ML20205B831

Application for Amend to License SNM-362,requesting Exemption to Various Portions of 10CFR36

ML20205B831
Person / Time
Site:	07000398
Issue date:	03/24/1999
From:	Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9903310377
Download: ML20205B831 (21)

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f, (, i UNITED STATE] DEPARTMENT OF COMMERCE National Insti. ate of Standards and Technology l

\\g Gaithersburg. Maryland 20899-0001 i

i March 24,1999 I

I Division of Fuel Cycle Safety License No SNM-362 and Safeguards Docket No. 070-00398 Office of Nuclear Materials Safety

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and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i

Subject:

Request for Exemption to Portions of Part 36; Request for License Amendment i

Gentlemen:

This letter is a complete submission for our request for exemption to various portions of 10 CFR Part 36 and for our request for amendments to license number SNM-362. It is intended to supersede our submissions of May 20 and Dec. 23,1998 and all other submissions on these topics. It responds to the telephone conversations Tom Hobbs of NIST has had with Anthony Kirkwood and Sean Somg of your office and to correspondence on these issues.

We request amendment to license number SNM 362 to show exemptions for 10 CFR Part 36, Sections 23(a),23(b),23(c),23(d),27(a),27(b),31(a), and 67(a). We are not requesting exemption to any section of 10 CFR Part 36.51. Enclosure la shows justifications for these portions. Enclosure Ib is a plan view of the vertical beam facility with the modifications involved. Enclosure Ic is the emergency instruction document posted at the facility and Enclosure id is a safety analysis prepared for the facility. One part of Enclosure 2a is an updated Section 1.8, page I-1-3, of the NIST Materials License Document showing this change in special authorizations, with the revised portion indicated with a highlight mark, i.e.,

indicated with a vertical mark in the margin.

We request amendment to license mtmber SNM-362 to change item 9 to show permission for off-site operations, by adding to the currently authorized place of use, the Gaithersburg, MD site, a phrase such as "and temporary job' sites under NRC jurisdiction". If necessary, some statement concerning reciprocity for state licensed job sites should also be included.

We request approval of a change to our Materials License Document to delete line item no. 2 in Section 3.2.8 (B), page I 3-4, in order to conform to current regulatory issues. This will reduce the removable l

contamination action level for the teletherapy sealed sources to 0.005 microcuries. We request approval l[

of a change to our Materials License Document to Section 2.11, page I-2-4, to reflect administrative I

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changes at NIST that affect titles for persons performing the fire safety review procedures utilized for l

major facility change proposals. Enclosure 2a shows the new pages with highlight marks for changes.

l We submit for information a change to our Material: License Document in Section 8.5, Table 11.8-2, I

page 11-8-2, to reflect the current NIST Materials License Summary. We submit for information a change to our Materials License Document in Section 9.6, page II-9-3, showing a complete revision to the fire protection section based on a thorough review of the existing fire safety protocols by the Fire Protection 9903310377 990324

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March 24.,1999 request for exemption and amendment request License No. SNM-362 Docket No. 070-00398 i

Group at NIST. We submit for information a change to our Materials License Document in Section 10.2, 3

pages 11-10-2 and 11 10-3, showing the current membership in our Ionizing Radiation Safety Committee.

1 The members shown in the revised list meet the conditions of Section 2.3, page I-2-1, concerning fields of expertise. Enclosure 2b shows these changes, with infana:ica :c S in;d m9 %@ M -i$

new information to be inserted indicated with a highlight mark.

Upon approval of the changes proposed for Part I and review of the changes submitted for Part II of the NIST Materials License Document, new pages showing these changes, highlighted and dated, would replace existing pages.

Thank you for your attention to our requests. If you have further questions about these requests, please contact Mr. T. Hobbs at 301-975-5800, MAIL STOP 3541.

Sincerely, et.6.7 L. E. Pevey, Chi f Occupational He h and Safety Division (Materials License Manager) enclosures I

CC: U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 I

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2-March 24,1999 U..S. Nuclear Regulatory Conunission ENCLOS'URES TO LETTER REQUESTING AMENDMENTS AND EXEMPTION TO SNM-362 Enclosure la - PART 36 JUSTIFICATIONS EXEMPTIONS Enclosure Ib - PLAN VIEW OF VERTICAL BEAM IRRADIATION FACILITY Enclosure Ic - EMERGENCY PROCEDURES Enclosure id-VERTICAL BEAM IRRADIATION FACILITY SAFETY ANALYSIS a - PART I, NIST MATERIALS LICENSE DOCUMENT, CHANGES PROPOSED b - PART II, NIST MATERIALS LICENSE DOCUMENT, CHANGES SUBMITTED i

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l Enclosure la, page 1 PART 36 JUSTIFICATIONS EXEMPTIONS i

L Section 23(a). iustification for exe notion The key that activates the control console, i.e., the key used to move the sources, must be in the console

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and in the ON position for the safety interlocks to be tested and for the runtime safety features to be active. To remove the key in order to gain access to the source room would mean that the test for operability of the safety features would not be possible. With that console key in the OFF position or l

removed, or with the room door open, the sources cannot be moved to the unshielded position. To modify j

the existing system would be prohibitively expensive and would offer no enhancement of safety.

