ML20148G925
| ML20148G925 | |
| Person / Time | |
|---|---|
| Site: | 07001359 |
| Issue date: | 10/13/1978 |
| From: | Mortz R IRT CORP. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7811130300 | |
| Download: ML20148G925 (17) | |
Text
{{#Wiki_filter:.. ' 5'.. l 7 3 iRT Corporation instrumentation lResearch / Technology ,:% CCT 16 i:.9 \\C 55 October 13, 1978 (t4P,C pyguC DOCUM,'.gm U. 0. _n U. S. Nuclear Regulatory' Commission Attn: Mr. L. C. Rouse, Chief Fuel Reprocessing & Fabrication Branch Division of Fuel Cycle and Material Safety Washington, D.C. 20555
Reference:
Docket 70-1359 SNM 1405 Gentlemen: Amendments number 4 and 8 of the referenced license specified that all SNM used at our Convoy Court facilities would be encapsulated. It is requested that the subject license be amended to allow the use of unencapsulated SNM at these facilities in limited quantities as follows: Material Form Quantity Use 235U Any < l.0 microcurie Research and Development ~ Pu Any < 0.1 microcurie Research and Development It is understood that this amendment requires a safety and environmental review by your office and that a maximum fee of S1,400 is associated with this review. A check is included with this application and the attached supplement provides a description of the. use, controls and procedures for handling these limited quantities of material. Thank you for your prompt attention to this request. If you have any questions or require additional information, please contact Mr. K. L. Crosbie at (714) 565-7171, extension 378. Yours truly, )ln A .i . L. Mert: J President RLM:wg Enclosures 4 m. A.MA. J 7650 Convoy Court
- P.O. Box 80817
- San Diego, California 92138 714 / 565-7171
- Telex: 69 5412 7g
~ IRT nIC-Corporation SUPPLEMENT TO AMENDMENT REQUEST FOR UNENCAPSULATED SNM AT 7650 CO!NOY COURT Limitation of Materials The specific quantities requested are minimum significant quantities listed in Table II, page 31 of IALA publication " Safe Handling of Radio-235g is isotopes," where the Pu is considered as very high toxicity and considered as high toxicity. This table also lists the type of laboratory required for handling certain amounts of these materials under various This minimum amount re-conditions using appropriate modifying factors. quested is not in excess of the amount which can be handled in a Type C (good chemistry laboratory) facility, even if the most severe modifying factor is applied. Safety and Handling Considerations The IRT Radiation Safety Committee, which reviews all in-house programs utilizing radioactive materials, has established a set of general safety rules for handling uncontained radioisotopes. If at all feasible, operations should be carried out within the 1. confines of a hood or glove box, even if the quantities are sufficiently small to warrant open bench top operations. All operations involving finely divided particles of pyrophoric 2. radionuclides must be carried out under an inert atmosphere within Storage of these materials must be in fireproof a glove box. containers. Keep work area free of all unnecessary equipment and cover work 3. area with protective absorbent paper. If possible, carry out operations within containers or catch trays and keep tools, in localized area within suitable containers. equipment, etc., Plan operations to minimize handling and transfer of materials 4. and amount of material used. e
IRT Corporation Supplement to Amendment Page 2 Keep waste generation to a minimum and maintain vaste containers 5. in immediate area; keep SNM and by-product wastes segregated. Contact Health Physicist for specific instructions for disposi-tion. Use protective clothing as necessary and monitor self prior to 6. leaving work area. Do not handle loose material directly; use tongs, tweezers, 7. Do not use mouth technique for pipetting pipettes, etc. operations. Make routine contamination surveys daily until operational 8. techniques are perfected and then if warranted on a weekly basis. Send wipe samples to Health Physics for analysis. Use portable air sampler in vicinity of operations whenever j 9. operations are in progress. Sand samples to Health Physics on daily basis for analysis. Store materials when not in immediate use in hood and return to 10. Health Physicist for storage when operations are completed. Store materials in closed metal cans and, if liquids, include enough absorbent material in container to fully absorb all material. In case of spills or any unusual events, contact Health Physicist 11. or Radiation Safety Officer for assistance. Other more specific requirements may be imposed by the Radiation Safety Committee contingent upon the particular program. As a general rule, the Health Physicist or Radiation Safety Officer will be present for the initial operations of any nonroutine program. In determining the amounts of materials which may safely be used outside a hood or glove box or within the confines of a hood, the Radiation Safety Committee follows the guideline, "Workplaces for Unsealed Radionuclides," authored by Mr. D. Pickler of the State o. California Radiologic Health Unit. This document is more restrictive than the recommendations referred to under the Material Limitation Section of this supplement.
