ML20148G994

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Discusses Isotope Measuring Sys,Inc Application for Amend for Model 5245 & Included Several Requests for Generic Authorizations
ML20148G994
Person / Time
Issue date: 05/28/1997
From: Doug Broaddus
NRC
To:
NRC
Shared Package
ML20148G975 List:
References
SSD, NUDOCS 9706090017
Download: ML20148G994 (1)


Text

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i 2 NOTE TO: FlL .

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L nbb Doug as Broad uf,,.$ 6/96{?y- ', <

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SUBJECT:

IMS application dated March 1r1995, and letters dated April 19,1996, February 2,1996, November 20,1995, and , March 1,1995. .

IMS's application for amendment dated March 1'i1995, for the model 5245 includes several I requests for " generic" authorizations. These " gene'ric" authorization requests are similar in i nature to requests made for the model 5321. device in in application for amendment, also dated March 1,1995. IMS provided 'a letter dated April 19, .1996, in _ response to a request for additional information conceming several of these " generic" authorizationsJ This' letter l referred to commitments made by IMS for the model 5321 for similar " generic" authorizations,

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that were subsequently authorized for the model 5321 device, and indicate'd that IMS was i reasserting these same commitments for the m'odel 5245 device."The releva'nt commitments are contained in IMS letters dated February 21,,1996, Novembef 20,1995, and March 1, 1995 (the 5321 amendment application). Therefore, these letters are being included in the background file for the model 5245 as additionalinformation suppor1ing IMS's April 19,1996, letter.

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.Mr. Douglas A. Broaddus Mechanical Engineer Nuclear Regulatory Commission Sealed Source Safety Section Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety, NMSS Washington, DC 20555 USA (301) 415-5847 (301) 415-7000 -main (301) 415-5369 -fax

Dear Doug:

This letter is our response to the telephone communication (96/1/24) requesting additional information forthe Device Application for Model 5321. Many of the questions were answered during the phone conversation so this will serve as our formal, written response.

. Inner temperature of the O-frame Discussion: In our device application, we described the gauge's environment as occasionally reaching subzero temperatures during plant outages. Our prototype testing completed at IMS was done only down to O C. Can we accept that the lowest operating temperature is O C, not subzero?

Response: We confirm that the gauge would not be operated below 0 C. During plant outages -

it may experience exposure of subzero temperatures. The prototype for this gauge that has been in operation at the Mannesmann, M0lheim, Germany facility since 1988 has experienced exposures below 0 C without any negative effect to the gauge.

. Cooling system Discussion: Regarding the particulate filters, water purity, and capacity, is the cooling system the j same as the 5245 device registration series?

Response: The cooling system will meet the minimum requirements as stated in the similar device registrations for the 5245 series.

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. Galvanic corrosion Discussion: We described the operating environment as being possibly 100% humidity.

Per D. Broaddus, in this environment aluminum and stainless steel can cause some galvanic corrosion. Sometimes a barrier (paint) between the gauge and the labels would restrict this galvanic corrosion.

Response: IMS has never had any galvanic corrosion problems with the materials selected.

IMS commits to continuing use of these materials since they have demonstrated robust suitability to the environment in which the gauge will be used.

. Cooling water temperature fault )

Discussion: What happens when the cooling water goes over 100 C7 Will the unit give a waming?

Response: IMS confirms that the unit gives a waming (fatal fault) which is sent to the customer es an output signal and also displayed on the operators' interface.

.9 rr 9606040902-951120 OS , D 3 PDR RC

. Source position indicator (illuminated sign)

Discussion: If one source housings does not close, will it indicate open?

Response: If even one of the source housings do not close, the source indicator shows "open".

. Appendix G; P 10 of the application I Discussion: In the safety instructions section, should " cooling air" be replaced with

  • cooling  ;

water"?  ;

Response: IMS confirms that the term

  • cooling air'should be replaced with " cooling water." i e November 20 response Discussion: Regarding the permanent process formed in the base material for labeling, i.e., i stamping, engraving, durable paints, etc., explain the " durable paints" reference. '

Response: The paint IMS was referring to was the yellow and magenta colors that are required  !

by the federal code. The remaining the lettering would be a permanent process formed in the  ;

base material. 1 e Signs i Discussion: IMS signs currently are worded

  • Serial Number xxxx" where xxxx was the combined l

rnodel number and the serial number given. .

Response: IMS will modify new signs to specifically state *Model xxxx Serial Number yyyy."

. Leak test following prototype testing i

Discussion: ANSI N538 requires a leak test to follow all of the testing.

Response: IMS confirms that the source holder successfully passed a leak test following the i ANSI N538 test. '

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. Air pressure variance Discussion: IMS varied the pressure during the test between 4 - 6 bars. Why was this done?

Response: This represents the range of working air pressure typically present in an industrial facility.

. Prototype results Discussion: On page 10,3rd parag?aph, should that have been 85 C instead of 0 C7 Response: IMS confirms that 0 C should be replaced with 85 C. 7 j . Prototype classification '

Discussion: The classification *S", i.e., *Special" was used instead of *4" yet classification '4" incorporates 85 C. Please explain.

Response: Our photocopied version of the ANSI classification appeared to associate  ;

classification 4 with 35 C. IMS confirms that Classification 4, i.e.,85 C is correct and a revised page 12 of the test report is enclosed.

. 300 and 400 stainless steel Response: IMS confirms that we willlimit gauge housing construction materials to 300 and 400 t stainless steel. '

. Source housing and bill of material Discussion: George will provide a step-by-step walk through explaining the drawings, detailing the components, and how they fit together. This was also done during our visit in Washington  :

with Steve Baggett.  !

Response: The walk through was completed during the week of February 26,1996. The  !

" Answers to Mechanical Drawings Review (Part II)* will follow this week.

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4. ANSI Classification The IMS Device TIAS 211 Heavy Metal Shielding (with integral shutter mechanism) is used in the IMS Model 5321 series of multi-channel tube gauges. Based on the test procedure and results presented above, the IMS TIAS 211 and the IMS Gauge Model 5321 series have the l

ANSI N538 classification desenbed below.  !

