ML20154D424

SER Supporting Application for Renewal of License SNM-1513

ML20154D424
Person / Time
Site:	07001703
Issue date:	09/30/1998
From:	Astwood H, Hardin K, Soog S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20154D403	List: ML20154D398 ML20154D409 ML20154D424
References
NUDOCS 9810070218
Download: ML20154D424 (7)

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NUCLEAR REGULATORY COMMISSION WASHINOTON, D.C. 20555-4001

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DOCKET: 70-1703 September 30, 1998 LICENSEE: Ea.stman Kodak Company Rochester, New York

SUBJECT:

SAFETY EVALUATION REPORT, APPLICATION DATED MARCH 23,1998, RE: LICENSE RENEWAL

1. INTRODUCTION By letter dated March 23,1998, Eastman Kodak Company (EKC) filed a renewal application for Materials License SNM-1513. As a result of teleconferences between NRC staff and an EKC l representative on September 24 and 29,1998, EKC provided supplementary information for the renewal application by letter dated September 30,1998. The license was last renewed in April 1993, with an expiration date of April 30,1998. During this period, Amendment 1 was issued dated May 18,1995, to incorporate the licensee's Physical Security Plan. EKC's license was originally issued by the U.S. Nuclear Regulatory Commission (NRC) in 1975 to authorize possession and use of 1582.6 grams of U-235 in a Californium Neutron Flux Multiplier (CFX).

The CFX is a subcritical assembly with the licensed material in the form of uranium-aluminum alloy fuel plates clad in aluminum. The CFX was manufactured by the NRC-licensed Intelcom Rad Tech Corporation (Docket No. 70-1359). EKC uses the CFX for neutron activation analysis and neutron radiography for research and development activities.

II. POSSESSION LIMITS EKC has reque sted authorization to possess the following licensed material:

Material E.qtm ouantity Uranium enriched to Uranium-aluminum Up to 1582.6 grams 5 93.4% in the U-235 alloy clad in of U-235 located in isotope aluminum the Californium Neutron Flux Multiplier Ill. AUTHORIZED ACTIVITIES AND PLACE OF USE EKC has requested authorization to use the materialin the CFX for neutron activation analyses

, and neutron radiography for testing film materials. The experiments will be conducted at Kodak Park, Building 82. The license renewal application is incorporated as a condition of the license, j as follows:

9. Authorized use: For use in accordance with statements, representations, and conditions specified in the licensee's application dated March 23,1998, and supplement dated September 30,1998.

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10. Authorized place of use: The licensee's Kodak Park, Building 82, in Rochester, New York, as described in the above application.

l IV. PERFORMANCE HISTORY Only one health and safety inspection has been performed since the license was last renewed in 1993. The inspection was conducted on April 18,1996. No violations were observed.

V. MANAGEMENT ORGANIZATION

! l l The Radiation Safety Officer (RSO) will be responsible for administering the radiation safety program. The RSO will manage the surveillance program, licensing activities, inventories, and new purchases of sources of radioactive material. The RSO will be assisted by one or more Assistant Radiation Safety Officers (ARSOs). The RSO will consult with radioactive material i

users on radiation protection matters. In the area where the CFX will be used, a Radiation l Safety Coordinator (RSC) will be assigned responsibility for radiation safety. The RSC will be

responsible for routine radiation monitoring and record retention and will serve as the liaison to I

the RSO. The RSC will be appointed by the Director of the Analytical Technology Division (ATD) and will be approved by the RSO.

l EKC's ATD has the administrative responsibility for the CFX. The Group Leader, reporting to l the Laboratory Head of the ATD, will be responsible for neutron activation analysis work and j the safe operation of the CFX.

EKC has established a Radiation Protection Committee (RPC), comprised of the Committee l Chairman; the Director of the Kodak Health, Safety, and Environment Organization; and the l RSO. The RPC will be responsible for establishing policies and providing guidance to the '

l Radiation Protection Program to ensure compliance with regulations, license conditions, and

! sound radiation safety practices. Other responsibilities of the RPC willinclude: (1) ensuring that the use of the licensed material is consistent with the A3 Low As Is Reasonably Achievable philosophy and program; (2) resolving issues identified by tne RPC, the RSO, or individual l users; (3) reviewing annually the overall status of the Radiation Safety Program; and l (4) reviewing and approving any changes to procedures that could increase experimental radiation levels. The RPC will meet on a quarterly basis or more frequently as needed. RCP l meeting minutes will be kept for 3 years.

