ML20203P531
| ML20203P531 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1985 |
| From: | Glenn J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Caine H BUTKIN PRECISION MANUFACTURING CORP. |
| Shared Package | |
| ML20203P530 | List: |
| References | |
| 104289, NUDOCS 8605070405 | |
| Download: ML20203P531 (5) | |
Text
1 OCT 16 ECS Docket No.
040-28863 Control No. 104289 Butkin Precision Manufacturing Corporation ATTN: Halide J. Caine Administrative Safety Officer 67 Erna Avenue Milford, Connecticut 06460 Gentlemen:
This is in reference to your application dated August 12, 1985 for a source material license.
In order to continue our review, we need the following additional information:
1.
Please specify the quantity of thorium in kilograms which will be possessed at any one time.
2.
Provide a clear and concise description of all chemical, physical, and metallurgical operations which will be performed on the source material (e.g. shaping, grinding, smelting, testing, dissolving, catalytic reactions). Describe each specific process and indicate the quantity of source material which will be used in each process.
3.
Paragraphs 40.13(c) and (d) of 10 CFR Part 40 authorize distribution of certain products containing source material to the general pub,lic. The manufacturer must ensure that the quantity of source material in the product does not exceed the quantity specified for that product in S40.13. The following information should be provided:
a.
The type and quantity of source material in each product; b.
The chemical and physical form of the source material; c.
The solubility of the identified source material; d.
The method for retaining source material in the product during normal and abnormal conditions of use; e.
The maximum external radiation levels at 5 and 25 centimeters from the surface of the product; f.
The estimated total quantity of source material you will distribute annually.
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REG 1 LIC40 0 PDR'
4.
Provide the radiation safety training of the Radiation Safety Officer, i.e. the person responsible for the safe ~ conduct of your source material operations. Also includes the name and training of cll individuals who will supervise the use of source material.
See page 8. of Proposed Revision 2 to Regulatory Guide 10.4 (Enclosed) for an example of acceptable training for responsible individuals.
5.
According to S 19.12 of 10 CFR Part 19, all individuals who work in or frequent restricted areas must be instructed in the health protection problems. associated with exposure to radioactive material.
In addition, person who actually work with radioactive material should receive training in the safe use of radioactive material.
Submit your training program for employees and confirm that this training will be given prior to any work assignment with radioactive materials and annually thereafter.
Include the name, title, and qualifications of the individual responsible for conducting the training.
Page 10 of the enclosed licensing guide provides an example of an acceptable training program.
6.
Submit a drawing of all work areas where. radioactive materials, will be used, processed or stored.
Include receiving and shipping areas as well as radioactive waste handling areas.
The drawings should be drawn to an indicated scale and should show the relationship and distance between identified restricted areas, where radioactive materials are handled, and -
unrestricted areas such as eating areas'and offices.
7.
Submit with your facilities diagram a schematic description of the ventilation system. This description should include air flow rates, filtration equipment and air and effluent monitoring instruments.
8.
According to SS 20.101 and 20.202 of 10 CFR Part 20, persons in restricted areas who are likely to receive doses of radiation in excess of 25% of the limits stated in S20.101 and persons in high radiation areas must use personnel monitoring devices.
If you have such areas within your facility or if you intend to monitor your personnel to ensure that they do not receive exposures in excess of those specified by the NRC, specify the type of device (film badge, thermoluminescent dosimeter (TLD)) you will use and the interval between exchanges. Extremity monitoring should be considered because it often provides a more accurate representation of the dose from source material. _If pocket chambers or pocket dosimeters will be used, you should specify the useful range, the frequency of reading, and the procedures for their maintenance and calibration.
If you do not plan to use personnel monitoring devices, you must submit calculations, documentation from radiation surveys, prior personnel monitoring results, or other information to demonstrate that it is unlikely that any individual will raceive a dose in excess of the limits specified in paragraphs 20.202(a)(1) and (2) of 10 CFR Part 20.
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. 9.
Please describe your area survey program. Your survey program should include storage, material handling and waste disposal areas as well as unrestricted areas such as lavatories and lunch rooms.
The surveys should include radiation exposure readings using an appropriate instrument such as a GM survey meter and a wipe survey to measure removable surface contamination.
Include acceptable contamination limits and the actions to be taken if those limits are exceeded. The frequency of these surveys should be at least monthly.
10.
In order to prevent the spread of contamination from restricted areas to unre:tricted areas and minimize personnel exposure, a personnel contamination monitoring program should be developed.