4 4.1 ANSI Standard N538 l

' The American National Standard N538 was issued in October 1979 and is entitled l

Classification of Industrial lonizing Radiation Gauging Devices. This standard applies to l the radiation safety aspects of gauging devices. j l

4.1.1 For the TIAS 211 (Free Standing) 1 The ANSI classification for the free-standing Heavy Metal Shielding Device TIAS 211 is j ANSI 538 - 565 - R1 J

4.1.2 For the IMS Model 5321 Gauge Series The ANSI classification for the IMS Model 5321 multi-channel tube gauge with the TIAS 211 installed is ANSI 543 - 885 - R1 0

1 Note Regarding OFF position measurements for the Model 5321:

The 5 cm measurement position is in the measuring gap. The 30 cm and the 100 cm positions

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  • are outside the gap as required to achieve the proper measurement standoff distances. The '

measurement gap is this case is a circle with an inside diameter of about 300 mm. All 1

measurements were taken from the nearest accessible surface.

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November 20,1995 Mr. Douglas A. Broaddus Mechanical Engineer Nuclear Regulatory Commission Sealed Source Safety Section Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety, NMSS

Dear Doug:

This letter is in response 19 the most recent communication requesting additional information to facilitate continued evaluation of the device registration for the IMS Model 5321. IMS is pleased to provide the following information as requested under items 1 - 15 of yourletter.

Introductory Paraaraph We wish to clarify our statement regarding the similarity of this Model 5321 to our Model 5301. As we stated in our application "This gauge is very similar to the gauge registered

[...] that is., same operating environment, same measuring appIIcation. The difference is in a change in the source housing configuration. The source housing construction materials are the same as the already approved gauge design."

We agree that the source housing design is quite dissimilar and did not state nor imply that the design was similar. We reaffirm, however, that the evaluation of this device registration application can rely extensively on the approved device (Model 5301) for operating environment, measuring application, and source housing construction material information.

IMS Inc. Response to item 1 Item 1 will be discussed on 1995 Nov. 20. IMS has prepared a partial response to this item as presented below. Addition information will follow, based upon discussions with the j NRC.  !

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Item 1a: Material Specifications IMS has deliberately not specified the composition of the steels and stainless steels used in the construction of the gauge because:

a. the cost and availability of these materials varies and IMS needs the freedom to select materials that are available and affordable.

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b. the specific alloy used in m FIf'nsbujn) u's4 ohNnot!effect:theEIation device. IMS intends to specify exact compositions only where the safety of the device significantly depends upon the material alloy composition. With respect to the measurement frame construction, for example, any grade of commercially available carbon, all6y, or stainMss steel could be used in the construction of a safe installation, in cases where material composition is essential to the device safety (e.g. the radiation source shielding material) IMS has specified the material type in detail.

Item 1b: 10 CFR 2.790 Requirements I IMS is not aware of any unmet 10 CFR 2.790 requirements. We would be gratefulif the i NRC could specify what points need to be addressed.

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lMS Inc. Response to item 2 Item 2a: Lock Out Valve:

The air lock-out valve depressurizes the compressed-air lines supplying the shutter i actuators when it is closed. The shutters cannot remain open when the compressed air  ;

supply is removed. The valve is equipped with a clevis, where workers can hang their l personal safety lock or safety tag before entering the controlled access area. Use of the '

lock-out valve should be specified in the site license. il Item 2b: Annual Dose Calculation:

The radiation flux at the perimeter of the controlled access area is less than 0.25 mR/hr.

Under a worst case scenario, a worker is assumed to spend no more than an average of one hour per day at the controlled access area perimeter when the shutters are open.

Assuming a standard 250 work days per year, the worker would receive less than 0.1 rem per year.

It is not anticipated that any members of the public willlinger near the gauge. The gauge is installed in a steel-making environment where members of the public are generally forbidden. The workers around the gauge are not considered to be members of the public.

Members of the public would have to spend 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> with their bodies pressed against the controlled access area boundary to accumulate a 0.1 rem dose. We feel that this is not likely to occur.

IMS Inc Response to item 3 Item 3a: Gaugo Layout (Location of Central Station, Gauger's Office, etc.)

The location of the Central Station will vary from one installation to another. This is a site license issue. The end user is responsible for positioning the Central Station and the gauger's office. Drawing 94-02-06-91 depicts a typical arrangement only. Other installations of this device will differ. In most cases there will be no gauger's office. The end user is required by virtue of their site license to ensure that employees and other individuals are protected as required by 10 CFR 20. IMS will verify that the Central Station and any gauge operator stations (e.g. a gauger's office, if present) are clearly outside the 0.25 mR/hr controlled access area.

Isotope Measunng systems,Inc. 108 Blue Ridge Dnve CranberryTwp. PA 16066 usa tel 412 776 9586 fax: 412 776 2700

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f 11/20/95 H:\ DATA \9fPFILES\ SUPPLIER \ RAD SAFEWRC\S321\5321DEF 002 Page 3 In cases where individuals are likely to linger near the controlled access area, these individuals are not considered to be members of the public.

In the sample installation shown in drawing 94-02-006-91, the anticipated radiation field at the Central Station is less than 0.1 mR/hr above background.

Item 3b: No Access to the Measuring Gap:

Access to the measuring gap is limited by the controlled access area. The controlled access area (and therefore controlled access to the measuring gap) is maintained by the site licensee as required by 10 CFR 20. A shutter lock-out valve is provided to protect individuals in the infrequent cases where entry of the controlled access is necessary. This is provided to prevent access to the measuring gap when no process material is in the gap.

Hot metal and/or rapidly moving production equipment present precludes access to the measuring gap during production. In ihe event of a production stoppage, where process

, materialis in the gauge, the materialitself will block access to the measuring gap.

Item 3c: Automatic Source Shutter Closure when Process Materialin Absent The radiation source shutters automatically close within 5 minutes after the process material to be measured leaves the measuring gap.

Item 3d: Lingering in the vicinity of the gauge The gauge user is required by their site license and maintain controlled access to a high I radiation area. The enforcement of the controlled access area requirement will prevent I persons from lingering in the vicinity of the gauge.

IMS Inc. Response to item 4 Will follow under separate cover.

LMS Inc. Response to item 5 ,

The ANSI N538 test results and classification have been sent under separate cover.

The safety related components have been subjected to the environmental extremes listed in the application. The prototype for this gauge has been operating in a hot seamless tube mill since 1988 without incident. IMS has enclosed photographs of this prototype installation for reference.

The cooling and pneumatic systems for this gauge have also operated in the prototype .

installation without incident since 1988. Moreover, the same cooling system components have been used in other NRC registered devices such as the IMS Model 5245.