' Based on the NRC staff's review, it is determined that EKC's management organization is consistent with good industry practice and is, therefore, acceptable.

i VI. TECHNICAL QUALIFICATIONS EKC has established minimum qualifications for the positions of Chairman of the RPC, RSO, RSC, ARSO, and Group Leader. These positions, except ARSO, require a bachelor's degree in science or engineering. In addition, EKC has set forth the following minimum qualifications:

The RPC Chairman shall have at least 5 years of experience in management, including 2 years of working with radiation.

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The RSO shall have at least 2 years of work experience in radiation safety and formal course work in radiation safety.

The RSC shall have at least 2 years of experience working with radioactive materials and/or x-ray equipment and a formal course in radiation safety.

The Group Leader shall have at least 2 years of experience with ionizing radiation.

Personnel in the position of ARSO shall have at least a two-year degree in science (or equivalent) and one year of experience with lonizing radiation.

Based on the NRC staff's review of qualifications for the EKC's technical staff, it is determined that they are consistent with good industry practice and are, therefore, acceptable.

Vll. ADMINISTRATIVE PROCEDURES A. Written Procedures EKC has committed that the CFX operation will be conducted in accordance with written procedures. These procedures will be approved by the RPC. EKC has committed that health physics activities will be conducted in accordance with written procedures and the procedures shall be approved and updated every 2 years.

B. Insoection EKC has committed to periodic inspections by safety personnel. These inspections will be performed quarterly by the RSO or ARSO in all work areas. These inspections will be conducted in accordance with written procedures. The findings of these inspections, with associated corrective actions, will be transmitted to the supervisor of the inspected area.

C. Training l

The RSO, Group Leader, and RSC will jointly provide radiation protection training to i each new worker. Retraining of workers will be conducted at intervals not to exceed 14 months. The effectiveness of the training will be monitored by the Group Leader and RSC.

Based on the NRC staff's review, it is determined that EKC's administrative procedures are adequate to administer an effective radiological safety program and are, therefore, acceptable.

Vill. RADIATION SAFETY The CFX, which contains 1582.6 grams of U-235, will be housed in the underground radiation cavity of EKC's Building 82. The shielding provided for the cavity will be adequate to assure that radiation exposure outside the cavity is less than regulatory limits. In addition, the following safety design features of the CFX and cavity will prevent potential mishaps:

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l a. An interlock system will prevent entry into the cavity when the CFX is operating l

l and the radiographic port is open. The system will be routinely checked by the '

RSC to ensure that it is operating properly.

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b. lon chamber detectors located in the device will automatically shut down the l device when the radiation level exceeds a preset level.

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! c. Radiation monitors in the cavity will trigger an alarm in the cavity and control room when the radiation level exceeds 10 mR/hr.  ;

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A. Control of Personnel Exoosure l l

l l Each worker who uses the CFX will be provided with a personnel radiation dosimeter and will be required to wear it at all times in the restricted areas. The dosimeters will be analyzed and evaluated monthly, if any worker's monthly exposure is above 100 mrem, j the RSO will immediately investigate the cause and will take action to prevent further I exposures.

l l B. C.ontrol of Surface Contamination Since the licensed material is a contained source and installed inside the CFX, the staff l has determined that the potential for surface contamination from the material is unlikely.

i The containment of the licensed material will be checked (i.e., leak-tested) every l 6 months. To ensure that leak-testing will be performed adequately, the staff imposes the following license condition:

11. The licensee shall comply with the attached " License Condition for Leak Testing Sealed Uranium Sources," April 1993.

The laboratories will be checked monthly for surface contamination. Typically, such contamination is from radioactive material licensed under the Agreement State license rather than NRC-licensed material. EKC has established appropriate criteria (i.e., action levels) for cleanup if contamination is detected.

