Site: | 07002930 |
| Issue date: | 07/22/1980 |
| From: | Stewart R FIVE FOUR THREE CO., INC. |
| To: | Jonathan Brown NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20141J561 | List:
|
| References | |
| 16897, NUDOCS 8602270699 | |
| Download: ML20141M286 (16) | |
Text
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o (j, fME FIVE FOUR THREE C0 INC,()
4 Rt. 4 Son 228 h _i,., W V 26505 Rt. 8, 3ox 2283 Morgantown, NV 26505
'7-2 2 - SO
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License Management Branch Division of Fuel Cycle and Material Safety
~
U.S. Huclear Regulatory Commission Washington, D.C.
20555 1G397 AT23NTION:
Joseph M. Brown, Jr.
2273REUC3:
Mail Control no. 11197 Gentlemen:
Refe* ring to my application dated Hovember 3, 1978, for a Special Nuclear Material license to posceas and u e plutonium cources and to Mr. 3rown's reply of January 25,19 /9, I wish to alter the application to climinate possession of sources, and limit the application to installation, leak testing and exchange of sources as subsequently described.
Essentially this application ic to provide Health Physica Services at licenced facilities which will not requii'e possecca.cn or use of cources on 545 Company property, beyond the use of calibration sources.
It is the intent of the 543 Company to encourage and assist replacement of all plutonium sources with curitm 244.
Accordingly the following information is submitted concerning the coal company facilities which will possess and use the sources, and does not include facilities of the 543 Company to be described in subsequent applications.
One problem area is that Regulatory Guide 10.3 is logically arranged to provide application information for a facility using special nuclear material, rather than for several different industrial installations.
Tnus, thic applica-tion is primarily concerned with the safe use of sources in industrial devicec.
Applicant states that he has been providing Health Physics Services for Sortex Ash Monitorn for over seven yeare, initially under URC license to the Bureau of Mines, Morgantown, NV, and for the past three years under Department of Energy regulations at the Morgantown Znergy Reccarch (Technology) Center.
I further claim to be the most knonladgabic and skilled. professional in this country concerning the safety featurec and practices involved in the industrial use of 3ortex Ash Monitors.
This experience includes the Health Physica Servicca for the first three ach uonitors in the United States, and the research and testing necessary to confirm adequate safety under an agreement between the National Coal Board of 2ngland and D03, for.nerly the Eureau B602270699 851203 REG 2 LIC70 SNM-1872 PDR t-o
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(j of Mines.
However, safety responsibility by D03 ic now terninating and this ar7,11 cation is to continue an accident-free Health Phycles Service, based on the e::perience acquired in the past seven years.
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The following information is submitted in the order of the specific questions in Mr. Brown's letter of January 25, 1979, and using the paragraph numbers of Guide 10 3.
4.3 Manufacturer and Model Number.
The Sortex Ash Monitor is manufactured by the Gunson Sorter Company, Ltd, England, and currently distributed by Hebden, Schibe and Smith Inc., 1699 Washington Road, Suite 301, Pittsburgh, PA 15228.
The Sortex Ash Monitor was formerly distributed by the Sortex Company of North America, Lowell, Mich., and test monitors have been loaned in the U.S. by the National Coal Board of England.'
The Sortex Phase 2A ash monitor and the Model 3A and Model 3A2 are or should have been registered with the NRC with the use of two 10mCiPu 238 sources.
These are low energy photon sources in X131 capsule, Amersham Model PPCL, catalog number PPCl3144.
Amersham plutonium-238 sources provided before 1975 contained an impurity level of plutonium-239 of twenty percent by weight and after this date just under ten parcent.
The recommended replacement of Pu 238 sources is Curium-244 low energy photon source in y131 capsule, Amersham Model CLCL of 20 millicuries each, two being required.
The source capsules are manufactured by the Radiochemical Centre, Amersham using Certificate cf Approval Design SFC 144, Drawing No.
BRC 10318/S Issue A, and specification RSD/CTR/59 dated June 1974.