The source shutter springs are rated for infinite life (greater than 1,000,000) cycles for the temperature range 0 - 100 C. IMS experience with the prototype device is consistent with this rating. This prototype has been in continuous operation since installation in 1988. The shutters have been actuated an average of < 200 times da;ly for 7 years, amounting to a more than 500,000 cycles without failure.

Isotope Measunng systems,Inc. 108 Blue Ridge Drive Cranberry Twp PA 16006 usa tel 412 776 9586 fax. 412 776 2700

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11/20/95 H \ DATA \WPFILES\ SUPPLIER \ RAD _ SAFE \NRC\532115321DEF D02 Page 4 l

IMS Inc. Response to item 6 1 SM-18 (Sintered Tungsten) Properties: ,

The physical and mechanical properties for the SM-18 material are listed below for l

reference. This is the same material used in the IMS Model 5301 and Model 5245. IMS has used this materialin hundreds of Cs 137 source holders around the world and has not experienced any SM-18 material failures. It should be noted that Tungsten is a common material and has been used for light bulb filaments for decades because of its high temperature and strength properties. l l

l SM-18 (Sintered Tungsten) Properties:

Half Value Thickness for Cs 137 Radiation: < 5.5 mm Modulus of Elasticity: 380 kN/mm^2 ,

Modulus of Rigidity: 150 kN/mm^2

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Hardness HB 285 1 Tensile Strength: 850 N/mm^2 Minimum Yield Strength (0.2 %) 520 N/mm^2  ;

Elongation 16 % l Compressive Strength 3950 N/mm^2 Thermal Expansion Coeff 20 - 200 C 5.5104/K l Specific Density: 18 Melting Temperature: > 1000 C. (the mech. strength at  ; i 1000 C is 260 N/mm^2) I l

IMS Inc. Response to item 7 Item 7a: Label Location Label location is variable, depending upon site conditions. In general, labels will be placed I such that they are visible to individuals approaching the gauge. Where feasible, labels will be located at near eye level, e.g. at +/- 30 degrees to the horizon for an individuallocated 5 -j meters from the measurement frame.  ;

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Labels will be installed by IMS personnel or by individuals authorized by IMS before the l

radiation sources are installed in the gauge. '

Item 7b: Protected Environment: -l A protected environment is any space that is protected from a harsh production  ;

environment. The inside of the measurement frame, for example, qualifies as a protected environment because it is kept cool and free of contaminants.

The minimum lettering size (1.5 mm) corresponds to 11 point font (the font used to print l I

this document). This small size is usec' because some of the labels are necessarily small.

The labels attached to the source holders, for example, are only large enough to .

accommodate 1.5 mm lettering. In a protected environment it is anticipated that 1.5 mm i j print would be legible, just as this letter is legible.

Isotope Measunng systems. Inc. 108 Dlue RKige orive Cranberry Twp PA 16066 usa tel 412 776 9586 fax. 412 776 2700

11/20/95 H:\ DATA \WPFILES\ SUPPLIER \ RAD _ SAFE \NRC\S321\S321DEF 002 Page5 Item 7c: Durable Metal: ,

The criteria used for selecting a durable metal for the label is as follows melting point: > 500 F thickness: > 20 gauge )

yield strength: > 5kpsi ,

elongation: < 65 % l l

The metal will be corrosion resistant, e.g. stainless steel, aluminum alloy, brass, or bronze.

l Galvanic Cell Effects: j l

The labels will be located where they will remain dry most of the time. In the absence of 'l extreme moisture, galvanic effects are not expected. The labels are constructed of materials that typically do not corrode. IMS does not expect galvanic effects to be a problem with this device because none were observed on the prototype installation after six years of operation in a production environment.

Item 7d: Equivaient Permanent Lettering Process: ll Any lettering process that causes the lettering to be formed in the base metal is an

" equivalent permanent process." Some label manufacturers use lasers, for example, to  ;

remove material from the base metal in the shape of lettering. This would be viewed as an equivalent process. Some coatings would also qualify as an equivalent permanent process i because they cannot be readily removed. Examples would include powder coating and baked enamel. Colors are used as indicated in the requirements found in 10 CFR 20.

Item 7e: Manufacturer's identification: .l The manufacturer in this case is the gauge manufacturer. A sample labelis attached for reference. .

1 IMS Inc. Response to item 8 The radiation levels at distances of 5,30, and 100 cm are included in the ANSI N538 test report.

The measured 0.25 mR/hr isodose curve for the nine source gauge is enclosed for reference (IMS Drawing 5321-0? 11) This curve is for the "least shielding possible" condition.

To expedite processing of the model 5321 device registration, IMS has dropped all variations of this model except the 9-channel configuration. IMS will seek approval for the model 5321 as a nine-channel gauge instead of a series of gauges with up to 13 channels at this time.

These drawings have been de-classified and do not need to be treated as proprietary.

Isotope Measunng systems, Inc. 108 Blue Ridge Dnve Cranberry Twp. PA 16066 USA tel. 412 776 9586 fax: 412 776 2700

7 11/20/95 H.\ DATA \WPFILES\ SUPPLIER \ RAD _ SAFE \NRC\5321\532iDEF D02 Page 6 IMS Inc. Response to item 9 IMS has dropped its request to seek approval of this device as a series. At this time IMS requests approval of the Model 5321 as a nine-channel gauge only.

Worst Case Scenario The worst case scenario for the conditions of use would be the prototype installation at Mannesmann in Muelheim, Germany. This prototype is installed immediately at the exit of a rotary sizing tube mill behind a piercer. The ambient temperature at this site frequently exceeds 150 F. The process material temperature routinely exceed 2000 F. Relative humidity around the gauge installation is typically 100 % because water is used to cool the production equipment.

The worst case scenario for the radiation profile is depicted in the enclosed isodose curve for the 13 source gauge.

The prototype testing is relevant to the other gauges in the series because

- the prototype has a perfect safety record

- it has operated without incident in harsh conditions

- it is representative of the other gauges in the series, as it is constructed using the same components and material.

IMS Inc. Response to item 10 The device measuring frame is designed to survive collisions with process material. The frame is constructed of ca.10 mm thick steel walls, which would not be penetrated by moving process material in a collision. The most likely outcome of such a collision is that the process material would be deflected backwards, away from the measuring frame. It is possible that the irame may be knocked over through a collision, in which case the compressed air supply to the shutters would be disrupted and the shutters would close. It is reasonable to assume that the site license holder will take steps to minimize, the likelihood of a collision to avoid costly production delays and repair costs.

