ML20217K996
| ML20217K996 | |
| Person / Time | |
|---|---|
| Issue date: | 08/12/1997 |
| From: | Bahadur S NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217L002 | List: |
| References | |
| FRN-56FR67011, RULE-PR-31, RULE-PR-32 AD34-1-046, AD34-1-46, SECY-87-167-C, SECY-91-275-C, NUDOCS 9708190005 | |
| Download: ML20217K996 (7) | |
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UNITED STATES I
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j NUCLEAR REGULATORY COMMISSION
' WASHINGTON, D.C. 30N64001
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August 12,1997 l
MEMDRANDUM T0:
Nuclear Documerit-System (NUDOCS)
~
l Mail Stop - OWFN P1-17 FROM:
Sher Bahadur, Acting Chief-I Regulation Development Branch Division of Regulatory Applications l
Office of Nuclear Regulatory Research
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SUBJECT:
REGULATORY HISTORY <INDEX FOR 10 CFR PARTS 31 AND 32 l
h Enclosed are the appropriate documents that comprise the Regulatory History for the proposed rule, entitled " Requirements for the Possession of Industrial Devices Containing Byproduct Material." This rule proposes to amend the NRC's regulations governing the safe use of byproduct material in certain measuring, i
gauging, or controlling devices. The proposed rule was published in the Federal Register at the end of December, 1991 (56 FR 67011).
A regulatory history index was not completed at that time. Since the final rule has been kept on hold for over three years, the Rules and Directives Branch of the Office of Administration has requested that the regulatory history for the proposed rule be ' completed and forwarded to NUDOCS.
The documents that comprise this regulatory history should be returned when you are finished.
Please provide me with two copies of the Regulatory History Index printout when it is completed.
If you have any questions or if we can be of further assistance. please call Joseph J. Mate at 415-6202.
Enclosures:
1.
Regulatory History Index 2.
Regulatory History Documents O\\
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81 005 970812 U
31 56FR67011 PDR
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L.1 i
REGULATORY HISTORY INDEX 1;
Memorandum from Hugh L. Thompson, Jr., Director. Office OF Nuclear
- Material Safety and Safeguards to Er_ic S. Beckjord Director, Office of Nuclear Renulatory Research dated July 6, 1988 and subject, USER NEED REQUEST FOR RULEMAKING ON CERTAIN GENERAL LICENSES.
2.
Memorandum from Richard E. Cunningham, Director Division of Industrial
- and Medical Nuclear-Safety, NMSS to Bill M. Morris, Director, Division
_of Regulatory Applications, RES dated October 31. 1988 and subject, 1 RACKING 0F DEVICES CONTAINING BYPRODUCT MATERIAL.
4 3.
Memorandum from Bill M. Morris-Director. Division of Regulatory Applications, RES to Richard E. Cunningham, Director Division of Industrial and_ Medical Nuclear Safety, NMSS dated January 1989 and
. subject; USER NEED REQUEST - RULEMAKING ON GENERAL LICENSES.
4.
Menorandum from Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards to Eric S. Beckjord, Director, Office-of Nuclear Regulatory Research dated February 27, 1989 and subject. REQUEST FOR RULEMAKING 10 CFR 31.5. TRACKING OF DEVICES CONTAINING BYPRODUCT MATERIAL.
6.-
Memorandum from Eric S. Beckjord, Director, Office of Nuclear Regulatory Research to Victor Stello, Jr.. Executive Director for Operations dated May 4, 1989 and subject, INITIATION OF RULEMAKING--REQUIREMENTS FOR THE POSSESSION OF INDUSTRIAL DEVICES (10 CFP 31).
6.-
_ Memorandum from Victor Stello, Jr.. Executive Director for Operations to Eric S. Beckjord. Director, Office of Nuclear Regulatory Research dated
-May 26-1989 and subject, INITIATIONS OF RULEMAKING - REQUIREMENTS FOR POSSESSION OF~ INDUSTRIAL DEVICES (10 CFR 31).
7.
-Memorandum from Robert M, Bernero, Director, Office of Nuclear Material
-Safety and Safeguards to Eric S. Beckjord Director. Office of Nuclear Regulatory Research dated July 31, 1989 and-subject. NMSS PRIORITY
' ITEMS, 8;
-Commission Paper from James _M. Taylor. Acting Executive Directs ' for Operations'to the Commissioners dated September 14, 1989 and si ject,
_ STAFF INITIATIVES-ON THE GENERAL LICENSE PROGRAM.
-~
9.-
Commission Paper from Victor Stello Jr., Executive Director for Operations to the Commissioners dated July. 9,1987 and subject, RESULTS 0F THE GENERAL LICENSE STUDY AND CORRECTIVE MEASURES TAKEN OR PLANNED BY I
THE STAFF.
10.
Memorandum from Bill M. Morris, Director Division of Regulatory Applications. Office of Nuclear Regulatory Research to Richard E.
Cunningham, Director, Division of Industrial and Medical Nuclear Safety.
Office of Nuclear Material Safety and Safeguards, Carlton C. Kammerer, Director of State, Local and Indian Tribe Programs Office of Governmental and Public Affairs, Donnie H. Grimsley, Director, Division of Freedom SOF Information and Publications Services. Office of Administration, and Stuart A. Treby, Assistant General counsel for rulemaking and Fuel Cycle. Office of the General Counsel dated January 29, 1990 and subject, PROPOSED RULEMAKING - TRACKING 0F DEVICES CONTAINING BYPRODUCT MATERIAL, 10 CFR PARTS 31 SAND 32.
11.
Memorandum from Donnie H. Grimsley, Director, Division of Freedom of Information and Publications Services, Office of Administration to Bill M. Morris, Director, Division of Regulatory Applications Office of Nuclear Regulatory Research dated February 2, 1990 and subject.
REQUIREMENTS FOR THE POSSESSION OF INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATERIAL.
12.
Memorandum from Carlton Kammerer. Dire"or State Programs to Bill M.
Morris, Director Division of Regulatory Applications, RES dated February 6, 1990 and subject, PROPOSED RULEMAKING - TRACKING OF DEVICES CONTAINING BYPRODUCT MATERIAL, 10 CFR PARTS 31 AND 32.
13, Memorandum from Brenda Jo Shelton, Chief. Information and Records Management Branch, Division of Information Support Services, Office of Information Resources Management to Day 1d L. Meyer, Chief, Regulatory Publications Branch, Division of Freedom of Information and Publication Services, Office of Administration dated February 7,1990 and subject.
REQUEST FOR COMMENT AND CONCURRENCE ON PROPOSED RULE, 10 CFR PARTS 31 AND 32. " TRACKING OF DEVICES CONTAINING BYPRODUCT MATERIAL."
14.
Memorandum from Richard E. Cunningham, Director, Division of Industrial and Medical Nuclear Safety, NMSS to Bill M. Morris. Director. Division of Regulatory Applications RES dated February 9, 1990 and subject.
PROPOSED RULEMAKING - TRACKING 0F DEVICES CONTAINING BYPRODUCT MATERIAL, 10 CFR PARTS 31 AND ?J.
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i 15.
Note from Dorothy Michaels. Office of General Counsel to Joseph J. Mate.
Office of Nuclear' Regulatory Research dated February 9.1990 and subject. PROPOSED RULEMAKING - TRACKING OF DEVICES CONTAINING BYPRODUCT MATERIAL. 10 CFR PARTS 31 AND 32.
16.
Note from Joe Mate. RES to Steve Baggett. NMSS dated March 9, 1990 and E
subject. RESPONSES FROM AGREEMENT STATES.
17.
Letter from Philip H. Kier. Argonne National Laboratory to= Joseph J.
Mate. Office of Nuclear Regulatory Research dated March 9,1990 and subject. ENCLOSED REVISED REGULATORY ANALYSIS.
4 18.
Note from Joe Mate. RES to Steve Baggett. NMSS dated March 1.4. 1990 and subject. ADDITIONAL AGREEMENT STATE RESPONSES FROM GPA.
19.
Memorandum from Eric S. Beckjord. Director. Office of Nuclear Regulatory Research, to Robert M. Bernero. Director. Office of Nuclear Material Safety and Safeguards, Harold R. Denton. Director Office of Government and Public Affairs. William C. Parler. General Counsel, and Patricia G.
Norry. Director Office of Administration dated March 14. 1990 and subject. PROPOSED RULEMAKING FOR POSSESSION OF INDUSTRIAL DEVICES -
10 CFR PARTS 31 AND 32.
20.
Note from Joe Mate. RES to Steve Bagoett NMSS dated March 19. 1990 and subject. NOTE TENESSEE'S COMMENTS.
21.
Memorandum from Harold R. Denton Director. Office of Governmental and Public Affairs to Eric S. Beckjord. Director Office of Nuclear Regulatory Research dated March 22, 1990 and subject. PROPOSED RULEMAKING FOR POSSESSION OF INDUSTRIAL DEVICES - 10 CFR PARTS 31 AND 32.
22.
Memorandum from Patricia G. Norry, Director. Office of Administration to Eric S. Beckjord. Director. Office of Nuclear Regulatory Research dated March 23, 1990 and subject. REQUIREMENTS FOR THE POSSESSION OF INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATERIAL.
23.
Memorandum from Robert M. Bernero. Director. Office of Nuclear Material Safety and Safeguards to Eric S. Beckjord. Director. Office of Nuclear Regulatory Research dated March 30, 1990 and subject. PROPOSED RULEMAKING FOR POSSESSION OF INDUSTRIAL REVIEW - 10 CFR PARTS 31 AND 32 3
24.
Note from Dorothy Michaels, Of fice of General Counsel to Joseph J. Mate.
Office of Nuclear Regulatory Research dated April 11, 1990 and subject PROPOSED RULEMAKING FOR POSSESSION OF INDUSTRIAL DEVICES - 10 CFR PARTS 31 AND 32.
25.
Note from Joseph J. Mate. Office of Nuclear Regulatory Research to Dorothy Michaels, Office of General Counsel and Steve Baggett, Office of Nuclear Material Safety and Safeguards dated April 23, 1990 and subject, FINAL REVIEW OF 10 CFR PARTS 31 AND 32.
26.
Letter from Philip Kier Environmental Assessments and Information Sciences Divisions, Argonne National Laboratory to Joseph J. Mate.
Office of Nuclear Regulatory Reseach dated April 23, 1990 and subject.
REVISION OF DRAFT REGULATORY ANALYSIS FOR REQUIREMENTS FOR POSSESSION OF DEVICES CONTAINING BYPRODUCT MATERIAL.
27.
Memorandum from Robert M. Bernero, Director. Office of Nuclear Material Safety and Safeguards to Eric S. Beckjord. Director. Office of Nuclear Regulatory Research dated May 21, 1990 and subject, PROPOSED RULEMAKING FOR POSSESSIONS OF INDUSTRIAL DEVICES - 10 CFR PARTS 31 AND 32.
28.
Note from Joseph J. Mate. Office of Nuclear Regulatory Research to George Pangburn, Office of the Executive Director for Operations dated June 1, 1990 tranemitting the Commission Paper on Parts 31 and 32.
29.
Memorandum from Sher Jahadur Regulations Development Branch. Division of Regulatory Applications. Office of Nuclear Regulatory Research to Brenda Jo Shelton Chief. Records and Reports Management Branch.
Division of Information Support Services. Office of Information Resources Managemeri. dated June 21, 1990 and subject. OMB CLEARANCE SUBMITTAL FOR THE PROPOSED RULE ENTITLED REQUIREMENTS FOR THE POSSESSION OF INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATERIAL" --
10 CFR PARTS 31 AND 32.
30.
Note from George Pangburn, Office of the Executive Director for Operations to Joseph J. Mate. Office of Nuclear Regulatory Research, dated August 3,1990 and transmitting the ED0's Office Comments.
31.
Note from Sher Bahadur Chief of the Regulation Development Branch, Office of Nuclear Regulatory Research to John E. Glenn. Chief of the Medical and Commercial Use Safety Branch. Nuclear Material Safety and Safeguards dated February 28, 1991 and subject. PROPOSED RULEMAKING PACKAGE ON 10 CFR PART 31.
