ML20198G322
| ML20198G322 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/1996 |
| From: | Brown R NRC |
| To: | NRC |
| Shared Package | |
| ML20198F790 | List: |
| References | |
| SSD, NUDOCS 9812290051 | |
| Download: ML20198G322 (37) | |
Text
.
t.
I:
I I.
From:
Robert Brown To:
sib, twr l
Date:
10/10/9611:13am
Subject:
WSMR CAL l
Please review the attachod file and send us your comments. Thanks i
i s
l I
9812290051 991110 i
hh]Y S' DGS/
4 CAL 96-005
[ RANGE COMMAND) f Department of the Army White Sands Missile Range White Sands, New Mexico 88002-5048
SUBJECT:
CONFIRMATORY ACTIONIEITER
Dear (Range Command]:
his refers to our investigation of the use of cobalt-60 sources manufactured by Neutron Products, Inc., in the irradiator at the Gamma Range Facility, White Sands Missile Range (WSMR). De investigation was initiated in response to notification provided by WSMR staff that a cobalt-60 source was identified as leakmg during a leak test performed on April 24,1996. WSMR had previously provided written notification of another leaking source of the same model, strength, and approximate age by letter dated June 23,1994. In addition, cobalt-60 sources of the same model and strength were previously found to be leaking in 1982 and 1983.
%e investigation included examination of the Gamma Range Facility, the irradiator and source transfer system, and source carriers used in the irradiator, all of which are unique. He inspectors also reviewed information relating to the irradiator design and previous analyses of the use of sealed sources in the system completed by WSMR and its contractor.
Our investigation of this matter has identified significant concerns about the continued use of sealed sources (both cesium-137 and cobalt-60), with source carriers supplied by WSMR, in the Gamma Range Facility. Specifically, the recent visual exammation (performed on July 30,1996, at Neutron Product, Inc.'s facility) of one of the leaking sources identified significant damage to the source capsule, allowing contamination to spread to the external surfaces of the source carrier and beyond to the intemal surfaces of the irradiator. In addition, based on our review of historical operation of the irradiator and WSMR's response to earlier incidents involving leakage of cobalt-60 sources, we are concemed that changes have been made to the source and carrier design without sufficient analysis of their impact on the integrity of the source capsule over a period of use. Further, we have also noted concems relating to operating practices which may require further review in order to determine whether they contributed to the source failures.
Dese concems were discussed with members ofyour staff responsible for operation of the Gamma Range Facility during a telephonic exit briefing oc October 3,1996, and will be described in detail in an inspection rep 4which will be forwarded to ye a in the near future. However, because WSMR has 9
hadpalincidJeninvolving contamination of ti e irradiator due to failure of cobalt-60 sources, I find it necessary to request that WSMR take prompt at tion to address these concems as described below.
Pursuant to a telephone conversation between you and Ms. Linda Howell of this office on 1996, it is our understanding that you will take the following actions:
1.
Complete and submit for NRC review an engineering assessment of the failure of two cobalt-60 sources (Neutron Products, Inc., Serial Nos. 175-90-4 and 175-90-1, nominal t
-. -. - ~.. -. - -..
activity of 4100 curies each) previously used in the irradiator at the Gamma Range Facility.
'Ihe assessment will focus on identifying the root cause of the failures, for both the source carriers and the manufacturer's source capsules, and any contributing factors, including
/
operating practices at the facility. The assessment will include examination of the remaining two cobalt-60 sources of the same model and nominal activity used in the irradiator between 1990 and 1996 to ensure a full evaluation of potential damage to sources used in the irradiator during this penod 2.
Based on the assessment described in Item 1, WSMR will propose and submit for review a /
design change for the sources and carriers used in the irradiator or, altematively, provide justificaten for continued use of the sources and carriers without modification.
WW 'ftY g' y/
l 3.
Based on the findmgs and conclusions developed under Ite 1 and 2, WSMR will complete l
and submit for review a validation study to support use of new source and/or carrier design or complete a new validaten studwto support continued e of the existing sources and carriers.Ilhe validaten I
lude evaluation /of the potential effects of the number o exposure clos hkehrlo exnerienced over the anticipated period of use of all sources in the irr
.ild WSMR decide to permanently discontinue use of the cesium-137~
in this system, your response to this letter should describe your plans for disposing of cesium-137 sources, and the validation study may be limited to the cobalt-60 sources S-proposed for use in the system.
4.
Submit a plan and proposed schedule for accomplishing Items 1 through 3 which will be incorporated in License 30-02405-01 by reference, within 30 days of the date of this letter.
L This submittal shall be in the form of a license amendment request.
5.
Submit, within 30 days of the date of this letter, a description of the interim actions that WSMR plans to implement to ensure that operational controls are sufficient to minimize the risk of further source failures adequate to provide for prompt identification of source leakage until Items 1 through 3 are comp e e 6.
Review your procedures relating to opera 6on of the irradiator and air handling systems, based on your findings under Item 1 above and the results of the NRC's investigation, and propose modificatons as necessary to address WSMR and the NRC's investigation findings. Any proposed changes to existing procediares or any new procedures developed in accordance with this letter will be submitted to the NRC for review, with a request for amendment of the license to incorporate the procedures by reference. Altematively, if you determine, based on your evaluaten and review, that changes or additions to existing procedures are not warranted, then you will provide ajustification to the NRC stating why you believe procedure modifications are not necessary.
Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, you are required to:
1.
Notify me immediately if your understanding differs from that set forth above; 2.
Notify me if for any reason you cannot complete the actions within the proposed schedule and l
advise me in writing of your modified schedule in advance of the change; and
_ _ _ _ ~ _. _. _ - _ _. _.__
4 l
l 3.
Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.
l l
Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above comnutments or requiring other actions on the part of the licensee; nor does it preclude the NRC L
from taking enforcement action for violatons of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action L6;ter may result in enforcement action ne responses directed by this letter are not subject to the clearance procedures of the Office of l
Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
i i
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure ((s), and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
i Sincerely, L. J. Callan Regional Administrator Docket:. 030-09345 i
License 30-02405-01 cc:
NRC Public Document Room New Mexico Radiation Control Program Director 1
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J. L Lieberman, D/OE (2)(7 H5)
. L J. Chandler, Asst. GC/OGC (15 BIS)
L, -
H. L. 'Ihompson, DEDS (17 G21)
L
- C. Paperiello, D/NMSS (T8F5)
L. W. Camper,IMAB/NMSS (T8F5) l RIV Coordmator, OEDO (17 Gtl)
L. J. Callan, RA i
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T.' P. Gwynn, ADRA
- W. L Brown, RC f l
i R. A. Scarano, D/DNMS G.C.Pangbum, ADD /DNM5 C. L Cain,TA/DNMS -
L L.'Howell, Branch Chief D. B; Ral*% Branch Chief F. A. Wenslawski, Branch Chief l~
G. F. Sanbom, EO B. Henderson, PAO J. Carson, ORA.
RIV Files i'
NMI&FC/DB File J RIV Materials File-5th Floor l-NMIAFC/DB and NMLB Inspectors (10)
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L DOCUMENTNAME: G:\\NMIS.O\\WSMRCAL.LLHAI96-288 l
Te seema espy er enenent, kumesse in ba: c = Copy wahout ancio.w E' = Copy we encksw
- N" = No copy RIV:C:NMI&FC/DB ADD:DNMS D:DNMS D:IMNS EO-L LUiowell-GCPangburn RAScarano DACool GFSanborn
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' OFFICIAL RECORD COPY o
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White Sands Missile Range License issues & Concerns Should we allow WSMR to continue operation?
i CONS:
4 Leaking Sources, all medium size, typically 1400 Cl (2 each, port #5 and port e
- 8)-1982,1983,1994, & 1996 Other medium sources in ports #6 and 7 are also frequently used WSMR personnel have not been able to provide information demonstrating that
=e
^
the system used to transfer sources in ports #5 and 8 are unique thereby providing some assurance that the other medium sources would not likely fall in i
the same manner
- personal observation is that the transport tubes and system are basically the same and therefore would expect the sources to be under similar stresses.
