ML20141M398
| ML20141M398 | |
| Person / Time | |
|---|---|
| Site: | 07002930, 07002888 |
| Issue date: | 11/03/1978 |
| From: | Stewart R FIVE FOUR THREE CO., INC. |
| To: | |
| Shared Package | |
| ML20141J561 | List:
|
| References | |
| 11197, NUDOCS 8602270755 | |
| Download: ML20141M398 (7) | |
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FILE 543-1 70-198v APPLICATION FOR SPECIAL NUCLEAR MATERIAL LICENSE
- 1. Applicant:
The Five Four Three Company, Inc., a non-profit company incorporated in the State of West Virginia, with principle offices at Route 8, Box 228F, Morgantown, West Vir-ginia 26505.
Phone (304) 292-9729.
The principal officers
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of the company are ROBERT F. STEWART, President and Chairman; Board of Directors:
DR. JOSEPH V. PANEPINTO, Ms. BEATRICE B.
HUNTER, and DR. RUTH ANN PANEPINTO, all United States' citi-zens, with residence in Morgantown and Fairmont, West Virginia.
- 2. Application is made to permit the incidental use of radio-active sources in ash and sulfur monitoring instruments owned by and located at various coal company plants throughout the United States. The primary purpose of the Five Four Three Company (543 Company) is to develop procedures for the safe use and operation of nuclear gages used for measurement and quality control of coal.
Development of these procedures re-quire the experimental use of radioactive sources, or instru-ment calibration standards, the use of gage sources to develop safe methods of source installation, inspection, leak testing and relocation of gages.
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Increasingly, the need for product and service standards, equit-ably developed and fairly implemented, has been accepted as cru-cial to the functioning of the, marketplace.
These standards are regulatory and nonregulatory in nature.
Many are designed to achieve health and safety objectives.
Over a period of years, the private and government sectors have developed a variety of testing procedures to determine whether a product or service conforms to a designated standard.
Essential to such a system is a national pro-gram to evaluate technically and. accredit laboratories.
The basis of such a program is the development of specific procedures 2nd methods for 1) testing of a product or service, 2) evaluation of the method by independent laboratories usually by a "Round Robin" of testing to establish accuracy and precision, and 3) recommenda-tion of the proposed standard to a national group for accredita-tion and adoption.
The 543 Ccmpany is formed to experimentally formulate and test pro-cedure based on newly developed technology requiring new standards for commercialization.
For example, ash and sulfur monitors for continuous, on-line measurement of the ash and sulfur content of coal streams have been developed to monitor high tonnage flow streams of coal.
These instruments use radioactive materials licensed by the Nuclear Regulatory Commission for industrial use.
Standards must be developed and tested for the safe installation, periodic leak testing and replacement or disposal of the radioactive sources used in such instruments.
Successful standards for the safe use of coal monitors would increase the use of the eastern high-sulfur coals in a more environmentally acceptable and economically sound manner.
It is essential that procedures leading to such national standards be developed in an equitable and fair manner.
For this purpose, a not-for-profit, unsponsored and completely independent professional group of highest ethical standing is appropriate.
The 543 Company is associated with but completely independent of the American Chemical Society (ACS), American Society for Testing and Materials (ASTM), and the Professional Association of Independent Scientific Laboratories.
The 543 Company has made application for committee membership in the National Voluntary Laboratory Accredi-tation Program, Department of Commerce.
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In the development of procedures and standards, the experimental work of the 543 Company will be conducted primarily at plants, fa-cilities and laboratories licensed by the NRC, or operated by con-tractors of the Department of Energy.
The actual ownership and possession of radioactive materials will be limited to instrument
' calibration standards for gages, survey and leak resting instru-ments.
The use of larger gage sources will be incidental rather g
dummy sources for testing and instruction.than operational, as necessary to develop p
- 3. This license is requested for a period of five years.
- 4. The special nuclear material to be used under this application:
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A. Plutonium 238 Two (2) sealed sources of 10 milli-curies each (Amersham /Searle Model PPCX)
The special nuclear material to be possessed under this appli-cation:
A. Plutonium Instrument calibration sources in-L' cluding NBS certified sources not to exceed a total of 50 microcuries
- 5. Place of use:
Industrial coal plants, testing laboratories and facilities throughout the United States licensed by the NRC, Agreement States, or operated by contractors of the Department of Energy.
- 6. Training and Experience:
Applicant states that all professional and technical em-ployees of the 543 Company will be qualified by reason of train-ing and experience to develop the procedural standards submit-ted for accreditation.
All instruction and conduction of com-
/ pany radiation work will be done by or under the supervision of 1 Robert F.
Stewart, in accordance with Part 20 of Title 10, all periodic updating of Part 70 and the 543 Company _ Radiation (7 )'
Safety Manual.
The training and experience of Rob'll FT Stewart
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e includes ls' years of laboratory experience on principles and practices of radiation protection, radioactivity measurement standardization and monitoring techniques, mathematics and cal-culations basic to the use and measurement of radioactivity and biological effects of radiation.