4
m 32, Note from' Joe Mate, RES to Beth St. Mary, IRM dated April 23. 1991 and subject, ADDITIONAL REQUESTED CHANGES.
33.
-Note from Sher Bahadur, RES to George Pangburn and Ronald Scroggins dated July 8, 1991 and subject FINAL COPY OF THE PART 31 RULEMAKING PACKAGE OF INDUSTRIAL DEVICES.
34, Note from Joe Mate, RES to Beth St. Mary IRM dated July 22, 1991 and subject REVISED SUPPORTING STATEMENT AND FRN PACKAGE.
i 35, Commission Paper from James M. Taylor Executive Director for Operations to the Commissioners dated August 27, 1991 and subject, PROPOSED AMENDMENTS TO 10 CFR PART 31,
- GENERAL DOMESTIC LICENSES FOR BYPRODUCT t
MATERIAL. ' and 10 CFR PART 32. " SPECIFIC DOMESTIC LICENSES TO MANUFACTURE OR TRANSFER CERTAIN ITEMS CONTAINING BYPRODUCT MATERIAL.'
- 36.
Memorandum from David L. Meyer, Chief Regulatory Publications Branch, Y
Division of Freedom of-Information and Publications Services Branch.
Office of Administration to Joseph J. Mate, Regulatory Development Branch. Office of Nuclear Regulatory Research dated September 9.1991 and subject REVIEW 0F SECY-91-275 " PROPOSED RULE ON REQUIREMENTS FOR THE POSSESSION SOF INDUSTRIAL DEVICES CONTAINING BYPRODUCT MATERIAL."
37.
Memorandum from James R. Curtiss, Commissioner. US NRC to James M.
Taylor. Executive Director for Operations dated October 4. 1991 and subject, PROPOSED AMENDMENTS TO 10 CFR PART 31, ' GENERAL DOMESTIC LICENSES FOR BYPRODUCT MATERIAL," AND 10 CFR PART 32. ' SPECIFIC DOMESTIC LICENSES TO MANUFACTURE OR TRANSFER CERTAIN ITEMS CONTAINING BYPRODUCT MATERIAL" (SECY-91-275),
38.
Notice of Budget Action from the Office of Management and Budget to Brenda Jo =Shelton, NRC Clearance Officer, U-S. Nuclear Regulatory Commission, Washington DC 20555 dated October 10. 1991 and subject.
APPROVAL OF INFORMATION COLLECTION.
39.-
Memorandum from Robert M. Bernero. Director, Office of Nuclear Material Safety and Safeguards to Eric S. Beckjord, Director, Office of Nuclear Regulatory Research dated October 21. 1991 and subject. CONCURRENCE OF MEMORANDUM-T0 COMMISSIONER CURTISS.
40.
Memorandum from James M. Taylor, Executive Director for Operations to Comissioner Curtiss dated October 28, 1991 and subject. PROPOSED AMENDMENTS TO 10 CFR PART 31, " GENERAL DOMESTIC LICENSES FOR BYPRODUCT 5
_ _ _ _ - _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - - _ _ _ _ - _ _ _ _ ~
MATERIAL, " AND 10 CFR PART 32, " SPECIFIC DOMESTIC LICENSES TO MANUFACTURE-OR TRANSFER CERTAIN ITEMS CONTAINING BYPRODUCT MATERIAL (SECY-91-275).
41, Memorandum from Samuel J. Chilk. Secretary to James M. Taylor. Executive Director for Operations, dated November 29, 1991 and subject.
-SECY-91-275 - PROPOSED AMENDMENTS TO 10 CFR PART 31. " GENERAL DOMESTIC LICENSES FOR BYPRODUCT MATERIAL, " AND 10 CFR PART 32, ' SPECIFIC D0:1ESTIC LICENSES TO MANUFACTURE OR TRANSFER CERTAIN ITEMS CONTAINING BYPRODUCT MATERIAL."
42.
Note from Sher Bahadur, Chief. Regulation Development Branch. DRA/RES to Margo Bridgers. Chief, Administration and Corrections Branch, EDO dated December 6, 1991 and subject, SIGNATURE ON FEDERAL REGISTER NOTICE.
43.
Memorandum from Sher Bahadur, Chief. Regulation Development Branch.
Division of Regulatory Applications. Office of Nuclear Regulatory Research to David L. Meyer, Chief, Regulatory Publications Branch, Division of Freedom of Information and Publicatitm, ranch, Office of i
Administration dated December 18, 1991 and subject, eUBLICATION OF FEDERAL REGISTER NOTICE.
44.
Copy of the Federal Register Notice (56 FR 67011) dated Friday, December 27, 1991.
6
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i ACTiDN Ticket s
DATE RECEIVED: 07/11/88 ORIGINAL DUE DT:
CONTROL NO: 8800299 REVISED DUE DT:
DOC DT: 07/08/88 FROM:
TIME:
COMP DT:
HUGH L. THOMPSON, JR.
NMSS TO:
p ERIC S.
BECKJORD
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ASSIGNED TO:
CONTACT:
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USER NEED REQUEST FOR RULEMAKING ON CERTAIN BECKJORD, W/0 ENCL, GENERAL LICENSES (NMSS 88-1)
ROSS SPEIS SPECIAL INSTRUCTIONS OR REMARKS:
ROSZTOCZY BURDA SLATER S.
DURAISWAMY, ACRS" FILE (O&M-ACRS)
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$K.06'980 k D 3 ll - l MEMORANDUM FOR Eric'S. Beckjord, Director
)DR Office of Nuclear Regulatory Research FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety dnd Safeguards l
1
SUBJECT:
USER NEED REQUEST FOR RULEMAKING ON CERTAIN GENERAL LICENSES This is to request that you initiate a rulemaking that would assist in ensuring that devices used under certain general license provisions of 10 CFR Part 31, are adequately maintained, pro)erly transferred, and not inadvertently discarded. This action has a ligh priority because of the potential radiation exposure and expense associated with poorly maintained devices and uncontrolled disposal of radioactive material.
General licenses were established to pemit possession and use of byproduct material without filing an application, thus eliminating a large number of repetitive licensing actions. General licensees who possess devices such as exit signs, industrial gauges, analytical equipment, and many other items l
are subject toathe requirements specified in Section 31.5 of 10 CFR Part 31.
During the past several years there have been almost no inspections of general As a result, until recently there was little or no data on whether licensees.
the current general license mechanism is an effective means of assuring the public health and safety.
In March 1983. HMSS began a two-phase study of several kinds of general licenses to determine adequacy of control and the effectiveness of the radiation protection of workers and the general public.
The subject of Phase 1 of the study was industrial gauges such as level and thickness gauges. The study indicated that the requirements of Section 31.5 were not being adhered to in all cases and that some gauges could not be located. As a result, a requirement for rulemaking was initiated on August 21
-1985, and the RES Director recommended ED0 approval on March 6,1986
- However, because Phase II of the study, covering devices other than gauges, indicated similar problems, the rulemaking for gauges was suspended until Phase II of the study could be completed in order to avoid duplication of a rulemaking effort. describes the scope of the various types of devices and the approximate numbers of devices involved in both phases of the study. The i
primary purpose of this rulemaking is to reduce the chance that general licensees will lose accountability and improperly dispose of the device.
/
Alw229a?L 77Wp
Eric S. Beckjord The scrap metal industry is helping with the problem by teaching recycling companies how to identify potential sources of contamination, but the staff does not believe this voluntary effort is sufficient. An increased NRC field inspection program would not be an efficient use of staff resources.
At this time the NHSS staff believes that the best regulatory alternative would be to 1
establish a registration and reporting program. NRC would periodically send a notice to each general licensee who would respond by indicating on the notice that the gauge is still in use, or reporting to whom it has beer, transferred, and then returning the notice to the NRC.
Non-respondents would be contacted s
by telephone and/or field inspection.
The procedural approach to rulemaking that we recommend is a Notice of Proposed Rulemaking with ample opportunities for public comment. While an ANPR before a Notice of Proposed Rulemaking would provide more opportunity for-industry consideration and coment, we believe the need for improved accountability outweighs the advantages. Opportunity for infonnal meetings with various end users, trade associations, and device manufacturers could be cMducted during the comment period to enhance feedback for practical adjustments of the rule.
Enclosed for the use of your staff is further background on the findings of the study.
We are prepared tg work closely with your staff to provide technical assistance and to aid in coordination with OGC and GPA. Mr.StevenBaggett(ext.20542) of the Division of Industrial and Medical Nuclear Safety will be the cognizant individual for NMSS.
b L. Thompson, r.,
ctor e of Nuclea Ma'te Safety d Safeguards
Enclosures:
As stated
. _ _ _ _ _. ~... _
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Ticket s
DATE RECEIVEDs 07/11/88 ORIGINAL DUE DT:
CONTROL NO: 8800299' REVISED DUE DT:
DOC DT: 07/06/88 FROM:
TIME:
COMP DT:
-HUGH L. THOMPSON, JR.
HMSS-TO:
ERIC S. BECKJORD 1
- YEL' **
' ASSIGNED TO:
CONTACT:
B. MORRIS [
kW DRA 6 FOR SIGNATURE OF:
- DESC:
ROUTING:
USER NEED REQUEST FOR RULEMAKING ON CERTAIN BECKJORD, W/O ENCL, GENERAL LICENSES (NHSS'88-1)
ROSS SPEIS SPECIAL INSTRUCTIONS OR REMARKS:
-ROSZTOCZY BURDA SLATER S. DURAISWAMY,-ACRS" FILE (O&M-ACRS)
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Enclo';uro 1 I
04/21/87 ESTIMATED NUMBER OF GENERALLY LICENSED DEVICES AND MATERIALS #
CFR DEVICE TYPE ISOTOPE NUMBER OF TOTAL SEC.
AND DEVICES NUMBER ACTIVITY SOLD OF PER YEAR DEVICES 31.3 STATIC ELIMINATOR H-3 (50 mC1) 7000 20000*
Po-210 (500 uCi) 31.5 AEROSOL NEUTRALIZER Kr-85 (10 mC1) 120 9600 31.5 BETA BACKSCATTER Pm-147 (900 uCi) 800 7000 GAUGE T1-204 (45uC1)
Sr-90 (5 uCi)
Cs-137 (30 uC1) 31.5 ELECTRON CAPTURE Ni-63 (15 mci) 900 8000 DETECTOR 31.5 ELECTROSTATIC Ni-63 (10 uCi) 890 3000 VOLTMETER 31.5 FILL LEVE8 GAUGE Am-241 (100 mci) 600 4200 31.5 FUEL DENSITOMETER Am-241 (50 mC1) 200 945 EMITTER 31.5 GAUGING DEVICES Am-241 (.5-1 G) 337 16000 (PART I)
Co-60 (.5-1 Cl)
Cs-137 (.5-1.5 C*r)
Kr-85 (.5-1.2 C)
Sr-90 (.5-103 31.5 IN FLIGHT BLADE Sr-90 (500 uC1) 200 1000 INSPECTION SYSTEMS 31.5 LIQUID SCINTILLATION Cs-137 (40 uCi) 600 7000 SPECTROMETERS I-129 (140 nCi)
Ni-63 (10 mci) 31.5 EELF-LUMINOUS EXIT H-3 (25 C1) 20000 180000**
SIGNS 31.5 STATIC H-3 (200 uCi) 80000 160000*
ELIMINATORS / METERS Po-210 (167 mC1) 31.5 X-RAY FLOURESCENCE Fe-55 (30 mC1) 90 720 SPECTROMETER Cd-109 (3 mC1)
Am-241 (10 mci)
Cm-244 (30 mC1)
04/21/87 ESTIMATED NUMBER OF GENERALLY LICENSED DEVICES
-AND'HATERIALS #
CFR.
DEVICE TYPE ISOTOPE
' NUMBER OF TOTAL SEC.
=AND DEVICES NUMBER-ACTIVITY SOLD OF-PER YEAR DEVICES 31.7 SELF-LUMINOUS H-3 (10 C1) 7600 80000**
AIRCRAFT SIGNS Pm-147 (300 mci)~
~~
31.8 CALIBRATION OR Am-241'(.005 uC1) 60 480 REFERENCE SOURCES 40.22 SOURCE MATERIAL DU 140lb 2000lb (DEPLETED URANIUM) 1' Numbers represent transfers of devices and materials as
/bportea to the NRC in non-agreement state quarterly reports.