Therefore, we request that separate keys be permitted, one for the console and another for the room door.

Section 23(b). iustification for exemDtion Entry security is accomplished with multiple door interlocks; opening a door causes the source to retum

- to the shielded position and, when the independent backup access control system is armed, notifies the security console, causing a security staff member to come to the area. Multiple radiation monitors in the

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room ale ~ an entering person that a radiation level above normal exists. Modifylg the independent backup access control system to provide automatic source shielding and locr.i alarms would be

, prohibitively expensive and would offer no enhancement of safety. Therefore, we request exemption to the implied requirements of this section.

Section 23(c). iustification for exemption A radiation monitor provides audible and visible indications within the room when rad;ation levels exceed about 2 mR/h. Another radiation monitor provides a meter indication of the measured radiation I

y level within the room under all conditions, and a visible and audible alarm when the room door is opened f

l and a radiation level greater than about 2 mR/h has been detected since the last reset of the alarm, even I

though the radiation level no longer exceeds the trigger level. To modify the system to meet conditions of this section, i.e., to cause the system from section (b) to activate the alarm, would be excessive and i

provide no greater radiation safety features.

Section 23(d). iustification for exemption A complete inspection of the room by the operator precedes a source activation. The room has no vision obstructing equipment or apparatus. The beam catcher pit has a locked lid that is only unlocked for infrequent beam alignment procedures by the Responsible Facility Operator or his designated ll representative. An inspection relay with timed action must be activated as the operator leaves the area to start an activation. There can be no inadvertent occupancy after the inspection while the source moves from its shielded position. Therefore, we request exemption to the requirements of this section.

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Section 27(a). iustification for exemotio_n -

Activation of the heat and smoke detectors alert the security console and the fire protection console, l

causing response by the Fire Protection Group. The emergency procedures posted in the Control Room tell the operator to close the source shutters, if possible, at a fire condition. The implication is that the shutter would be closed unless the operator were incapacitated or had to flee a hazardous situation. To modify the system to cause automatic shutter activation at the fire detection system activation would be

. very expensive and would add incrementally to radiation safety.

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Enclosure la, page 2 Se'ction 21(bl iustification for exemotion Portable fire extinguishers are located in the control room and within the radiation room. No sprinkler

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system exists, thus, no flood control shut-off valve _ exists. No _ storage of combustibles in the room is permitted. A complete review by the Fire Protection Group has determined that the major fire hazard is electrical, with burning-insulation and electrical sparks, and with too little heat to harm the shutter operating mechanism. Therefore, we request exemption from the requirements of this section.

Section 31(al iustification for exemption-A radiation monitor indicatorjust inside the door to the radiation room latches an alarm at the indicator when the radiation level inside the sliding lead door rises above about 2 mR/h. This triggers the visible and audible alarm when the door is opened following an irradiation procedure, even though the radiation q

level has fallen to normal, non-operating levels. To reset the alarm, the person entering the room must push a button located beside the meter, thus facing and observing the meter indicating the radiation level inside the sliding lead door. The key to the console must be in place and turned to energize the console before the tests required for an irradiation procedure can be performed. To open the door to observe that the interlocks that close the shutter function properly, the console key and the door key are simultaneously needed. Therefore, we request that we be exempted from the requirement for a survey meter to be attached to the key and the requirement that the console, or source control, key be the same key used for the door.

Section 67(al iustification for exemption The automatic initiation of the visible and audible alarms upon opening the entry door following a beam-on procedure forces the entering person to reset the alarm before sliding open the lead door. Should the radiation level inside the lead sliding door still be elevated, the alarms will re-initiate. This avoids the possibility of human errer in forgetting to carry, neglecting to check operability, mispositioning, neglecting J

to observe meter indications, or misreading the survey meter indication, or the possibility of an undetected survey meter malfunction.

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i Enclosure Ic, page 1 EMERGENCY PROCEDURES 3/99 MALFUNCTION:

IF POSSIBLE, CLOSE THE SOURCE SHUTTER. INSURE THE DOORS ARE LOCKED AGAINST INADVERTENT ENTRY AND MARKED AS MALFUNCTIONING. CALL THE RESPONSIBLE FACILITY OPERATOR AND CALL HEALTH PHYSICS.

l POWER ON THE FIRST RADIATION ROOM ENTRY DURING OR FAILURE:

FOLLOWING A POWER OUTAGE, A PORTABLE SURVEY METER MUST BE CARRIED INTO THE RADIATION ROOM l

TO INSURE THAT THE SOURCE SHUTTER HAS CLOSED.