Information relating to this Certificate can be obtained from the Department of the Environment, 2 Harsham Street, SWI 323, London, Telex 22801, answer back DOE, Marsham, London.
Sources of Pu238, Em 244, and Am 241 in this design have been evaluated and tested for seven years at the U.S. Bureau of Mines, now Department of Energy, without leakage or corrosion or any damage or loss of radio-active material in both laboratory testing and supervised actual plant use.
4.5 Descriotion of control procedures.
The key locking system of the Sortex ash monitor uses four separate keys, two that permit the device to be turned on and off and two more that permit the 120-pound lid to be unlocked and unbolted for access to the installed
' sources.
These security devices are described in the Sortex Manual and in NRC registrations.
It is the responsibility of the source installer to instruct company personnel concerning location in the plant of these four keys, two retained by plant operators and two by the administrative safety officer.
This instruction is given at the time of source installation by the applicant, R. F. Stewart, at a formal lecture to the licensee users and safety officer together with additional NRC posting and record keeping required by the specific license.
Compliance with these and all URC regulations 9 1s verified at each 6-month leak test and by NRC Compliance Inspectors.
Additional shielding and security features of the Sortex Ash Monitor are described in the manufacturer's manual.
Since the monitor design prevents personnel access to any detectable radiation, emphasis is placed on instant alarm for loss of source, an automatic electronic shutdown.
Only a qualified radiation worker with access to foar separately stored keys, tools, and a lid hoist can gain access to
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the source holder.' In the event of plant accident damaging the two-ton monitor, plant personnel are instructed to call emergency radiation services at posted phone numbera.
A fifth security device is characteristic paint marka placed on the source holder retaining screws, which serve to prevent screw loosing from vibration and which prevent removal without cracking the paint marks, indicating alteration.
THese paint marks are known only to manufacturer's technicians and source installers and not to plant personnel.
These five independent methods provide source security through 1) formal instruction,2) separate key storage,3) h'oist and tool requirements,
- 4) automatic alarm on loss of source, and 5) paint marka/ cracks to indicate unauthorized removal.
4.4 Connany Personnel to Suoervise Material.
The only and sole person of the 543 company who will directly supervise the use of radioactive material under this application is Robert F. Stewart.
In the event of emergency or incapacitating illness, the company Board of Directora has a list of fourteen qualified radiation workers at she Department of 2nergy in Morgantown and at West Virginia University who have agreed to assist in an emergency, only after the Board of Directors phones the NRC concerning the circumstanceo.
A copy of the 543 Company Radiation Safety Manual is enclosed aa-Appendix A.
This manual is patterned after that of the U.S.
Department of 2nergy because of years of familiarity by the Board of Directors and is far too elaborate for the present quite limited application.
However, it serves for a future goal as'the scope of the company enlarges.
4.5 Descriution of Equicment. Facilities, and Instrumentation.
The 543 Company fac111tico include an isolated two-room radioisotope laboratory, each room approximately 120 square feet in floor size, containing work benches, instruments, and shielding materiala.
The locked laboratory is located adjacent to the main office, all build-ings called the Main East Research Center (MERC) in Union District, Monongalia County, West Virginia, being a part of the real estate i
described by deed dated June 25, 1959, of record in the office of the Clerk of the County Commission of Monongalia County, West Virginia, in Deed Book No.575 at page 222, supplemented by additional real estate described by deed dated March 14, 1980, in Deed Book i
836 at page 677.
i The bulk of the equipment and instrumentation located within the radioicotope laboratory is used beyond the acope of this appli-cation.
The primary instrumenta useful for installation and leak testing of cources and area survey which were operable and cali-brated on June 15, 1980, are:
i n.
Molochem Low Level Counter Model 30,/m, with count rate Sorial No. 178, for alpha measurement censitivity of 2 c 1
of 250 15 c/m for a 0.005 microcurie calibrated alpha cource using colid state detector, uaed for measuring awab wipes.
b.
Victoreen Model No. 6A Serial No. 345545, beta, samma 0.1 mr/hr for surveying.
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Victoreen Model No. 6A Serial No. 343324, beta, gamma 0.1 mr/hr for surveying.
d.