IMS Inc. Response to item 11 The Amersham Model CDC.38210 Capsule X.38/4 is also known and registered as CDC711M. The Sealed Source Registration Number is NR-136-S-232-S.

IMS Inc. Response to items 12 -14 The IMS Inc. response to these items will follow under separate cover, isotope Measuring systems. Inc. 108 Blue Ridge ortve Cranberry Twp PA 16066 usa tel' 412 776 9586 fax. 412 776 2700

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l IMS Inc. Response to item 15 Even though the IMS location has not changed, IMS Inc. got a new mailing address in 1995

! when a new post office was established in Cranberry Twp, PA. The old address (Mars, PA) will still be valid under a post office grace period for several months. For the record, however, the new address for IMS Inc. is: ,

Isotope Meast:ing Systems Inc. (IMS Inc.)

108 Blue Ridge Drive Cranberry Twp. PA 16066 USA tel: 412 776 9586 i fax: 412 776 2700 We hope this information will be helpful, and look forward to working together with the NRC to ensure a safe and timely introduction of the Model 5321 in the USA.

Best Regards, i

jet N U, George Burnet, VI General Manaaer IMS Inc.

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l March 1,1995 l l

Mr. John Lubinsky US Nuclear Regulatory Commission Commercial Section l Washington, D.C. 20555 l USA l

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(301)415-7868 I (301) 415-7000 -main

Dear Mr. Lubinsky:

i We respectfully submit an application for a tube wall gauge device registration. This i gauge is very similar to the gauge registered under number NR-375-D-103-S, i.e., I same operating environment, same measuring application. The difference is in a ,

change in the source housing configuration. The source housing construction materials  !

are the same as the already approved gauge design.

We thank you in advance for your review. If there are any questions, please telephone l Susan K. Burnet or George Burnet at (412) 776 - 9586 or Sue Engelhardt at (800) 525- ]

3078. '

Sincerely, lw%WW Susan K. Burnet President. IMS Inc.  !

Enclosures:

l Device Application Model 5321 Tube Wall Thickness Gauge Appendices A - G 1

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SUMMARY

DATA Date: March 1,1995 l

Applicant: Isotope Measuring Systems (IMS) 108 Blue Ridge Drive Applicant is the Distributor Cranberry Twp, PA 16066 George Burnet 412-776-9586 Susan Burnet 412-776-9586 Susan Engelhardt 800-525-3078 Device Type: , Tube Thickness Gauge - Direct Transmission Gauge Model: 5321 Other Companies involved: Isotope Measuring Systems Dieselstrasse 55 Heiligenhaus D-42579 Germany .j (Manufacturer - Headquarters) i Source Model Designation: Amersham international j

, Model CDC.38210 Capsule X.38/4 Radionuclides: Isotope: Cs-137 Activity: 10 Ci/each

, (max.13 sources per device)

Leak Test Frequency: Each 6 months Principal Use Code: (D) Gamma gauge Specific License Custom Device: No l

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1995 March 1 Model 5321 Isciope Measuring Systems Page 1 l

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2.

SUMMARY

DESCRIPTION 2.1 Summary of Major Components i

Metal frame structure with multiple radioactive source housings, each containing a source and an ion chamber Central station electronic cubicle housing and microcomputer signat processing system

. Remote mounted input station l

. Local operator input station

. Source shutter open/ closed indicator light box j

l 2.1.1 Use Summary

. i The Model 5321 device is a multi-channel thickness gauge used to measure thickness  !

of tubing. This gauge also measures eccentricity of the tube wall. Eccentricity is the j degree to which the center bore of a tube is not concentric with the outer wall of the j tube. This device provides information which assists optimization of mill setup on a  ;

tube-by-tube basis during production runs. Each of the detectors and sources are

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individually paired with a source or detector on the opposite side of the O-frame 41 supporting the source and detector units. This measurement technique produces an accurate representation of the wall thickness variation around the entire tube.

2.1.2 Operation Summary The gauge operates by manual or computer control. As the measured material  !

approaches the gauge, the gauge completes a calibration, the materialis measured, l and the gauge then completes another calibration. The operation of the gauge is monitored through computer generated display screens.

4 2.1.3 Radiation Safety Features Summary

. Air actuated and fail-safe shutter control

. Source shutter status indicator light box

. Rugged metal device housing

. Monitor displays and operator controls

. Cooling system monitoring 2.2 Written Description 2.2.1 Nature and Intended Purpose The nature and intended purpose of the device, i.e., what it is and how it is to be used is given above in the Summary Description. The device is installed in a fixed location.

The source housing does not move during normal use. For servicing, the entire device travels on a fixed rail from the measuring position to the maintenance position.

1905 March 1 Model 5321 Isotope Measuring Systems Page 2

1 2.2.2 Radiation Safety Features - Brief Description 2.2.2.1 Dimensions See the dimensions table in Appendix A.

2.2.2.2 Materials of construction The gauge housing is constructed of steel and the radioactive source is enclosed inside of the frame such that it is protected from the operating environment, as well cs operators of the gauge. The source housing is composed of tungsten alloy. The source holder, Iccated in the housing, is also of tungsten alloy.

2.2.2.3 Methods of assembly and attachment The methods of assembly and attachment are described in a logical progression from the source capsule outward: The source capsule is completely contained inside the .

source housing. The capsule resides inside a holder. This holder held in place by a source locking bolt. A compression spring applies a constant force on the source holder. The locking bolt is held in place by screws. The source housing is attached to the measuring frame with bolts. The housing is completely contained inside the measuring frarne. The measuring frame is a heavy-walled welded steel structure. The  ;

measuring frame is mounted on drive rails. i 2.2.2.4 External radiation levels :i During normal operation of the gauge, hot production tubes are passing through the air l1 gap and there is no access to the measuring gap. An air lockout valve is provided to  !

ensure that no one enters the controlled access area during maintenance procedures. 4i No person would receive greater than 0.5 R/ year from working near the device frame. j 2.2.2.5 Description of shielding The manufacturer assists the end-user in designing radiation shielding required to li' suitably confine the controlled access area as appropriate for site conditions. Types of shielding materials include steel, iron, concrete, and lead.

2.2.2.6 Method for securing the source in the device The source is secured in the source housing by means of a locking bolt and coverplate.

