ML20198E645
| ML20198E645 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1997 |
| From: | Hauber R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9801090179 | |
| Download: ML20198E645 (2) | |
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NUCLEAR REGULATORY COMMISSION I
J WASHINGTON, D.C. 3006H001 December 23, 1997 MEMORANDUM TO:
John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards Paul H. Lohaus, Deputy Director Office of State Programs
- /
FROM:
fkRonald D. Hauber, Director Nonproliferation, Exports and
\\1ultilateral Relations Office of Intemaoonal Programs
SUBJECT:
PROPOSED IMPORT OF RADIOACTIVE WASTE FROM TAlWAN (APPLICATION NO. IWOOS)
Attached is an application (IW005) from Chem-Nuclear Systems, Barnwell, South Carolina for the imped of radioactively contaminated metals from Taiwan. Your advice and assistance in the review of the application would be appreciated.
The wastes to be imported are from Chinshan Nuclear Power Station and consists of 1.3 to 1.4 million pounds of tubes and tube plates. The material was generated as a result of the condenser tube externals being exposed to contaminated service water.
The material will be imported to the Chem-Nuclear Consolidation Facility (CNCF) and then transferred to Manufacturing Sciences Corporation (MSC), in Oak Ridge, Tennessee for processing. The radioactive materiallicenses for the two facilities are attached alorig with the permit application for NRC review.
The condenser tubes will be received at the CNCF, receipt surveyed and packaged for transport to Manufacturing Sciences Corporation (MSC), the material will be decontaminated to unrestricted release levels and recycled. The applicant advises that any material which cannot be decontaminated will be processed through the MSC furnace for production of radioactively contaminated Ingots for reuse. The proposed schedule for shipment is from January 1998 through June 1999.
The import licensing criteria in 10 CFR }110.43 are as follows:
j (a)
The proposed import is not inimical to the common defense and security.
(b)
The proposed import does not constitute an unreasonable risk to the public health and safety.
(c)-
Any applicable requirements of subpart A of part 51 of this chapter are satisfied.
-o
.(d)
With respect to the import of radicactive waste, an appropriate facility has agreed to MD D I
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'J. Greeves accept the waste for management or disposal.
I would appreciate your comments, including recommended consultations, if any, with Federal agencies or with interested States, or low level waste Compacts, in addition to the State of -
o-Your commente are requested by January 14,1998. Please callif you need additional information.
Attachments; import license application dated October 14, ' ;97 (lWOO5) cc w/ attach:
T. Tsothschild, OGC DISTRIBUTION: tuf@M Central Files: T-5 C3 (IP 2A-49)
PDR DCS M OlP r/f CRStolber, OIP JKennedy, NMSS SSalomon, OSP.
DOCUMENT NAME: A:\\lWOOS.MEM T3 recew a copy of We docume% Indicate in be boa: 'C's Copy w4hout enclosures T e Copy wie _ -;
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oGC f QlP' % R.D - l NAME h W M rlbut:rto Tf% trig &illd F/ V%Hauber DATE "12Li97
,/12/ /97 12/ 197 OFFICIAL RECORD COPY I
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c CHEM NUCLEAR SYSTEMS 7
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--CONSOUDATION FACIUTY
. P.O. Box 828 o 'Barruell. South Cadina 29812 1.T CCT 20 Gif 59 October 14,1997 LDG-077 97 -
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//004995 Mr. Ronald D. Hauber Director for Non-Proliferation, Exports & Multilateral Relations Office ofinternational Programs U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Hauber:
Chem Nuclear Systems, LLC (CNS) requests, undt r 10 CFR 110.31(a), the issuance of a specific license as authorization to import radioactively contaminated mctals to our Chem-Nuclear Consol;dation Facility located in Barnwell, South Carolina.
Name and Address of Applicant:
Chem Nuclear Systems, LLC Consolidation Facility Highway 64, P.O. Box 828 Barnwell, South Carolina 29812 Name and Address of Supplier:
Taiwan Power Company Chinshan Nuclear Power Station P.O. Box 8, Shihmen Taipei, Taiwan, R#bhu dC;mm Country of Origin:
Rgth of C;mm The material will be imported to the Chem-Nuclear Consolidation Facility, and then transferred to M.anufacturing Sciences Corporation (MSC),804 Kerr Hollow Road, Oak Ridge, Tennessee 37830 for processing. The radioactive material licenses for these two facilities are enclosed with permit application for NRC review.