Approximately 60% of the devices were transfered to non-agreement states.
The rest went to agreement states.
The total numbers of devices nationwide may be higher because agreement state licensees are not required to submit quarterly reports to the NRC.
Represents the number of static eliminators sold in the last 3 years, which is the useful life of static eliminators.
They are then thrown away or replaced.
Represents the number of signs sold in the past 10 years, which is the useful life of exit signs.
(
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I dnclosure 2 General License study Report e
ABSTRACT A study conducted by tFa Nuclear Regulatory Commission (NRC) in 1984, 1985, and 1986 revealed several areas of safety concern about the use under general license of radioactive material and devices containing radioactive material.
Inadequate
_ accountability of these devices and users' frequent lack of awareness of regula-l tions were found.
Currenuf,' co aid in accountability, the NRC authorizes com-mercial distribution of these devices only by specifically licensed manufacturers and distributors (vendors).
The vendors submit periodic reports of transfers.
The accountability _ problem-appears to be caused by inaccurate reports and unauthorized subsequent transfers.
An example of improper subsequent transfer is the redistribution of self-luminous signs by electrical retailers who are not specifPally licensed and do not report sales of the signs to the NRC.
Users of these devices frequently are unaware of the regulations concerning transfers, disposal, and recordkeeping.
Thus these devices are susceptible to loss, improper transfers, and improper disposal.
4 As corrective action, the study recommends several changes in the current regulatory program for generally licensed use.
0,ne,recor,mendation is to
(.
encourage vendors to more effectively communicate with their customers about
\\
regulatory requiremeats.
This could increase awareness of and complianci with the requirements.
Another_ recommendation is a computerized nationwide registry whip would_ track all devices and users of the device.s.
The registry would enable the NRC to send periodic information notices to the users.
This should help alleviate the accountability problems and would remind users of their regulatory responsibilities.
Other recommendations include (1) standardizing reports of transfers from the vendors to facilitate complete and accurate periodic reporting, and (2) advising the industry to modify current distribution practices for self-luminous exit signs.
The goal of these and other suggestions is to remedy present radiation safety related inadequacies in order to ensure that the general license program can effectively protect the public health and safety.
iii
TABLE OF CONTENTS Ea2' '
ABSTRACT.............................................................-
111-ACKWOWLLDGEMENTS.....................................................
1 INTRODUCTION......................................................
1
'1.1 Furpose......................................................
7 1.2 Background...................................................
1 1.3 Data Sources.................................................
3 1.4 Limitations..................................................
4:
1.5 Scope.......................................................
4 21 THE GENERAL LICENSE...............................................
5 3 SECTION 31.3:
STATIC ELIMINATORS, ION GENERATORS.................
5 4 SECTION 31.5:
CERTAIN MEASURING, GAUGING, OR CONTROLLING DEVICES..............................
6-4.1 'Section 31.5, Part 1: Background.............................
7 4.2 Section 31.5, Part 1: Findings...............................
9 4.2.1 Awareness of Regulations and Accountability........................................
9 4.2.2 Compliance With Transfers and Di sposal Regul ations..................................
9 4.2.3 Compliance With Leak Test and Maintenance Regulations...........................
10 4.3 Regional Findings of Part 1 Surveys..........................
11 4.4 Agreement State Findings.....................................
11 4.4.1 Background............................................
11 4.4.2. Incident Reports......................................
11 4.4.3 Agreement State Surveys and-Inspections...............
'12
-4.4.4 General Conclusions and Recommendations................
12 4.5 -Section 31.5, Part 2: Background.....:.......................
13
'4. 6 Section 31.5, Part 2: Findings...............................
.13
>4.6.1 ^Self Luminous Exit Signs..............................
13
- 4. 6.1.1 Description..................................
13 4.6.1.2 Awareness of Regulations and Accountability................................
13 v'
TABLE OF CONTENTS (Continued)
Pa2_e 1
4.6.1.3 Compliance'with Leak Tests and Maintenance Regulations.......................-
14
-4.6.1.4 Loss or Damage...............................
14-
- 4. 6.1. 5 Labeling.....................................
14
'4.6.1.6 Vendor Reporting.............................
14 4.6.1.7 Compliance with Transfer and Disposal Regulations..........................
15 4.6.2 Beta Backscatter Gauges...............................
16 4.6.2.1 Description..................................
16 4.6.2.2 Awareness of Regulations and
-Accountability................................
16 4.6.2.3 Compliance with Transfer and Disposal Regulations.........................
17 4.6.2.4 Compliance with Leak Tests and Maintenance Regulations.'......................
17 4.6.2.5 Damage.......................................
18 4.6.3 Static Elimination Devices............................
18 4.6.3.1 Description..................................
18 4.6.3.2 Awareness of Regulations and Accountability..........................-......
18 4.6.3.4 Compliance with Transfer and Disposal Regulations..........................
20 4.6.3.5 Compliance with Leak Tests and i
Maintenance Regulations.......................
20 4.6.4 Electron Capture Detectors and Liquid Scintillation Spectrometers...........................
20 4.6.5 X-Ray Fluorescence Spectrometers......................
21 4.7 Comparison of Telephone and Site Surveys 4
With Regional Findings.......................................
21 4.8 General Conclusions and Recommendations for Part II Findings..................
22 4
4.8.1 Awareness of Regulations.............................
22 4.8.2 Reporting.............................................
22 4.8.3 Labeling..............................................
22 4.8.4 Redistribution........................................
23 4.8.5 Recordkeeping.........................................
23 4
vi
TABLE OF CONTENTS (Continued)
P.,a!Le 5 SECTION,31.7:
LUMINOUS SAFETY DEVICES FOR USE IN AIRCRAFT........................................
23 5.1 Description / Background.......................................
23 542 Findings.....................................................
25 5.3 Conclusions / Recommendations..................................
25 6 SECTION 31.8:
AMERICIUH-241 IN THE FORM OF CALIBRATION OR REFERENCE SOURCES...................
25 7 SECTION 31.10:
GENERAL LICENSE FOR STRONTIUM-90 ICE DETECTION DEVICES............................
26 8 SECTION 40.22:
SMALL QUANTITIES OF SOURCE MATERIAL...............
26 8.1 Description / Background.......................................
26 8.2 Findings....................................................
27 -
8.3 Conclusions / Recommendations..................................
28 9 SECTION 40.25:
GENERAL LICENSE FOR USE OF CERTAIN INDUSTRIAL PRODUCTS OR aFNICES....................
28 a
10 SECTION 70.19:
GENERAL LICENSE FOR CALIBRATION OR REFERENCE SOURCE.................................
20 11 OVERALL CONCLUSIONS AND RECOMMENDATIONS..........................
29 APPENDICES A
_ Examples of Survey Questionnaires and Guidance for Collection.....
35 8
Outline of General License Regulations...........................
41 C
Samples cf Gauge Literature.......................................
66 0
Agreement State Incidents Involving Generally Licensed Devices....
67 E
Breakdown by Type of Active Specific Distribution License for
- NRC and Agreement States..........................................
75 F
NRC Form 244 (10 CFR 40.25.......................................
97 G
General License Study Analysis of Hazard..........................
98 H
Comparison to Specific Licensees..........r.......................
112 I
Information Notices Sent to General License Users and Vendors.....
114 J
Photographs.......................................................
115 K
Model Licenses Authorizing Distribution and Redistribution af Products to General Licensees..................................
116 gdb-L Industry Environment..............................................
117 M
Procedures to Handle 31.5 and 32.51 Reporting Requirement Report..
120 i
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vii
1 INTRODUCTION 1.1 Purpose A general license study was initiated by the Office of Nuclear Materials Safety and Safeguards (NMSS) of the Nuclear Regulatory Commission (NRC) in 1984 to, determine whe_ther NRC_has_a. problem _with_generalJfcensed usen and, if._fo, its A en.
This paper summarizes the findings of the study and offers some eg recommendations on improving the program.
- 1. 2 Background The NRC and the Agreement States regulate the distribution and use of all products within the United States that contain typroduct material.
The NRC classifies the regulatory control of byproduct material into one of three categories:
specific license, general license, or exempt om regulations.
The classification depends on the type, quantity, and use of the material.
4 Specific licenies are issued to persons who have filed an application demon-strating that their training, experience, equipment and facilities are adequate to perform the requested task and meet the NRC public health and safety protection requirements.
There are many products containing radioactive material that can be used by the general public and industry without extensive radiation safety programs. These products contain relatively small amounts of radioactive materials that are sealed within the device (sealed source) so that they can be used by persons M thout radiological training.
These products containing byproduct material, along with small amounts of source material, fall under the category of general licenses. General licenses are in effect for persons usino certain radinactive materials wit.hout the filing of an application with the Commission.
Devices used under the general licenses must be manufactured and distributed under a specific license. The specific license may be issued by the NRC or by_
A0_ Agreement State.
The radiation safety of the device design is evaluated against regulatory' requirements prior to being listed on a specific license authorizing distribution to general licensees.
1
4 Those who obtain devices under the general license are listed in the manufac-turers' quarterly reports of transfer to the NRC.
Agreement State distributors have similai' reportirg requirer..ents in that they are required to notify the NRC when they sell generally licensed devices in areas under NRC jurisdiction.
dl The Atomic Energy Commission (AEC), fromathe NRC was formed in 1975, was set up in part to control the distribution and use of radioactive materials.
Persons wishing to use radioactive materials had to apply for a specific license.
To make radioactive materials for medical and educational use more accessible, the AEC issued an exemption to its specific license requirements in 1951.
This exemption was considered too lax, so in 1953, the AEC placed conditions on the ex6mption, such as restrictions regarding the administration of radioactive materials to humans.
As technology progressed, industrial applications for radio &ctive material were developed, such as static eliminating devices. Static eliminators containing less than 300 microcuries of Polonium-210 were added to the conditional ewmp-tion in 1954.
gsmoreindustrialusesforradioactivematerialsweredeveloped, the AEC decided to create a separate general license to regulate devices which were of low hazard, but of sufficient hazard such that an exemption is not applicable.
"1he devices under consideration herein are constructed with inherent radiation protection features and may be used safely by untrained persons, provided that they are adequately labeled, used in the manner for which they were intended, and repaired and serviced by trained personnel.
It is therefore considered unnecessary to require the users of the gauges to obtain a specific license, as required by our present regulations."
'Because of the use of these products by the industry and public, the NRC was faced with the problem of regulating the use of these relatively safe products without imposing burdensome and expensive licensing requirements on the general licensee.
A general license policy was iraplemented as a means of simplifying the specific license process where a case-by-case determination of the adequacy of qualifi-cation ir not necessary.
A generally licensed device is a " black box,"
i.e.,
2
i the radioactive material is contained in a sealed source within a shielded device.
The device is designed with inherent radiation safety features so that it can be used by persons without any radiation training or experience.
Due to the relatively small radiation risk of generally licensed devices compared to the risk of other specifically licensed installations, the limited manpower available to perform inspections, and the absence of contact by other
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regulatory groups, general licensees have been infrequently contacted.
Several occurrences involving industrial gauges being dismantled and melted with scrap steel or simply being lost during in plant changes stimulated the NRC's interest in reviewing the effectiveness of the general license.
In 1982, the NRC's Office of Research (RES) agreed to conduct a General License Study under NHSS guidance.
An HMSS task force was established in March 1983 and approved in June 1983.
Subsequent to the task approval, RES informed HMSS that it could not perform the task because of higher priorities and lack of resources.
Thegefore, HMSS decided to complete the study, f
This report covers the general license study and the supplemental work done by the NMSS task forces, NRC Regional Offices, and the Agreement States.
1.3 Data Sources The sources use_d for this report were telephone and site surveys from the task force, all five NRC Regional Offices, and the Agreement States Texamples of questionnaires can be found in Appendix A).
The identification of general.
licensees was primarily through the use of quarterly reports of transfers sited by the specifically licensed manufacturers or distributors.