The coverplate is secured by screws. In addition to the shielding, the source is protected from access. It is secured in the source holder, secured by the source capsule locking bolt, such that the source holder keeps the source in place. The source holder is then secured in the source housing. Therefore, radiologically it is quite secure.

2.2.2.7 Description of on-off mechanism The device can be powered on and off locally by a main switch located in the Central Station. The customer supplied power to this Central Station can also be switched off and locked-out per plant standard procedure. The air that opens and closes the shutter can be locked out via a valve located in the air line.

1995 March 1 Moc'el 5321 Isotope Measuring Systems Page 3

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l 2.2.2.8 Description of on-offindicators The indicator displays the shutter mechanism position. It consists of three all-round view indication fields each with two controlled lamps. The following three fields are l

indicated: Electrical power on; Shutter open; and Shutter closed. The dimensions are ca. (circa) 140 x 140 x 445 mm. The indicator is mounted on a post near the frame and i the exact location and height will vary per application to allow placement in the most .

visible location.  !

2.2.2.9 Installation description See installation description below in details of construction.

2.2.2.10 Radioactive Source Classification The ANSI N542, " Sealed Radioactive Sources, Classification" for the X.38/4 capsule is -l C66646.

2.3 Drawings The drawings can be found in Appendix B.

l l

3. DETAILS OF CONSTRUCTION AND USE l

3.1 Conditions of Use 3.1.1 Planned Use of tI1e Device ,

The device will be used in manufacturing environments to measure tube wall thickness l and eccentricity. I 3.1.2 Extremes of Environmental and Operating Conditions The environment in which the device is used is often humid, wet and warm. Conditions at the measuring position are cooled to maintain inner frame temperatures below 100 C, in that the materialis rolled at high temperatures. During plant maintenance outages, the operating environment can reach sub-freezing temperatures. The operating environment is such that the frame design must, and does, mitigate completely the effects of abrasion, corrosion and vibration. The frame is retractable for maintenance. When the frame is in the on-line measuring position, it will be subjected to a degree of dirt and water that is normally associated with industrial operating environments.

3.1.3 Types of Users The users of this gauge will be equipment operators in manufacturing environments.

Maintenance personnel will be required to also operate the gauge.

3.1.4 Locations of Use The gauges will be located in a fixed position on the metal production line.

1995 March 1 Model 5321 tsotope Measuring Systems Page 4

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i 3.1.5 Occasions When Persons Will Be Near The Device And Frequency During normal operation of the gauge, hot production tubes are passing through the air gap and there is no access to the measuring gap. Operating personnel are usually present in the vicinity of the gauge during normal operation, but not within the controlled access area. The frequency of maintenance occasions is weekly for l

cleaning and inspection of the device and every six months for wipe tests. The expected duration for the maintenance procedures is ten minutes.

3.1.6 Possibility of Device Used as a Component in Other Products There is no reasonable possibility that the device will be used as a component in other products.

3.1.7 Expected Useful Life of the Device  !

The expected usefullife of the device is 20 years. -j 3.2 Details of Construction 3.2.1 Engineering Drawings The engineering drawings showing materials of construction, dimensions, methods of fabrication, means for mounting the source and source holder in the device, and means of securing the device in its installed position can be found in Appendix B.

i 3.2.2 Special Design Features ll l

l1 3.2.2.1 Protection of Source from Abuse i The measuring frame is of a rugged steel construction that has been designed to protect the source from abuse. The source is protected inside a massive sintered .

tungsten alloy housing. If the gauge is abused to the point of removal from the -!

pneumatic and electrical connections, the source housing has been designed to be fail-safe and will close.

3.2.2.2 Control of Hazard from Direct or Scattered Radiation The source resides inside a massive sintered tungsten alloy housing to control the hazard from radiation. The radiation beam is high!y collimated such that only the primary radiation required for measurement is emitted. An air lockout valve is provided to protect individuals from both direct and scattered radiation in the controlled access area. A 0.25 mR/hr controlled access area is maintained around the device at all times.

3.2.2.3 Discouraging Unauthorized Access to the Source Warning labels clearly identifying the radiation hazard are prominently mounted on the gauge. Multiple fasteners must be removed to gain access to the source housing.

Additional tamper evident fasteners would need to be removed to gain access to the source.

l 1995 March 1 Model 5321 Isotope Measuring Systems Page5

3.2.2.4 Accessibility of the Radiation Beam During Use There is no access to the radiation beam during normal operation of the gauge duc to the themial and mechanical properties of the production process, i.e., high speed, high temperature. An air lockout valve is provided to ensure no access to the radiation beam during maintenance procedures.

3.2.2.5 Size of Openings or Gaps The air gap size is given in Appendix A.

3.2.2.6 Description of Shutter Mechanism The source capsule is hcused within a source housing / shutter mechanism. This mechanism is constructed of heavy metal (tungsten alloy). Source capsules are maintained in position by a source holder. A shutter is fixed to the shaft of a pneumatic actuator that operates when the shutter open command is given by either the operator panel or the central station cubicle. Mechanical return springs assure automatic closure of the shutter in the event of air or electrical supply failure.

The source housing / shutter mechanism consists of redundant shutter return springs, source capsule pressure pring, shutter bearings, source shutter position sensors, shutter actuator, pneumatic connection hose, source housing shielding, source shutter, source holder, source captule locking bolt, and source shutter drive shaft bearing. The source housing is bolted to the frame with SAE grade 5 or equivalent M12 or larger bolts. Data sheets for these components can be found in Appendix C.

3.2.2.7 Source Position Indicator .

The source position indicator is described above and in the drawings. " M 3.2.2.8 Cooling System A closed or open loop water cooling system is used to protect the mechanical and electrical components of the device. Components of the cooling system Mclude steel waterjackets with size and shape determined by the size of the frame and site conditions. A pressure relief valve vents to atmosphere if system pressure exceeds a safe limit. At least three temperature sensors mounted in the device monitor the , ,

cooling system. ,,,,  ;;

i il 0.3 Labeling 3.3.1 Label Description, Attachment, and Location The device contains the following labels:

. Caution Radiation labels - containing the standard radiation s.ymbol and words

" Caution - Radioactive Material". y

. Manufacturer's identification - containing manufacturer's name, model number,5 { ,, < -

serial number, radionuclide, activity, and date of assay for sources.

The label material is alu;ninum or other durable metal attached by metal fasteners SAE Grade 5 or better. The lettering is through engraving, etching, stamping or other e equivalent permanent process. The label size in a protected environment will have a ,

El 1995 March 1 Model 5321 Isotope Measuring Systems Page 6 w.