Victoreen Model No. 63 Serial No. 277183, bota, gamma 0.1 l
mr/hr for surveying.
Backup instrumentation operable and calibrated if appropriate is listed in the Instrument Inventory.
Additional description of equipment, facilities, and instru-mentation available but not necessarily useful for purposes of this application include 4.5.1 Remote handling devices include one to three-foot tongs six each, a twelve-foot telescoping clamp, a dosen six-to twelve-inch special purpose pliers, two each remote angle dental mirrors, l
one angular beam flashlight, one high-intensity deck lamp, two l
reverse angle swab holders, one-ton chain hoist, and one cable wrench.
l 4.5.2 Storage containers include six lead piga of 1 to 42 l
pounds, approximately 600 poundo of assorted sine lead bricks, l
sheet lead and strap, 20 each solid cement blocks, and 200 pounds of paraffin blocks, four tool cheats with key locks, one briefcase with keylock and one trunk-locked company vehicle.
4.5.3 Protective equipment includos rubber and disposable gloves, film badges and dosimeters, rubber apron, goggles and dia-posable bench covera.
Since no work is done nor planned with unsealed sources, protective equipment is planned for omorgency, not daily, use.
4.5.4 A line drawing sketch of the radioisotopo laboratory is shown in figure one illustrating the nature and une of areas adjacent to the laboratory.
4.5.5 The radiation detection instrumento are listed in l
paragraph 4 above and in the Instrument Inventory.
The instrument calibration mathods currently in uao concist of calibration and measurementa using accondary exempt reference cources which in turn are calibrated against primary standards at '. lost Virginia l
University and the Department of Enorgy.
l The bota/ gamma survey matera are calibrated and roset within
- 5 porcent at 6-month intervals or following each repair by transport to the Department of 2norgy for calibration with NBS primary standarda using a two-point calibration method for each l
scale.
Each motor is then checked daily when in use for operability l
within 120 porcent of the midacale using the built-in cource.
l l
The Holochen alpha counter la calibrated at 6-month intervals uaing a D02 primary courco of Am 241 certified by UB3 to contain O.006 microcurica depositod on a platinum dick.
This standard, placed in a vipo toat planchot, producco 240 to 260 counta por minuto, equivalent to a cena itivity of approximately one-hundredth of 0.005 microcurios of removablo alpha contamination.
Operability of the one scalo of tho alpha counter la determined beforo and aftor cach wipe toot carica uaing a secondary uranium avab standard L
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emitting 0.002 microcuries 4 percent of alpha radiation.
Tho Molechen alpha counter has a background count rate of less than 0.01 cpm with discriminator set at 4 Mev.
Amplifier noise is 10 Kev, RMS typical and a count capacity of 9999 standard.
Accuracy of calibration of the Molechem alpha detector is better than *5 percent full scale.
Using a wet test awab of cotton and acetone on a uranium plate, less than 0.0002 microcuries of removable contamination can be detected depending on the extent of swab scrubbing and swab extraction and evaporation on a planchet.
Any removable contamination from the beryllium source window of a
?u 238 source in amount above 0.0003 microcuries indicates the possibility of corrosion and leakage within the next six montha.
Such an indication, well below 0.005 g Ci of removable contamination should require removal of the source lor detailed laboratory examination.
No dry paper wipe test is adequate measurement of a hacardous source that should be removed from use.
Calibration of survey instruments is conducted in accordance with URC Regulatory Guide 10.6 (proposed revision 1 in 1950).
However, for use with low energy photon sourcea of Pu 238, Cm 244 and Am 241 used in the Sortex Ach Monitor, no detectable radiation can be determined at any accessible point on the monitor regardless of source on or off position.
Thus, while a negative-type curvey is conducted before and after source installation, no reliance can be placed on such a curvey.
Only a wet acetone wipe test of the cource and source holder with negative results can acnure abaence of alpha contamination.
The 543 Company plans to calibrate its own curvey and measure-ment inctruments using the procedures and methods developed and used by the applicant, Robert F. Stewar c, during twenty years of profeccional radioicotope research at the U.S. Department of 2nergy, formerly 2RDA and the U.3. Bureau of Mines.