No definitive analysis performed that indicates root cause of any of the failures e
- Only report provided to NRC by WSMR was from a contractor their hired J
to perform an engineering analysis. The report stated that, "The only probable failure mode was deduced to be fatigue failure in the medium size source carrier body after approximately 520,000 frontal impacts with the exposure head."
- The report was not validated - the sources had only been subjected to less than 10,000 cycles.
- The report did not accurately reflect the conditio'ns the sources were exposed to (e.g., assumed a solid slug versus the carrier design with internal Belleville springs, only considered the forward impact of travel).
WSMR could not provide justification or documentation for why they chose to insert Belleville springs within the source carrier and why they heat-treated the source carrier, i
Contamination outside the transport tubes occurred as a result of missing screws e
in the head position indicator.
- no torque requirements for screws i
- no analysis / testing to establish what pressures the seals / negative pressure shroud can withstand
- observed several (at least three) screws missing in negative air pressure shroud -
7-l' 1
(
- no limitation on transfer pressures, they have changed them over time.
l Their current system allows for a maximum of 1500 psi (external) to be applied to a stuck source.
infrequent / inadequate maintenance / monitoring e
-inadequate / improper survey techniques used to survey exposure head when shots are completed
- negative air pressure / exhaust fan filter / absolute filter had contamination i
(3mR/hr). Only replaced once in the last 20 years (as a result of the most recent leaking source)
- wear on springs / system - checked about once per year
- log indicated failure of components more frequently than annually (e.g., head and storage position switches) l.
- interlocks / switches frequently bypassed to allow further operation before L
. complete analysis was performed on failure mechanism. Several stuck sources L
were a result of broken components Analysis of recent source failures is not expected to be completed in the near e
future. May be longer that a year to complete and implement corrective actions.
WSMR had an individual assigned to this task, but this individual has been reassigned to another higher priority task.
Review of Log Books indicated:
- numerous instances where sources were stuck (both large and medium 1
sources). High pressure was required to move the sources in most cases (up to 500 psi). A major concern related to this is that WSMR, when using the high pressure to unstick the source, overrode the negative pressure interlock in some instances. This could lead to a greater spread of contamination if the source-I carrier was leaking radioactive material.
-numerous instances where several interlocks were by-passed. The negative pressure interlock was frequently by-passed.
Poor contamination control procedures -A sticky pad was still on the floor from i
e when they were deconning the sy.ctem.
e Lack of management involvement
-the RSO was not fully aware of actions and instruments used at the facility
-management often gave answers that conflicted with those given by the operators
-sources often stayed stuck for extended periods of time without a determination as to why it became stuck
-More attention needs to given to information recorded in the log books t
They have no idea what the negative pressure is in the negative pressure shroud or what effect the use of high pressure would have on the system.
l.
l l
. ]
~. - -. - -..-_. - -
f PROS:
Benefits of use may outweigh small chance of major health and safety risks -
e protection of military / civilian personnel-> National Security Five layers of protection - double encapsulated source, carrier, sealed transfer l
. tube and negative pressure shroud
- have never breached all five layers of protection Sources use cobalt 60 in the form.of a solid slug -low solubility
- e Procedures state that they survey t'he exposure head after each job /use. They e
have been recently modified to include the use of more sensitive instruments and better surveys techniques.
They monitor intake / exhaust line filters weekly for contamination More than adequate security / access controls e
New sources installed this year - few cycles e
NOTE: It does not appear that NRC is clean on this issue. WSMR had previous leaking and stuck sources and,it appears that we allowed them to continue to operate without adequate protective measures and analysis of the failures.
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4 RECOMMENDATION - OPTIONS
- 1) Reverse CAL This was suggested by RIV - Linda Howell. Wants the licensee to commit and
, provide us assurances that necessary and corrective actions will be taken, etc.
In light of generic implications with these sources and the fact that they have not adequately addressed the cause of the failures in the past and have not taken necessary corrective actions, this approach does not seem practical. We need to turn up the heat and get to the root cause of the problem ASAP,
- 2) CAL This is probably the most feasible solution at this point due the benefits provided by the operation versus the low health & safety risk. It turns up the heat and allows this issue to be tracked more closely and not get lost. The CAL must be carefully written so that our concems are addressed, that necessary corrective actions will be taken (including commitments to procedural changes - i.e.,
. surveys, monitoring,' that proper tests will be conducted (limits on air pressure, etc.) and maintenance) and that a proper analysis of the cause of failures will be conducted by WSMR.
We may want to consider limiting the use of the medium size sources. However, WSMR currently has customers needing to use these sources.
- 3) ORDER MODIFYING LICENSE This option shuts down their operation until the problem is corrected.
This option is not practical based on the perceived low health & safety risk versus the benefits. In addition, NRC in the past has allowed them to operate after the previous sources have failed.
- 4) OTHER p
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White Sands Missile Range License issues & Concerns Should we allow WSMR to continue operation?
l l
CONS:
4 Leaking Sources, all medium size, typically 1400 Ci (2 each, port #5 and port e
- 8)-1982,1983,1994, & 1996 Other medium sources in ports #6 and 7 are also frequently used e
t WSMR personnel have not been able to provide information demonstrating that e
l l
the system used to transfer sources in ports #5 and 8 are unique thereby providing some assurance that the other medium sources would not likely fail in l
the same manner
- personal observation is that the transport tubes and system are basically the same and therefore would expect the sources to be under similar i
stresses.
No definitive analysis performed that indicates root cause of any of the failures L
e-l
- Only report provided to NRC by WSMR was from a contractor their hired to perform an engineering analysis. The report stated that, "The only probable failure mode was deduced to be fatigue failure in the i
medium size source carrier body after approximately 520,000 frontal impacts with the exposure head."
- The report was not validated - the sources had only been subjected to less than 10,000 cycles.
- The report did not accurately reflect the conditions the sources were exposed to (e.g., assumed a solid slug versus the carrier design with internal Belleville springs, only considered the forward impact of travel).
WSMR could not provide justification or documentation for why they chose to insert Bellevillo springs within the source carrier and why they heat-treated the source carrier.
Contamination outside the transport tubes occurred as a result of missing screws in the head position indicator.