The material to be imported consists of1.3 to 1.4 million pounds of tubes and tube plates.
The material was generated as a result of these condenser tube externals being exposed to contaminated service water. A total of 120,000 tubes measuring 1 inch in diameter and 22.5 feet long consisting of an alloy concentration of 76% Cu,22% Zn and 2% Al, and 209 square feet of tube plate consistin;; of an alloy concentration of 70% Cu and 30% Ni is the quantity of radioactively contaminated material for inyort/. The contamination levels are 1.64 Bq/gm,3,000 dpm/ linear foot removable external and less than 1,000 dpnV15 cm fined extemal, and is predominantly Co-60 and Cs-137.
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R.D.Hauber, NRC
= 10/14/97 The cordenser tubes will be received ?.t the CNCF, receipt surveyed and packaged for transport to Manufacturing Sciences Corporation (MSC). the material will be
- decontaminated to unrestricted release levels and recycled.- Any material which cannot be decontaminated will be processed through the MSC furnace for production of radioactively contaminated ingots for reuse. The proposed schedule for shipment is from January 1998 tin'ough June 1999.
- Enclosed is a check in the amount of $5,000 for the initial application fee in accordance with 10 CFR 170.31. Ifyou have any questions or require any further information please do not hesitate to contact us.
Sincerely, CHEM-NUCLEAR SYSTEMS, LLC
'LM M
Lynne D. Garner Licensing Engineer Attachments 65 Flu 02130 El d!0 u2Al3E.;
1 1'
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P g3 1 of i P:g:s SOtfrH CAROLINA DEPAR1 MENT OF HEALTH AND ENVIRCNKICTTAL COffrROL RADIOACTIVE MATERIAL LICENSE Pursuant to the Atomic Energy and R.diation Control Act, Section 13 7 40 et. seq. of S.C. Code of Laws of 1976, as amended, and Supplements thereto, and the South Carolina Department of H3alth and Environmental Control Regulation 61 63, Radioactive Material (Title A), and in roliance on stat ements and representations heretof ore made by the applican"., a license is horeby issued authorizing the licensee to receive, acquire, possess and transfer radioactive material listed below/ and to use such radioactive material for the purpose (s) and at the designated below. This license is subject to all applicable rules and regulations of place (s) the South Carolina Department of Health and Environmental Control now or hereafter in effect cnd to any conditions specified below.
Amendment No. 25 Amends
- 3. License Number:
LICENSEE
- 1. Name:
Chem Nuclear Systems, LLC 287-04 in its entirety.
Chem-Nuclear Consolidation Fac;11ty A Subsidiary of Waste Management, Inc.
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South Carolina Hvy. 64 Snelling, SC 29812 December 31, 2000 t,. Radioactive Material
- 6. CE mical an6/or
- 7. Maximum Radioactivity (Element & Maen No.)
Phycical Form and/or quantity of material which licensee may possess at any one time.
A. Hydrogen 3 A. Any Form A.
100,000 Ci D. Source Material B. Any Form B.
4,000,000 lba C. Any radioactive C. Any Form C.
25,000 Ci material with Atomic numbers between 2 & 91 inclusive (except SNM &
source material.)
D. Special Nuclear D. Any Form D. 350 grams total of 8"U or 200 grams of 3"U or 200 grams Material.
of plutonium or any combination of these provided the sum of the ration of the quantities does not exceed unity.
E. Any radioactive E. Any Form E. 30 Ci material with Atomic Numbers 93 and above (except SID4) 00 6 U 05 DD ta dl Cl/s'Mi..
DHEC 812 (11/81)
P 93 2 Cf i P g;3 SOWH CAROLINA DEPAR'IMIDfT OF HEALTH AND IDNIRONMENTAL CONTROL Radioactive Material License Supple'mentary Sheet License No.
287-04 Amendment No.
21 8.
Authorized Use:
A.
E.