FIRES:

IF POSSIBLE, CLOSE THE SOURCE SHUTTER. CLOSE AND LOCK ALL DOORS. PROCEED TO A SAFE AREA, CALL THE EMERGENCY NUMBER, AND AWAIT THE ARRIVAL OF TRAINED RESPONSE PERSONNEL.

INJURIES:

CALL THE EMERGENCY NUMBER. PROVIDE FIRST AID IF TRAINED. OTHERWISE, AWAIT TRA!NED RESPONSE PERSONNEL.

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l RESPONSIBLE FACILITY OPERATOR EMERGENCY NUMBER PAUL LAMPERTI, EXT. 5591 EXT.2222 ALTERNATE RFO HEALTH PHYSICS JILEEN SHOBE, EXT. 5595 EXT.5800 i

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Enclosure Id, page 1 VERTICAL BEAM IRRADIATION FACILITY SAFETY ANALYSIS 3/99 I

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_ This' safety analysis concerns the facility in Building 245 that utilizes teletherapy-style source heads.

l Although the sources are not used for human exposures, the facility meets the conditions'specified in l

10 CFR Part 35.615(b). The sources are used for research and development projects, calibration of i

instruments, and irradiations of dosimeters and other materials. Customers include medical, i

commercial, federal and state govermnent, and international facilities. There are three heads: one (1) in Room B034 and two (2) in Room B036, with the control console for all units in the middle rootn, B035, in Bldgc 245. The facility was built in the early 1960's and irradiations began in 1965. Through the ensuing years, modifications for operations and for safety purposes have been incorporated.

l I. Access Control i

Keys to the Control Room, B035, are restricted to members of the Radiation Interactions &

l Dosimetry Group of the Ionizing Radiation Division and to Health Physics. Access to keys to the beam rooms and to the operating console are restricted to authorized operators of the units.

II. Source Storage and Operations For normal use of the facility sources, specified information is entered in the log book kept at the console. For situations other than normal irradiation procedures, e.g., for maintenance, the Responsible Facility Operator will record specific conditions and characteristics for the special circumstance in the same log book.

Prior to initiating an irradiation, the operator will ascertain that no person remains in the radiation room by visually examining the entire area before pushing the inspection interlock, located just inside the sliding lead door. Within thirty (30) seconds, the operator will slide the lead door shut and leave the room, closing the personnel entry door. The console key will be inserted in the console and the panel activated. The operator will ooen the shutter, go to the personnel entry door, listen to assure that the warning buzzer is sounding within the radiation room, and look up to see that the radiation lights are lit. Opening the door, the operator assures that the shutter automatically shields the source. After opening the door, the operator quickly notes the condition of the set of two (2) red and two (2) opal lights just outside the sliding lead door, assuring that the red lights go off and the opal lights come on, l

indicating that the source shutter has closed and that the interlocks have functioned correctly. The operator will reset the visual and audible alarm on the radiation monitor just inside the door. A single test will suffice for a series of irradiation procedures with no intervening period of non-operation.

If any of the preliminary tests does not demonstrate proper functioning, the operator will implement the Emergency Procedure for malfunctions. Following the safety check assurances, the operator closes the doors, as above, and the exposure procedure may be initiated. If the facility is to be operating and unattended for a period of more than four hours, the user is to arm the security alert system by calling the security console attendant.

III. Fire Safety The Fire Protection Group has confirmed that the only source ofignition in the room is electrical.

L The Responsible Facility Operator permits no storage of flammables, explosives, or combustibles in l

the radiation room that can cause a fire threat to the integrity of the source capsules or the functioning js of the shutter. Heat and smoke detectors are mounted at the ceiling level. These signal the security

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console in Bldg.101 and at the Fire Station console of fire conditions. The fire protection personnel responding to a signal will stop at the personnel entry door and await the arrival of the Responsible

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Fa' ility Oix:rator or Health Physics.

c IV.i Emergencies,

An emergency instruction protocol is posted at the entrance to the facility. In case of facilty malfunction or fire, the operator is to close the shutter, if poaible. The shutter automatically closes in case of electrical power or air pressure loss.

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--IV. Other Hazards An individual may not work alone in the radiation room when the beam catcher pit is uncovered.

' Safety shoes and safety glasses should be considered to help avoid work-related injury.