- no torque requirements for screws
- no analysis / testing to establish what pressures the seals / negative l
pressure shroud can withstand
- observed several (at least three) screws missing in negative air pressure
shroud
- no limitation on transfer pressures, they have changed them over time.
Their current system allows for a maximum of 1500 psi (external) to be applied to a stuck source.
I Infrequent / inadequate maintenance / monitoring e
-inadequate / improper survey techniques used to survey exposure head when shots are completed
- negative air pressure / exhaust fan filter / absolute filter had contamination (3mR/hr). Only replaced once in the last 20 years (as a result of the most recent leaking source)
- wear on springs / system - checked about once per year
-log indicated failure of components more frequently than annually (e.g., head and storage position switches) 1
-interlocks / switches frequently bypassed to allow further operation before complete analysis was performed on failure mechanism. Several stuck sources were a result of broken components Analysis of recent source failures is not expected to be completed in the near e
future. May be longer that a year to complete and implement corrective actions.
WSMR had an individual assigned to this task, but this individual has been reassigned to another higher priority task.
Review of Log Books indicated:
- numerous instances where sources were stuck (both large and medium sources). High pressure was required to move the sources in most cases (up to l
500 psi). A major concern related to this is that WSMR, when using the high pressure to unstick the source, overrode the negative pressure interlock in some instances. This could lead to a greater spread of contamination if the source carrier was leaking radioactive material.
-numerous instances where several interlocks were by-passed. The negative pressure interlock was frequently by-passed.
Poor contamination control procedures -A sticky pad was still on the floor from l
when they were deconning the system.
l l
e Lack of management involvement 1
-the RSO was not fully aware of actions and instruments used at the facility
-management often gave answers itat conflicted with those given by the operators
-sources often stayed stuck for extended periods of time without a determination as to why it became stuck
-More attention needs to given to information recorded in the log books They have no idea what the negative pressure is in the negative pressure shroud or what effect the use of high pressure would have on the system.
l
..... -. _ - -... -. -..... - -. ~. - -. -
PROS:
Benefits of use may outweigh small chance of major health and safety risks -
~ e protection of military / civilian personnel -> National Security
' e '-
Five layers of protection - double encapsulated source, carrier, sealed transfer tube and negative pressure shroud
- have never breached all five layers of protection e.
Sources use cobalt 60 in the form of a solid slug -low solubility Procedures state that they survey the exposure head after each job /use. They e
' have been recently modified to include the use of more sensitive instruments
.and better surveys techniques.
They monitor intake / exhaust line filters weekly for contamination o
More than adequate security / access controls
'e e
New sources installed this year - few cycles NOTE: It does not appear that NRC is clean on this issue. WSMR had previous leaking and stuck sources and it appears that we allowed them to continue to operate without adequate protective measures and analysis of the failures.
L r'
i b.
1 F
T
-r, 4
4 w
isr
i l
RECOMMENDATION - OPTIONS
- 1) Reverse CAL This was suggested by RIV - Linda Howell. Wants the licensee to commit and provide us assurances that necessary and corrective actions will be taken, etc.
In light of generic implications with these sources and the fact that they have not adequately addressed the cause of the failures in the past and have not taken necessary corrective actions, this approach does not seem practical. We need to tum up the heat and get to the root cause of the problem ASAP.
j
- 2) CAL This is probably the most feasible solution at this point due the benefits provided by the operation versus the low health & safety risk. It turns up the heat and allows this issue to be tracked more closely and not get lost. The CAL must be carefully written so that our concerns are addressed, that necessary corrective i
actions will be taken (including commitments to procedural changes - i.e.,
surveys, monitoring, that proper tests will be conducted (limits on air pressure, etc.) and maintenance) and that a proper analysis of the cause of failures will be conducted by WSMR.
We may want to consider limiting the use of the medium size sources. However, WSMR currently has customers needir.g to use these sources.
- 3) ORDER MODIFYING LICENSE i
This option shuts down their operation until the problem is corrected.
This option is not practical based on the perceived low health & safety risk j
versus the benefits. In addition, NRC in the past has allowed them to operate after the previous sources have failed.
- 4) OTHER 1
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i
Other issues and concerns Given that this is not a normal irradiator facility for which the Regulatory Guide was developed, we suggest you consider the following items during the next licensing action.
Specifications for acceptable air pressures and purity specifications that can be applied to the system which would not cause any damage to the system (components include, seals, sources, shroud, etc.)
Maintenance / inspection intervals for Belleville springs, seals, and position e
switches.
Numerous listings in log books indicating stuck sources, bad switches, etc.
The licensee should implement a plan to ensure that these intervals are followed.
The licensee should specify the air flow rate and method for determining this rate. The air flow rate should be sufficient enough to ensure adequate negative air flow during normal operating conditions and during stuck source conditions.
The rate should be set at a level to ensure that in the event that another source were to leak, the contamination would remain within the negative air pressure shroud.
There should be torque requirements for bolts and screws for all components requiring an airtight seal (switches, negative air pressure shroud, etc.)
Survey frequency for absolute filter (roof). Their procedures say to check it annually, During questioning, it does not appear that they checked it annually, only replaced once in over 20 years. The licensee needs to implement a plan to ensure that this filter is periodically checked at a reasonable interval based on their operation.
Clarification on access control as defined in Part 36 (will mention these in the TAR response).
Roll-up Door -
Outer fence appears to be the primary barrier, the inner fence appears to be the secondary barrier Side Door -
Inner fences appear to be the primary barrier, door interlock second independent barrier
" Sticky" mat - why is it there?
o
Procedures that require management review of the events (failures of e
components, stuck sources, bypassed interlocks, etc.), procedural changes, and equipment malfunctions. Many instances in the log where interlocks were bypassed, for several days, before components were fixed. Many instances of stuck sources, whereby the same source was sticking over several days, it appears, they did not inspect / determine the root cause of the sticking, instead, kept on applying pressure until they became dislodged.
Adequate procedures on surveying the exposure head for contamination, it appears that their new procedures were adequate, but were not sure if they committed to using them.
The region should consider continued use of the cesium sources based on their o
current design of their facility, chemical form (cesium chloride), and age of the sources.
The region should ensure that the licensee's emergency procedures adequate address leaking sources and contamination.
The region should consider whether or not to continue to allow the licensee's practice of overriding the negative air pressure system.
I l
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C:\\wpdocume\\wsmr. sib Memorandum to; Linda Howell l
From'S Baggett T Rich m'
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Subject White Sands Missile Range (WSMR) ' sgQegr.ad d_,.dca of two leaking Cobalt-60 i
p Sources. License Number 30-02405-10 e"
ef tiu un" w.,p wu The follo ' g is a summary of the inspection and selmetion of the leaking sources. The reot-cause th.i.: is a design problem in the carrier aemom for.-TW ' rp-t the-R 7;. JV eita 4 + -* "'?" '-" -*h. @ J,wg 9
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On July 30,1996, the following individuals net to discuss and 541mm8Fparticipate in the avahiatinn of the leaking sources at Neutron Products Inc. (NPI) facility in Dickerson Maryland.