IRT Corporation' 1 Supplement to Amendment ') Page 3 I lt ium i As an example, the Pickler limit for use of uncontained p u on outside of a hood ranges from 200-picocuries for the most hazardous operation to 2-microcuries for the least hazardous operation; the other reference sets limits of 100-nanocuries to 100-microcuries for these This guideline does not consider external radiation same operations. External radi-protection in setting the specific amounts of materials. j The ation protection is considered elsewhere in the program review. Radiation. Safety Committee does impose a modifying figure of 0.1 for 'i highly toxic alpha emitters such as plutonium, americium, curium and f californium, which in effect lowers the limits by a factor of 10 for all f The Pickler guideline is included with this supplement. \\ operations. l Location of Activities _ Thu 7650 Convoy Court facility has been described in previousFor It contains several laboratories where SNM is.used. amendments. The comLination reference, Figure 1 shows the layout of the facility. 600, 601 and 604 has been modified recently to provide a chemistry of labs This area is equipped with several hoods, work lab and counting room. All Figure 2 shows the area in more detail. benches and a glove bo:5. activities requiring a hood or glove box will be confined to this area and in following the general safety rules set by the Radiation Safety committee, essentially all activities involving uncontained SNM will be conducted in this area. I 1 l Representative Program _ A laboratory bench scale program is planned for measuring long lived ] radionuclides (fission products and transuranics) which may be present in filt.ers used to sample gaseous effluents from several nuclear power P ants.-.This will require the use of sub-microcurie amounts of plutonium l Two isotopes transuranics, and microcurie amounts of by:-product material. 236Pu is 'L. of plutonium are used in the radiochemical separatory process. 239Pu is used to prepare standards used as a tracer in'the real process and 4 1 4
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i WORK BENCH k pl GLOVE HOOD H000 BOX 4 WORK '~ BENCH g H000 WORK BENCH h j L O I COUNTING ROOM 4 WORK BENCH CHEMISTRY CHEMISTRY H000 LAB g WORK BENCH SINK i h W FIGURE 2. MODIFIED LAB AREA RT-17209
_ ~... 1RT-Corporation'. Supplement to Amendment-Page 4 i These isotopes for checking the efficiency and reliability of the process. are in the form of standard O'.5M hcl solutions with a concentration of The' total quantity of each isotope is 500-picocuries per milliliter. less than 10-nanocuries and the isotopes are supplied in puncture seal medicinal vials to allow microsyringe transfer. The filter samples as received are garna scanned and then subjected ~ The basic to a radiochemical separatory process for further analysis. scheme is outlined below. To check the process, standard filters are prepared by spotting filter papers with known amounts of standard solutions of radioisotopes. The separatory scheme is as follows: Leach the filter material with hot nitric acid. A.l. Add La, Ni, Fe, and Sr 2. Evaporate the acid to a small vol":m. 236 Add 10 volumes of yellow fuming carriers and Pu tracer. nitric acid. Chill with an ice bath for 15 minutes. Decant or pipette the supernate to a clean vessel
- 3.. Centrifuge.
l for the next step, and save the Sr(NO ) 2 precipitate for d 3 subsequent processing (B). Evaporate the supernate from step 3, dilute with water, add 4. hydra::ine hydrochloride to reduce Pu and Am to the (III)
- state, and add HF.
