ML20213H189
| ML20213H189 | |
| Person / Time | |
|---|---|
| Site: | 07001703 |
| Issue date: | 05/13/1987 |
| From: | Bidinger G, Soong A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20213H158 | List: |
| References | |
| NUDOCS 8705190191 | |
| Download: ML20213H189 (7) | |
Text
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MAY 131987 FCUF: ALS DOCKET N0: 70-1703 LICENSEE: Eastman Kodak Company (EKC)
FACILITY: Rochester, New York
SUBJECT:
SAFETY EVALUATION REPORT, APPLICATION DATED MARCH 10, 1987, RE LICENSE RENEWAL, SNM-1513 I. Background By letter dated March 10, 1987, Eastman Kodak Company (EKC) filed a renewal application for SNM-1513. The license was renewed in April 1982 with an expiration dated of April 30, 1987. During the period of this license, two amendments were issued; one concerned changes in personnel, and the other incorporated the licensee's Physical Security Plan. EKC's license was originally issued by the Commission in 1975 to authorize possession and use of 1,582.6 grams of U-235 in a Californium Neutron Flux Multiplier (CFX). The licensed material is in the form of uranium-aluminum alloy clad in aluminum.
The CFX was manufactured by the NRC-licensed Intelcom Rad Tech (Docket No.
70-1359). EKC uses the CFX for neutron activation analysis and for neutron radiography.
II. Scope of Review The safety review of the licensee's request included an evaluation of their application dated March 10, 1987, and discussion with Region I Inspector, Mr. J. Roth.
III. Discussion A. Possession Limits The applicant has requested the following licensed material:
Material Form Quantity Uranium enriched to Uranium-aluminum- Up to 1,582.6 grams
< 93.4% in the U-235 alloy clad in of U-235 located Isotope aluminum in the Californium Neutron Flux Multiplier (CFX) l 8705190191 EDhD513 PDR ADOCK 07001703 C PDR
i Eastman Kodak Company SER 2 MAy y 3 ggg7
- 8. Authorized Activities and Place of Use The applicant has requested authorization to use the material in the CFX for neutron activation analyses and neutron radiography for testing film materials.
The experiments will be conducted at the Research Laboratories Building 82.
Accordingly, the following license conditions are recommended:
Authorized Use: For use in accordance with statements, representations, and conditions specified in the licensee's application dated March 10, 1987.
Authorized Place of Use: The licensee's Research Laboratories Building No. 82 in Rochester, New York, as described in the above application.
C. Management Organization EKC's Health and Environment Laboratories (HAEL) is responsible for administering the radiation safety program. The HAEL provides technical support to Kodak Plants on health-related matters including industrial hygiene and health physics. The radiation safety program is managed by the Occupational Health Laboratory (OHL) of HAEL. The Radiation Safety Officer (RS0) of OHL is responsible for approving purchases of radioactive material and licensing activities and is the consultant to the radioactive material user for radiation protection. In the area where a
the CFX is used, a Radiation Safety Supervisor (RSS) is assigned responsibility for radiation safety. The RSS is responsible for routine radiation monitoring and record retention and serves as the liaison for the Radiation Protection Committee.
The RSS is appointed by the Area Division Manager and is approved by the RSO.
EKC's Analytical Technical Division has the administrative responsibility for the CFX. The Group Leader, Atomic Spectroscopy Unit, is responsible for neutron activation analysis work and safe operation of the CFX.
EKC has established a Radiation Protection Committee (RPC) comprised of the Director of Occupational Health Laboratory and the Radiation Safety Officer.
The RPC is responsible for formulating company policy on the use of the licensed material and dealing with unusual radiation problems, such as approval of changes to procedures which could increase experimental radiation levels. The RPC meets at least twice a year.
D. Minimum Technical Qualifications The licensee has established the minimum qualifications for the positions of the Chairman of the Radiation Protection Committee, Radiation Safety Officer, Radiation Safety Supervisor, and Group Leader. These positions require a bachelor's degree in science or engineering and 1 to 2 years work experience.
The applicant would require that the Chairman of the Radiation Protection Committee and the Radiation Safety Officer have a minimum of 1 year work experience. Accordingly, the staff recommends the following license condition:
Eastman Kodak Company SER 3 MAY 13 ES!
Notwithstanding Section 2.2 of the application:
- a. The Chairman of the Radiation Protection Committee shall have at least 5 years experience in management including 2 years working with ionizing radiation.
- b. The Radiation Safety Officer shall have at least 2 years work experience in health physics.
E. Administrati") Procedures Written Procedures The applicant has committed that the CFX operation will be conducted in accordance with written procedures. The procedures will be approved by the Radiation Protection Committee. The applicant did not commit to written health physics procedures. Accordingly, the staff tccommends the following license condition:
The licensee shall establish, maintain, and follow written procedures for carrying out the health physics activities. The procedures shall be approved by the Radiation Safety Officer.
Inspection The applicant is not committed to periodic inspections by safety personnel.
The staff, therefore, recommends the following license condition:
The RSO shall conduct quarterly inspections of radiation safety at all work areas. The inspection shall be conducted in accordance with a written procedure, and the findings of the inspection with needed corrective actions shall be transmitted to the supervisor of the inspected area and the Radiation Protection Committee.
Training The Radiation Safety Supervisor and Group Leader jointly provide inhouse training to each new worker and conduct retraining once a year. The staff recommends a license condition to specify the maximum interval between training sessions. The condition reads as follows:
l Notwithstanding the retraining in Section 3.5 of the application, the retraining of operators in radiation safety and safe operations of CFX shall be performed at intervals not to exceed 14 inonths.