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Members of NPI hot cell support staff.
Marvin Turkanis, NPI-VP Jeff Williams, NPI-RSO Richard Williams, WSMR Roland Penny, WSMR Douglas Mcdonald, WSMR Allen Jacobenson, State ofMD Thomas Rich, NRC Steven Baggett, NRC V
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NPI provided a discussion about fabricatingtsources using thc [obait40 f
and how ""'
'eisources are installed into WSMR su plied carriers,and4 hey ug eM f
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,A-I 'c.dded shut. Dummy samples of the various products were'available for inspection,aed diminuion of the vrious-dcsiga changcs th;^ "'SMD has made ci cc the lo7n's. NP4-also t~i 4-+ :- tqthey changed source fabrication from a single i f d k
welding a piece of flat stock ont8irod stock and thenfnal machiridg to @p A
\\n. windo;c (about 20 thou=ds of an La ilak fui icletherapy-sources)..This was re erredTo as the r
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SMR descultedlheirradiator facility, its uses and general description of the ation of thd f
t)M facility /Ariim~;portant issue is that neither NPI nor WSMK c5 Bid c1EarTy-wii2they j
'sfEted using Belleville springs in the carrier. Also in the early 80's, WSMR requested that NPI l
weld the threaded plug in place to further reduce the likely hood ofleakage. Other facts of l
interest were presented by WSMR as follows: some corrosion problems have been identified in l
the exposure head of the device due to humidity in the compressed air system; it is not clear as to what the actual pressure applied to the carriers do to the location of the pressure valves; based on.
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% the last 2 years operational data only one stuck source has occured and it was moved using about 300 psi instead of 10-20 psi; the radiography system is designed to use 1500 psi nitrogen for stubborn stuck sources; heat treating of th,e carriers was done in the mid 80's but not sure why; WSMR staff are complying historical use data to be used in its investigation of the event,.bccesse
_-r their-C LJ o, o ;A _., :: !, WSMR appears to exercise flexibility in what the users of the irradiators can do without a conscious decision as to the cause and efTect of the change on the entire system.
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u " weld failure at the end cap and'/e progr:m dS!undon was to proceed. How Attached is an outline of how t1
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difficulty getting the second source out of the carrier,the pregram p
was-momGed. Also attached is a front view of the exposure head denoting the source port arrangement as provided by WSMR.
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NPI performed swipe test on the carriers.whieh-identified contamination. A helium bubble test conducted on both carriers, had negative results, that is to say no bubbles were observed. The capsule (SN 17591) from port number 5 was machined off at the carrier threaded end plug and k
the sourceTrfmoved. The outer encapsulation of the scurce was deformed (coavex,tc fh void m b#
cpm hon.cr end) and showed signs of weld failure at the end cap. The4 uter capsi was-M er ved andprrt of tne inner capsule was stuck into the outercapsule. The inner capsule weld fa' ed at what appeared to be the end ca =d P "<. e cais=r:pMc M"re. Examination of the b leville springs,showed apparent defo ation of the springs. h o
/
- * & Q&
I staff machinedNe threaded end plug of the carrier for#apsule (SN 17594{or from port hg number 8 carner)but were rfcF5fe to get the source out of the carrie halted because any further machining would likely damage the source and any information that ap#, mightte stained Lum visuai mmination.
g uw, m.a NPI placed all components into seal welded canisters for later retrieval should WSMR deem h%,
6.o, metallurgical analysis will provide further insight into the failure of the capsule $ NPI also took several photographs using a periscope. We will forward you copies when they are available.
M Based on our ana sis of the above data and the design of the carrier, the source failed because of treTrilTer desi of the carrierWiiIs 3@id not appear to use good engineering practice to eliminate stres where possible but rather concentrated them. As a result, we asked WSMR personnel to include a redesign of the carrier and design validation program in its response to Region IV. Such a program,must consider all factors the sources are exposed to during use, transport, storage, etc. The design change should consider but not be limited to the following issuespElimination of the belleville springs,iedesign of the internal of the carrier,"possible source capsule redesign for this application, yr heat treatifFg of source capsule Wins. We strongly suggested that WSMR do prototype testmg of a dummy source to prove the efTectiveness of any design change.
We had suggested that WSMR provide a realistic schedule for design change and validation. This scheduled should address the issue of replacWof the source', because it is very likely the sources currently in the system will be damaged and, leak. We reconginze that it is difficult to' determine m
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- when it will leak, but the it should be replaced before the 5 year period and as soon as a design change validation is completed and(ne vendor can provide new sources.
~ %
We would suggest that WSMR and NRC personnel, visit the site and review the equipment and possible affects to be considered in the validation program. Tom Rich is available to participate in such a meeting on site.
If we can provide further assistance please contact us.
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3 White Sands Missile Range Licenso issues & Concerns Should we allow WSMR to continue operation?
CONS:
4 Leaking Sources, all medium size, typically 1400 Ci (2 each, port #5 and port e
- 8)-1982,1983,1994, & 1996 Other medium sources in ports #6 and 7 are also frequently used e
WSMR personnel have not been able to provide informathn demonstrating that e
the system used to transfer sources in ports #5 and 8 are unique thereby providing some assurance that the other medium sources would not likely fail in the same manner l
- personal observation is that the transport tubes and system are basically the same and therefore would expect the sources to be under similar stresses.
l No definitive analysis performed that indicates root cause of any of the failures
- Only report provided to NRC by WSMR was from a contractor their hired to perform an engineering analysis. The report stated that, "The only probable failure mode was deduced to be fatigue failure in the medium size source carrier body after approximately 520,000 frontal impacts with the exposure head."
l
- The report was not validated - the sources had only been subjected to I
less than 10,000 cycles.
l
- The report did not accurately reflect the conditio'ns the sources were exposed to (e.g., assumed a solid slug versus the carrier design with internal Belleville springs, only considered the forward impact of travel).
l WSMR could not provide justification or documentation for why they chose to insert Belleville springs within the source carrier and why they heat-treated the source carrier.
Contamination outside the transport tubes occurred as a result of missing screws o
in the head position indicator.
- no torque requirements for screws
]
- no analysis / testing to establish what pressures the seals / negative pressure shroud can withstand
- observed several (at least three) screws missing in negative air pressure shroud
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- no limitation on transfer pressures, they have changed them over time.
Their current system allows for a maximum of 1500 psi (external) to be appiied to a stuck source.
e infrequent / inadequate maintenance / monitoring
-inadequate / improper survey techniques used to survey exposure head when shots are completed
- negative air pressure / exhaust fan filter / absolute filter had contamination (3mR/hr)l Only replaced once in the last 20 years (as a result of the most recent leaking source)
- wear on springs / system - checked about once per year
- log indicated failure of components more frequently than annually (e.g., head and storage position switches)
- interlocks / switches frequently bypassed to allow further operation before complete analysis was pedormed on failure mechanism. Several stuck sources were a result of broken components Analysis of recent source failures is not expected to be completed in the near e
future. May be longer that a year to complete and implement corrective actions.
WSMR had an individual assigned to this task, but this individual has been reassigned to another higher priority task.