FCr receipt, storage, consoli'ation, repackaging, processing, and transfer to authorized licensess or as ca',1 bra t i on and reference standards for radiological analysisi or as contamination upon surf aces or contained within tools and equipment used at the Chem Nurdear consolidation racilitys or as contamination in/on tools and equipment used on field projectig.
Conditions 9.
Radioactive material as radioactive waste may only be received, processed, repaciaged and stored at the location indicated in Item 2 of this license.
This lice e does not~
authorize reciprocity in any other Agreement State, or state or territory subject to jurisdiction of 'the U.S. Nuclear Regulatory Commission.
10.
The licensee shall comply with all applicable provisions of Departmeat Regulation 61-63, Radioactive Material (Title t.),
Department Regulation 6 '. - 8 3,
Transportation of Radioactive Waste Into or Within South CarW ina, U.S.
Department of Transportation Regulation 49 CFR, and Radioactive Materials Licenses and Acceptance Criteria for Low-Level Radioactive Waste Disposal Facilities in which radioactive waste is transferred 11.
Operations of the consolidation Facility shall be conducted under the supervision o.
Steven P. D11tchington, Clifford E. Bowers, Mark S. Whitaker (RSO), John R. Lash, Richard E. Campbell, Lynne D. Garner, Charles B. Poston, Kirby P. Coggin, Michael Benjamin or other individuals designated by the CNSI Safety Review Board.
12.
Unless otherwise authorized in writing from the Department, the licensee shall only accept radioactive waste for processing, storage and transfer from those components of the United States Govemment exempted f rom pemitting requirements as specified under the Principles of Understanding (POU) between the State of South Carolina and the Department of Def ense dated December 4 and 10, 1980, and between the State of south Carolina and the Department of Energy dated October 29, 1980, or frc.a waste generators which have been issued a valid S.C.
Radioactive Waste Transport permit.
13.
The licensee shall not accept radioactive waste for consolidation, repackaging, otorage, or transfer unless the shipper has t rovided a properly executed Department Form DHEC 803, Radioactive Waste Shipment Certifisation Form, Part I and II.
Shipments consisting of more than 75 cubic feet or containing more than one (1) curie, shall be accompanied by a properly completed and executed Department Form DHEC 802, Radicactive Waste Shipment Prior Notification and Manifest Form.
14.
The licensee shall only accept radioactive waste in accordance with the terms and conditions of the license and Consolidation Facility Acceptance Criteria..
Any variance from this license shall have prior written approval from the Department with the excaption of radioactive waste traneportation regulations addreesed in Cnndition 21.
15.
Radioactive waste received for processing and transfer shall only be stored f ar a maximum of one year from date nf receipt.
DHEC 012 (11/81)
DHEC/BRH/1093
- - _ = -
i Page 1 of A Par,es SOUMI CARO'.,INA DEPARDODIT OP HECTH AND ENVIRONMENTAL CONTROL Radioactiva Material License supplementary sheet License No:
287304 Amendment Hot Lg 16.
The licensee shall not transfer radioactive waste to a disposal facility that is not acceptable under the terms and conditions of that facility's radioactive material license and acceptance criteria, such radioactive waste received for consolidation and repackaging shall be returned within two weeks of such determination to the original waste generator / shipper in accordance with applicable regulations.
17.
The licensee shall comply with all applicable provisions of 10 CFR 20.311, Transfer for Disposal and Manifest.
If provisions of the regulation are in conflict with or less stringent than those conditions of the disposal facility's radioactive material license, the conditions of the facility's license shall prevail.
28.
Sealed sources containing radioactive material shall not be opened by the licensee.
Each sealed source containing radioactive material, other than Hydrogen 3, with 18.
A.
a half lif e greater than thirty (30) days and in any form other than gas shall be twated for lealtage and/or contamination at intervals not to exceed six (6) months.
In the absence of a certificate from a transferor indicating that a test has been made within sLx (6) months prior to the transfer, the sealed source shall not be put into use until tested.
B.
The test shall be capable of dett inq the presence of 0.005 microcuries of radioactive raterial on the test sat The test sample shall be taken from the sealed source or from the surfaces one device in which the sealed source is pe rmanently mounted or stored on which one might expect contamination to accumulate. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the Department.