3o e

i s' l minimum letter size of 1.5 mm and a minimum dimension of 20 mm x 50 mm. All others i will have a minimum of 3 mm letter size and minimum dimension of 100 x 150 mm. l The labels are located to either side of the device, directly on frame where visibility is optimized for site conditions. ^ n,c 3.4 Testing of Prototypes The description of the tests performed on the prototype device and the test results that establish the integrity of the radiation safety features of the device under the conditions of use to which the device is likely to be subjected can be found Appendix D.

l 3.5 Quality Control m  !

The QA program is in accordance with the applicable regulatory control, i.e., AECB y INFO-0338-1 and ANSI N538. The details are covered in Appendix E. W' 3.6 Radiation Profiles  ;

Isodistances for measuring in both the on (shutter open) and the off (shutter closed ) i conditions are 5 cm,30 cm, and 100 cm from the nearest accessible surfaces of the l device. Calculated isodose curves are given in Appendix F. The curves pertain to a gauge free standing on a concrete foundation. Actual, as-installed, isodose curves will be verified after installation using a Victoreen 471 or equivalent meter calibrated yearly.  !

As-installed isodistances will in all cases be less than the free standing " worst case

isodistances.

3.7 Installation The measuring frame is permanently instatied on drive rails. Limited accessibi!ity is inherent to this type of installation because of the nature of the production process. An air lockout valve is provided to ensure no access to the radiation beam during ,

maintenance procedures. The manufacturer issists the end-user in designing radiation shielding required to suitably confine the controlled access area as appropriate for site conditions. Types of shielding materials include steel, iron, concrete, and lead.

Installation of the gauge is completed by the end user under direction of the manufacturer. Installation of the sources is done by the manufacturer or their qualified designee.

3.8 Radiological Safety Instructions See Appendix G for comp'ete radiological safety instructions.

3.9 Documentation Accompanying the Device 3.9.1 Leak Test and On-off Mechanism / Indicator Certificate The distributor will supply a certificate providhg date and results of the most recent leak test, assay test, and test of the on-off mechanism and indicator performed on the j device.

I 1995 March 1 Model 5321 Isotope Measunng Systems Page 7

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l 3.9.2 Radiation Surveys Radiation surveys in the form of isodose cuves will accompany the device. These isodose curves describe the radiation levels at the time the device was manufactured and when the device was installed.

3.9.3 Transportation l A copy of the documentation of the test on the package demonstrating that it meets the requirements of the relevant DOT specifications will accompany the device.

3.10 Servicing The following is a list of services that will be provided by the device manufacturer or distributor-

. Radiation survey and leak test at the time of installation Transfer of the sources from the transport container to the device at the time of installation

. Repairs to the source housing

. Source replacement,if needed

. Calibration of the gauge

. Training of operators on safe device operation

. Training of maintenance personnel on safe device maintenance 3.11 Leak Testing i A leak test frequency of every six months is required for this device. l 3.12 Safety Analysis The gauge incorporates several safety features which will help to minimize health and safety risks from the radioactive sources. The safety features include robust  ;

mechanical structure, fail-safe shutter operation, air lockout valve, temperature monitoring, monitor displays, operator controls, and shutter status indicator.

I in the event of fire, air feed hoses would melt and cut off the supply of compressed air thereby closing the shutter. In case of a catastrophic hit to the gauge, i.e., the gauge is removed from its mounting, the air lines and electrical lines would likely be detached ,

from the gauge and thereby closing the shutter.

No individual should receive more than 0.5 R/yr (5 mSv/yr) under normal operating  ;

conditions.

The manufacturer and the distributor have made every reasonable effort to maintain radiation exposures as low as is reasonably possible when designing and constructing  ;

devices for installation, maintenance, repair, and use. '

Based on these safety features, the information and test data cited, the ANSI classifications, and the fact that the manufacturer has over 40 years experience with l

these and similar gauges, it is expected that the gauge would maintain its integrity during normal and accidental conditions of use.

I' l,

1995 March 1 Model 5321 Isotope Measuring Systems Page8 I

C:/ 5% 5%q REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its' entirety)

NOt: -NR-375-D-102-S DATE: June 22, 1995 PAGE 1 OF 9 DEVICE TYPE: Profile Thickness Gauge

.l MODEL: 5245-xx series (see description for approved model numbers) i DISTRIBUTOR: Isotope Measuring Systems, Inc.

108 Blue Ridge Drive Mars, PA 16046 ,

MANUFACTURER: Isotopen Messsysteme GmbH (IMS)

Dieselstrasse 55 Postfach 10 03.52-7\9 5628 Heilgenhaus 1 GERMANY SEALED SOURCE MODEL DESIGNATION: Amersham: CDC.PE4 ISOTOPE: MAXIMUM ACTIVITY:

Cesium-137 275 Ci (10.175 TBq)

(55 Ci/2.035 TBq per source; Table I lists sources / device)

.i i

LEAK TEST FREOUENCY: .Ei Months  !

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PRINCIPAL USE: (D) Gamma Gauge I CUSTOM DEVICE: YES $X NO

/Y/  !

6}$0S'ist'7c33907- l

l  ;

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l' REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES  !

' SAFETY EVALUATION OF DEVICE i (Amended in its entirety)

HQt: NR-375-D-102-S DATE: June 22, 1995 PAGE 2 OF 9 DEVICE TYPE: Profile Thickness Gauge DESCRIPTION:

An Isotope Measuring Systems 5245-xx Series profile thickness gauge consists of the following:

  • Metal Measuring Frame Structure (C-Frame or O-Frame) )
  • Individual Source Housings
  • Ionization Chamber Detectors  !
  • Electronic and Microcomputer System j
  • Air Blower Purge System . I
  • Remote Mounted Operator Panel
  • Source Shutter Open/ Closed Indicator Light Boxes The device has the sealed sources mounted in source housings in the upper arm of the measuring frame. The source housings are  !

made with Heavy Metal (Tungsten Oxide, specific gravity =18.9, j melting point =3380*C) cylindrical shutters with fan type collimators The shutters are mounted with axial springs which-close the shutter if there is a electric power or pneumatic failure. The housings are_ mounted some distance apart along the ,

upper arm of the frame and are tilted so that the cross-sectional  ;

area of each radiation beam will cover all the detectors which i are mounted along the bottom arm of the measuring frame.  ;

The measuring frame is constructed from 0.375" (0.953 cm) thick steel box section and rides on three rails set into the floor of the facility. The frame is moved by an electric motor on the rails between a storage and a measuring position. The microcomputer system ensures that the shutters on the device cannot be opened or remain in an open position unless the measuring frame is in the measuring position.