Review of Log Books indicated:
- numerous instances where sources were stuck (both large and medium sources). High pressure was required to move the sources in most cases (up to 500 psi). A major concern related to this is that WSMR, when using the high pressure to unstick the source, overrode the negative pressure interlock in some instances. This could lead to a greater spread of contamination if the source carrier was leaking radioactive material.
-numerous instances where several interlocks were by-passed. The negatt a pressure interlock was frequently by-passed.
Poor contamination control procedures -A sticky pad was still on the floor from when they were deconning the system.
e Lack of management involvement
-the RSO was not fully aware of actions and instruments used at the facility
-management often gave answers that conflicted with those given by the operators
-sources often stayed stuck for extended periods of tirne without a determination as to why it became stuck
-More attention needs to given to information recorded in the log books They have no idea what the negative pressure is in the negative pressure shroud or e
what effect the use of high pressure would have on the system.
~
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PROS:
e Benefits of use may outweigh small chance of major health and safety risks -
protection of military / civilian personnel -> National Security Five layers of protection - double encapsulated source, carrier, sealed transfer e
tube and negative pressure shroud
- have never breached all five layers of protection e.
Sources use cobalt 60 in the form of a solid slug -low solubility Procedures state that they survey the exposure head after each jobluse. They have been recently modified to include the use of more sensitive instruments and better surveys techniques.
They monitor intake / exhaust line filters weekly for contamination e
More than adequate security / access controis e
New sources installed this year - few cycles e
NOTE: it does not appear that NRC is clean on this issue. WSMR had previous leaking and stuck sources and it appears that we allowed them to continue to operate without adequate protective measures and analysis of the failures.
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i COBALT CARRIER ASSEMBLY 1.-
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' Source Carrier. Plug
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1.
Belleville-spring part numbers are Bearing Engineers, Inc.,
and are listed for size information only.
2.
Model 176 source carrier.is designed for a 1.264" long by 0.617" outside diameter cobalt source. Other source sizes will require other spacer sizes.
3.
'Belleville springs are shown uncompressed to show orientation which is critical for the front spring.
4.
Approximately 15 feet-1b of torque on the carrier plug is
. required to compress the belleville springs.
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'A-04 L
l RECOMMENDATION - OPTIONS
- 1) Reverse CAL This was suggested by RIV - Linda Howell. Wants the licenses to commit and provide us assurances that necessary and corrective actions will be taken, etc.
In light of generic implications with these sources and the fact that they have not j
adequately addressed the cause of the failures in the past and have not taken necessary corrective actions, this approach does not seem practical. We need to turn up the heat and get to the root cause of the problem ASAP.
a
- 2) CAL Thia is probably the most feasible solution at this point due the benefits provided 1
by the operation versus the low health & safety risk. It turns up the heat and l
allows this issue to be tracked more closely and not get lost. The CAL must be
]
carefully written so that our concerns are addressed, that necessary corrective actions will be taken (including commitments to procedural changes - i.e.,
I surveys, monitoring, that proper tests will be conducted (limits on air pressure, etc.) and maintenance) and that a proper analysis of the cause of failures will be conducted by WSMR.
We may want to consider limiting the use of the medium size sources. However, WSMR currently has customers needing to use these sources.
- 3) ORDER MODIFYING LICENSE I
This option shuts down their operation until the problem is corrected.
This option is not practical based on the perceived low health & safety risk versus the benefits. In addition, NRC in the past has allowed them to operate after the previous sources have failed.
- 4) OTHER
kI INST RUMEN1.
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- 1 UNITED STATES E
E NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. N1
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August 9, 1996 MEMORANDUM TO:
Linda L. Howell, Chief Nuclear Material Inspection and Fuel Cycle / Decommissioning Branch Division of Nuclear Material Safety Region IV FROM:
Steven L. Baggett, Section Chief a
Sealed Source Safety Section Medical, Academic, & Commercial
'f4,, /
Use Safety Branch Division of Industrial and v
Medical Nuclear Safety, NMSS Thomas W. Rich, Acting Section Chief
,m Commercial Section Medical, Academic, & Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
WHITE SANDS MISSILE RANGE (WSMR) INVESTIGATION OF TWO LEAKING COBALT-60 SOURCES. LICENSE NUMBER 30-02405-10 The following is a summary of the investigation of the leaking sources. The apparent cause of the failures was a design problem in the carrier-source configuration.
On July 30,1996, the following individuals met to discuss and participate in the investigation of the leaking sources at Neutron Products Inc. (NPI) facility in Dickerson, MD:
Marvin Turkanis, NPI - VP Jeff Williams, NPI-RSO Richard Williams, WSMR Roland Penny, WSMR Douglas Mcdonald, WSMR Allen Jacobenson, State of MD Thomas Rich, NRC Steven Baggett, NRC 4 G-fofscim,
. _ ~
J Linda L Howell 2
WSMR personnel briefly described the irradiator facility, its uses, and general description of the operation of the facility.
NPI personnel provided a discussion about their fabrication method for the sources and how the sources are installed into WSMR supplied carriers. Dummy samples of the various products were made available for inspection. In addition, WSMR and NPI personnel discussed the various design changes,'and reasons for the changes, that were made to the design since the 1977s. One of the major design changes, as indicated by NPI, was that they changed source fabrication from a single piece of rod stock to welding a piece of flat stock onto the rod stock and then matched the outer capsule to specifications. (Similar construction used for their teletherapy sources).
A possible issue is that neither NPI nor WSMR could clearly document why they started using belleville springs in the carrier. Also, in the early 80's, WSMR requested that NPI weld the threaded plug in place to further reduce the likelihood of leakage. Other facts of interest were presented by WSMR as follows: some corrosion problems have been identified in the exposure head of the device due to humidity in the compressed air system; it is not clear as j
to what the actual pressure applied to the carriers does to the location of the pressure valves; based on the last 2 years operational data, only one stuck source has occurred and it was moved using about 300 psiinstead of the normal 10-20 psi; the radiography source movement system is designed to use 1500 psi nitrogen for stubborn stuck sources; heat treating of the carriers was done in the mid 80's, but the reason is not known and; WSMR staff are compiling historical use data to be used in its investigation of the event. WSMR appears to exercise flexibility in what the users of the irradiators can do without a conscious decision as to the cause and effect of the change on the entire system.
Attached is an outline of how the investigation was to proceed; however, the outline was modified due to a weld failure at the end cap and difficulty was experienced gettino the second source out of its carrier. Also attached is a front view of the exposure head denoting the source port arrangement as provided by WSMR.
NPI performed swipe tests on the carriers. The test results identified levels of contamination above 005 microcurie. A helium bubble test conducted on both carriers had negative results; that is to say no bubbles were observed. The first capsule (SN 17591, from port nuinber 5) was machined off at the carrier threaded end plug and the source was removed.
The outer encapsulation of the source was deformed (the end cap was convex and showed signs of weld failure). An attempt was made to separate the outer and inner capsules, however, the end cap broke off (window end). The inner capsule we'd failed at what appeared to be the end cap of the inner capsule. Examination of the belleville springs inside the capsues showed apparent deformation.