The manufacturers and distributors were particularly helpful by supplying current contacts (name and address), where possible, needed for the general license study.
1.4 Limitations The numerical accuracy of the results of the General License Study may be affected by the following f actors:
3
- Budget and time contraints accounted for small sample groups for both
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telephone and site surveys.
- Some vendors failed to give accurate contacts (names, addresses, 7
departments etc.).
" ~ '
- Site visits were concentrated to certain areas with large and diverse concentrations of general licensees in order to be cost-effective.
- Some end users were out of business and left no forwarding address.
- Some vendors were out of business and records of transfer were destroyed.
These factors affect the securacy of statistic analysihHowever,thefindings he survey clearly reflect the overall problamlFeas of the general license program and express possible concerns for the public health and safety.
4 1.5 Scope This report summarizes the following:
1.
History of the general license regulations.
2.
Description of the general license program.
3.
Background of study.
4.
Findings of the study with respect to the general licenses authorized in:
A.
10 CFR 31.3 B.
10 CFR 31.5 C.
-10 CFR 31.7 D.
10 CFR 31.8 E.
10 CFR 31.10 F.
10 CFR 40.22 G.
10 CFR 40.25 H.
10 CFR 70.19 5..
'Overall general conclusion / recommendations.
4
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u i
'2fTHE[GENERALLICENSE 1
.Besides specific licenses, the NRC regulates the distribution of. radioactive p
matericis under about 17 generel licenses.
Seven general licenses allow-the licensee'to transport, store, or install _the radioactive material, but not to l
use it._-The other 10 general licenses allow the licensee to use the devices or materials.- The regulations allowing use of material under^eight gi5dal e -
licenses are the subject of this study.
Since the licenses vary greatly in their scope and requirements, they are being studied and presented individually.
An outline of the general license regulations ia listed in Appendix B. _ Appen-dix 8 also contains a list of the types of devices that may be distributed per the' regulations.-
F, 3 'SECTION 31.3:
STATIC ELIMINATORS, ION GE.1ERATORS l-N.54 Section 31.3a gulates the use of static-e nating devices containing less L
than 500 microcuries of polonium-210 and ion-generating devices containing less than 500 microceries of polonium-210 or 50 mil 11 curies of hydrogen-3.
(Static eliminators are also covered under section 31.5.
These are primarily for industrial use.) The static eliminators covered under section 31.3 are used primarily by the general public.
These devices are fine-bristled brushes that contain polonium-210 elements which emit positively cNrged alpha particles.
The alpha particles neutralize ' static _ electricity c:enonconductive surfaces prone to static buildup.- This. facilitates the removal of dirt and dust-particles-from the surface.
The brushes have two major applications.
Photographers use-them to remove dust buildup from lenses, film, and other photographic equipment.
The brushes are also popular among high fidelity audio enthusiasts, who use them to remove dust and static buildup on record albums.
Section 31.3 requires the manufacturer of these devices to have a manufacturing license (issued only oy the.NRC), but-the devices may be redistributed by retailers l
such as audio-and photographic 1 stores without a specific license.
The general licensees covered _under section 31.3 differ,from those covered under section 31.5 in-that the general licensees under 31.3 have no leak test,. transfer, disposal or maintenance restrictions placed on them.
See Appendix B-1 for an outline of L
the general license regulations.
5-
. ~. -. -. _ -. -. -
?:
Presently, only one company is licensed by NRC to manufacture this type of static eliminator.- - This company sells two models, one containing 200 microcuries of polonium-210, and the other containing 500 microcuries.
The 200 microcurie brushes are_usually used by the audio' enthusiasts, while the 500 microcurie brushes are used by photographers.
The manufacturer estimates that it has sold about 100,000 of the 500 microcurie brushes and about 500,000 of the 200 micro-curie brushes since 1980 at a rate of about 7,000'per year.' 'Due to t;.* short half-life of polonium-210 (138 days), these brushes usually have an effective life of about one year.
The manufacturer states in the instruction book _that the devices should be returned to the manufacturer for disposal.
The manu-
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facturer, however, reports that only about 25% of the brushes are returned.
The rest are either kept as dust brushes or thrown away.
A comprehensive environmental impact study was conducted on these (and other) radioactive consumer products in 1980 (NUREG CR-1775); it was determined that there is minimal radiological health risk involved in-the use or disposal of static eliminating brushes.
However, using the updated numbers of devices sold and return rates, the hazard analysis was reevaluated.
4 l
4 SECTION 31.5:
CERTAIN MEASURING, GAUGING, OR CONTROLLING DEVICES The general license in section 31.5, which has been part of the NRC's (and the AEC's) regulations for over 26 years, covers a wide range of gauges and devices used by industry and the public.
These devices range in cost and complexity from self-luminous signs costing about $150 to thickness monitoring systems costing tens of thousands of dollars.
Because_of the broad scope of the devices covered under section 31.5, the study was divided into two parts.
The first part of the study involved industrial gauging and_ measuring devices, such as large scale level, density, and thickness monitors.. The second part of the study involved self-luminous signs and analytical instruments.such as X-Ray fluorescence spectrometers, liquid scintillation spectrometers, and electron capture detectors.
The second part also included smaller. scale thickness, density, and leyel gauges.
4 6
4.1 Section 31.5, Part 1:
Background
General licensees covered under section 31.5 have several obligations and responsibilities.
General licensees must have the devices leak tested period-ically (usua_1,1y _every six to 36 months) and must keep records of leak tests.
(Devices that contain krypton-85, hydrogen-3, less than 100 microcuries of beta emitting material, or 10 micrccarM cT alpt,a-emitting material are exempt from leak testing.)
The general licensees can only transfer the devices to specific licensees authorized to receive them for repair, replacement, or disposal.
General licensees must also maintain transfer and maintenance records and must raport any losses or damages to the NRC.
Manufacturers and distributors of these devices must have specific licenses to manufacture and distribute these devices, and must submit quarterly reports of sales to the NRC.
They are also required to inform the general licensees of-their obligations in gection 31.5.
See Appendix B-2 for a complete outline of the general license regulations.
As stated earlier, Part One of the study of section 31.5 involved gauges and devices commonly ured by industry.
These gauges can measure the density, weight, or fill level of materials in pipes or containers, and the thickness of products, such as steel, paper, and plastic sheeting.
All the devices work on a similar principal in that each contains a radioactive source that is shielded in all directions except for a small opening which emits a beam of radiation.
The beam passes through the material being measured to a detector.
Some of the radiation is blocked or reflected by the material, depending on how thick or dense the material is.
Denser or thicker matenials tend to block the radiation reaching the detector.
These fluctuations in the amot'nt of radiation passing through the material can be calibrated to measure thickness, density, or weights of the materials.
This information is then used to control manufacturing processes, such as the thickness of steel, paper, or plastic sheeting, or the fluid level of beverage cans and bottles.
A sample of some gauge literature may be found in Appendix C.
7
The first part of the study was initiated in response to several incidents involving industrial and medical devices containing radioactive isotopes.
One such event occurred in 1983 when one or more sources containing a total of 3
17.5 to 34.4 curies of Cobalt-60 were inadvertently melted at a scrap recycling plant in New York.
About 120 tons of steel were contaminated (NUREG-1188).
Immediate discovery or tn# lncident by the plant avoided distribution of the contaminated steel and limited contamination to the plant, but cleanup and disposal costs were estimated at over $2,200,000.
A much more costly and damaging incident occurred in Mexico in 1984 when a se,sp recycling plant melted a 400 curie Cobalt-60 source from a teletherapy unit.
The incident was not discovered until a truck carrying a load of steel bars made from the contaminated steel tripped a radioactive monitor at an exit _
station out of Los Alamos (NUREG-1103).
By the time the incident was discovered, much of the steel had already been distributed throughout the United States in steel bars and restaurant table legs.
It took about eight staff years of effort and about $233,000 to locate and recover the contaminated products in the U.S.
Several persons working in the recycling plant and a few living in the town close to the plant also received abnormally high radiation exposures from the radioactive pellets that were dislodged from the source.
Another event involving a steel plant in South Carolina, occurred in 1984 when a stream of molten steel struck a fill level gauga and melted the 1 curie cesium-137 source. Cleanup and disposal costs were between $400,000 and $500,000.
Since the 1984 study, two other incidents have been reported.
The first involved a steel plant _in California that melted a gauge containing 1.5 curies of cesium-137.
A similar incident in Alabama was-discovered by an aerial radia-tion survey during a search for three missing gauges.
Cleanup for the California incident was estimated at about $1,000,000, while the Alabama incident cost between $50,000 and $500,000.
Although these-incidents were not traced to generally licensed devices, it is highly likely that similar incidents could be caused by such devices.
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.4.2' Section 31.5, Part=1:: Findings
= 4. 2.1' Awareness of Regulations and Accountability-With' the recent contaminations of steal and scrap facilities from radioactive gauges and,other devices, accountability ofl gauges is a primary concern. Of
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6-th: 22' 04t:isurveys conducted by_the 1984 summer study group, 36 general hicenseescouldnotaccountforsomeoralloftheirgauges-(67gaugestotal).-
[
The' regional offices were then asked to investigate the cases of missing; i
igauges.
After their investigations, the regional offices had determined the _
i disposition of all but nine of the 67 original missing gauges.
During their own surveys, the regional _ offices discovered that other licensees could not account for an additional 11 gauges.
Four other general licensees-in Region IV-i could not account for their gauges; the number of_ gauges is unknown.
Whs.; a gauga could not be accounted for, the tssk group or regional offices l
would contact the vendor of the gauge.to see if the gauge (s) had been returned-for repair or cysposal.
Most of the gauges, however, were over eight years old, which made it difficult or impossible to track down these gauges.
The flicensees usually did not have records of transfer for the gauges, and vendors did_not have records of_ disposal or repair of the missing gauges.
While the
-disposition of the gauges could not be determined, it is presumed that they were lost, stolen, improperly disposed of or transferred, or vaturned to the vendors for disposal or_ replacement.
-4.2.2 Compliance With Transfer and' Disposal Regulktions The general licensee is responsible for kesping track of all transfers of their
_ auges and reporting to the NRC to whom the gauges are transferred.
For g
instance, if a licensee sends a gauge back to the vendor for disposal, the
~1icensee must report to the NRC stating that the gauge was' disposed of by the-1 vendor. General licensees are also restricted from-transferring gauges to anyone other than facilities specifically licensed by the NRC to handle and dispose of.
[
radioactive material. The survey revealed that some of the licensees were not-keeping adequate' track of the disposition of their gauges, and others were transferring,the gauges _-to unauthorized persons.- For example, by sale of the
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Of the 185 licensees surveyed that could account for their gauges, 82 (44%) did not notify the NRC of transfers of their gauges.
About 19 (10%) improperly transferred their gauges to persons not specifically licensed to receive the gauges, such as another general licensee.
Ten (2%) licensees changed ownership of the facilities and gauges without notifying the NRC.
Without transfer and change of ownership notifications, the NRC cannot effectively maintain accurate records of the disposition of these gauges.
4.2.3 Compliance With Leak Test and Maintenance Regulations Most of the gauges involved in the survey required radiation leakage tests over six to 36 months, depending on the type of gauge.
The study revealed that 20 (11%) were not performing t h required leak tests and eight (4%) were not main-taining leak test records as required.
Similarly, 22 (12%) were not inspecting the gauge's on/off shielding mechanisms as required.
The general license also requires that the gauges be insta11ad, maintained, and removed by specifically licensed persons.
The study group found that 19 (10%) licensees had their gauges relocated or installed by nonspecifically licensed persons.
In addition, six (3%) were performing their own service and maintenance on their gauges.
Many of the general licensees surveyed had service contracts with the gauge vendors to perform the required service and testing on the gauges.
These contracts help raise the compliance percentages by freeing the general licensee of the burden of regularly scheduling the required service.
The vendors usually contact the licensee when service is due so that a service visit can be scheduled.
Many of the licensees that were violating the general license requirements had discontinued this service due to cost constraints. One problem discovered in the surveys is that the licensees think that having the service contract frees them from all the licensing requirements.