It is not appropriate to further describe the calibration proceduroc for survey instrumenta used relative to this limited application for low energy photon cources for which conventional curvey instrumenta are ineffective.
Such a description would involve the relative efficiencies of detecting 12 to 18 key gamma rays and of 2 to 5 Mov alpha particles with variable air absorption.
A future objective of the 543 Co=pany is to develop a satisfactory standard method for effective and acceptable measurement of low energy inductrial devices.
3uch a procedure would incorporate the principlea outlined in paragraph 4.5.
4.6 Procedures to ensure compliance with provisions of 10 C?R Part 19 and 10 CFR Part 20 are primarily concerned with instructions to coal plant personnel who are responcible for use of Sortex Ach Monitors, rather than to perconnel of the 543 Company.
It ic quite fencible for a Health Phycica Service company to inctall, leak test and exchange for diapocal, those industrial cources needed for an ach monitor, without ever poaceccing or receiving auch sourcea.
The cources are shipped by Amercham directly to the URC or agrcement state licensee.
They will be received, inapected, and installed by R.F. Stewart on plant property.
Area curvoya are made befora and after inctallation to verify abaence of any measurable radiation at accecaible parta.
All requirementa of the URC licence and information given in the company application are verified, including
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notice requirements, record keeping, labeling, etc.
A formal lecture is given to preacheduled plant personnel concerning source security and safety requirements, posting requirements,. operation of equipment, emergency procedures, and all items'of, radiation safety that may be encountered in the dis-charge of duties..
At sik-month intervals, a' leak test is performed on each source together with visual examination of source window for evidence of wear or. corrosion.
In seven years of investigation of safety feature and monitoring of plant operations no hazardous condition or safety infraction has been found.
This includes sale and restorage of ash monitors, plant fires.where fire hoses were turned on the two-ton monitors without damage, and loading rail car urecks into the loading tipple building concaining tne overhead monitor.
The largest potential danger is from years of coal acid condensation and corrosion which has damaged locking devices but not the source or source holder.
i 4.6.10 Coal Plant Personnel.
The training of coal plant l
employees includes a listing,of all employees who will come within the. area of installed Sortex. Ash Monitors, assignment of ladividual responsibilities, and instruction in radiation safety and source security at the time of source installation with verification and additional instruction at 6-month intervals.
For the Elkay Mining Company, Lyburn, WV, 25632, application of 12/14/79, the following employees are scheduled for instruction:
l Robert L. Culberson, Plant Superintendent William Cwens, Plant Foreman Darrel (sp?) Foxx, Plant Foreman
[
Ronald Townsend, Blectrician Richard McGuire, Electrician Cha'les Preston, Operator Glen Craddock, Operator Optional e=ployees:
Gene Chaffin, Sampler
[
Harold Curry, Sampler Harlan Podunavac, Sampler For the Badger Coal Company, P.O. Box 436, Philippi,
'.IV, license 47-14771-01:
3am Laws, Plant Superintendent l
Bill Dean, Foreman j
Bob Hedrick, Foroman i
Gene Baker, Electrician Dennis Hines, 21ectrician i
Dave Tollman, Operator Boy Pettitt (sp?), Operator.
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-Cptional employees:
Leby Sturn Marlin Rosier Jerry Robinson Stanley Greggory (sp?)
John Love John Fenny L
Dave Lonbert Mickey Mitchell For the Pittston Coal Company, license No. SHM 1617, the employees are:
?.L. Stanley, Preparation Engineer Andy Hall, Superintendent William Patterson, Foreman 2aul Co6nts, 31ectrician Sam Sanders, Asst. Superintendent L
Among these employees, it is customary and advisable to choose
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one employee during the instruction period to be the Acting Radia-tion Safety Officer and contact point who will receive additional l
irstructions during the first six months of operations.
While the Plant Superintendent must concur and is responsible for radiation i
. safety, this acting RSC, usually an electrician, bears the day-l by-day responsibility for successful and safe use of the Sortex L
Ash Mon! tor.