This would include monitoring the hands, hair, clothing and shoes of individuals before crossing from a restricted area to an unrestricted area.
Please submit your personnel contamination monitoring program.
Include,on your facilities diagram, allowed crossover points between restricted and unrestricted areas where this monitoring will be done.
- 11. S20.103 of 10 CFR Part 20 limits concentrations of radioactive materials in air in restricted areas.
In order to ensure that these limits are not exceeded an air sampling program is required. Describe the area where samples will be taken, the frequency of sampling, and the location of the sampler with respect to restricted and unrestricted areas. Describe the type of assays to be performed to evaluate air samples and the methods used to relate results to actual personnel exposures.
- 12. S20.106 of 10 CFR Part 20 limits radioactivity in eff'fuents to unrestricted areas.
In order to ensure that these limits are not exceeded, an effluent monitoring program for all airborne and liquid radioactive materials released to unrestricted areas is required.
Calculational and theoretical evaluations should be supplemented by stack monitoring, waste-stream monitoring, water sampling, and other environmental monitoring appropriate for the planned and potential releases. Explain the basis for any decision not to take measurements.
- 13. Please describe the radiation detection instruments which will be used for your radiation protection monitoring program. These instruments should include portable survey meters capable of detecting the presence of beta and gamma surface contamination and measuring external radiation levels. Air sampling devices and low-level laboratory counting equipment for the analysis of the air and wipe samples should also be described.
Instruments should be calibrated and operable in order to perform appropriate surveys and monitoring. You need not provide a detailed description of your calibration procedures, but you need to state in the application that the instruments will:
a.
Be calibrated so that the reading are 20% of the actual values over the range of the instrument, OFFICIAL RECORD COPY ML126/LTR - 0003.0.0 10/10/85
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. b.
Have al calibration chart or graph affixed to the survey meter that shows-the results of the calibration, the date of the last-calibration,'and the due date for the next calibration, and c.
Be calibrated at least annually and after servicing.
Also state that caObration records 4til be kept for a minimum of 2 ye'ars after each calibration and identify who_ wilP calibrate the instruments.
If the man'ufacturer will calibrate them, you do not need to specify any additional information.
If a person or firm outside your organization (aside from-the manufacturer) vill calibrate them, identify each person or firm by name and NRC or.Agraement State license number.
For detailed information about survey instrumer:t calibration, refer to ANSI N323-1978, " Radiation Protection Instrumentation Test and.
Calibrati.on, copies of which may be obtained from the American National Standards Institute, 1430. Broadway, New York, NY 10018.
14.
Please describe your radiation safety program an'd include the following information:
a.
Program objectives b.
The responsibilities,and duties with. respect to radiation safety of management, radiation safety per_sonnel, work supervisors, and workers w
c.
' Primary program tasks d.
Methods for auditing andieyaluating the effectiveness of yotm l
radiation safety program e..
The formats (or forms) to be.used by your personnel for recording:
i Results of personnel monitoring Results of radiological instrument calibrations
'Results of radiclogical surveys Quantitiesofradioa(tivityineffluents.
Inventories (fg"ceipts, transfers, 'or disposals) of source
~
materials Accident and incident investigation reports Audits and evaluation of radiation safety program
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. Exhibit 1 Page 19, of the enclosed licensing guide is an example of a Radiation Safety Program submittal.
15.
Please submit a sample emergency procedure that will be provided to personnel who work in or frequent restricted areas and that instructs personnel about actions they are to take in the event of fires, explosions, accidental releases of source material, or other potentially hazardous occurrences involving source material.
- 16. Describe your methods for disposing of radioactive waste.
Include the following:
a.
An assessment of the quantity of types of wastes to be generated.
b.
Your method of recording receipts, transfers, and disposals.
c.
A description of your storage facilities and methods used to secure waste against unauthorized access and to prevent weathering or other damage that could result in release of source materials.
d.
The name and license number of the waste disposal company you will be using.
We will continue our review upon receipt of this information. Please reply in duplicate to my attention at the Region I office and refer to Mail Control No. 104289.
Sincerely, Original Signed By1 John E. Glenn John E. Glenn, Ph.D., Chief Nuclear Materials Safety Section B Division of Radiation Safety and Safeguards
Enclosures:
1.
10 CFR Part(s) 19, 20, and 40 2.
Regulatory Guides (s) 10.4 RI:DRSS RI:DRSS Wurtz/mlb Glenn/
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