The measuring frame is equipped with a cooling system which will ensure the temperature in the area of the measuring frame will not exceed 158'F (70*C). Temperatures above 158'F (70*C) will cause the system to give faulty readings. The device itself will maintain its radiological integrity at temperatures up to 599'F  !

l' (315'C) . l t

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REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

EQ : NR-375-D-102-S PATE: June 22, 1995 PAGE 3 OF 9 DEVICE TYPE: Profile Thickness Gauge DESCRIPTION (cont' d) :

I The measuring area of the device is equipped with an air purge system which will clear any corrosive vapors from the area. This !

system is also equipped with an alarm which will notify the  ;

operator if the air system is not operating correctly. '

l

- Other safety features of the device include: ,

e automatic shutter closure if there is an electric or air  !

failure, if there is no material in the measuring gap, if the device is knocked over or moved out of its measuring position, or if the temperature exceeds 158 F (70 C).

a steel / lead wall constructed in front of the C-frame opening to prevent the radiation dose rate from exceeding 0.25 mR/hr (2.5 pSv/hr) in any accessible area near the C-frame opening. For O-frame gauges, the lead / steel wall may not be applicable since there is no opening. However, even with O-frame gauges, a 0.25 mR/hr (2.5 ySv/hr) controlled area must be maintained. ,

l

  • source shutter open/ closed (red / green light) indicator light l boxes on the top of the unit (C-frame gauges), or wherever '

they provide best visibility to the gauge operator and other  !

plant personnel '(0-frame gauges) .

The 5245-xx Series profile gauges have been registered as a  !

series because the distributor indicates that gauges will be  !

manufactured for licensees on an individual basis. Therefore, i the dimensions of the gauge may vary but the design of the source I housing will remain the same. The distributor will submit the j design of each new gauge of the series to NRC for approval. The -

approved series model numbers are listed in Table I, next page: i l

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9 REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

NQt: NR-375-D-102-S DATE: June 22, 1995 PAGE 4 OF 9 DEVICE TYPE: Profile Thickness Gauge DESCRIPTION (cont ' d) :

l t

TABLE I. Dimensions and Activity - 5245-xx Series Gauges 5245-01 l 5245-03 l Length (inches) 206 319.4 (meters) 5.23 8.114 Height (inches) 144 147.6 I

(meters) 3.66 3.750 Width (inches) 17 20.9 (meters) .-

0.432 0.53 Air Gap (inches) 98 88.6 .

(meters) 2.49 2.25 l Ionization Chambers 56 93 Source Housings 2 5 Total Activity (Ci) 110 275 (TBq) 4.07 10.175  ;

DIAGRAM: ,

l Attachments 1-5 show profile thickness gauge Models 5245-01 and 5245-03, the source housing, and the radiation dose rate contours for each gauge.

1 b

LABELING:

The device is labeled in accordance with Subpart J, 10 CFR-Part all/4(

20. .The labels contain the radiation symbol, isotope, activity,  ;

model number, serial number, name of the distributor, the words  !

" CAUTION-RADIOACTIVE MATERIAL", and' full details of contact names and telephone numbers.

The labels are made of aluminum, steel, or brass, are rectangular in shape, and are permanently attached by screws to the device.

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REGISTRY OF RADiv?CTIVE SEALED SOURCES AND DEVICES SAFET'.' h?ALUATION OF DEVICE i (Amended in its entirety)

NO.: NR-375-D-102-S DATE: June 22, 1995 PAGE 5 OF 9 DEVICE TYPE: Profile Thickness Gauge CONDITIONS OF NORMAL USE: l l The device is intended for use in industrial gauging applications. The device is typicclly used to measure thickness profiles of metal plate / sheet ranging in thickness from 0.0004"

, to 10" (0.01 mm to 25.4 cm). The device is designed for the following environments:

Temperature ..................... Up to 158'F (70*C) ,

(operating)  !

Device will maintain its  :

integrity in temperatures l up to 600'F ( 315 ' C) i Pressure ........................ Atmospheric j Vibration........................ Ranges from zero to mild  !

Corrosion ....................... Ranges from zero to Highly Corrosive Vapors i Fire ............................ 1472*F (800*C), 20 minutes l

PROTOTYPE TESTING:

Both the profile thickness gauge and the source housing used I within the gauge have been tested in accordance with the i procedures specified in the NBS Handbook 129, American National )

Standard N538. The s'ource housing received a classification of

, ANSI 32-SSS-454-R3. The profile thickness gauge received a classification of ANSI 32-SSS-985-R3.

Stray radiation measurements for both the source housing and the device, shutter in the open position, are equal because they were measured in the primary beam. The radiation measurements are 1936.0, 167.2, and 17.6 R/hr (19.36, 1.672, and 0.176 Sv/hr) at 6*, 30, and 100 cm (2.4" 11.8", and 39.4".), respectively.

  • 6 cm is the smallest distance .from the source housing due to the geometry of the measuring device.

In addition, the shutter mechanism was subjected to cycle testing. Shutter open/close operation was performed every 40 seconds for over 1300 cycles in temperatures ranging from O'F

~

(-17'C) to 140*F (60*C).

~

REGILTRY OF RADIOACTIVE SEALED SOURCES AND D5 VICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

NO.: NR-375-D-102-S DATE: June 22, 1995 PAGE 6 OF 9 DEVICE TYPE: Profile Thickness Gauge 4

PROTOTYPE TESTING (cont ' d) :

Prototype sources of the ones used in the device have achieved ANSI N542 classifications of 77E63535.

EXTERNAL RADIATION LEVELS:

Isodose curves showing a 0.75 mR/hr (7.5 pSv/hr) contour around the Model 5245-01 measuring frame are shown in attachment 3. The same contour around a Model 5245-03 loaded with 250 Ci (9.25 TBq) of ""Cs is shown in Attachment 5. The contour lines show the 0.75 mR/hr (7.5 Sv/hr) area with the shutter in the open position. The 0.25 mR/hr (2.5gsv/hr) contour can be defined by simply, reducing the distance from the measuring frame by a factor of 1.E3.