C. Airborne Activity The staff has concluded that because of the nature of the radioactive material being handled and the double aluminum housing in which the materialis encapsulated, hazardous exposures to airborne radioactive material are unlikely, D. Instrument Calibration l

! Portable meters and area monitors will be calibrated yearly by persons licensed to calibrate health physics instruments. This calibration frequency is consistent with Regulatory Guide 8.23, " Radiation Safety at Medical Institutions," and thus acceptable to the staff.

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E. Radioactive Waste Discosal l Radioactive waste generated by the CFX will consist of activated samples contained in sealed polyethylene capsules. These capsules will be packaged for disposal according to the requirements of the U.S. Department of Transportation and New York State. To ensure that contaminated equipment will be released according to NRC guidelines, the l

staff imposes the following condition:

12. Release of equipment or material for unrestricted use shall be in i accordance with the attached " Guidelines for Decontamination of

Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," April 1993.

The staff has review EKC's radiological safety program and determined that it is sufficient to meet 10 CFR Part 20 requirements and is, therefore, acceptable.

IX. NUCLEAR CRITICALITY SAFETY l

A. Descriotion of the CFX The ATD of EKC supplies analytical support for EKC's manufacturing and research and development activities. One section of this division is assigned to a specially designed and equipped area for neutron activation analysis and radio-tracer work. This specialty work is performed using a CFX.

The CFX is composed of a central, polyethylene filled flux trap, a surrounding core of Materials Testing Reactor type fuel plates alternated between polyethylene moderator slabs, and a close fitting polyethylene reflector. The flux trap is a small cube of high-density polyethylene used for

its moderating characteristics. Each fuel plate surrounding the flux trap consists of a 0.02-inch-

! thick core of uranium-aluminum alloy, which is enriched to 93.4% U-235. The total mass of l

U-235 in the CFX is 1582.6 g. Each of the four major fuel containers has a pressure plate at

! one end to ensure that no voids exist between the fuel and moderator plates. The reflector

. located outside the pressure plates consists of 4-inch-thick polyethylene slabs.

Two penetrations into the CFX exist for activation analysis irradiations: one penetrates into the central flux trap and the other penetrates approximately halfway into the center of one of the fuel boxes. The neutron radiography port is a horizontal rectangular cone that penetrates into the center of the flux trap and contains a guide tube for the Californium-252 source. The source is located in the flux trap during normal operation and in a storage pig when the CFX is shut down.

Four safety rods made of 0.02-inch-thick aluminum-clad cadmium are magnetically held in a vertical position above the system. If power is lost to the electromagnet, the rods will fall by

- gravity into the fuel region.

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B. Criticality Safety Review of the CFX The staff has reviewed the information submitted by EKC and has performed a technical assessment of the activities associated with the use of the CFX.

EKC performed experimental measurements and had an independent contractor perform ,

computer simulations on the CFX. These measurements and simulations were used to i determine the reactivity effects of three scenarios: (1) increasing the amount of reflector, (2) flooding the sample ports, and (3) performing both conditions in one scenario. The results from both the measurements and simulations agreed that all three scenarios produced I

) negligible changes in reactivity (i.e., an increase in reactivity of 0.00007 for each scenario by itself and 0.00014 for the combination scenario). The measurements and simulations were also used to confirm that the CFX had an optimum moderator hydrogen-to-uranium (H/U) ratio.

Because the CFX is optimally moderated and the contributions to reactivity due to both additional reflectors and flooding are negligible, the staff agrees that no additional reflectors 4

and/or moderator will make the CFX go critical. Because the fixed geometry of the CFX is optimized to give the highest reactivity, the staff agrees that any arrangement of fuel and moderator other than the intended arrangement will result in a less reactive system. Thus, the staff agrees that there are no credible normal or abnormal conditions that could result in reactivity increases equal to more than a small fraction of the minimum margin of subcriticality.

Because EKC is only authorized for 1582.6 g U-235 and that amount of fissile material is already in the core of the CFX, the staff concludes that it is not credible for additional fissile material to be introduced into the CFX.