Eastman Kodak Company SER 4 MAY 131981 F. Radiation Safety The CFX, which contains 1,582.6 grams of U-235, is housed in the underground radiation cavity of EKC's Building No. 82. The shielding provided for the cavity is adequate to assure that radiation exposure outside the cavity (control room) is less than regulatory limits. In addition, the following safety design features of the CFX and cavity prevent potential mishaps:
- a. An interlock system prevents entry into the cavity when the CFX is on and the radiographic port is open. The system is routinely checked by RSS to ensure it is working properly.
- b. Ion chamber detectors, located in the device, automatically shutdown the device when the radiation level exceeds a preset level.
- c. Radiation monitors in the cavity will trigger an alarm in the cavity and control room when the radiation level exceeds 10 mr/hr.
Control of Personnel Exposure Each worker who uses the CFX is provided with a personnel radiation dosimeter and is required to wear it at all times in the restricted areas. The dosimeters are analyzed and evaluated monthly. If any worker's monthly exposure is beyond 100 mrem, the RSS will immediately investigate the cause and will take action to prevent further exposures.
The maximum annual exposure of any worker reported by EKC for 1984, 1985, and 1986 was 100 mrem per year.
Control of Surface Contamination Since the licensed material is a contained source and is installed inside the neutron multiplier device, the potential for surface contamination from the material is unlikely. Accordingly, the containment of the licensed material is checked (leak testing) every 6 months. The laboratories are checked monthly for surface contamination (primarily for radioactive material licensed under Agreement State license). EKC has established criteria (action levels) for cleanup if contamination is detected. These criteria were reviewed and considered to be acceptable.
After reviewing the licensee's radiation program for the control of surface contamination, the reviewer has found the licensee's program does not include:
- a. Criteria f,r releasing contaminated equipment and material from the facility to the unrestricted area.
- b. A procedure for leak testing the sealed licensed material.
.o Eastman Kodak Company SER S MAY 1 a 1987
- c. A survey frequency for measuring radiation exposure levels in the control room areas and outside the building.
To correct these deficiencies, the staff has proposed the following license conditions:
Release of equipment or material for unrestricted use shall be in accordance with the enclosed Annex A, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," May 1987.
Notwithstanding the statement on wipe testing in Section 5.2.3, Page 11, of the application, the licensee shall comply with the enclosed Annex B,
" License Condition for Leak Testing Sealed Uranium Sources," May 1987.
The licensee shall conduct monthly radiological surveys of the CFX control room and above the cavity outside Building 82 (ground level) to ensure the radiation levels are within regulatory limits.
G. Nuclear Criticality Safety Enriched uranium is used in a subcritical assembly which has a k-effective of 0.99 with all centrol rods withdrawn. This k effective is based on a measured value for a specific configuration established by the vendor who assembled the subcritical assembly in the licensee's facility. To assure that the configuration is maintained, the staff recommends the following license condition:
Manipulation of the aluminum fuel container for the CFX is not authorized.
l The total mass of U-235 in the CFX is 1,582.6 g. To ensure that no additional i fuel will be at the facility that may cause an increase in k,7f, the staff recommends the following license condition:
The licensee shall not possess any special nuclear material other than the 1,582.6 g contained U-235 authorized by this license.
Since the CFX cannot be made critical at any degree of water moderation and reflection, the exemption from the criticality alarm requirements of 10 CFR 70.24 is justified. Moreover, the licensee has gamma-monitoring system probes in the cavity where the CFX is located and in the control room to monitor radiation levels from the CFX. The probes are set to trigger an alarm when I the radiation levels excced 10 mr/hr, thus alerting personnel that high radiation levels exist.
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4 8
MAY 131987 Eastman Kodak Company SER 6 Eastman Kodak's administrative controls for periodically checking the operability of controls and interlocks and the CFX operation are adequate to protect the health and safety of the operating personnel, the public, and environment.
Accordingly, the staff recommends the following license condition:
The licensee is hereby exempt frcm the requirements of 10 CFR 70.24 (d) insofar as the section applies to material held under this license.
H. Environmental Protection The licensing of the Eastman Kodak activities is in accordance with 10 CFR 51.22(c)(14)(v), therefore, neither an Environmental Impact Statement nor an Environmental Assessment is warranted for this action.
I. Region I Comments On April 6 and 29, 1987, the staff discussed the renewal application with Mr. J. Roth, Region I Facility Inspector, and he foresaw no safety related problems with the issuance of the renewed license as conditioned.
IV. Conclusion and Recommendation Upon completion of the safety review of the licensee's application, the staff has concluded that activities to be authorized by the renewed license, subject to the additional conditions developed by the staff, will not constitute an undue risk to the health and safety of the public or the environment.
Subject to the above conditions, it is recommended that the license be renewed for a 5 year period.
Original Signed Bv ?
A. L. Soong Uranium Fuel Section Fuel Cycle Safety Branch Division of Fuel Cycic, Medical, Original Signed By f Approved by: ,
George H. Bidinger Uranium Fuel Section A _
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________ ______ p___:_FCUg__________:_FCUF 4 ___ 9g_f3_ _ _ _ _ _:
NAME: ALSoong:ht:GlaRoche :VLTharpe :GHBidinger :
DATE:05AP/87 :05//1/87 :05/ /87 :05/S/87 :
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