Stir and let stand for five minutes. Decant or pipette the supernate to a clean vessel 5. Centrifuge. for the next step and save the La (Pu, Am, Cm) F3 precipitate for subsequent processing (C). Make the supernate from step 5 ammoniacal by the addition of 6. Stir well and let stand one NHgOH until the pH is 7.5 to 8. minute. Centrifuge. Decant or pipette the supernate to a clean vessel for the next step and save the Fe(OH) 3 precipitate for subsequent processing (D). 7. Add 1 percent dimethylglyoxime (DMG) in alcohol to the supernat.e from step 6. Add NH40H,'if necessary, until Ni-DMG precipitates, stir and let stand one minute. Extract the Ni-DMG into CHC1 7 i 3 i [' l "+-7 --%-6
. (RT: ,1 Corporation. 1 Supplement.to Amendment Page 5 separate the phases, and strip the nickel from the CHC1 3 phase into 6N hcl and save for subsequent processing (E). f The Sr(NO )2 precipitate is dissolved in water and oxalate 3 B. is added to precipitate'SrC 0.H 0, which is filtered, washed, 24* 2 dried, weighed, mounted, and counted. C.l. The La(Pu, Am, Cm)F3 precipitate is dissolved by slurrying q Sodium with a boric acid solution and then adding HNO. 3 nitrate is added. The solution is adjusted to 0.5M H+ and Pu+4 is extracted with Z. 0.5M thenoyltrifluoroacetone - (TTA) in benzene. The organic l , phase is separated. The aqueous solution is saved for step (3), and either: (a) the-organic colution is evaporated on a planchet for the Pu counting determination, or alternatively, (b) the Pu may be stripped from the organic solution into a-reducing (hydrazine) aqueous solution and the Pu electroplated for the Pu counting determination. i The aqueous phase is adjusted to pH 3.5 and Am+3 and Cm+3 are 3. extracted with 0.2M TTA in benzene. The organic phase is sep-arated (the aqueous phase may be discarded) and Am and Cm are prepared for counting on a planchet by direct evaporation and firing of the organic material. Alternatively, Am and Cm may be stripped from the organic phase into 1M HNO3 and electro- 'f .I plated after adjusting:the solution to near neutrality. The Fe(OH) 3 precipitate is dissolved in 6N HCL, and Fe(III) D. is extracted into diethyl ether that has been previously equilibrated with GN HC1. The Fe is prepared for counting on j a planchet by direct evaporation and firing of the organic
- material.
The 6N HCL solution containing Ni(II) is partially neutralized j E. with'NHgOH and alcohol solution of DMG (1 percent) is.added. Additional NHgOH is added'untilLthe Ni-DMG is precipitated, and ~ The Ni is prepared for~ the precip'itate is' extracted into CHC1. 3
- counting by direct evaporation and firing'of the organic material.
j Corpo' ration j l Supplement to Amendment Page 6 f The quantities of materials' involved in the above operation with real -] The filter samples are 1/4 or 1/2 sections of 2-1/2-inch samples are'small. diameter HEPA type in stacks of eight. The total' mass is less than 10-grams. The radionuclides are expected to be in trace quantities only and the SNM In the introduced in the process is of-the order of 50-picocuries. (236Pu) case of standards prepared to test the process, the amount of by-product i materials would be'of the' order of 100-nanocuries and transuranic materials would be of the' order of 150-picoeuries of which 50-picocuries would be SNM These 236Pu would be included in these standard samples. (239Pu). No standards would be prepared in the hood by spotting clean filters with In this approximately 0.lec of material from vials via a microsyringe. the operations involving evaporation, extraction, particular program, leaching, drying, transfers and standards preparation would be carried out j in a standard chemistry fume hood and other operations carried out in the. chemistry lab on bench top and in the counting room adjacent to the chemistry The guideline indicates that all of the operations can be done laboratory. These operations would be generally classified as complex outside'of a hood. 10 x IRT wet operations with risk of spills which allows a maximum of MPC x 10 modifying factors J 10 x lo-1 = 2 x 10-3 pc of Pu 2 x 10-12 x 10 Any single operation falling into the specified category would not involve this total quantity of material. The total quantity of transuranics, (Am ', Cm, Pu) involved with each standard is 40.150 x 10-3 pc. Preparation of the standards would be categorized as very simple wet operations which would to be outside of the hood--this is more than the total allow 200 x 10-3 pc However, following-the RSC rules, inventory.of transuranics for this program. all of'the operations save centrifuging and counting will be conducted in the chemistry hood.. e