They are unaware that they are responsible for maintenance, service and transfer records on the gauges, as well as reporting to the NRC any transfers of gauges from the facility.
g 4.3 Regiona! Findings of Part 1 Surveys The regional offices conducted 132 inspections of general licensees and found problems of noncompliance similar to those found by the task group.
The 10
l percentages of noncompliance, however, varied slightly from those discovered by the task group.
About 3G (27%) of the general licensees surveyed by the regions were not fully complying with the section 31.5 general license regula-tions.
The largest percentage of violations was for leak testing and shutter testing of the gauges.
Of the licensees surveyed, 29 (22%) were not performing leak or shutter tests every six months or as required.
Other violations include unauthorized transfer of gauges to persons not specifically licensed to receive byproduct material (51), and unauthorized installation or removal, or transfer of gauges by persons not specifically licensed to service the gauges (6%).
Seven licensees (6%) were also not maintaining transfer and leak test records as required.
Four (3%) cases of radioactive labels becoming illegible due to wear, corrosion, or t.trt support the findings of NHSS that labels on the gaugts are becoming unreadable due to the caustic shvironment in which the gauges are used, making the gauges susceptible to improper disposal or transfer.
4.4 Agreement State Findings 4.4.1 Backgroupd Most of the Agreement States, upon request of NHSS, submitted information for the general license study.
Several Agreement States conducted surveys of general licensees in their state, while others sent copies of incident reports involving generally licensed devices to NHSS.
Some states, because of budget and manpower constraints, did not participate in the study.
4.4.2 Incident Reports Twelve Agreement States reported a total of 34 incidents involving generally licensed gauges and devices, most_of which occurred between 1975 and 1980.
Fourteen of these reports involved lost gauges or devices, of which only one gauge was recovered.
Devices were apparently disposed of in landfills or in scrap yards.
In three cases, devices were severely damaged or destroyed by industrial m?chinery or solvents.
Radioactive contamination occurred in five other casee dhen devices were damaged by misuse or improper maintenance.
11
In four other cases, a total of 36 gauges and devices were discovered by chance.
A tritium source was discovered in a wooded area, 23 thickness gauges were found in a landfill (by persons looking for a lost cobalt-60 source), two exit signs were found on a public bus, and ten thickness gauges were discovered in an aban-doned paper mill.
These accidental discoveries suggest that licensees are improperly _ disposing or losing gauges and devices more frequently than repor_te.d._
A summary of the incidents can be found in Appendix D.
4.4.3 Agreement State Surveys and Inspections The Agreement States that conducted surveys and inspections found problems I
similar to those found by NMSS and the regional offices.
Typical violations cited were unaccountable devices, improperly or poorly labeled devices, inade-
\\'quateleaktests,poorlymaintainedrecords,andimpropertransfersordisposals.
See Appendix E for a table of the Agreement States' findings.
4.4.4 General Conclusions and Recommendations s
lCne of the major concerns with the use of generally licensed industrial gauges
,is accountability.
The study has revealed that gauges are being resold, lost, l
and scrapped by persons not aware of the transfer and disposal regulations.
Increasing the gauge users' awareness of the regulations should decrease these occurrences.
To solve this problem, the NRC should consider using a computerized registry that would track all generally licensed devices sold in the Onited State's.
Periodic follow-up notices to general licensees would remind them to keep track of the devices and would alert the NRC of possible accountability problems.
4 In the meantime, manufacturers and distributors could help increase the aware-ness of their customers by making the general license information more visible and understandable.
One manufacturer, for example, claims that the frequency of loss or damage.to its static eliminators has decreased since it improved its vendor training p ogram~and redesigned its information notices.
I 12
i To help avoid the recycling and improper disposal of industrial gauges, the NRC sent a poster (NUREG/BR-0108) to scrap yards and refineries to alert them to the problem.
The, poster, which was modeled after a poster that the Atomic Energy Control Board of Canada distributed several years ago, tells scrap dealers how the devices can be spotted, and what to do if oae is found.
4.5 Section 31.5, Part 2:
Background
As mentioned earlier, the second phase of the section 31.5 study covered devices such as self-luminous exit signs, small thickness, density, and level gauges, and analytical analysis equipment.
While the industrial gauges covered under part one of the study have common characteristics and applications, the devices under part two vary greatly in design and use.
The survey also discovered several problems that were unique to some of the devices.
For these raasons, the part two findings are itemized by device type.
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4.6 Section 31.5, Part 2:
Findinas 4
4.6.1 Self Luminous Exit Signs 4.6.1.1 Description Self-luminous exit signs contain hydrogen-3 (tritium) gas that excites phosphorous-coated glass tubes, giving off light.
These signs are frequently installed in places where it would be difficult or expensive to wire for electrical signs.
Of the devices surveyed, exit signs were the most commonly used and were therefore studied closely.
The findings of the 09 surveys are listed below.
'4.6.1.2 Awareness of Regulations and Accountability
_ Only 14 (16%) were aware of the regulatory requirements on the possession and
'}
use of the signs, including some that were not aware that the devices contained radioactive material.
The rest could not recall if the vendors of the signs had informed them of their obligations as general licensees.
13
t 4.6.1.3 Compliance with Leak Tests and Maintenance Regulations Of those surveyed, 65 (76%) reported that they kept the required records.
This i
i does not contradict the low percentage of awareness because exit signs are not leak tested or serviced, so only records of purchase, installation, and transfer are kept.
These records are usually purchase orders, work orders, and shipping i
i records, which are kept as standard business practice.
4.6.1.4 Loss or Damage There were only three reports of damage to exit signs.
Two persons reported i
that they received broken signs in the mail.
One per;,on reported that the sign was damaged by a fire hose during a fire.
4.6.1.5 Labeling to e
re ua y un ed Ita e a y
do r o
of the vendors put the label on the side mounting to the wall, making the label unreadable once installed.
Other vendors put the label along the bottom c 4 e of the sign, so that it is visible to persons looking up at the sign.
One general licensee surveyed took the cover off the sign and found the label inside the casing.
Overall, 24 (27%) reported that they could not see a label on the sign from the floor.
Since the labels are usually the only way that the signs are identified as radioactivo, the label should be clearly visible to persons in contact with them.
4.6.1.6 Vendor Reporting As explained in the outline of section 31.5, manufacturers and distributors must send the NRC quarterly reports of all transfers of devices to general licensees.
They must provide the general licensee's name, address, contact person or posi-tion, the number of products transferred, and the isoi.0pe used in the device.
14
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Vendors are not reporting all sales of the signs in their quarterly reports.
j'Thegenerallicenseessurveyedreportedhavingabout30%moresignsthanwere listed in the quarterly reports.
Furthermore, some quarterly report 5 are missing some of the required information, such as complete addressw., contact names, and quantities of shipment.
Lastly, many quarterly reports prior to 1985 are missing.
4.6.1.7 Compliance With Transfer and Disposal Regulations Several problems were also found concerning the distribution of exit signs, resulting from the resale of signs by unlicensed electrical distributors.
Vendors are selling the signs to electrical distributors and contractors as general licensees, who, in turn, resell the signs to another person.
A sampling of vendor quarterly reports showed that this problem is widespread.
Furthermore, 14 of the 16 electrical distributors surveyed were not aware of the licensing regulations, which suggests that almost all of these distributors' customers are also unaware of the regulations.
This improper distribution pathway has createdasignigicantaccountabilityproblem.
Some vendors have recognized this problem and require the electrical distributors to tell them the name and address of the customer buying the signs so that the vendors can list t h correct end user in their quarterly reports.
Most, however, are treating the electrical distributors as the general licensee and end user, making the true end user traceable only through the inconsistent records of the electrical distributors.
Another problem discovered was the transporting of exit signs by vendor sales representatives.
These representatives carry the signs in their cars to show prospective customers.
This may be a violation of the Department of Transpor-
' tation's regulations since they may not be propo 'y packaged for transportation.
4.6.2 Beta Backscatter Gauges 4.6.2.1 Description These gauges contain a small sealed source and a radiation detector that measure how much radiation is reflected back from a material sample.
Different thicknesses 15
I i
of dat ial reflect varying amounts of radiation from the material.
The f
@tectet a connected to the readout portion of the gauge which converts the I
f? M @ ions in radiation reaching the detector to a digital thickness display.
[,
fhese gauges differ from the industrial thickness gauges in that they contain l
smaller radioactive sources (usually less than 100 microcuries) than the thickness gauges and are also much smaller dimensionally.
2 Small thickness gauges also differ from the industrial gauges looked at in part one in that the radioactive sealed sources are removed and changed easily by persons using the device.
This allows the general licensee to purchase several sources for different applications or as backups when the original source must be returned to the manufacturer for inspection or replacement.
Beta backscattter gauges are used for thickness measurement of material, such as i
plastic, paper, steel sheets, precious metal platings, plating of circuit boards, and plastic coatings.
Because they can give quick and simple measurements, they are commonly used in quality control labs.
The gauge sources are usually l
strontium-90, tha111um-204, and promethium-147.
The findings of the telephone surveys conducted by the task group are discussed below.
. 4.6.2.2 Awareness of Regulations and Accountability 4
One concern was the accountability of removable sources.
These sources are about the size of a quarter, making them susceptible to loss.
The surveys revealed three cases involving missing sources.
Two licensees said that their sources had been lost in the mail (three sources, total).
The other general licensee could not account for two sources that were apparently thrown away.
Awareness of regulations was also low among thickness gauge users.
Of those i
surveyed, 55% said that they were aware of the general license requirements.
t One damage and possible exposure incident involving a beta backscatter gauge was discovered.
A quality control engineer visua,11y examined a 100 microcurie thalium-204. source after it fell out of a beta backscatter gauge.
He reported the incident to the manufacturer of the gauge, who then sent him an estimated whole-body exposure report.
However, because of the close visual inspection, 16-
the critical exposure area was the eye. The NRC Region I office investigated the incident.
4.6.2.3 Compliance with Transfer and Disposal Regulations Vendor reports, like those for exit signs, did not accurately reflect the correct number of radioactive sources owned by the licen.ees.
One reason for this is that the sources, which are usually detachable, are periodically replaced because of decay.
The general licensee must report all disposals of sources to the NRC.
Because of the low percentage of awareness, however, this is seldom done.
What commonly happens, therefore, is that the NRC will have records showing that the general licensee has a certain number of sources, when in reality, some of the sources have been returned to the manufacturer.
4.6.2.4 Compliance with Leak Tests and Maintenance Regulations Despite the low awareness of regulations, most of the general licensees reported that they were tyving leak tests parformed on the sources and 80% kept proper leak test, servics, and receipt records.
This apparent contradiction in findings may be due to the fact that the thickness gauge manufacturers usually send their customers reminders of upcoming leak tests and explicitly remind them to save leak tes,t and maintenance records. The manufacturers, therefore, improve compliance in these two areas even though the licensees may be unaware of the rest of the regulations.
While the new sources are clearly stamped as radioactive, some of the older sources had stick-on labels that fell off or became illegible from wear.
Overall, 86% reported that their gauges and sources were clearly labeled.
4.6.3 Static Eliminating Devices 4.6.3.1 Description Static eliminators are used by industry in a variety of ways, such as elimina-ting static on spray paint and ink jet nczzles, plastic laminates, paper sheeting, and many other products.
These devices are different from the other products 4
17
covered under 31.5 in that most manufacturers lease rather than sell the devices.
The lease period is usually six to twelve months.
At the end of the lease period, new static eliminators are shipped to the licensee who installs them and ships the old ones back to the manufacturer.
4.6.3.2 Aware *iss of Regulations and Accountability Eight of the 12 (67%) licensees surveyed were aware of the general license regulations, while 80% kept proper records of receipt and transfer.
Four of the licensees surveyed reported misplacing some of their static elimina-tors (10 devices total).
NHSS has also received two reports of lost or damaged devices from general licensees and two from an Agreement State (New York).
One licensee, in searching for a lost static bar, found two other previously misplaced devices in a closet, but could not find the bar that he was looking for.
Another static eliminator bar was damaged while it was being removed from its mounting brackets.
The vendor leak tested the bar and found.101 microcuries of Polonium-210afrom the first wipe test, and.081 microcuries from the second.
Another general licensee damaged a static bar by attempting to mount the bar with a "C" clamp, partially crushing it.