If the test reveals the presence of 0.005 microcuries or more of removable C.
contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired or to be disposed of in accordance with Department regulations. A report shall be filed within five (5) days of the test with the Director, Division of Radioactive Waste Management, South Carolina Department of Health & Env1.onmental Control, 2600 Bull Street, Columbia, roath Carolina 29201, describing the equipment involved, the test results, and the corrective action taken.
Tests for leakage and/or contamination shall be performed by the licensee or by other 20.
persons specifically authorized by the U.S.
Nuclear Regulatory Commission or an Agreement State to perf orm such service.
The licensee shall immediately notify the Department of any violations of applicable 21.
radioactive material or radioactive wa:te transportation regulations, conditions of this license, or radioactive waste acceptance criteria.
(6) 22.
The Ideensee shall conduct an inventory monthly and a physical inventory every months to account for the sealed source and all radioactive material received and The records of the inventories sha'11 be maintained for possessed under the license. and shall include the quantiti'es and kinds of licer. sed inspection by the Department material, location of radioactive material, and the date of the inventory.
DHEC B12 (11/81)
DHEC/BRH/1093
P 93 i cf i P gao SOUTH CAkOLINA DEPAR7 MENT OF HEALTH AND ENVIRONMENTAL CONTROL Radioactive Material License Supplementary Sheet License No:
20 hoi Amendment No: 2.1 23.
The licenseo shall~not receive liquids for processing or storage without prior written approval from the Department. Waste containing small quantities of liquids in volumes not to exceed four (4) liters per individual container may be received without approval from the Department.
Radioactive liquid wastes may be received at the THERMEX pilot unit or THERNEX Central Facility for processing without prior Departmental approval.
A monthly processing report of the activities conducted at the THERMEX pilot unit shall be submitted to the Department.
24.
Except as specifically provided otherwise, the licensee shall possess and use radioactive material described in Items 5, 6, and 7 of this license for the purpose of processing, repackaging, and transporting radioactive waste and conduct the operations of the Consolidation Facility in accordance with statements, representations, and procedures contGined in the followingt a.
Letters with attachments dated March 28, 1990, June 23, 1991, March 25, 1992, April 10, 1992 and signed by William B. House.
b.
Letter dated April 27, 1992, signed by Kevin Petherick for William D. House.
c.
Letter and procedus s dated April 22, 1993, signed by Limne D. Garner.
d.
Letters and procedures dated August 13, 1993 and September 30, 1993, signed by Lynne D. Garner.
c.
Letter with attachments dated February 1, 1994, signed by Lynne D.
- Garner, f.
Letter with attachments dated July 11, 1994, signed by Lynne D. Garner.
g.
Letter and first submittal dated July 11, 1994; letter and second submittal dated October 20, 1994t and letter and third submittal dated December 16, 1994 on THERMEX Central Facility application, signed by Lynne D. Garner.
h.
Letter with attachments on changes to the design procest, on THERMEX Central Facility dated August 18, 1995, signed by Lynne D. Garner.
I.
Letter and first submittal dated May 12, 1995; letter with attachments and second cubmittal dated Augwat '. 1995 Ictter with attachments dated October 2, 1995; letter and third submittal dated October 3, 1995; and letter with attachments dated October 31, 1995 on Durachem Vitrification Facility application, signed by L)mne D. Garner,
j.
Renewal application with attachments dated November 30, 1995, signed by Lynne D.
- Garner, k.
Lettets with attachmente dated September 23, 1996 and February 20, 1997, signed by Lynne D. Garner.
For the South Carolina Department of Health and Environmental Control Date of Issuance horil 9.
1997 By r...k M 2
- 1 DHEC 812 (11/81)
Virgil R\\ Au'tr'y,~ Direc or,'Tiv. of Radir etiVe Waste Manag' ment
4 TANNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF RADIOLOGICAL HEALTH Soccce rneTet_ g (hid3 I l
RADIOACTIVE MATERIAL LICENSE AMENDMENT 38 Pursuant to Tennessee Dorartment of Environment and Conurveuen Regulations, and in reliance on and reptuentations heretofore made by the linnue, a licenu is hereby issued authorizing the'lic seguire, pouns sad transfer radios.ctive meteriallisted below; and to use such radioactive purpose (s) and at the place (s) designated below.This licenu is subject to all applicable ru Tennessee Department of Environment and Conservation and orders of the DMelon of Radiologic heresfter in effect and to any conditions speelfled blow.