- ,c 4
,\\. I i I WORKPLACES FOR UNSEALED RADIONUCLIDES 1 By \\ D. A. Pickler 1 f A search was made for existing guidelines as to the maximum amount of unsealed radioactive material which can be safely used: (1) outside hoods or glove boxes, and (2) in hoods. Of the guidelines examined (Refs B, C, D, and H), only References E and H The latter part of this paper proposes a new guideline 1 are definite in this respect. which, it is beileved, has advantages over those of the referenced publications. Reference A discusses the toxicity of radionuclides which may become incot - porated in the human body. Of special interest is the conclusion that, in working with i i radionuclides, inhalation, rather than ingestion, is the most significant mode of entry in the body because ingestion is usually more readily controlled or avoided by taking l d simple precautions. Accordingly, in that document radionuclides are classified as to toxicity based on two factors, the MPI (annual inhalation maximum premissible intake) in' microcuries and 'the MP1 in micrograms. The MPI in microcuries is the only factor used for radionuclides of higher specific activity. With radionuclides of lower specific activity both f actors are used, the MPI in micrograms being used to "dowrtgrade" the I toxicity because of the smaller probability of breathing significantly harmful amounts of radioactive material with lower specific activity. All radionuclides with an MPI of All radionuclides with an MPI of over 10 milligrams are classified as " low" toxicity. between 0.1 and 10 milligrams which would be classified as " upper medium" toxicity. Thus, for example, strontium-90 is classified as "high" toxicity and natural uranium and natural. thorium are classifiec as " low" toxicity although the MPI in microcuries is greater for stronitum-90 than for natural uranium or natural throlum. l References B and C are very similar to each other. Apparently Reference C was based directly or indirectly on Reference B. Both contain the following table: UI #- e .e e ; 7 't ,,,p
Type of laboratory or working Relative place required radio-Minimum Type C Type B Type A toxicity of significant Good chemical Radioisotope High level isotopes quantity laboratory laboratory laboratory Very high 0.1 uc 10 uc or less 10 uc - 10 mc 10 mc or more High 1.0 pc 100 uc or less 100 uc ,100 me 100 mc or more i Moderate 10 uc 1 m e or less 1 mc - I c 1 c or more Slight 100 uc 10 me or less 10 mc - 10 e 10 c or more References B and C also contain a statement as follows on modifying f actws to be used with the above table: Procedure of operation Modifying factor X 100 Storage X 10 Very simple wet operations X 1 Normal chemical operations Complex wet operations with X 0.1 risk of spills X 0.1 Simple dry operations Dry and dusty operations and those where. isotopes are X 0.01 evolved as gases r Each of the more generally used radionuclides is listed under one of the four radiotoxicity classifications in the first column of the table. The method of classifi-cation is not specified except in a very general manner. In Reference B the equipment required for type A, B, and C latioratories or No statement is made as to working places is described only in a very general manner. The whether type B and C facilities should include hoods or glove boxes or both. statement is made that "in general, type A laboratories will use glove boxes or other completely enclosed systems." Reference C describes in considerable detail guidelines for design of a type B laboratory, including guidelines for design of hoods and glove boxes. Although Ref-erences B and C provide guidelines for the amount of material which can be safely used in type A, B, and C facilities, neither provides guidelines for the amount of material which may be safely used in hoods for the amount of material which may be safely used in facilities with neither hoods nor glove boxes.