He is phoned weekly for the first month and monthly l
until the 6-month leak test concerning operation of the monitor and source security.
4.6.5 Record Management and General A Radiation Survey drogram applicable to the Sortex Ash Monitor has been described previously.
The primary emphasis L
ic on alpha survey by wipe testing because of the Ash Monitor design and safety features.
A report of the negative-type survey is sent to the coal company by the 543 Company with each Leak Test Report which essentially reports the absence of any measurable radiation before and after each installation or leak test.
A conflict may exist between the Licensing Division and the Compliance Division as represented in prior years by Dr. W. H.
Young, an AEC Compliance Inspector, Atlanta.
Dr. Young, upon plant inspection, insisted that a Leak Test and Area Survey Report filed by the coal company should be a simple report stating less than 0.005 401 of removable contamination and no detectable radia-tion.
He definitely did not want any details of accuracy, repeat tests, methods of calibration, etc.
Both type reports are supplied by the 543 Company to the coal company, one a simple statement, the other detailed technical results.
Copies of both type reports are retained and available from the 543 Company for five years.
Typical reports are enclosed.
4.6.4 Waste Disposal Low energy photon sources of 10 or 20 mci of Pu 238 or Cm 244, no longer in use are disposed of by return to the supplier, the Amersham Company.
Disposal of no other radioactive L
b' ms cateri"' is required within the litited scope of this application.
Sincerely, fp WS Robert F. Stewart President and Board I~ ember The Five Four Three Company Rt. 8, 3cx 228E 1:organtoun, TI 26505 304-599-7101 gs 93 7/0/
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RADIATION SURVEY OF ROOM 38A Do Not Move or Disturb any Material in this Room 1.- Make an area survey of the room on the attached form, marking the location of sources and the maximum activity it accessible areas.
Note that the Model 700 survey meter is not calibrated when used with an open window but does measure beta and gaena radiation.
Description, i.e.,
" block spot test plate", " surface of desk", " drawer Type activity 2' from floor",
(alpha, beta, Maximum Source No.*
etc.
narna, neutron) activity
- Encircle source number on form, numbering from 1 through 10 or 12, starting at door.
2.
For a Bureau of Mines Radiation Worker, the " maximum pemissible dose" of radiation to whole body is mr/ quarter or mr/ hour; for a hand or foot exposure this value is__
mr/ quarter. For a non-radiation worker employed within the Bureau, this value is r/ year.
3.
Measure and estimate the maximum permissible working time of an employee sitting in the chair
-If the radiation flux were 100 times larger, the maximum permissible working time would be
. Signature Date
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<g AR U SURVEY CHART-COAL RECYCL Q YSTEM Test bin d '
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LOCATION GAHMA READING,HR/HR NEUTRONS, MR/HR A
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F OTHER AREA SURVEY BY DATE AND TIME OF SURVEY INSTRUMENTS USED SIGNED FILE HRC 44, ROOH 8.
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ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION MORGANTOWN ENERGY fiESE ARCH CENTER
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P.O. Boa 8 8 0 Collins Ferry Road Morgantown. Y/est Virginia 20505 July G, 1977 I
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Stanley, Prop Eng.
Pittston Company
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- non, Va.
24266 l
7'.c Nr. Stan1cy, I
I G as discussed with Grady. Enclosed are the 1,cak testing certificates of i
4/77 and September-3, P. ': pac Sincerely, A12itralo, HERC ce
- iCwallace, Jr., RERC fhf(','
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s'ile R. F. Stcwart Analytical'Eciuipment Rescarch and I
Developmenc Branch I
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Installatad and 1.cah Testing of Phase NAsh. Monitor On September 3,1976, the two 10 mei Pu sources were wipe tested and installed in the Sortex Phase 3A Ash !!onitor at the Pittston Company preparation plant, I.cbanon, Virginia, in accordance with NRC licence No. SRI-1617, Amendment No. 01 dated August 12, 1976, e,:piring March 31, 1981.