Hinor radioactive cleanup was required.
Lastly, a general licensee reported that two air ionizers had been " lost, destroyed, or stolen."
The relatively high number of loss and damage reports prompted the study group to investigate the use and distribution of the static eliminators more closely.
This included looking into the distribution and safety policies of one of the largest NRC manufacturers of static eliminating devices.
The manufacturer, as part of its licensing agreement, kept records on cases of loss and damage of its devices.
From 1979 to 1983, the manufacturer sold approximately 160,000 static eliminating devices in the United States.
Of the 100,000 undamaged devices returned and leak tested during this time, 50 were over the.005 microcurio limit for removable contamination.
Forty-five of the 50 failures involved two static bar models and one air ionizer model.
These three models contain 10 to 216 millicuries of polonium-210.
18
l Because these devices are usually installed on industrial manufacturing lines and must be placed within a few inches of the product to be effective, they are subjecttodamage.
The manufacturer reported that 81 incidents involving i
208 devices occurred between 1979 and 1983.
Eighty devices were damaged by solvents; 69 were damaged by fire or heat; and 59 were damaged by physical abuse.
Of the 17 incidents involving solvents, 13 required some decon-tamination.
Only cr,a of 'd.a 32 fire or heat incidents required radioactive cleanup, but nine of the incidents were fires in which part or all of the plant burned down.
These devices were not recoverable, and were disposed of in landfills with other debris after consultation with regulatory authorities.
Ten of the 32 incidents of physical damage required minor radioactive cleanup also.
The cleanup was usually done by the manufacturer's personnel, or, when necessary, regulatory personnel.
~
The manufacturer also reported that the frequency of occurrence of incidents decreased sharply over the five year period.
The vendor feels that this decrease was due to the "...a better program of instruction of our customers by our static analgsts and improved visibility of the special precautions section in the instruction sheets."
The task group is also concerned about devices that are not returned to the vendors after their lease period expires. The manufacturer reported that it has taken steps to avoid this problem. First, when the general licensees receive new devices, they are asked to return the old ones in the cases that the new ones were shipped in.
If the licensee loses these cases, it can receive new ones by calling the manufacturer.
If it does not receive the devices within two months of the expiration of lease date, the manufacturer sends a letter reminding the general licensee to return the devices.
Another letter is sent after another two months.
If the general licensee cannot account for the devices, the manufacturer sends a letter explaining that the licensee must report the loss of the devices to the NRC within 30 days.
4.6.3.4 Compliance with Transfer and Disposal Regulations Because of the leasing system and the short life of these products, many transfers occur between the vendors and the licensees.
While shipments to the 19
_ _ ~-, _ _ _ _ _ _ _ _ _...
licensees are being reported to the NRC in the required quarterly reports, shipments for replacement of disposal from the lie.ensee are not.
This causes the NRC's records to show the licensees in possession of more device's than they-actually have.
4.6.3.5 Compliance with Leak Tests and Maintenance Regulations Static eliminators are normally returned before leak tests are required and no maintenance, other than cleaning, is required.
Leak test and maintenance regulations therefore are not applicable to these general licensees.
4.6.4 Electron Capture Detectors and Liquid Scintillation Spectrometers Electron capture detectors are used in gas chromatographs to analyze the chemical composition of gas samples, while liquid scintillation counting systems are used to determine the radioactivity of samples.
Both devices are used predominately by biomedical and chemical research facilities.
4 Fifteen licensees using electron capture detectors and eight using liquid scintillation spectrometers were surveyed.
All but one were aware of the regulations, performing the required leak tests, and keeping proper records.
There were no reports of damage, although one licensee could not account for his electron capture detectors.
This high rate of compliance is probably due to the higher degree of training needed to work with these devices, as well as good vendor service programs.
There was also the potential for donations of equipment to other groups.
This was found on several occasions.
4.6.5 X-Ray Fluorescence Spectrometers X-Ray Flourescence Spectrometers, also used by the research industry, determine the elemental composition of samples.
An X-Ray flourescence spectrometer works by bombarding the sampig with photons, which excite the electrons of the sample, The electrons give off some of this extra energy that they obtain in the form of light.
Elements and compounds emit light in fixed and unique ways.
An X-Ray fluorescence spectrometer can be used to analyze this information and identify elements and compounds much like fingerprints identify individuals.
20
Six licensees using these devices were interviewed.
Four were aware of the general license regulations, performed the leak tests, and kept the necessary records.
Five reported that the devices were clearly labeled as centaining radioactive material.
No significant problems with X-ray spectrometers has been discovered.
d.7 Comparison of Telephone and Site Surveys with Regional Findinas The HMSS study group conducted 77 site visits in seven states to determine the validity of phone surveys.
In addition, the regional offices interviewed and inspected 59 general licensees with devices covered under part two of the survey.
Overall, the results of the site visits and regional inspections confirmed the findings of the telephone survey. While the degree of each problem varied among the three types of surveys, they all found similar problems of accountability, leak testing, record keeping, and labeling.
For a statistical comparison of the three survey types, see Appendix F.
One finding froeg the site visits that was not evident in the phone surveys was that some of the licensees interviewed said that they were not aware of the 31.5 licensing requirements, even though they possessed manuals for the devices that outlined the regulations.
This finding suggests that some of the general licensees are not carefully reading the information supplied by the vendors.
The vendors, therefore, are not solely responsible for the lack of awareness of regulations among the general licensees.
4.8 General Conclusions and Recommendations for Part II Findinas 4.8.1 Awareness of Regulations Users of exit signs, backscatter gauges, and static eliminators were least aware of. the license regulations.
As discussed in the comparison of phone surveys and site visits, one reason for this lack of awareness is that the licensees are not carefully reading information supplied by the vendors.
Another reason, which applies especially to exit signs, is that some vendors are reluctant to ad ertise the radioactivity of the devices, because it may hurt their sales.
The NRC should admonish these vendors to fulfill their requirement of informing the licensees of their obligations.
21 r-4--
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i Licensees using other instruments such as x-ray spectrometers, electron capture detectors, and liquid scintillation spectrometers were more aware of the general license program and its requirements.
The higher degree of awareness is due to both the complexity and expense of these instruments. These instruments are used by trained personnel and require a more comprehensive vendor information and service program, which improves knowledge and awareness of the general license program.
4.G.2 Reporting Some vendor reports are inconsistent and inaccurate, and licensees are not reporting transfers and disposals, making it difficult to account for these devices. One possible solution would be to standardize vendor report forms and to require the vendors, not the general licensees, to report transfers back to, the vendqrs for disposal or replacement.
4.8.3 Labeling 4
While labeling for most devices was good, exit signs appear to be inconsistently labeled.
The NRC will have to study the present labeling methods and decide if the label should be in plain view after the device is installed rather than a visible label upon removal of the sign.
4.8.4 Redistribution Many exit signs are being improperly resold by general licensees (electrical distributors).
These unauthorized distributors do not report sales to the NRC, making it difficult or impossible to account for these signs.
One possible solution would be to allow the redistribution of signs by electrical distributcrs,
'provided the devices are for specific orders only (i.e. not stocked), and the dis +.ributor reports all the required customer information for the vendor's quarterly reports.
The vendors would then be required to inform the distributors' customers of their licensing obligations.
22
4.8.5 Recordkeeping Licensees using research inscrun.ents such as x-ray flourescence spectrometers, electron capture cetectors, and liquid scintillation spectrometers keep better records on their devices than licensees with exit signs, backscatter gauges, and static eliminators.
One reason for this difference is that licensees using research instruments comonly use other radioactive materials in their experi-ments, and therefore have a radiation safety officer responsible for keeping track of all radioactive materiais and insuring that they are used safely.
Licensees using exit signs, backscatter gauges, or static eliminators do not normally use other radioactive materials and so do not have radiation safety officers.
The responsibility for the devices are usually added to someone's normal work load, which may make it difficult for the person to properly maintain the device and keep proper records.
The regulations for these devices will probably have to be considered separately to meet the special problems of these devices.
4 5 SECTION 31.7:
LUMIN0US SAFETY DEVICES FOR USE IN AIRCRAFT 5.1 Description /Backaround Under 10 CFR 31.7 a general license is issued to persons who need to receive, possess or use luminous safety devices for use in aircraft.
Appendix B-3 contains a list of license requirements.
These devices may contain up to 10 curies of tritium or up to 300 mil 11 curies of promethium-147.
A cineral licensee under this section (10 CFR 31.7) is exempt from Parts 19, 20, and 21 except they are required to report theft, loss, or incidents involving byproduct material to the NRC.
These aircraft luminous safety devices are found in most
' commercial aircraft.
There are six or more luminous safety devices in the large commercial planes (DC-10) and four to six in the smaller commercial planes (727 DC-9).
Presently. there are more than 30,000 luminous safety devices
~ installed in aircraft.
The general licenst,a is not allowed to assemble, manufacture, repair, import / export these types of devices or to use, receive, or possess instrument dials containing promethium-147.
23
l An incident concerning these general licensed devices wcurred in March 1982.
A' physician inquired about radiation exposures from tritium that were received i
from luminous safety devices used in aircraft.
These signs were removed from i
28 aircraf t and then disposed in a sanitary landfill by an Oregon company between 1972 and 1979.
The signs were removed in order to convert from passenger to cargo aircraft.
d According to 10 CFR 31.7(b), persons who possess these markers are exempt from the requirements of Parts 19, 20, and 21 except for the provisiuns of 20.402 and 20.403.
Therefore, the disposal did not violate NRC (nor Agreement State) regulations.
These luminous safety sources have a radioactive half-life of 12.3 years for those containing tritium and 2.62 years for those containing promethium-147.
Due to reduction of light output, these signs must be replaced periodically.
The average lifespan of a plane in the U.S. is approximately 40,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> air time (20-30 years).
Then they are usually resold overseas either totally intact er with their interiors stripped.
A few signs pose little hazard.
However one *:ompany stripped 36 planes for sales overseas, as one airline did, and approximately 216 signs needed to be disposed of properly.
The signs must be disposed in a radicactive waste site or returned to a specific vendor licensed to receive the radioactive material.
If these signs are not disposed of properly, a matter of concern for public health and safety arises.
Another concern is how these signs are being handled for storage, installation, and removal.
5.2 Findinas Nineteen general licansees were randomly picked to be surveyed from the quarterly
=
reports of specifically Itcensed vendors distributing aircraft signs.
Of the 19 general licensees, three were not locatable and one general licensee stated that he never received or used the luminous safety devices.
A high percentage of the licensees (14 out of 15) were keeping proper records of receipt.
However, due to the large amount of records kept by the aircraft industry to meet FAA requirements, most licensees can easily access only records dating back one month.
Only 10 out of 15 had adequate records of transfer.
24
4 Keeping track of the luminous safety devices is almost impossible.
When the planes are sold, the licensees have records of only the first users.
Many of these planes are modified and then resold.
Also, many vendors stock a large quantity of these signs at a time and use them as needed.
The records of transfers of the individual signs are not kept, just records of the planes themselves.
1 1
5.3 conclusions / Recommendations Except for transfer records, the general licensees' conduct under section 31.7 does not appear to be violating the current regulations.
However, there is some concern about safety due to the large quantities of signs being bought and then stocked at one location. Another concern is the reselling of planes
- containing these signs.
The signs may go to users not aware of the regulations, tt possibly leading to improper disposal.
To solve these problems, possible solutions are to impose regulatory requirements on disposal.
6 SECTION 31.% AMERICIUM-241 IN THE FORM OF CALIBRATION OR REFERENCE SOURCES.
Under this general license, a licensee who holds a specific license to receive, use, or transfer radioactive material is allowed to receive, use, or transfer no more than five microcuries at any one time of americium-241.
However, the americium-241 must have been initially transferred by a person holding a specific license authorizing distribution to generally licensed persons.
Although there are no regulation requiring the filing transfer reports, each specific licensee is required by license condition to report annual sales.
Appendix B-4 contains a list of license requirements.
The general licensee must hold a specific license to use byproduct material, source material, or special nuclear material in order to transfer, possess, or use americium-241.