V. Posting and Labeling The source heads will be labelled with CRM signs with nuclide and dated quantity information. The personnel entry door will be labelled with CRM and with " Grave Radiation Danger" posters. Two (2).

red and two (2) opal lights will be inside the personnel entry door, to indicate shutter closed (opal) or shutter open (red) condition. At least one (1) red light will be visible outside the personnel entry door to indicate shutter closed (light OFF) or shutter open (light ON) condition. The lights are triggered by a radiation monitor within the radiation room but not in the direct beam.

VI. Facility Supervisors The Responsible Facility Operator is Paul Lamperti, ext. 5591. The alternate RFO is Jileen Shobe, ext.

5595.

VII. Operator Training Operators will be annually trained and tested by Health Physics or by the Responsible Facility Operator or a designated alternate. Training will include safety features such as safety' interlock assurance testing, emergency procedures, and contact lists for response personnel, e.g., Health Physics.

A list of current trained operators will be maintained at the console, with annual updating. The

-j Responsible Facility Operator will assure that interim training information on such matters as facility or operational changes, reports ofincidents from this or similar irradiation facilities is made available to trained operators to supplement the training required for this facility.

INCIDENT ANALYSIS ADDENDUM The maximum loading of 12 kCi of 6 Co yields a maximum exposure rate in the direct beam of about 108,000 R/h at a distance of 1.5 m down from the head. Using a rule-of-thumb of 0.1% for the exposure scattered at right angles from the direct beam (see: NCRP Report No. 49, Table B-2, page.

l 59), that exposure rate would be 108 R/h. Thus a person inadvertently entering the room would be overexposed in about three minutes, a time quite adequate'to notice that the shutter condition was not the nonr. ally closed position expected.

To date, after many thousands ofindividual source uses, there has never been a safety feature failure that permitted any person to put himself or herself at risk from an unshielded source. Safety features include at least nine individual interlocking shutter controllers for the entry door, the sliding lead door, air pressure, electrical power, and console switches, and at least seven individual interlocking warning controllers for the radiation monitor systems. In an elementary approach, using an extremely conservative statistical analysis, i.e., for the incredible event case, consider that there is a one in-one thousand probability of failure for any individual shutter controller or radiation alert mechanism; then the overall pmbability of a failure that could lead to inadvertent overexposure is (10'), or one chance

. in 10".

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. a This enclosure is a set of the pages proposed as replacements for the existing pages in Part I of the NIST Materials License Document dated 6/19/97, with lines involved in changes highlighted.

PAGES INVOLVED I-1-3 I-2-4' I-3-4 b This enclosure is a set of the pages submitted as replacements for the existing pages in Part II of the NIST Materials License Document dated 6/19/97, with lines involved in changes highlighted.

II-8-2 11-8-3 II-8-4 (new)

II-9-3 II-10-2 II-10-3 II-11-3 II-Il-5 l

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Among the types of activities that may be authorized, the following topical list illustrates typical projects that may exist. Also listed are those buildings that would most probably be involved in a particular type of activity, although special authorizations by Health Physics could alter the locations listed.

materials and equipment irradiations - Bldgs 235 and 245 a

source preparations - Bldgs 220-226,235, and 245 m

source calibrations - Bldgs 220-226,235, and 245 m

instrument calibrations - Bldgs 220-226,235, and 245 m

sample assays - Bldgs 220-226,235, and 245 m

source characterizations - Bldgs 220-226,235, and 245 m

instrument and device characterizations - Bldgs 220-226,23f, and 245 m

reference or counting source uses - Bldgs 101,220-226,235, and 245 m

radiochemistry - Bldgs 220-226,235, and 245 m

general research and development - Bldgs 101,220-226,235, and 245 m

sources incorporated into devices or equipment - Bldgs 101,220-226,235, and 245 m

miscellaneous, e.g., static elimination - Bldgs 101,220-226,235, and 245 a

1.8 Special. Authorizations We request that radioactive material use be authorized at off-site locations subject to the a.

following provisions:

the proposal is reviewed and approved by Health Physics and, if required, by the Ionizing a

Radiation Safety Conunittee.

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NIST is responsible for the safe use of the radioactive material, which is controlled by m

i an authorized individual who possesses written operating instructions while engaged in the project.

the radioactive material is an integral part of a measurement instrument or a centained a

source, such as a check or reference source.

lead-in-paint detectors may not exceed 100 millicuries of cadmium-109 or americium-241 a

as sealed sources in each device, otherwise the total quantity of radioactive material for a single authorized use may not exceed ten times the activity listed in 10CFR20, Appendix C, or, for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity, b.

We request authority to release contaminated equipment to uncontrolled areas in accordance with the USNRC's April,1993 " Guidelines for decontamination of facilities and equipment prior to release for unrestricted use or termination oflicenses for byproduct, source, or special nuclear material."