Reference D divides the more commonly used radionuclides into four groups,"very high hazard", "high hazard", " medium hazard", and " low hazard" for the soluble forms, it contains no classification for the insoluble forms. For " normal chemical operations" a given amount of a radionuclide is a " low level" amount, a " medium level" amount, or a "high level" amount (with borderline areas extending for a factor of 10), depending upon Factors for use the group to which it belongs, as shown in Table 2 of that document. other than " normal chemical operations" are the same as for References B and C, To illustrate differences in grouping of radionuclides in References B and C on one hand, and Reference D on the other, strontium-89 is listed as "high" in References B and C, but as " medium" in Reference D, while sodium-22 is listed as " moderate" in References l B and C, but as "high" in Reference D. Reference D states that for low-level work an ordinary fume hood such as is used in chemical laboratories may be usea; it also states that for highly toxic or high-level radioactive material, the velocity through hood openings must be 125 to 200 fpm. No amount of radioactive material is specified as small enough for use outside a hood, or as too large for use in a properly designed and operating hood. Reference E also divides the more commonly used radionuclides into four groups It lists some radionuclides not mentioned in "very high", "high", " moderate", and " low". References B and C, and does not include some radionuclides listed in those documents. Uranium-233 is classified as "very high" in References B and C, and as "high" in Natural uranium is classified as "high" in References B and C, and as Reference E. " low" in Reference E. Reference E includes the following equation to obtain a guide to the type of workplace required: H = QTU, where H = Hazard guide value Q = Quantity of radionuclide (in c) T = Relative toxicity factor U = Use Factor Relative toxicity f actor (T) is 100 for radionuclides classified as "very high",10 for those classified as "high", I for those classified as " moderate", and 0.1 for those classified as low.
b Use Factor (U) Type of Operation 0.01 Storage 0.1 Very simples, wet 1 Normal 10 Simple, dry 10 Complex, wet - 100 Dry and dusty The workplace required is a function of the hazard guide value (H) as follows: f Hazard guide value (H)- Workplace required _ Less than 100 Type I Type 11 100 - 1000 More than 1000 Type 111 Type 1-15 described in some detail, and is essentially a good laborator Type !! is also described in some detail, including a hood or glove box required. ] minimum requirement that operations be carried out in hoods. Type Ill is als in some detail, including a minimum requirement that operations be carriedf gloved boxes.- Reference H provides a guideline based on eight toxicity groups, but with 'n The eight groups are i allowance for variations according to procedures and operations. chosen to correspond 'tu the eight orders of _ magnitude over which the es maximum doses per curie range for the various nuclides when they are deliv single intake by inhalation. The following disadvantages are listed for the above described methods of e tablishing guidelines for workplaces for radionuclides: References B,' C, and D do not establish guidestines for operations requ 1. hoods and glove boxes. Reference E does not assign a use f actor for gases and volatile mater 2. Reference H does not assign any use factors. Radionuclides are classified into groups, with each group assigned a r 3. toxicity factor of 10 greater than that of the less toxic group adjacen i resulting in the following conditions: Many radionuclides are not listed in any of the groups. a. W . L _y
b. The classification does not take into account the chemical form of the radionuclide. For example, each guide either considers soluble material only, or there is no distinction between soluble and insoluble forms, although the MPC in air may be quite different for soluble and insoluble material; for radium-226 the MPC in air for solubk and insoluble material is'different by a f actor of about 6,000. However, cue should be exercised in classing a highly toxic material as " insoluble". For example, radium sulfate might be thought of as " insoluble" as its solubility is listed (Reference F) as 2 x 10-8 gm/cc at 25 degrees centigrade and 5 x 10-8 gm/cc at 45 degrees centigrade. If one assumes that the s >lubility is 4 x 10-8 gm/cc at body temperature and that the amount dissolved in the gastro-intentinal tract from a single large ingestion of radium-226 is equal to the amount which can be dissolved in one liter of water (a purely arbitrary assumption), by using the data in Reference G it is seen that, under these conditions,1.1 microcuries of radium-226 (11 times the maximum permissible body burden) could be expected to be deposited in bone from this one ingestion of " insoluble" material. Relative toxicity between the most toxic and the least toxic of the four c. 3 groups of References B, C, D, and E is assigned a value of 10. However, the MPC in air for hydrogen-3 (soluble) is greater than that for 7 plutonium-239 (soluble) by a f actor of about 10. To eliminate the above listed disadvantages, it is suggested that a new guide for workplaces for unsealed radionuclides be set up. This guide would, like those discussed above, be for protection against internal exposure only, and would not consider external radiation. The guide would be based on MPC's' for air as stated in Handbook 69, except that the criteria for radioactive material of very low specific activity would be different from that for other radioactive material. Handbook 69 is suggested as a basis for the guide because it is widely distributed and contains information on all commonly used radionuclide's for both soluble and insoluble forms. The exact formulas would hav to be arbitrary to some degree, as are all such formulas. The criteria and formulas below are suggested as such a guide; recommendations are welcomed for modifications of'either the criteria or formulas or both. Of course exceptions to the guide would be made whenever it is reasonable to do so.