I However, the measurements and simulations were also used to determine the minimum amount of 93.4% enriched U-235 that would need to be added to the system to achieve

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criticality. The results from both the measurements and simulations showed that criticality would require either the addition of 72.9 g of U-235 as more fuel plates or 33.26 g of U-235 as

. UO2 in the sample activation position. Because the geometry of the CFX is fixed, the staff concludes that the accidental addition of enough fuel plates to go criticalis not credible. The i

maximum amount of U(93.4)O2 that could fit into a sample vialis approximately 14 g U-235.

Because only one sample vial can be placed into the sample activation position at a time using the CFX's transfer system and the maximum amount of U-235 that can fit into a sample vial (i.e.,14 g U-235) is less than the amount required for criticality (i.e., 33.26 g U-235), the staff agrees that the accidental addition of enough U(93.4)O2 to go criticalis not credible.

Because fully withdrawn rods have zero reactivity worth, any movement of the safety rods into the CFX will decrease the reactivity of the system, and both measurements and simulations results agreed that, in both credible normal and abnormal conditions with the safety rods fully withdrawn, the maximum k, was 0.99, there is no credible mechanism for an accidental criticality to occur without the addition of unlicensed fissile material.

EKC committed to establish and implement written procedures to ensure that fissile material will not be present in any sample for use in the CFX. The procedures shall include provisions that trained personnel shall verify that each sample for use in the CFX contains no fissile material.

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In addition, two postings will be placed in the facility. The postings will be placed in the sample preparation area and by the radiographic port of the CFX. The postings will provide warnings that no fissile materialis allowed to be in a sample for use in the CFX. The staff concludes that the use of mass controlin conjunction with the radiological administrative controls and interlocks in the facility make it not credible that unlicensed fissile material will be introduced l into the CFX and create an accidental criticality.

l In the renewal application, EKC requested an exemption from the criticality accident alarm system requirements of 10 CFR 70.24. Because no additional mass of fissile materialis allowed by the license, there are administrative controls on the mass of fissile material for use l in the CFX, and as discussed above, it is " incredible" that an accidental criticality can occur, the staff concludes that EKC may continue to be exempted from the criticality accident alarm system requirements in 10 CFR 70.24. Accordingly, the following license condition is l incorporated into the license:

13. The licensee is hereby exempt from the requirements of 10 CFR 70.24 insofar as this section applies to the materials held under this license.

X. ENVIRONMENTAL PROTECTION I

The licensing of EKC activities is in accordance with 10 CFR 51.22(c)(14)(v), and therefore, neither an environmental impact statement nor an environmental assessment is warranted for this action.

XI. DECOMMISSIONING Because of the nature of the EKC licensed material (i.e., sealed sources), a decommissioning funding plan is not required by 10 CFR 70.25.

I XII. EMERGENCY PLAN i

Because EKC is not required to have a criticality accident alarm system and does not possess any uranium hexafluoride or plutonium, pursuant to 10 CFR 70.22(i)(1), an emergency plan is not required. l l XIll. PHYSICAL SECURITY PLAN EKC has a Physical Security Plan (Plan) for the protection of special nuclear material as required by 10 CFR 73.67. The Plan was approved and incorporated into Materials License SNM-1513 on May 8,1995. The Plan still remains in effect as a part of the license.

Accordingly, a condition is imposed to incorporate the Plan into the renewed license:

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14. The licensee shall follow the phyaical protection plan entitled " Licensee Physical Security Plan for the Protection ot' Special Nuclear Material of Moderate Strategic Significance," dated February 2,1995 (transmitted by letter dated April 4,1995) and as it may be further revised in accordance with the provisions of 10 CFR 70.32(e). l l

l XIV. . CONCLUSION AND RECOMMENDATION On completion of the safety review of EKC's application, the staff has concluded that licensed l activities will not constitute an undue risk to the health and safety of the public nor to the I environment.

! Subject to the above conditions, it is recommended that EKC's license be renewed for a

.10-year period, expiring September 30,2008.

Region I has no objection to this licensing action.

. Princioal Contributors Sean Soong i Heather Astwood Kim Hardin Harry Felsher l

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