We request exemption from 10 CFR Part 36, Sections 23(a),23(b),23(c),23(d),27(a),

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27(b),31(a), and 67(a), in accordance with our letters of March 24,1999.

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Supervisory Health Physicist conduct radiation workplace safety observation tours at least

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quarterly for those workplaces that pose significant potential for radiation exposures or releases of radioactive materials, following written plans. Results of the tours are documented and corrective action needs found during the tours are transmitted to workplace supervisors in a timely fashion.

2.9 Investigations and Reporting of Off-Normal Occurrences Health Physics, based on reports from Division Chiefs or workers, or on results of monitoring or surveillance, investigates suspected off-normal occurrences. The Chief, Occupational Health and Safety Division, reports these conditions to authorities and to management, as required by applicable regulations, procedures, and license conditions.

2.10 Records Health Physics maintains documentation on the results of required monitoring and surveillance,

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the results of approved proposal reviews, off-normal occurrence investigations, and other radiological safety program information, sufficient to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee documents and retains information on audits and provides reports to management as required. Retention times for documents are as required by regulations or for at least two years.

2.11 Fire Protection l

A Fire Protection Group in the Facilities Services Division provides a trained fire and emergency response organization. Any proposed laboratory or facility construction or modification must be reviewed by and have the approval of such management interests as l representatives of the Chief of the Occupational Health and Safety Division and the Chief of the Plant Division, and the Fire Protection Specialist or his designated representative. Members of l the staff of the Fire Protection Group are trained to the equivalent of Fire Fighter III level.

Maintenance of fire fighting equipment is conducted according to written procedures. Extensive pre-fire plans exist, with infermation on locations of radioactive materials, fiammable materials, and other hazardous materials, and includes fire fighting protocols for those areas. The plans l include locations of water supplies, storage areas, and other appropriate information. The Fire l Protection Group maintains extensive documentation on maintenance and deployment of equipment, pre-fire planning, facility characteristics, training, results of actual occurrences, etc.

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2. The' periodic leak test required by this section does not apply to sealed sources that are

' stored and not being used. Prior to any use or transfer to another person, the source shall be leak tested within 6 months prior to the date of use or transfer.

B.

The test shall be capable of detecting the presence of 0.005 microcuries of radioactive I

material on the test sample. The sample shall be taken from the sealed source or appropriate accessible surfaces of the container or from the device where the sealed source is mounted or stored in 'vhich one might expect contamination to accumulate. Records ofleak test results shall be kept in units of microcuries and maintained for inspection by the USNRC.

l If the test reveals the following:

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The presence of 0.005 microcuries or more of removable contamination from the sealed sources other than described below, or l

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An indication that the sealed source which is stored in the water pool for shielding l

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purposes is leaking, then NIST shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a per' son appropriately licensed to make such repairs or to be disposed ofin accordance with USNRC regulations.-

Within 5 days after determining that any source has leaked, NIST shall file a report with the Division of Fuel Cycle Safety and Safeguards, USNRC, Washington, D. C. 20555, describing the source, test results, extent of contamination, apparent or suspected cause of source failure, and l-corrective action taken. A copy of the report shall be sent to the Administrator of the NRC j

Regional Office for Region I.

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8.4 Maps, Buildings, and Site Information Attachment I contains a NIST site plan and a topographical representation, building locations on site, and floor plans for buildings. The site exhibits a gently rolling topography and contains i

l both open and wooded areas. Buildings include a central complex of the main administration -

building and several general purpose buildings designed to contain laboratories that accommodate l

customary scientific research and development functions, buildings that house the support functions ranging from grounds management, heating and air conditioning, and the like, to procurement, and special purpose laboratory buildings that are dedicated to specific research and development functions. This last category includes the Reactor and the Radiation Physics 1

Buildings, where the majority of the work involving radiation and radioactive materials is conducted.

8.5 License History Table 11.8-2 shows a chronological ordering of licensing history at NIST for radioactive materials. This history tracks licenses to the most recent renewal. In some cases, e.g., for 08-00566-05, the byproduct material license, a full history would extend to more than thirty years with many amendments and renewals. In 1980 a Materials License Manager was named to bear responsibility for licensing other than for the NIST Reactor. In 1985, five major licenses were consolidated into the single SNM-362 license.

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03/24/99 TI-8-2

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TABLE 11.8-2 NIST MATERIALS LICENSING

SUMMARY

j YEAR LICENSE ACTION (identifier) l 1997 SNM-362 renewal

-l 1990 -

SNM-362 amendments 1 - 4 1994 1985 -

SNM-362 amendments 1 - 4 1990 1985 08-00566-05, 08-00566-10, 08-consolidation, incorporation into 00566-12, SMB-405, SNM-362 License No. SNM-362 1983.