NPI staff machined off the threaded end plug of the carrier for the second capsule (SN 17594, from port number 8) but were not unable to get the source out of the carrier.
Further attempts were halted because any further machining would have likely damaged the j
source and any usefulinformation that might have been obtained.
Linda L. Howell 3
NPI placed all components into seal welded canisters for later retrieval should WSMR deem necessary (i.e., metallurgical analysis may provide further insight into the failure of the capsules). NPl also took several photographs using a periscope. Copies will be forwarded
)
to you when they are available.
J l
Based on our analysis of the above data and the design of the carrier, the source failed l
because of design of the carrier source / configuration. This design did not appear to use l
good engineering principles to eliminate stress concentrations where possible, but rather concentrated them. As a result, we asked WSMR personnel to include a redesign of the carrier and design validation program in its response to Region IV verbal request for an l
investigation plan. Such 'a program must consider all factors the sources are exposed to j
during use, transport, storage, etc. The design change should consider, but not be limited to, the following issues: 1) elimination of the belleville springs,2) redesign of the carrier,
- 3) possible source capsule redesign for this application and (4) a heat treatment (anneal) of i
i the source capsule. We strongly suggested that WSMR do prototype testing of a dummy source to demonstrate the effectiveness of any design change.
We also suggested that WSMR provide a realistic schedule for design change and validation.
This schedule should address the issue of replacing the sources, because it is very likely the sources currently in the system will be damaged and leak. We recognize that it is difficult to determine when it will leak, however, the sources should be replaced before the normal 5-year period, and as soon as a design change validation is completed and when the vendor can provide new sources.
(
We would suggest that WSMR and NRC personnel visit the site and review the equipment and possible affects to be considered in the validation program. Tom Rich is available to participate in such a meeting.
A copy of this memorandum was sent to the State of Maryland. If we can provide further assistance please contact me at (301) 415-7273 or Tom Rich at (301) 415-7893.
I i
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Distribution:
SSSS Staff SSSS r/f NE02-SSD-6 DOCUMENT NAME: H:\\TRACl\\WSMR.SLB *see previou.s concurrence Ta r:cese a copy of this document, indecate in the boa:
"C* = Copy without attachment / enclosure
- E' = Copy with attachment / enclosure
'N' = No copy 0FFICE IMAB*
lc IMAB*
lc l
l NAME Trich SBaggett DATE 8/ 9/96 8/9 /96 y
0FFICIA_ RECORD COPY i
l
L Linda L. Howell 3
NPI placed all components into seal welded canisters for later retrieval should WSMR deem necessary (i.e., metallurgical analysis may provide further insight into the failure of the capsules). NPI also took several photographs using a periscope. Copies will be forwarded to you when they are available.
Based on our analysis of the above data and the design of the carrier, the source failed j
because of design of the carrier source configuration. This design did not appear to use good engineering principles to eliminate stress concentrations where possible, but rather concentrated them. As a result, we asked WSMR personnel to include a redesign of the carrier and design validation program in its response to Region IV verbal request for an investigation plan. Such a program must consider all factors the sources are exposed to during use, transport, storage, etc. The design change should consider, but not be limited to, the following issues: 1) Elimination of the Belleville springs,2) redesign of the internal of the carrier, and 3) possible source capsule redesign for this application and a heat treatment of the source capsule. We strongly suggested that WSMR do prototype testing of a dummy source to prove the effectiveness of any design change.
We also suggested that WSMR provide a realistic schedule for design change and validation.
This schedule should address the issue of replacing the sources, because it is very likely the sources currently in the systam will be damaged and leak. We recognize that it is difficult to determine when it willleak, however, the sources should be replaced before the normal 5-year period, and as soon as a design change validation is completed and when the vendor can provide new sources.
We would suggest that WSMR and NRC personnel, visit the site and review the equipment and possible affects to be considered in the validation program. Tom Rich is available to participate in such a meeting.
A copy of this memorandum was sent to the State of Maryland if we can provide further assistance please contact me at (301) 415-7273 or Tom Rich at (301) 415-7893.
Distribution:
SSSS Staff SSSS r/f NE02-SSD-6
! DOCUMENT NAME: H:\\TRACI\\WSMR.SLB Ta rectbs a copy of this document, indicate in the boa: "C" = Copy without attachment / enclosure
'E' = Copy with attachaient/ enclosure "N" = No copy 0FFICE IMAB l
IMAB fj, l
l l
l NAME TRi ch N.a.
SBagcf1Ct DATE 8/9 /96 8/(//96 OFFICIA_ RECORD COPY i
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- uipe test the carriers, outer capsules and int er capsules of both sources;
- He bubble leak test the carriers, outer capsules and inner capsules of both sources;
- photograph selected vieus;
- veld slugs in storage capsules (in the ever-
- h n bcth the inner and outer capsules ns/e f ailed); and,
- veld uaste into wa.ste capsules.
2.
Grind veld nff NR-1 encapsulation 3.
Place MR-1 in the hot cell 4.
Remove the two sources from UR-1 and place on hot cell table EXA!!INATION (July 30 and 31, if necessary) 1.
Training course for WS!!R and NRC, !!D observers for entry into LAA 2.
Examine carriers 3.
Prevleu examination
) jf C ti CARRIERS h,.
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4.
Confirm source identification 5.
Visually examine carriers 6.
Photograph 7
Wipe test carriers 8.
Eubble test carriers 9.
Remove carriers from each source 10.
Photograph (optional)
OUTER CAPSULE I
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V;sually examine.' uter :apsules 12.
Photograph.(optional)
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- 14. Bubble test outer capsules
- 15. Remove outer capsules
- 16. Photograph (optional)
INNER CAPSULE (optional)
- 17. Visually examine inner capsules
- 18. Photograph (optional)'
- 19. Wipe test inner capsules 20.
Bubble test inner capsules
- 21. Remove inner capsules STORE 22.
Weld slugs in storage capsule Weld waste in waste capsule REPORT
- 23. Write report of observation and recommendations, if any, to WSHR.
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s LIMITED ACCESS AREA i.
INSTRUCTION TO VISITORS AND CONTRACTORS l
INTRODUCTION l
L Neutron Products' Limited Access Area (LAA)is the portion of the facility where radioactive material is processed and stored. Entry to the LAA is restricted to prevent unauthorized access to Radiation Areas and to isolate radioactive contamination.
l The major radioactive isotope found in the LAA is cobalt-60. Cobalt-60 is a metallic, manmade isotope that emits beta and gamma radiation. The beta radiation has low penetrating power and is completely absorbed by a thin layer of material, usually the stainless steel cladding which L
encapsulates the cobalt-60. On the other hand, the gamma radiation has very high penetrating power. Reducing the radiation emitted by high activity source to safe levels requires several inches to several feet of shielding material. Materials commonly used for shielding gamma
~ ddiation include lead, steel, concrete, and water.
L r
i The major facilities housed within the LAA include:
l
)
The Main Storage Pool and Transfer Canals - A 22,000 gallon, stainless steel lined pool,24 ft at its deepest level where cobalt-60 inventory is stored. The pool is filled with high purity water, which shields the gamma radiation and cools the sourc'.ss. Valved pass throughs
- connect the pool to transfer canals used to move radioactive material into and out of the hot cell and irradiater storage pools. Items are handled underwater using long manipulator tools.