e 1. Based on experience, natural thorium, thorium-232, _ natural uranium, uranium-235, and uranium-238 need not be handled in a hood or glove box provided the material is in a form which is neither volatile nor apparently contains respirable size particles. For radioactive material not meeting all the provisions of I above, guides are based on the following more or less arbitrary assumptions: Inhalation is the most significant mode of entry into the body. 1. 2. Each person breathes 2 x 10 ml of air per day while working with radioactive 7 material. (Reference G) The maximum fractional part of radioactive material present which is inhaled 3. per day by any person is as follows: Outside hood or in hood Procedure or operation glove box Operations involving gases or 10,3 3 x 10,3 volatile liquids Dry operations with respirable 10-2 3 x 10-4 size particles Dry operations with apparently 10-3 3 x 10-0 no respirable size particles Complex wet operations with 10-3 3 x 10-0 risk of spills 10-" 3 x 10-6 Normal chemical operations 3 x 10-7 10 Very simple wet operations Storage of solids and volatile liquids Storage of solids and nonvolatile liquids Storage requirements to be based on leakage rate and on maximum credible accident.
- Storage requirements to be based on maximum credible accident.
l l l l
Using the above assumptions, one arrives at the following guides (MPC means MPC in uc/miin air for a 40 hour week): I l Maximum amount to be handled outside Maximum amount to Procedure or operation hood or glove box be handled in hood (u c) (uc) Operations involving gases of 8 MPC x 3 x 10' MPC x 10 volatile liquids l 10 Dry operations with respirable 9 MPC x 3 x 10 size particles 11 Dry operations with apparently 10 MPC x 3 x 10 MPC x 10 no respirable size particles 11 Complex wet operations with 10 MPC x 3 x 10 MPC x 10 risk of spills II 12 MPC x 10 MPC x 3 x 10 Normal chemical operations 12 I3 MPC x 10 MPC x 3 x 10 Very simple wet operations Storage of gases and volatile liquids Storage of solids and nonvolatile liquids Storage requirements to be based or leakage rate and on maximum credible accident. Storage requirements to be based on maximum credible accident. When radioactive material is handled outside hoods or glove boxes, Refer-111. ence E requirements for " Type I workplaces" (paragraph D.I. of Reference E) When radioactive material is handled in hoods, Reference E will apply. requirements for " Type II workplaces" (Paragraph D.2. of Reference E) will When radioactive material is handled in facilities designed for apply. containment superior to that of hoods, Reference E requirements for " Type III workplaces" (paragraph D.3. of Reference E) will apply.
I' -j
References:
-A. A Basic-Toxicity' Classification of Radionuclides, IAEA Technical Reports Series No.15,1963. B. Safe Handling of Radioisotopes,IAEA Safety Series No.1.,1958.
- l C. _ Design Guide for a Radioisotope Laboratory (Type B), American Standards Associa-tion, incorporated, sponsored by American Institute of Chemical Engineers,1964.
D. National Bureau of Standards Handbook 92. Workplaces for Radionuclides, Lawrence Radiation Laboratory (Livermore) Health E. Chemistry Manual, Part I, Procedure 701,1963. F. Handbook of Chemistry and Physics,45th edition, The Chemical Rubber Co. G. Health Physics, June 1960. H. Brodsky, Indistrial Hygiene Journal, May-June,1965, p. 294. l i I i I .- ( '}}