08-00566-05 Class I irradiator request 1982 all lonizing Radiation Safety Committee 08-00566-05 change in limits (byproducts) l all personal dosimetry technique 1981 SNM-362 filter process (SNM)

SNM-362 change'in limits i

l 08-00566-10 renewal (teletherapy) 1980 SMB-405 license manager named (source)

J 1979 SNM-362 renewal 08-00566-05 change in limits

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1978 SMB-405 renewal p

08-00566-12 renewal (irradiator) 1977 08-00566-05 renewal i

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I 8.6 Changes in Procedures, Facilities, and Equipment NIST employees and other individuals working on the NIST site are responsible for-obtaining authorizations from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiological safety, or for disposition of

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radiation sources. Division Chiefs are responsible for ensuring that staff members comply j

with radiohigical safety rules and that staff members are aware of radiological safety procedures. The Chief, Occupational Health and Safety Division, is charged with managing the radiolor,ical safety program and with representing the National Institute of Standards and l

. Technology in all matters relating to materials licensing. The Chief, Health Physics, is J

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charged with administering the radiation safety program at NIST, including maintaining documer.tation to demonstrate the adequacy of the radiological safety program. The Ionizing Radiat on Safety Committee is responsible for reviewing major radiation facility proposals i

and significant proposals for use of radiation, including modifications to existing facilities, i

and for assuring the performance quality of operations that provide radiological safety i

assurance.

8.7 Examples of Operations That Might Be Conducted As an example of the miscellany of types of work done at NIST, consider NCRP Report No. 58, A handbook ofradioactivity measurements procedures, second edition. Of the flfteen consultants listed in the preface to the first edition, ten were from one working group within NIST (then NBS), as well as the chairman of the scientific committee. The preface to the second edition names twenty-four persons who made contributions to that edition. Of those, fifteen were NIST (then NBS) personnel, including Health Physics staff members. The wide variety of operational activities and of radionuclides described in the publication, essentially i

the product of only one of the groups at NIST, illustrates the extremely broad scope of work done at NIST.

For the specific nuclides listed in Table I.1-1, the following example: of research, l

development, and other activities will suggest the variety of operations involving radioactive j

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materials at NIST. Uranium at any enrichment, from depleted through 99.9% 235U, 23'U, any nuclide of plutonium, and thorium, might be used in metallurgical research, for beam transmission studies, in neutron beam research, for check sources, or as beam filters. Scaled 1

sources of 23sPu are used as thermal sources. PuBe, Puli, and other sealed Pu-X sources are I

used in neutron research and are calibrated for customers. Sealed sources of"Co, SCs, 2iopo l

'(sometimes as PoBe),2*Am,252Cf, or "Sr might be used in research requiring photon, neutron, or beta radiations, for instrument calibrations, in neutron physics research, medical device (implant seeds, eye irradiation applicators, etc.) calibrations and research, or basic nuclear chemistry and physics research such as half-life studies. Miscellaneous byproduct materials, including materials and containers irradiated in the NIST Reactor and brought out i

of the Reactor licensed area, might be used as check sources, in laboratory intercomparison tests and studies, for light sources, for basic radiochemistry and nuclear physics research, for 1

sample preparations for authorized customers, or in research for medical or other specific laboratory types.

ON24/99 H-8-4 I

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4 Wastes with short half-lives are treated by decay-in-storage. Disposal of decay-in-storage waste, as provided in 10CFR20.2001(a)(2), is in accord with conditions given in 10CFR35.92.

9.5 Chemical Systems Nonradioactive chemical operations are the responsibility of the Environmental Compliance Group of the Occupational Health and Safety Division. Any facility or operation involving j

toxic materials is reviewed to insure compliance with appropriate regulations.

9.6 Fire Protection j

j The buildings and facilities at NIST were constmeted in accordance with applicable l

i regulations for Federal facilities in effect at the time of construction and are maintained under l

the fire protection auspices of the Fire Protection Group of the Facilities Services Division.

l l

The coverage by this trained fire and emergency response group includes around-the-clock l

l fire, emergency medical, and hazardous material response capabilities l

The Fire Protection Group reviews facility plans, including locations of fire hydrants, l

sprinkler systems layouts, access pathways, and other layout information related to fire l

fighting. The plans are maintained in the offices and workspace of the Fire Protection Group l

work area. Training of fire fighters is according to the State of Maryland and local County l

having authorization, in conjunction with NFPA. Materials and equipment available to the l