The only place where an individual can stand within three feet of the Model 5245-01 C-frame during normal operation is in front of the 'C' opening. (An individual cannot stand within three feet of a Model 5245-03 0-frame gauge during normal operation.) This area will have a lead / steel wall constructed to confine the radiation dose rate to 0.25 mR/hr (2. 5 ySv/hr) .

Radiation dose rates at 6, 30, and 100 cm (2.4", 11.8", and 39.4") from the source housing and the Model 5245-01 are shown in Table II, below:

Table II. External Dose Rates - 5245-01

. Distance from Radiation Dose Rate in mR/hr (pSv/hr)

Source' Housing or Meas. Frame Source Housing Meas. Frame Primary Beam Shutter Closed Shutter Closed Shutter Open 6 cm/2.36" 50.40 mR/hr 0.5 mR/hr 1936.0 R/hr 30 cm/11.81" 4.00 mR/hr Background 167.2 R/hr 100 cm/39.37" 0.36 mR/hr Background 17.6 R/hr

4 l

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

HQ2: NR-375-D-102-S PATE: June 22, 1995 PAGE 7 OF 9 DEVICE TYPE: Profile Thickness Gauge OUALITY ASSURANCE AND CONTROL:

IMS has submitted quality assurance and control procedures for the manufacture of 5245-xx Series gauges that have been deemed acceptable for licensing purposes by the NRC. Also, IMS has procedures for inspecting units received at customer facilities in this country. A copy of each set of procedures is on file with the Source Containment and Devices Branch of the NRC.

LIMITATIONS AND/OR_Q.TliER CONSIDERATIONS OF USE:

5245-xx Series devices shall be distributed only to persons specifically licensed by the NRC or an Agreement State.

  • Handling, storage, use, transfer, and disposal: To be determined by the licensing authority. In view that the sources used in the device exhibit high dose rates, the sources should be handled by experienced licensed personnel using adequate remote handling equipment and procedures.
  • Model 5245-xx gauges shall be leak tested at intervals not to exceed 6 months using techniques capable of detecting 0.005 pCi (185 Bq) of removable contamination.
  • The Model 5245-03 gauge is to be installed at Bethlehem Steel. The 5245-01, meanwhile, is approved only for measuring aluminum.
  • REVIEWER NOTE: A) The device must have all of the following safety features checked for proper function at the time of installation and at intervals not to exceed 6 months:
  • spring mechanism which will close the shutter if there is a power failure.

i e air / electric supply failure detection system.

  • proximity switches which will ensure shutter closure if the device is not in the measuring position.
  • detection system which will ensure shutter closure if no material is in the measuring gap.

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

REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES  :

SAFETY EVALUATION OF DEVICE '

(Amended in its entirety)

HQ : NR-375-D-102-S DATE: June 22, 1995 PAGE'8 OF 9 r DEVICE TYPE: Profile Thickness Gauge )

LIMITATIONS AND/OR OTHER CONSIDERATIONS OF USE (cont ' d) :  !

e shutter indicator light boxes.  !

  • REVIEWER NOTE: B) A Model 5245-01 device must be installed I with a lead / steel wall constructed in front of the 'C'  !

opening of the device. The wall must confine the radiation ,

dose rate to 0.25 mR/hr (2.5 pSv/hr) or lower. O-frame gauge installations may not necessitate this wall. A controlled area shall be maintained around both C-frame and 0-frame to ensure that no individual will be exposed to a  ;

radiation dose rate greater than 0.25 mR/hr (2.5 gSv/hr) . l The areas above the device, such as catwalks, must be L unaccessible during operation due to the high radiation dose rates in the area above the measuring frame. l l

  • If Isotope Measuring Systems wishes to add any new devices  !

l to this registry sheet as members of the 5245-xx series, -

they must submit design details for the gauge to the NRC.

  • This. registration sheet and the informaticn contained within the references shall not be changed without the written  !

consent of the NRC.  !

l SAFETY ANALYSIS

SUMMARY

l l Based on our review of Isotope Measuring Systems' 5245-xx Series i profile thickness gauges, and the information and test data cited below, we continue to conclude that these devices are acceptable r

for specific licensing purposes.

Furthermore, we continue to conclude that these devices would be expected to maintain their containment integrity for normal

l. conditions of use and accidental conditions which might occur l

during useu specified in this certificate.

H l i i  !

i

, _ _ . _ . _ _ _ . _.-.m_-. ...-_--_____._m -

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) REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES l 1

SAFETY EVALUATION OF DEVICE i j

(Amended-in its entirety)- ] t NO.: NR-375-D-102-S DATE: June 22, 1995 PAGE 9 OF 9 1

] DEVICE TYPE: Profile Thickness Gauge j

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i l 'i

REFERENCES:

) The following supporting documents for the Model 5245 series

! profile thickness gauge are hereby incorporated by reference and  ;

{ are made a part of this-registry document.

1 c

l

  • Lorenz.&'Engelhardt's application for AEG dated June 8, i j

1990, and' subsequent letters dated July 17, 1990, July 31, I 1990,' October 12, 1990,_ November 24, 1990, and January 17, l l

1991, with-enclosures-thereto.  !

  • Engelhardt & Associates' letter for Isotopes Measuring  !

Systems dated. July-28, 1992, with enclosures thereto.  !

4 -

1 .

1'-

  • Isotope Measuring Systems' letters-dated July 31, 1992, J

! March 1, 1995, and facsimile transmissions dated June 14, l

1995, and June 16,'1995, with enclosures thereto. i j ISSUING AGENCY

i -

U.S. Nuclear Regulatory Commission '#

j Date: June 22. 1995 Reviewer: "'

l

,t Steven ,

- a ett -

-i l

t l Date: June 22, 19.95 Concurrence: - - /3/ t s

p/Jo'hii W. "Lubinski (

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REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

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REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES  !

SAFETY EVALUATION OF DEVICE '

(Amended in its entirety) j NO.: NR-375-D-102-S DATE: June 22, 1995 ATTACHMENT 2 l

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SAFETY EVALUATION OF DEVICE t (Amended in its entirety)

E: NR-375-D-102-S DATE: June 22, 1995 ATTACHMENT 3 l

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REGISTRY OF RADIOACTIVE SEALED SOURCES AND DEVICES SAFETY EVALUATION OF DEVICE (Amended in its entirety)

NO.: NR-375-D-102-S DATE-. June 22, 1995 ATTACHMENT 4

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