The pool water circulates through a system that removes radioactive contamination, impurities, and heat.
L The Hot Cell - A steel lined room with thick concrete walls where cobalt-60 is processed, calibrated, and transferred to and from shielded shipping containers. Operators use master-slave manipulator arms to handle radioactive material remotely. A five-foot thick window made'of high density glass allows for observation of the cell. Personnel access is through a thick, heavily shielded door. An interlock system prevents entrance to the cell when l
high dose rates are present.
l l
. Hot Cell Exhaust System - Air from the hot cell exhausts through a series of high efficiency l
filters that remove over 99.99% of any airbome radioactive contamination before venting. The filters, fans, and other components of the system are located on the second floor in a normally locked room. As the filters collect contamination, the dose rate close to this equipment becomes significant.
courtyard - The outside portion of the LAA which is surrounded by a security fence. Cobalt-60 shipping containers enter and leave the LAA through the courtyard gate which, except during shipping and receiving, is closed and locked. The courtyard also provides access to
. hot waste storage.
Hot Waste Storage - Two shielded vaults store radioactive waste. The doors of these vaults i
are normally locked.
. The LAA also includes workshops, laboratories, offices, storerooms, and a shielded room used for storage of contaminated tools and equipment.
r.
l1 i
3 1
Instructions for LAA Visitors Page 2 RADIATION EXPOSURE AND HEALTH EFFECTS l
Biological radiation doses are expressed in rem, a unit that relates to the radiation energy absorbed and to the potential for specific kinds of radiation to inflict biological damage. Typically, doses are measured in millirem (mrem); 1000 mrem equals 1 rem.
High energy radiation can cause chemical changes to occur in living tissue. Chemical bonds can be broken and cells may be damaged or killed. Most biological damage is reversed by our L
biochemical repair mechanisms which have evolved to counteract such effects as those from background radiation.
j Radiation health effects may be acute or chronic. Acute health effects require exposure to doses of 25 rem or more in a short period usually hours or less. The seriousness of acute effects
)
depends on the total dose received and the area of the body irradiated. Acute effects resulting from whole body irradiation are sometimes known as radiation poisoning. These can include nausea, hair loss, immune system damage, fever, weight loss, and an increasing likelihood of death as short-term exposures reach 300 or more rem. Somewhat larger doses confined to a potion of the body such as a hand would result in a nonlethal radiation damage to tissues. Acute effects require rapid exposure to high doses that exceed the body's natural ability to repair damage. Similar exposures occurring gradually over prolonged periods would not result in acute effects.
L Chronic effects result from repeated exposure to smaller doses over long periods of time. The most important and only well established chronic effect from low level radiation exposure for humans is cancer.
l The health risks from high acute doses are well known; however, any risk associated with low levels of exposure cannot be directly measured. The risk of developing cancer from low dose exposure is very small compared to the prevalence of cancer in the general population. Any effect caused by low-level radiation is too small to be directly determined from health statistics.
l Govemment agencies, such as the Nuclear Regulatory Commission, apply what is known as the Linear-No Threshold Hypothesis to predict the risk from low level exposure and set regulatory l
limits. The Linear-No Threshold Hypothesis is a model which assumes that health effects are proportional to dose and that no minimum dose, or threshold, is required for effects to occur.
Using this model, known effects at high doses are extrapolated to zero dose to predict the unmeasurable effects of lower doses. The hypothesis has not been proven; in fact, many scientific data contradict it. However, it does provide a highly conservative estimate of risk, preferred by the International Commission on Radiation Protection as a prudent basis for controlling exposure to radiation. The risk estimates cited here are published by the NRC and I
are based on the Linear-No Threshold Hypothesis.
The hypothesis predicts that 1 rem of exposure will result in 4 fatal cancers among 10,000 adults.
2,000 out of every 10,000 people normally die of cancer, so a 1 rem exposure is assumed to increases the risk of cancer fatality by 0.2%. Since the hypothesis is linear, the risk is directly l
proportional to the dose; for example, an exposure of 0.1 rem (100 mrem) would result in a
+-
0 4
Instructions for LAA Visitors Page 3 increased risk of fatal cancer of 4 out of 100,000. Remember, this risk estimate is based on data from high doses at high dose rates. There is still uncertainty associated with this estimate.
However, the NRC believes it is the best available for workers to use to make informed decisions conceming acceptance of the risks associated with exposure to radiation.
It is helpful to place the risk of exposure to radiation in context with other risks routinely encountered other common activities. The risk of developing fatal cancer from a 100 mrem exposure is roughly equal to that of smoking a pack of cigarettes. Risks from low-level radiation exposure are smaller than those associated with motor vehicle accidents, industrial accidents, alcohol consumption, and being nioderately overweight. Radiation work, on average, is safer than other occupations.
It is also useful to compare occupational exposure to background exposure. The average individual in the United States is exposed to a dose of about 360 mrem a year. Most of the background exposure is from radon, other naturally occurnng radioisotopes and cosmic radiation.
Some exposure results from medical uses, like x-rays, and from consumer products.
REGULATORY DCSE LIMITS Exposure to radiation may be extemal or intemal. Intemal exposure arises from ingestion or inhalation of radioactive material. For regulatory purposes intemal exposure is reported as the Committed Effective Dose Equivalent (CEDE). The CEDE is calculated by converting the annual intake of activity to the dose that would result over the next 50 years. Calculation of the CEDE takes into account the nuclear decay rate, the retention of the isotope by the body, and the body organs targeted.
The NRC has established an annual limit for workers at 5 rem total effective dose equivalent (TEDE). The TEDE combines the whole body extemal exposure and the CEDE. The NRC limits the dose to extremities and skin to 50 rem per year and the lens of the eye to 15 rem per year.
In addition, no intemal organ can receive a dose equivalent above 50 rem from intakes during one year.
Pregnant woman and minors under eighteen are limited to an annual occupational TEDE of 500 mrem. Members of the public are limited to an annual dose of 100 mrem. In Maryland, the regulations conceming radiation safety are enforced by the Radiological Health Program of the Maryland Department of the Enviroment.
LAA SPECIFIC FACTORS This section contains information about specific radiation safety aspects of the LAA. General instructions for limiting exposure are provided for guidance only. Conditions within the LAA are subject to changes which are immediately made known to occupants.
... -. - _.. -. _ - - -. -..-. -. -. -........ - - -.. -.. - - - -. ~.
I Instructions for LAA Visitors l
Page 4 Dose Rates l
L The dose rate within the LAA varies from less than 1 mrem /hr to greater than 1 rem per hour.
Any area with a dose rate exceeding 5 mrem per houris considered a Radiation Area. Any area with a dose rate exceeding 100 mrem per hour is a High Radiation Area.