Fire Protection Group include appropriate vehicular firefighting apparatus, water supply l

systems, automatic sprinkler systems, portable fire extinguishers, protective clothing, and took l

used in fighting a variety of fires, e.g., structural, vehicular, etc. Maintenanc; and deployr; l

of fire fighting equipment is in accordance with NFPA codes. Ex. asive pre-fire plans have l

been developed incorporating information on location of radioacti /e materials, flammable l

substances, and har udous materials storage areas. The plans incluie fire fighting protocols l

for those areas, with locations of water supplies, automatic fire figl. ting response mechanisms l

that might be employed, and other pertinent information. The Fire Piotection Group maintains l

extensive documentation on deployment and maintenance of equipmett, pre-fire planning, l

facility characteristics, training of personnel, results of actual occurrences, etc. Portable fire l

extinguishers are deployed according to NFPA 10; these are commonly ccy chemical and CO I

I 2

types. In addition, portable extinguishers are commonly located in each laboratory and l

building hallways. Portable fire extinguisher agency is determined by the fire load in the area l

of work. Building entrances and stairwells have standpipe connections; fire hydants are l

)

located at various positions on the exterior of buildings. The loading dock of Building 245 l

has a sprinkler system.

I Laboratories are monitored with automatic fire alarm devices activated by heat or smoke, or l

both. The fire alarm device type is determined by the fire hazard within the work area l

i covered. Manual fire alarm boxes (pull stations) are located according to the NFPA code.

I Upon activation of any alarm, the signal is received at two locations: in the Fire Station in l

Bldg. 303 and in the Security Office in Bldg.101.

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i radiation safety program.

10.1.4 Division Chiefs Each Division Chief managing radiation work is responsible for the following:

Ensuring that staff members comply with radiation safety rules in implementing the

. a.

NIST radiation safety policy; b.

Ensuring that staff members are aware of radiation safety procedures and receive training as required; a

c.

Reporting potential items of substantial safety hazard as dermed in 10CFR21.3(k) to the Chief, Health Physics, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence or discovery, except for items relating to the Reactor license which are to be handled according to that license; and d.

Reporting significant radiation safety matters to his or her supervisor.

10.1.5 Staff NIST employees and other individuals working on the NIST site are responsible for the following:

a. -

Observing approved radiation safety rules; b.

Consulting with Health Physics early in the planning of operations that might involve radiation sources; I

Obtaining authorization from Health Physics for radiation source acquisitions, for any c.

modifications in radiation source use that might affect radiation safety, or for disposition of radiation sources; d.

Notifying Health Physics of any occupational radiation exposure from work at facilities other than NIST; e.

Immediately informing Health Physics upon discovery ofloss or theft of any radioactive materials; f.

Immediately informing their supervisors and Health Physics of accidents involving radiation or radiation sources; and a

g.

Informing their supervisors of defects that could create a substantial safety hazard.

-l -10.2 Organization l'

Members and alternates of the Ionizing Radiation Safety Committee are named.by the L l Deputy Director of NIST. The current list, with organizational titles, is:

l-l (Chair) Dr. Bert M.- Coursey, Director, Ionizing Radiation Division (IRD),

l l

Physics Laboratory (PL) l (Vice Chair) Dr. Richard M. Lindstrom, - Research Chemist, Nuclear Methods Group, ACD, l.'

CSTL' i

l Dr.' James M. Adams, Research Physicist, Neutron Interactions and l

Dosimetry Group, IRD, PL l Mr. Jeffrey T. Cessna, Research Chemist, Radioactivity Group, IRD, PL

- l Dr. Heather H. Chen-Mayer,

. Research Chemist, Nuclear Methods Group, l

Analytical Chemistry Division (ACD), Chemical l

Science and Technology Laboratory (CSTL) 03/24/99 H-10-2 i

1 v.

Mr. Keith H. Eggett, Safety Engineer, Environmental Compliance l

Group, Occupational Health & Safety Division l

l (OHSD), Office of the Director of Adn inistration l

)

, idmin) l Mr. Douglas M. Eagleson, supervisory Health Physicist, Health Physics l

Group, OHSD, Admin l

Mr. Thomas G. Hobbs, Chief, Health Physics Group, OHSD, Admin.

l Dr. Santos Mayo, Physicist, Semiconductor Electronics Division, l

Electronics and E!ectrical Engineering Laboratory l

(EEEL) l Mr. J. Frankhn Mayo-Wells, Staff Assistant for Technical l

Goordination/ Operations, EEEL l

Mr. Lyman E. Pevey, Chief, OHSD, Admin l

Dr. Henry J. Prask, Physicist, Neutron Scattering Group, NIST Center l

for Neutron Research (NCNR), Materials Science l

and Engineering Laboratory (MSEL) l 1

Dr. J. Michael Rowe, Director, NCNR, MSEL l

Dr. Francis J. Schima, Research Physicist, Radioactivity Group, IRD, PL l

i Dr. Christopher G. Soares, Research Physicist, Radiation Interactions and l

Dosimetry Group, IRD, PL l

Dr. David S. Simons, Leader, Analytical Microscopy Group, Surface and l

Microanalysis Science Division (SMSD), CSTL l

Mr. Lester A. Slaback, Jr.,

Supervisory Health Physicist, Health Physics l

Group, OHSD, Admin l

Ms. Cynthia J. Zeissler, Physical Scientist, Analytical Microscopy Group, l

SMSD, CSTL l

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L 11.6 Surface Contamination