The general licensee that meets the requirements for a specific license is familiar with the regulations, and has radiological training in the handling and use of the byproduct material, source material, or special nuclear material.
Since the sources are used under the oversight of a 25
i specific license, the requirements of section 31.8 and posses a low radiation hazard associated with their use, this general license was not studied in the report.
~
~ /
I 7 SECTION 31.10:
GENERAL LICENSE FOR STRONTIUM-90 ICE DETECTION DEVICES
"^
Ice detectors containing no more than 50 microcuries of strontium-90 are regulated under the general license in section 31.10.
The general licensee must assure that the devices are in good physical condition and must leak test the device whenever it is damaged.
The general licensee must also maintain the manufacturer's labels on the detectors and must dispose of the devices to licensed waste sites.
The staff could not locate any specific licensees authorized to distribute these detectors or any general licensees using them, therefore the staff believes that this general (Icense is serving no useful purpose.
Section 31.10, therefore, should be considered for deletion.
Appen-dix B-5 contains a list of license requirements.
8 SECTION 40.2?g SMALL QUANTITIES OF SOURCE MATERIAL 8.1 Description / Background Under 10 CFR 40.22 "Small quantities of source material" a general licensee is allowed to use and transfer up to 15 pounds of source material at any one time, but not more than 150 pounds per calendar year.
However, the general licensee is not allowed to administer source material or the radiation therefrom, to human beings, without direct authorization stating otherwise from the NRC.
In a previous inspection of a general licensee working under 10 CFR 40.22, four concerns were found.
These violations included quantities in excess of licensed limits, refusal to make available records for inspection, incomplete records, and disposal of source material to unauthorized areas.
Due to the uncertainty of the effectiveness of the regulations pertain.ing to 10 CFR 40.22 this section was made a part of the study.
The NRC identified four major processors of depleted uranium (DU) who distribute 00 for use under part.40.22, and requested a list from them of the general licensees they distribute to.
All four distributors cooperated with the NRC by giving contact 26
names and addresses (obtained from their shipping and billing records) of the Itcensees they shipped DU to.
One distributor reported shipping 1.5 to 3 million pounds per year of DU to their parent company who redistributes a small part of the DU to general licensees.
8.2 Findings
Several problems were found while conducting this study.
The distributors are not always informing the licensee that the depleted uranium is radioactive; and they are not required to submit a report to the NRC showing the contact names of the end users.
This makes it difficult to enforce the general license regula-tions.
The general licensee may receive DU from multiple distributors or general licensees and then later transfer the DU to another licensee. Since the general licensees and the distributor do not have to report receipt or transfers to the NRC, determining how much DU a licensee has in possession and whether he is following the regulations is unquestionably a challenge.
Thirteen users of depleted uranium were visted.
A sample survey used to obtain informa-tion may be fougd in App 6ndix A.
Only 6 of the 13 licensees contacted used the depleted uranium.
Of the remaining seven licensees, two licensees were out of business, two licensees shipped back their DU when they found out it was radioactive, and three licensees never used the DU after receiving it and later returned it to the distributor.
When asked, only two licensees were not aware that they had received the DU, and three licensees did not have records of receipt or transfers.
Of the six licensees that used DU, five licensees tested it for chemical content.
The licensees do a chemical dissolution with nitric acid to precipitate out a uranium based compound or the DU is dissolved for use as a catalyst.
These procedures create both chemical and radioactive > wastes.
The remaining licensee
' machines the DU to specifications set by the distributor and then ships it back to the distributor to be used as a component standard on their equipment.
Because of possible health hazards, one distributor sent in a health physics team to evaluate the operations evolved in machining the DU.
The team set up special filtering systems for air and the cooling fluid used in machining.
The health physics team evaluated the filters for contamination.
They found no significant contamination and later removed the filtering system.
- However, l
27
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)
there is a fan still set up to disperse the gases released while machining away from the machine operator without further health physics support.
i 8.3 Conclusions / Recommendations Even though all the licensees that were visited seem to follow the regulations, this may be misleading since the records the MLB has may no~t*contain all of the transfers of DU to the licensees.
There should be some means of keeping track of where the depleted uranium is distributed and transferred.
One possible solution would be to set up a reporting requirement like the one used for specifically licensed distributors of generally licensed devices (10 CFR section 32.51).
9 SECTION 40.25:
GENERAL LICENSE FOR USE OF CERTAIN INDUSTRIAL PRODUCTS OR DEVICES The section 40.25 general license regulates the use of depleted uranium contained in industrial pgoducts or devices for the purpose of providing a concentrated mass in a small volume, such as counterweights.
General licensees must register with the NRC (NRC Form 244) showing that they have procedures to control the possession and transfer of the depleted uranium, so that it is not disposed or or transferred to persons not authorized to receive it.
The general licensees are also restricted from performing any metallurgical processing on the depleted uranium, except for repair or treatment of the plating or covering on the
- materini, Furthermore, the general licensees can only transfer the depleted uranium only to persons authorized to receive it, and must report transfers within 30 days.
HMSS has been unable to locate any persons in non-agreement states that are specifically licensed to distributa depleted uranium products to these general licensees or any general licensees using the products.
As stated before, persons who receive or use depleted uranium must file Form 244 with the NRC (see Appendix 6).
There were 1000 copies of this form printed in 1982 and no forms have been printed since that time.
After the general licensee completes this form, it is submitted to the Director of Inspection and Enforce-ment (IE).
However, af ter contacting IE, they do not : acall ever receiving any 28
of these forms through thele offices.
Since general licensees under section 40.25 could not be located, the tahk group did not cover this section in the general license study.
The NRC should consider eliminating this general license i
since it appears to be serving no useful pt ;ot e.
10 SECTION 70.19:
GENERAL LICENSE FOR CALIBRATION OR REFERENCE SOURCE Section 70.19 allows a person who already holds a specific license from the Cr,mmission or Atomic Energy Commission to use, transfer, or receive radioactive i
material to use, transfer, or receive calibration or reference sources contain-ing plutonium.
The task force identtified only one distributor of these sources.
This distributor is located in an Agreement State.
During a phone conversation with this company it was learned that the interest in these sources is very small and that most sources are sold to the Department of Energy.
The NRC made several initial contacts with users of plutonium.
The licensees contacted vere aware of the regulations pertaining to section 70.19.
Since the general lictnsegs under this section must also be specific licensees there were no accountabi!ity problems, and the task force group did not further evaluate this general license.
11 OVERALL CONCLUSIONS AND RECOMMENDATIONS l
A solution to correct the accountability and awareness problems would be to issue only specific licenses, and eliminate all general licenses.
- However, this would involve the addition of about 15,000 specific licenses to NRC's current 8,300 specific licensees.
The task force does not believe this is feasible due to manpower and cost restraints.
However, the task force believes that the general license concept could be improved with minimal increased cost to industry and NRC while maintaining public health and safety by (a) taking greater advantage of new technologies (nonradioactive alternative and lesser activities); (b) allocation of NRC inspection resources on the tiasis of risk (similar to what is done for specific licenses);~(c) encourage greater industry responsibility; (d) periodic evalua-
-tion of the general licensees performance and (e) maintain communications with the Agreement States.
29
J Acot>r solution to help alleviate the accountability problem is to standardize l
the quarterly reports.
By requiring use of a specified format for reports, the
}
informatior, would less likely be inaccurate or incomplete, thus, making it l
easier to obtain needed information ou general licensees.
a.
j Also, a closer HRC and general licensee relationship may decrease improper trarafars and disposals.
By having surveys, questionnaires, or information notices periodically sent to general licensees, the general licensees would be mora informed of the regulations and their rerponsibilities.
This procedure thould decrease thA frequency of improper disposals and transfers by the general R ear.see, and increase general licensees awareness of regulations.
The task force recommenis estaMishing a national registry to maintain accountability of I
all dev h s erid i.Le spneral licensees using the devices.
This system would also allow for e H y access tn names and addresses 03 the general Itcensees and, could be used for addressing periodic notices and the task force also recommends
]
the following:
L (a) Elimiente sections 40.25 and 3L10 since there are no known NRC I
persons using these general licenses.
(b) Eliminate transuranic elements from certain (mainly 31.5) general licenses because of the difficulty with disposal.
(c) Hold a public meeting for all manufacturers and distributors of products to general licensees and reduce the confusion about concepts and requirements between NRC and Agreement State licensed vendors.
-(d) Improve inspection guidance for general licensee and vendors.
t 4
(e) Establish a testing program whereby acceptability of a general licensed product may be evaluated by a third party.
This group could determine with minimal bias if what the manufacturer / distributor indicated in their submittal is actually true and reasonable when compared to the actual product.
30 i
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(f) Establish a testing program whereby devices both new and those damaged by accidental conditions, i.e., fire, explosion, could be evaluated on a case by case basis to determine if a need exists to change the evaluation criteria, for a type of device, in view of increased public health concerns resulting from the test data, j
(g) Establish a regulation to allow for an exemption category for industrial productt.
This limit could be based on ten times the activity spedfied per isotope in schedule 30.718 of 10 CFR 30 and allow for specific isotopes activities of 250-750 mil 11 curies 3H, 2 mil 11 curies Promethium-147 and 20 mil 11 curies of Nickel-63 per device.
These levels are currently distributed as exempt products under various other exemption categories.
For example currently, these are about 5000-40 microcurie devices that could be exempted fromregulationcontrolifanindustrialproductcouldbedistribute$
under an exemption.
Considering the present wording of Section 30.15 and 30.18 one could say that NRC is not concerned with the use of 10 units.each of 10 microcurie in any form but is concerned about the use of 40 microcuries of Cs-137 in a device under the general license.
(h) Provide guidance Improve guidance to license reviewers in the form of Regulatory Guides and Standard Review Plans for manufacturers and distributors of products to the general licensees.
(i)
Increabe inspection of installation and service companies performing leak test and maintenance activities for general licensees.
(j) Improve inspection of geneNI licensees by periodically using temporary employees to make contact and site visits.
This approach could also be done to increase inspection of low priority specific licensees.
(k) Revise wording in the general licenses to improve clarity as to what and how informatio,1 should be reported to the NRC by both the general licensee and the vendor.
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(1) Establish a regulatory mechanism whereby the installer _of the device must assess that the environment into which the device is placed is -
not hostile to the integrity of the device or sealed source.
The task force feels that the immediate changes above will temporarily fix the accountability and awareness problems.
In the future, convertitig some general licenses to specific licenses would be the M tter solution to effectively protect the public health ano safety ~ '
f provided they are inspected within a reasonable. time frame.
This appears to be unlikely due to budget cutbacks.
Therefore, the most workable solution would be to set up a system of periodic mailing contacts with the general licensees and follow up on those that do (m) tab VN R on a ch to handle licensing and inspec,
tion activities for manufacturers and distributors of products (e.g.,
sealed sources and devices) containing byproduct, source, or special nuclear material.
Emphasis of this group would be on the product thatjstransferredforusebyothers.
Pre-marketing reviews of pro-l ducts, inspection of quality control programs, and consideration of defective products would be designated responsibilities of this group.
The group would also recommend and provide input to needed standards and regulations. Among other possibilities, the activities of this group might lead to reduction of the continuing problem of radiography incidents.
g i
6 I
6 32
REFERENCES AEC. 1953. Amendments to radioisotope distribution regulations.
Unpublished, J
Atomic Energy Commission report AEC 398-9*.
AEC. 1954. Amendments to radioisotope distribution regulations.
Unpublished, Atomic Energy Commission report AEC 398-6*.
- ~
AEC. 1958. Amendments to part 30 - licensing of byproduct materials.
Unpub-lished. Atomic Energy repor'. AEC-R 30/9*,
Cobb, L., 1985. Hemo: NRC survey of general licensees that possess generally licensed gauges pursuant to 10 CFR 31.5.
Document control number 106.
Henry, J.,1967. The commission's general licenses. Unpublished, Atomic Energy Commission report *.
Lubenau, J. and fussbaumer, D., 1986. Radiation contamination of manufactured products. Unpublished, presented at 31st annual Health Physics Society meeting, July 22, 1986, Pittsburgh, PA. NRC. 1985. Contaminated Mexican steel incident.
USNRC report NUREG-1103.
