ML20149L005
| ML20149L005 | |
| Person / Time | |
|---|---|
| Issue date: | 01/17/1996 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20149J596 | List: |
| References | |
| NUDOCS 9602230142 | |
| Download: ML20149L005 (4) | |
Text
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION 9.,,,j WASHINGTON. D.C. 30666-0001 r
January 17, 1996 MEMORANDUM TO:
Charles W. Hehl, Director Division of Nuclear Materials Safety, RI FROM:
Donald A. Cool, Director 7' - I
Division of Industrial and h
MedicalNuclearSafety,NMSp i
SUBJECT:
TECHNICAL ASSISTANCE REQUEST: HIGH STEEL STRUCTURES, INC.;
LICENSE NUM8ER 37-17538-01 i
I am responding to your technical assistance request (TAR) dated May 23, 1995, transmitting letter dated May 9, 1995 (Attachment 1), from High Steel 4
Structures, Inc. (High Steel) requesting an exemption from certain provisions specified in Section 34.20 of 10 CFR Part 34.
Completion of this action has been delayed pending the Commission's decision regarding implementation of the l
January 10, 1996, date specified in 10 CFR 34.20(e).
~
High Steel requests an exemption from the provisions of 10 CFR 34.20(a) that i
radiography exposure devices must meet the requirements specified in American National Standards Institute N432-1980 (ANSI-N432).
High Steel is authorized for Amersham's Model 616, which High Steel indicates does not meet two of the ANSI-N432 requirements. First, when loaded with its maximum authorized iridium-192 activity (200 curies), the external radiation levels exceed the limits specified in Item 8.1, " Shielding Efficiency Test," of ANSI-N432.
4 Second, High Steel reported Amersham Corporation's confirmation that the device would not meet the 30 foot (9 meter) accidental drop test criteria specified in Item 8.4 of the ANSI standard. After reviewing the registration sheet for the device, we noted a third issue:
there is no information in the i
registration sheets to indicate that the device was prototype tested in accordance with ANSI-N432, as will be required by 10 CFR 34.20(a) after January 10, 1996. The registration sheet for the device is classified as
- inactive," indicating that Amersham does not intend to distribute any new 3
1 devices under this model number. However, we understand that Amersham intends to continue to provide some support for the model.
The Amersham Model 616 is considered to be a type of device commonly referred l
to as a "pipeliner." High Steel notes that the 10 CFR 34.20 requirements are "primarily directed at improving the safety of the crank-out type exposure d
devices" and states that the Model 616 devices "are not subject to the mechanical errors this regulation addresses." While High Steel uses the device in " field-type" radiography settinS (versus an exposure cell), we note that its license restricts High Steel operwtions to only two licensee-controlled locations, which, we believe, limits the situations in i
I' 9602230142 960209
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1 C. W. Hehl 2
which the device is used. We also note that High Steel is only authorized for the Amersham Model 616 device.
The exemption would allow High Steel to i
continue to use its Amersham Model 616 exposure devices.
Without the exemption, High Steel would have to discontinue using the devices after i
January 10, 1996, as required by 10 CFR 34.20(e).
l l
In its letter, High Steel appears to indicate that it would be willing to i
reduce the maximum activity it uses (and is authorized for) in the Model 616 in order to ensure compliance with the radiation limits specified in Item 8.1 i
of ANSI-N432.
We find this licensing request acceptable and note that an i
exemption for this aspect would not then be necessary. However, High Steel's letter implies that 10 CFR 34.20(a) restricts " maximum radiation levels to i
50 mR/hr at 6 inches from the radiographic exposure device."
Instead, the criteria specified in Item 8.1 of ANSI-N432 provides that the maximum exposure rate for portable devices not exceed 2 mR/hr at I meter from the surface and 3
either not exceed 200 mR/hr at any point on the surface or 50 mR/hr at 50 millimeters from the surface using the averaging technique described in Item 8.1.2.
High Steel needs to ensure that the maximum source activity it uses will not exceed these limits.
We have attached a copy of this section of ANSI-N432 which High Steel may find useful (Attachment 2).
4 l
Regarding the accidental drop test (30 foot) criteria specified in Item 8.4 of i
the ANSI standard, High Steel contends that due to the limited nature of its operations, it can restrict use of the devices to a height no greater than 10 feet.
However, the licensee's submittal did not include copies of 4
l.
operating procedures instructing workers of this height limitation, t
Section 34.51 of 10 CFR Part 34 provides that the Commission may grant exemptions from requirements when it determines the exemptions "... are authorized by law and will not endanger life or property or the common defense l
and security and are otherwise in the public interest." The requested l
exemption is authorizeo by law because it is permitted under the Atomic Energy Act of 1954, as amended.
This exemption will not endanger life or property or j
the common defense and security and is otherwise in the public interest.
1 l
Although the device, which was introduced in the late 1960's, preceded l
ANSI-N432, we note that the safety analysis ammary section of the device 2
registration sheet, which was reissued in 1993, concludes, "... the J
Model 616 would be expected to maintain its integrity for normal conditions of use and accidental conditions which might occur during uses as specified in 4
the certificate " Based on this information, High Steel's commitment to restrict use of the device, and provided High Steel submits acceptable l
procedures directing workers to limit the height when using the device, it l
appears continued use of the device should be acceptable, and an exemption i
from the requirements of 10 CFR 34.20(a) may be authorized.
High Steel must i
either identify acd demonstrate the maximum activity that will be used in the device which ensures that the applicable exposure limits will not be exceeded 4
a i
C. W. Hehl 3
or verify that the activity indicated in its May 9,1995, letter would ensure this. We recommend that Item 10 of High Steel's license be amended to reflect this maximum amount, when verified, and a condition be added which clearly indicates the conditions of the exemption. Attachment 3 is the suggested text for an acceptable license condition.
i Attachments:
1.
Ltr dtd 5/9/95 2.
ANSI-N432 Section 4
3.
Suggested Text for License Condition CONTACT:
J. Bruce Carrico, NMSS i
(301) 415-7826 i
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C. W. Hehl 3
or verify that the activity indicated in its May 9,1995, letter would ensure this.
We reconenend that Item 10 of High Steel's license be amended to reflect this maximum amount, when verified, and a condition be added which clearly indicates the conditions of the exemption. Attacnment 3 is the suggested text for an acceptable license condition.
Attachments:
1.
Ltr dtd 5/9/95 2.
ANSI-N432 Section 3.
Suggested Text for License Condition CONTACT:
J. Bruce Carrico, NHSS (301) 415-7826 Distribution:
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