. Table H.11-1, Controls and Action levels, and Table II.11-2, Administrative Action Levels and Actions, list controlling levels for surface contamination. Measurements for surface contamination checking and protective measures are described in sections 11-11.1, II-l1.4, and II-l1.7 of this

- manual.

Hand and shoe monitoring may be performed with conveniently placed equipment; resuspension factors for transforming surface contamination levels to _ airborne activity l

concentrations are applied as described in section 1I-11.5 of this manual.

l 11.7 Shipping and Receiving All radioactive materials received at NIST and all radioactive materials shipped from NIST are controlled by Health Physics. Usually, incoming packages are brought to the Health Physics receiving area in Building 245, unless altemate provisions are made with the ultimate recipient.

In either case, surveys for compliance with t ansport regulations are made within time limits specified by the regulations. Health Physics and the recipient then survey the package and contente an 1 detennine if the shipment is acceptable for incorporation into the project for which

. the source is intended. Usually, outgoing packages are held in the NIST shipping area in Building 301 until Health Physics or a designated representative checks the package for compliance with

. transport regulations.

Type B shipments are made in accord with the provisions of the quality assurance program as detailed in a separately submitted document.

If an incoming shipment shows contamination at any level of packaging, the package is held in the Health Physics or other designated storage area until a decision is made, jointly between Health Physics and the recipient, on returning the source, decontaminating the source, disposing of the materials, or establishing proper controls for safe use of the source.

11.8 Posting and Labeling Table 11.11-1 shows control mechanisms and action levels under which radioactivity operations are permitted. The contamination limits shown represent a departure from customary practice in that specific nuclide limits are provided for beta-emitting nuclides when the identity of the nuclide is known. As an ALARA precaution; Health Physics requests decontandnation of areas i

in which any detectable contamination above normal background levels are found. Health Physics I

review may result in a determination that actions other than described in this table should be implemented. Such alternate actions are documented by Health Physics.

i

- 11.9 Surveys Health Physics performs weekly routine surveys of a laboratory in which unsealed radioactive material is utilized when the initial proposal or subsequent evaluation of the work environmem demonstrates that levels could exceed the levels at which posting is required, as shown in Table II.ll-1. As specified by Health Physics, the surveys could include smear tests of surfaces, i

radiation level tests, radiation quality tests, air activity contamination tests, or combinations of these red other radiation safety assurance procedures. For special situations, such as maintenance, similar surveys, time and motion studies, or practice sessions on mock

)

03mm no3

L e

centamination ~might be expected to accumulate. Sources will be immediately withdrawn from use and action taken to repair or dispose of the source, and appropriate actions taken to notify the NRC, if the following limits are exceeded for removable contamination:

a any indication ofleakage from the irradiator sealed source in the water shielding pool.

e 0.005 microcuries or more from any other sealed source.

l 11.12 Respiratory Protection Health Physics may issue dust stop or similar particulate breathing masks for dusty work i

environments. At the conclusion of thejob, Health Physics retrieves the masks and prepares them for reuse.

11.13 Protective Clothing Health Physics maintains a nominal supply of various protective clothing items, including j

gloves, shoe covers, coveralls, head covers, etc. These are freely available as needed for issue to laboratory workers using dispersable radioactive materials. For situations requiring potective l

clothing beyond the normal issue quantities, the requesting work unit may be asked to replenish the supply.

I1,14 Reports and Records The Chief, Occupational Health and Safety Division, documents management and authority l

notifications resulting from reports from Health Physics on off-normal investigations. Health Physics maintains documentation on routine and special radiological surveys, personnel

)

monitoring, licensing interactions with NRC, instrument calibrations, ALARA reviews and.

findings, employee training and familiarization, environmentel monitoring, and source control.

l The Chairperson of the Ionizing Radiation Safety Committee maintains records of meetings of 1

the Committee, Committee audits, and special reviews and investigations by the Committee.

Normal retention time for these records and documents is two years unless otherwise specified l

by regulations.

11.15 Administrative Control Levels Table II.11-2 describes the administrative action levels and the actions taken at those levels to control radiation and radioactive materials in specific situations and under specific conditions.

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