Radiation Areas in the LAA are found in the areas immediately surrounding and above the main pool and canals, the hot cell access room, decon room, the courtyard outside the hot waste storage rooms and on the second level outside the hot cell fan room. High Radiation Areas are found within the hot cell, contaminated tool room, and hot waste storage rooms. Access to High Radiation Areas is restricted and controlled.
s Time spent in Radiation Areas should be limited to that required by the specific task being conducted. Once the task is completed, minimize exposure by moving to an area with lower a dose rate. Visitors are not allowed in High Radiation Areas unless specifically authorized.
The self-reading pocket dosimeter keeps track of your accumulated dose. Reading the dosimeter will provide feedback on how much radiation exposure you have received at any point during the LA-A entry.
Contamination Control The LAA is divided into zones based on the likelihood and degree of removable radioactive contamination.
Contamination Control Zones (CCZ) are areas which are :reated as if they were contaminated at significant levels. Entry to a CCZ requires an extra pair of shoe covers and sometimes other additional protective clothing as appropriate. A CCZ may be established anywhere within the LAA based on sampling data or operations taking place. The CCZ will be cordoned-off or otherwise posted. Standing CCZs include: the roped off area in front of the main pool, the area behind the pool and south canal, the hot cell, hot cell access room, decon room, contaminated tool storage room, and the hot waste storage rooms.- Visitors may not enter contamination control zones unless authorized to do so.
The General LAA is an area where significant removable contamination is not likely to be found. Contamination in the General LAA is, however, possible, and shoe covers are requ..ad. The area is routinely surveyed.
Clean Rooms serve as a buffer between the LAA and the rest of the facility and surrounding property. The contamination levels in the Clean Rooms are expected to be very low. The area is used for changing clothes, showering, surveying, and other activities associated with entry to and exit from the LAA.
l To prevent migration of radioactive contamination from the LAA, protective shoe covers are worn.
j When moving from the General LAA to a CCZ, an additionallayer of shoe covers is worn. When l
~
)
Instructions for LAA Visitors Page 5 exiting a CCZ for the General LAA the outer most layer of shoe covers are removed at the step-off pad and deposited in the receptacle provided. When exiting the LAA to the Clean Room a step-off pad is provided for removing shoes and donning a new pair of shoe covers. Some operations in a CCZ may require gloves or disposable clothing. These are, also, removed before exiting the CCZ.
To reduce the chances of contamination, avoid casual contact with surfaces inside the LAA.
Airbome Contamination Airbome contamination levels in the LAA are usually very low. Full time LAA personnel receive sn insignificant fraction of their annual TEDE from airbome activity. During normal LAA conditions the likelihood of inhaling or ingesting a measurable quantity of cobalt-60 is very small, but remains finite.
Certain infrequent operations, such as hot cell decontamination or waste transfer, create the potential for airborne dispersion of fine radioactive particles. This raises the chances for j
inhalation or ingestion of a particle. Therefore, protective equipment like supplied air hoods or 1
purifying respirators is used to prevent intemal exposure. These activities are limited to trained Neutron employees.
ENTRY AND EXIT PROCEDURES Unless otherwise specifically authorized, a knowledgeable escort is provided for all LAA visitors and contractors. Follow his instructions and those of LAA personnel when directed.
Prior to entry you will be given a self reading pocket dosimeter. This is in addition to the visitors badge you received when entering the plant. Both of these are to be wom at all times while in the LAA. The pocket dosimeter measures accumulated dose, not dose rate.
Complete and sign a LAA Visitors Form and the LAA Entry Log fellowing the directions of your escort.
If you plan to bring any items with you into the LAA, bear in mind that they may become contaminated. All items will be sur/ eyed for contamination before being released from the LAA.
If found to be contaminated, every effort will be made to decontaminate the item. However, if decontamination efforts are ineffective, the item cannot be removed from the LAA. The taking of photographs or video tapes in the LAA is not allowed without prior permission.
To prevent the migration of Iadioactive contamination from the LAA and to minimize the potential for exposure, street clothes are not wom in the LAA. Coveralls will be fumished for your visit.
Change into the clothes provided, and place a pair of shoe covers over your socks. Affix both dosimeters to the coveralls and proceed into LAA. Select a pair of shoes from the rack. These will have shoe covers on them already.
o j
1
)
Instructions for LAA Visitors
~
Page6 To exit the LAA, remove one shoe at a time at the step-off pad and replace on the rack. Remove one shoe cover and place in the receptacle and put on a new shoe cover. Repeat with the other foot.
l Reenter the Clean Rooms and proceed to the frisking station. Under direction of your escort, slowly move the pancake probe over your body paying particular attention to hands, wrists, feet, face, neck, chest, and abdomen. If contamination is found, follow the instruction of health physics personnel.
Remove your protective clothing and go on to the shower room. Shower, scrubbing vigorously with a wash cloth and soap; shampoo your hair. After drying off, put on your underwear and a rftw pair of shoe covers on your feet.
You will be instructed in the operation of the HECM portal monitor. Highly sensitive beta counts will be taken from all four sides. Each count takes about thirty seconds. If contamination is found, health physics personnel will locate the activity and assist in decontamination.
If HECM results are negative, you may retum to your street clothes. Submit all items carried out of the LAA for survey. Sign out on the LAA Entry Log recording pocket dosimeter reading and time out. Retum pocket dosimeter to the rack.
- CONCLUSION This document is intended to provide infomistion required for visitors and contractors to make infqrmed choices regarding the potential risks of LAA entries and to impart essential radiation safpty instructions. It is impossible to treat either topic exhaustively in a brief text. We encourage you to ask questions.
M v,n-y --
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m-
r PROGRAlf POR EVALUATION OF WSMR " LEAKERS" N
PREPARATION (prior to July 30, 1996)
@ U y & W ""
g%
3 01 1.
Setup hot cell to o p3
[5%
- visually examine the capsule through the hot cell window with the periscope;
- wipe test the carriers, outer capsules and inner capsules of both sources
- He bubble leak test the carriers, outer capsules and inner f
capsules of both sources
- photograph selected views:
- weld slugs in storage capsules (in the event that both the inner and outer capsules have failed); and,
- Weld waste into waste capsules.
2.
Grind weld off WR-1 encapsulation 3.
Place WR-1 in the hot cell 4.
Remove the two sources from WR-1 and place on hot cell table EXAMINATION (July 30 and 31, if necessary) f 1.
Training course for WSHR and NRC, MD observers for entry into LAA 2.
Examine carriers
/
3.
Preview examination
) g - 9D -l CARRIERS 4.
Confinn source identification 5.
Visually examine carriers 6.
Photograph 7.
Wipe test carriers 8.
Bubble test carriers 9.
Remove carriers from each source 10.
Photograph (optional)
OUTER CAPSULE
(
l l
l 11.
Visually examine outer capsules 12.
Photograph (optional) i
- 13. Wipe test outer capsules l
- 14. Bubble test outer capsules I
15.-Remove outer capsules l
l:
- 16. Photograph (optional)
INNER CAPSUIE - (optional) -
- 17. Visually examine inner capsules
- 18. Photograph (optional) l:
- 19. Wipe test inner capsules
- 20. - Bubble test inner capsules
- 21. Remove inner capsules STORS 22.
Weld slugs in storage capsule Weld waste in waste capsule REPORT.
23.~ Write report of observation and recommendations, if any, to WSHR.
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