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No measurable accumulated dose is expected or likely for workers of the 543 Company in the performance of their duties.
When as-signed duties off company property at other cooperating facili-ties,' employees of the 543 Company will abide by the specific safety regulations of that facility when not in conflict with the possibly more stringent requirements of the 543. Company manual.
The nwnber of employees and part-time assistants of the company is k
expected to fluctuate with each' procedural standard, so that emphasis in radiation. safety is in specific training.
For ex-ample, the company's newest employee, R. Chris Stewart, with only two years of general college courses,has received on-the-job training in leak testing of Sortex Phase 3A ash monitors, first with simulated (dummy) sources, then with plant installed monitors under the close supervision of a qualified professional.j Chris is qualified only to conduct swab testing and not complete l leak testing, pending successful completion of a 40-hour course in basic health physics scheduled in December 1978.
- 7. Equipment and facilities of the 543 Company include as a minimum, a one-room radioisotope laboratory and basic survey and monitor-ing instruments, since in most cases, instruments of the co-operating test facility will be available and used at that plant or facility.
Verification of instrument calibration and source standardization will be conducted as appropriate for the specific procedure.
In the event of accident or emergency, back up fa-cilities and equipment will be immediately available from the Department of Physics, West Virginia University, and through co-operative agreement, from the Morgantown Energy Technology Center, Department of Energy.
In addition, notification will be made by phone to the nearsst NRC Office of any incident involving danger to life or property.
- 8. Procedure to protect health and minimize danger to life or property vary with each type application.
The primary purpose of the 543 Company is to develop and test such procedures.
An example of a current problem will illustrate the type procedure.
An ash monitor has been developed in England and offered com-mercially for sale in the United States, as a Sortex Phase 3A Ash Monitor containing two 10 mei Pu 238 sources.
Since 1974, three of these monitors have been used irregularly in the United States without serious problem from the viewpoint of health and danger to property. Both short and long term hazards exist potentially, such as loss of plutonium, wear and corro-sion of the source and source holder, leakage and related prob-lems for which procedural standards are needed to improve safety and operational accuracy.
A schedule of inspection standards are needed as the number and potential hazards of larger numbers of monitors increases with'the national emphasis on coal use and environmental emissions.
Similarly sulfur monitors using other radioisotopes are technically proven, but safety procedures for industrial use are yet to be developed.
Thus, the 543 Com-pany applies for licensing to develop appropriate procedures.
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Attachment:
Appendix A--Fees for Facilities and Material-Licenses.
Signed:
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n Robert F.
Stewart, President
.IHE FIVE FOUR THREE CO., INC.
Rt. 8 Box 228
/ Company Stamp]
' Morgantown, W V 2650s
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APPENDIX A Fees for Facilities and Materials Licenses Application for exemption of license application fees is requested by the 543 Company under Part 170.11 (a)(9)(b), on the basis that the 543 Company is incorporated as a non-profit corporation for the purpose of developing procedures "to establish standards for products and services in industrial nuclear chemistry rela-tive to the safe use of radioactive materials in industrial plants and testing laboratories."
Incorporation Articles filed in the Office of Secretary of State of West Virginia, 1978.
However, in the unlikely event of an accident or emergency pro-cedure which occurs during the development of such procedures, the 543 Company proposes that the NRC consider this application as a Special project under Part 170.12 (f), with fees to be pay-able upon notification by the NRC, when review has been completed of such an unlikely event.
Statement of Consideration.
Incorporation of the 543 Company, a
non-profit institution under the laws of the State of West Virginia, provide for exemption of taxes and fees together with provisions for the regulation of the internal affairs of the corporation that restrict the 543 Company from payment of fees to, conduct the primary purpose of the company, development of radiation procedures.
De-velopment of procedures include experimental testing, inspections and training which may, as an incidental and unexpected part, dis-close the existence of a hazardous condition requiring immediate corrective procedures.
A hypothetical example is described to 11-lustrate the condition:
Procedures are being developed for ash and sulfur monitors installed in industrial coal cleaning plants for process control of high tonnage coal streams. ' The. procedures may involve installation-of radioactive sourges_in the gages, pro-cedures for inspection or operation, for routine liak' testing'or~
for removal of the coal monitors.
During development and testing of such procedures, it may happen that cn accident or emergency is disclosed, such as wear or dislodgement of the source holder requiring immediate corrective action.
This is an unlikely but possible emergency event that has not occurred in years of opera-tion, and to prevent such accidents, specific procedures and emergency procedures are preplanned.
Despite all precautions, such an emergency may be d'sclosed for which a representative of the 543 Company is uniquely qualified to remedy.
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Sound health physics principles and practice dictate that the representative of the 543 Company provide corrective procedures, that he be trained and qualified for such an emergency and that he follow through with required reporting and notification of such an incident.
Under such emergency conditions, the purpose of the 543 Company changes from academic to emergency, the requested classification of the 543 Company license changes from exempt to special project and the fee payable upon notification by the NRC when review of the incident is completed.
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