Sources number Z3792 and Z3793 were un-
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packed Trom the Amersham shipping container, Customer Order No.
0518A, Lab Order lio. E19510 at 9:50 a.m.,
September 3, 1976. in the office of Bill Patterson, Moss #3 Preparation Plant of the Pittston Conpany, Clinchfield Coal Company Division.
The sources were inspected, photographed, wipe tested (see page 40) and installed in the source holder of the Ash Monitor, carried to the in-place monitor and installed in operable cond.ition.
Area Survey monitoring of accessibic surfaces showed no radio-activity above background and less than 0.06 mr/hr gamma radiation.
The monitor was labeled 20 mei Pu 238, dated 9/3/76 as leah tested.
One identifying gunned label was placed inside the removable source holder and a duplicate placed on the outside surface of the monitor attached to the radiation sign.
The sources were subse'quently certified to have less than 0.005 microcuries of removabic contaminatio'n based on measurement of the swabs and planchets described on page 40 of the Contracting Record Book maintained in R216 of MERC, Morgantown, Kest Virginia.
The swabs were tested and measured with a Model 30, Serial 78 Molechem Alpha counter calibrated by a sensitivity test on 9/6/76 of an NBC Am 241 source standard of 0.006 uCi placed in detector and reading 216 counts per minute.
The installation of the Phase 3A Ash Monitor at Mass #3 of J
the Pittston Company is considered to be in accordance with standard Health Physics Practices, in accordance'with the intent and restrictions i
of NRC license No. S!O!-1617 and satisfactory for operations from all safety viewpoints.
It is recommended that future inspections and leak testing of
'[
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sources be conducted within a few weeks of routine operation of the Ash lionitor.
It is estimated that some time may be required to obtain routine operation because of possible material handling and electronic problems independent of radiation safety.
During this time interbtl between installation and operation, the sources cannot be considered to be "in use" nor "in storage" where separate safety con-siderations apply.
Because of the possibility of corrosion, wearing of surfaces by the moving coal and similar possible operational prob 1 cms, the sources should be inspected and leak testc d about four weeks after operations begin, and again after three months.
MshJ F. Steuart s.
Staff Scientist O
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' Leak Testing C fication of Pu 238 Sources-Mods No. 3, Pittston Coal Co
'On June in the Sortex Phase 3A Ash Monitor at24, 1977,'the two 10 mei Pu sources were wip Lebanon, Virginia, in accordance with NRC-license No.the Pittston Company prepara SNM-1617, Amendcient No. 03 dated August 12, 1976, expiring March 31,.1981, issued to the Pittston-Company, Clinchfield Coal Company Division.
The sources were inspected for
. thear, wipe tested and surveyed in the source holder of the Ash Monitor to the in-place monitor and re-installed in operable condition.
carried monitoring of accessibic surfaces showed no radio-activity above backgroundArea Surve and less than 0.06 nr/hr gamma radiation.
Pu 238, dated 6/24/77.as leak tested.
The monitor was labeled 20 iaci-
' surf ace of the.monit or attached to the radiation sign.i The-sources were subsequently certified to have less than 0.005 micro-curies of. removable contamination based on measurement of the swabs and planchets described on page 44 of the Contracting Record Book maintained in R216. of HERC, Morgantown, Uest Virginia.
The swabs were. tested and measured with a Model 30, Serial 78 Molechem Alpha counter cal.ibrated by a sensitivity test on 6/27/77 of an NBC Am 241 source standard of 0.006 uCi placed in de-tector.and reading 248 counts per minute.
The operation of the Phase 3A Ash Monitor at Moss #3 of the Pittston.
Company is considered to be in accordance with standard Health Physics Practices, in accordance with the intent and restrictions of NRC license No SNM-1617 and satisfactory for operation from all safety viewpoints.
s
~
Y bwW R.F.' Stewart Paul Counts, Rod. Prot.,
Staff Scientist. ERDA cc:
Officer, Moss #3 Morgantown Energy Research Center F. L. Stanley, Prep. Eng.,
.P.O.
' Box 880,
.Pittston Co.
File Morgantown, West Virginia, 26505
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