LICENSEE
- 8. License number S 010M00 AhENDED IN ITS ENTIRETY 2
- 1. Name Manufacturing Sciences Corporation 3, g,p37,gi,,,,,,
December 31,2000 804 Kerr Hollow Road OakRidge,TN 37830
- 6. Tile no.
S 01046 l
- 6. Radioactive Material
- 8. Chemical an#ot physicalform
- 9. Maximum Radioactivity an&or
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quantity of material which licenne (Element and Mass Number) may possess at any one titae.
See Supplementan Sheets 1
10, Authorized Use See Supplementary Sheets
~
CONDITIONS j
~ 1L Unless otherwise specified, the authorlud place of use is thelicenue's address stated initem 2, above, See Supplementary Sheets For the Commiuloner Tennessee Department of Environment and Conservation
$DIts of!ssuance December 5,1995
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TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVAT30N DIVJ510N OF RADIOLOGICAL REALTH RADIOACTIVE MATERIAL LICENSE Amendmeat,M Supplementary Sheet Liccese Number $_01046 IA0 Page,2, of,(, Pages
- 9. Maximum Radioactivity an&or Quantity of MaterialWhich
- 6. Radioacths Licenses May Possess Metcrial(Element
- 8. Chemical an&or and Mass Number)
MgallED1 at AnyOnt3gg A. Naturaluranium A. Elemental, oxides, A. 216,818 kilograms and as residual contamination on and/orin fenous and nonerrous Sc!als B. Uranium depicted B. Same as in 8A B. 409,091 kilograms
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in the U 235 isotope C. Natural thorium C. Same as in 8A C.15.9 kilograms t:
D. Uranium enriched to D. Fixed contamination D.Not to execed 350 3% Uranium 235 on molybdenum plates grams' contained Uranium 235 E. Any radionethe material E. As residualcontamination E.100 curics
- Mth atomic number on an&orinferrous and betwocn 3 and 33 nonferrous metals inclushc (except carbon 14)
F. Hydrogen 3 F. Same as in BE F.100 curles
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G. Carbon 14
- 0. Same asin 8E 0,10 curies
'For each kind of special nuclear material'dctermine the tatto between the quantity of that special nucle material and the quantity specified herc for the same kind of special nuclear material. The sums of s retlos for all kinds of specist nuclear material in combination shall not exceed "1" (i.e., unity).
i
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TENNES$EC DEPARTMENT OF ENVIRONMENT AND CON 52RVATICN DIVISION OF RADIOLOGICAL HEALTH i
RADIOACTIVE MATERIAL LICENSE Amendment.H Supplementary Sheet License Number S-01046. Loo Pagelof1Pages H. Anyradioactive H. Same as in 8E H.10 curies matedal with stomic number between 84 and 91 inclusive (excluding radium)
!.10 curles and radium 228 J.Transuranics (axcept J. Same as in BE J. I curie SpecialNuclear Matedal)
K. Uranium enriched in the K Sarne asin SE K Combined popessionlimit U.235 Isotope for MSClleenses
- 5 01046. LOO and
&01078.L00 350 grams' of contained U 235 L. Uranium 233 L. Same as in SE L. Combined posseulonlimit for MSC licensos
- $ 01046.Lb0 and
- R 01078.L00 200 grams' M. Plutonium M. Same as in 8E M. Combined possession 11mit for MSClicenses
- $.01046. LOO and
%01Olt. LOC 200 grams' i
l
- For each kind of special nuclear material determine the ratio between the quantity of that special nuclear l
material and the quantity spectiled here for the same kind of special nuclear material. The sums of such i
j ratios for all kinds of special nucicar material in combination shall not exceed "I" (i.e., Jnity).
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26 i-l I
TENNESSEE DEPARTMENT OF ENVIRONMENT AND
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. DIVISION OFRADIOLOGICAL HEALTH i
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meTot MEW RADIOACTIVE MATERIAL LICENSE i
Pursuant to Tennessee Deps.rtment of Environment and Conurvadon R 3
acquire, possess and transfer radionettve materiallis nu on stakments ensee to receive, purposefs> and at the ptscets) designated below. This lieense is subject to all app Ter.nenee Departme.it of Environment and Conservation and ord material for the e and rervlations of the henoner in effect eod to any conditions specified below.
ea t, now or I.!CENSEE I' "'"
- 3. !Jeena number Manufacturing Sciences R-01078.L00 Ccrporation
- s. Addreu 4 E*Piratica dat*
1 304 KerrHollowRoad OakRidge, TN 37830 Neamh*0 1 '1000
- 6. File no.
R 01078 fl. Redienetive Metorial
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(Element and Mus Number)4. Chemical en&or physlcalform
- 9. Maximum Redioectivity anWer quandty of materialwhichllunsee may possess at arty one time.
See Supplementary Sheets
. 10. Authorind Use See Supplementary Sheets CONDITIONS
- 11. Unleu otherwise specified, the autherlud piece of use is the licensee's add em 2, above.
See Supplementary Sheets For the Commlufoner Tennupe Department ofEnvir.mment and Conurvstion Dete ofissuanu 6-h_ t t os3 -
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DIVIB30NOFPADiotoolcAt/keAt,TH M,,,,,. usi Ronald E. Wynn Health Physicist
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TENNESSEE DEFAMTMENT OF ENVIRONMENT AND CONSERVATION DIV1510N OF RADIOLOGICAL HEALTH RADIOACTIVE MATERIAL LICENSE Supplementary Sheet Liconst Number R 01078 LOO Page,2. of.i.Peges 9, Maximum!!adioactMty an&or Quantity of Material Which
- 6. Radioactive LicenseeMayPossess Material (Element 8, Chernicalan#or at Any One Time gj[jdass Number)
Phtsfest Form A. Natural urardum A. Elemental, oxides, A. 216,818 kilograms and as msidual contam! nation on an#ctinferrous and non ferrous metals B. Uranium depleted B. Same as in BA B. 409.091 kuograms in the U.235 isotope C. Natural thorium C. Same as in SA C.15.9 kilograms D. Uranium enriched to D. Fixed contaminatten D.Not to exceed 350 3% Uranlum 235 on molytdenum p!stes grams
- contained Urardum 335 E. Any radioactive m:6erial E. As residualcatamination E.100 curies with a'omic number on an#ctin ferrous and between 3 and 83 nonfer.ous meuls inclusive (except carbon 14)
F. Hydrogen 3 F. Same as in SE F.100 curies O. Carbon 14
- 0. Same as in 8E O.10 curics
'For each kind of special nuclear material determine the ratio between the quantity of that special nuclear material and the quandty specic:4 here for the samt kind of specist nuclear material. The sums of such rados for all kinds of special nuclear material in combinaden shall not exceed "1" (i.e., unity).
3 rom miss e-tA
- 8)
TENNES$EE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF RADIOLOGICAL HEALTH RADIOACTIVE MATERIAL LICENSE Supplementary Sheet License Number R.01078.ibo Page.1,of J.Pues il Any redloactive H.Same asin 8B H.10 cudos material with atomic number between 84 and 91 inclusive (excluding radium)
- 1. Same asin SE 1.10 cudes and radium 228 J.Tranruranics(execpt J. Same as in SE J. I curie Special Nuclear Material)
K Uranium enriched in the K Same asin SE K Combined possessionlimit U 235 isotopc for MSC lleentes
- S 01046 LOO aad
- R 01078 L00 350 grams' of contained U.235 L. Uranium 233 L. Same as in 8E L. Combined possessionlimit for MSClicenus
- $ 01046 L00 and
- R41078 000 200 grams' M. Plutenlum M. Same as inIE M. Combined possessionlimit for MSClicenses
- 5 01046140 and
- R 01078140 200 grams *
'For cach kind of special nuclear material determine the ratio between the quantity of that special material and the quantity specified here for the same kind of special nucleaf material. The sums of su i
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. - - -. - -