NRC. 1980. Environmental assessment of consumer products containing radioactive material. USNRC report NUREG/CR-1775.
4
- Reports are available from the NRC library, Bethesda, Maryland.
33
APPENDIX A Examples of Survey Questionnaires and Guidance for Collection
~
9 6
34
Guidance for Collection of the Other General License Study Date Introduction In selecting the general licensed users for visits and in collecting data during visits, please keep in mind that the primary objectives of the study are; (1) to evaluate how well the reuuldory program for other generally licensed products is working, and (2) when shortcomings are found in the program, to decide appro-priate corrective actions.
Observations about the licensees prcgras and possible
-underlying causes for violations and unsafe practices would be useful.
In our discussions with Agreement States personnel and with specifically licensed distributors of these potential problem areas have been identified.
These are:
1.
Accountability - are the poducts still in use, or are they lost, or were they disposed of along with ordinary scrap or trash?
2.
Maintenaneg - are the radiation protection features of the product properly maintained; particularly on those that were distributed by manufacturers who have gone out of business?
-3.
Unauthorized movement of the product - following initial installation by a specifically licensed installer, has the general license reinstalled the product at some other location where it may cause a radiation safety problem?
4.
Failure to comply with specific requirements clearly spelled out in the general license.
.The above list is not all inclusive but rather is intended to indicate some of our present concerns.
Your site visits to the general licensees should help determine whether these are significant problem areas and identify whether there are other problem areas.
Selecticia of' Users to Visit Quarterly reports and shipment vouchers from NRC and Agreement States specific licensed distributors / licensees should be used in selecting generally licensed 35
l i
users for lists.
Try to visit users who possess products distributed by sev-eral different manufacturers.
Also, try to visit several types of users, e.g.,
food, paper, cement, chemical, plastic, others.
If you encounter difficulty in i
locating a contact at the general licensee's facility, fee free to contact the specifically licensed distributor for assistance.
A list of most distributors is attached.
Every etfort should be made to avoid extensive travel time; therefore, choosing several general licensees in a given area that can be reached by rental car or public transportation is advisable.
Try to concentrate on products which are several years old.
This should provide greater opportunity for evaluating the performance of required periodic tests and maintenance.
It also provides a greater likelihood of encountering problems associated with turnover of personnel.
Since accountability is a major area of concern, we are interested in difficulties that you may haye in locating contact persons and the product.
Visits When inspecting for compliance with the requirements of the general license, please remember our interest in determining how well the gereral license is working and what remedial actions may be needed for problems.
If an item of non-compliance is found, try to determine the reason for the non-compliance.
Those reasons will be useful in deciding what changes, if any, should be made in the regulations or in how we administer the regulations.
For example, if required periodic leak tests are not performed because the indi-vidual who knew about the requirement has left the company, then perhaps this problem as well as other "over-sight" problems could be minimized by more frequent contacts between the general licensee and the NRC.
A concise summary report of your findings should be placed on the back of each survey form.
36
I l
l SURVEY QUESTIONNAIRE 1
l For Telephone Survey use Items 1 - 12.
For On-Site Visit use items 1 - 14.
i i
l 1.
Name and address of general licensee.
-- Name and telephone number of irdividual contacted.
Principal business of the general licensee.
j 2.
Purpose for which the gauge (s) are used (e.g.. maasurement of the level in a closed can of soup; measuring and controlling the thickness of sheet steel) 3.
For each gauge, identify the following:
a.
Manufacturer or initial transferor b.
Model number
+
l c.
Radionuclide in the sealed source d.
Quant $tyofradioactivityinthesealedsourceanddateof i
determination of the quantity.
l L
e.
Date the gauge was received.
f.
Date of source replacement,- if any.
. 4 Name of specific licensee who installed the gauge.
- 5.
Does the gauge have a durable, legible, clearly visible label?
6.-
Does the general licensee have a copy of the general. license?
7.
Does the general licensee have a copy of the initial radiation survey perfermed atL the time of installation?
' 8.
Leak tests a.
Have the tests been performed?
- b..
Name of firm or person who performed the test c.
- Does the general licensee have records.of leak test results?
-37 y
..mm_,
c~,
.-._....,r_..m
.,y_,
4-.,,...
~
4 9.
On-off mechanism and indicator tests a.
Have the tests been performed?
b.
Name of firm or person who performed the test' c.
Does the general license have records of on-off mechanism and indicator tests?
F 10.
Has the gauge been moved from its original location?
If so, by whom?
11.
Does the general licensee have personnel who are aware of the general license conditions and responsible for assuring compliance with the general license conditions?
12.
Has the general Itcensee made any transfers of gauges?
If so, were the gauges transferred to specific licenstes?,
13.
Your observations of the program conducted by the general licensee.
For example, are gauges in a dirty environment so that labels become obscured? aHave gauges been removed from use and stored in uncontrolled areas, etc.?
14.
Any observations regarding environment of use as it related to stress imposed on safety aspects of the gauge.
(e.g., use of a gauge on a glass melting furnace where the gauge may be subjected to high temperatures.)
Note:
In some instances one or more of the above items will not be applicable, e.g., item 8 would not apply to gauges containing krypton-85 or tritium and item 9 would not apply to gauges containing tritium.
38
APPENDIX B Outline of General License Regulations
. 39
Appendix B Outline of General License Regulations 10 CFR S31.2 - Terms and Conditions
$30.14(d) except under~a specially issued license, no person may introduce byproduct material into a product or material if it might be transferred to persons exempt from regulation or equivalent-regulations of Agreement State.
$30.34(a) each license subject to all valid rules, regulations and orders of Commission (b) licenses and rights under licenses not transferred, assigned, disposed of unless NRC consents (c) gossession and use of byproduct material confined to authorized locations and purposes.
Unless otherwise authorized, licensee under Parts 31 to 35 have right to receive, acquire, own and possess byproduct material.
Part 71 applies to shipment and transport.
(d) licenses under Parts 31 to 35 subject to 183(b)-(d) inclusive of the Act.
(e) HRC may insert additional requirements and conditions.for licensee subject to Parts 31 to 35 on receipt, possession, use or transfer
$30,41 transfer of byproduct material 930.42 inspections
-630.51 records of receipt; transfer and disposal 40
+
,,4
- ..530.53 tests 530,55 pempts Part 31 from tritium reports 930.61 modification-and revocation of licenses
{
$30.62 right to'cause the withholding or recall of byproduct material-t
$30.63 violations
- Parts 19 notices, instructions and reports.to workers; inspections 20 standards for protection against radiation 21 reporting of defects and noncompliance 4
e i
4 Unless otherwise indicated =in the general license, 41 I
~...
-.. -.... ~
... +
r
. 1.0; CERTAIN DEVICES ~AND EQUIPMENT ($31.3) 1.1 _ LICENSE MATERIAL CHARACTERISTICS' 1.1.1 General Description.
T Isotope Activity
. Static elimination devices Po-210 1500 pci Ion generating tube
.Po-210 1500 pci.
H-3 1 50 sci 1.1.2 Form sealed source 1.2 - LICENSE REQUIREMENTS - For all intent this regulation is used as an exemption type license.
a 1.2.1 Records
{
1.2.1.1 ' Leak Test not applicable 1.2.1.2 Service not' applicable 1.2.1.3-Receipt
$30.51(c)(1) - receipt records maintained for'2 years
-after. transfer or-disposat 1.2.1.4 1 Transfer
$30.51(c)(1)~- transfer records maintained for Siyears.
.. ~.
42
1.2.1.5L Disposal not applicable.
1.'2.2 Report Requirements-1.2.2.1 General License not applicable--
1.2.2.2-Specific Distribution License not applicable.
1.2.3 Other 1.2.3.1 Applicable Regulations a11' standard general license regulations apply (10 CFR $31.2)-
i 1.2.3.2 Specific Conditions l
specific license for manufacturers issued o g by the Commission under $30.33 I
T 43.
-=
2.0 MEASURING GAUGING OR CONTROLLING DEVICES (931.5) 2.1 LICENSE MATERIAL CHARACTERISTICS 2.1.1-General Description Any byproduct material contained in devices designed and manufactured for the purpose of detecting, measufing, gauging-i or controlling thickness, density, level, interface location, radiation, leakage, or qualitative or quantitative chemical composition, or for producing light or an ionized atmosphere.-
Istope and activity are determined by the device's ability to meet certain safety criteria.
2.1.2-Form Sealed source 2.2 LICENSE REQUIREMENTS 2.2.1 Records 2.2.1.1 Leak Test Devices containing krypton-85 and tritium (gas) sources need not be leak tested; devices containing gamma / beta sources only required to be leak tested when greater than 100 pei; alpha when greater than 10 pci
$31.5(c)(2) - devices checked every 6 months or as specified up to three yeart.
Devices containing gaseous sources need shutter function test at specified intervals.
631.5(c)(4) - records of tes.t results maintained for one year
-after next required test or until transferred or disposed of 44
2.2.1.2 Service S31.5(c)(2)- requires servicing of on-off mechanism and-indicator every six months or as specified (up to three years) s
$31.5(c)(4) - records of test results for on-off and indicator maintained for one year; and other services,
~ testing, installation and removal records maintained for two years 2.2.1.3 Receipt 1
630.51(c)(1) - receipt records maintained for two years after _
transfer or disposal 2.2.1.4 Transfer 4
$30.51(c)(3) - transfer records maintained for five years 2.2.1.5 Disposal
$20.401(c)(3) - records of disposal of licensed material maintained-until NRC authorizes disposition (this applies only if a specific license authorizes disposal, otherwise transfer regulations apply) 2.2.2 Report Requirements 2.2.2.1. General License 631.5(c)(5) - if failure of shielding, on-off mechanism or indicator, or detection of >0.005pci removable radioactive material suspend operation of device until-repaired, disposed of, or transferred; d
45
report of event and remedial action due to I&E within 30 days.
631.5(c)(9)-
transferrer must report within 30 days to NMSS; not applicable if for replacement of a similar device 2.2.2.2 Specific Distribution License 632.52(a) -
report all transfers quarterly within 30 days after end of quarter to NMSS; must maintain transfer records for five years from date of recorded event 2.2.3 Other 2.2,3.1 Applicable Regulations 4
931.5(a) -
general license is issued to commercial, educa-tional and medical institutions, to individuals in the conduct of their business and to federal, state or local government agencies to acquire, receive, possess, use or transfer 632.51 -
specific license for distribution of generally licensed products
$20.402 -
report of theft or loss 620.403(a)(b) - report of exposure or incident
$31.2 -
standard general license regulations apply (10 CFR 31.2), except exempt from 10 CFR Parts 19, 20, and 21 except 20.402 & 20.403 46
2.2.3.2 _Special Conditions
$31.5(c)(6) -
device shall not be abandoned'
$31.5(c)(7) -
device not exported (except in accordance with Part 110)
$31.5(c)(8) -
- transfer a device only to person holding specific license (NMSS notification within 30 days) 631.5(c)(9) -
transfer to another general licensee, conditions are:
a.
use at same location - notify NMSS within 30 days b,
device held in storage in original shipping container at the same location prior to initial use by general licensee (NMSS notification of intermediary and end user of general license required) e 47 4
6 2ast-J p-J
.4 h
E*.
s.
.*--A--wu.
si-a
.A J'4
- CrS--
-J-*
-7++-d
-~
3.0; LUMINOUS DEVICES FOR USE IN AIRCRAFT (631.7) 3.1 LICENSE MATERIAL CHARACTERISTICS 3.1.1 General Description Isotope Activity
" ~ ' '
H-3 5 10 ci-Pm-147 5300 mei 3.1.2 Form Tritium gas in sealed. glass tubes or promethium-147 contained in a device.
3.2 -LICENSE REQUIREMENTS 3.2.1 Records 4
3.2.1,1. Leak Test not applicable 3.2.1.2 Service not applicable 3.2.1.3 Receipt
$30.51(c)(1) ", receipt records maintained for two years after transfer or disposal 5
.3.2.1.4 Transfer
.630.51(c)(3) - transfer records maintained for five years 48
-4
3.2.1.5 Disposal Not applicable.
3.2.2 Reoort Requirements 3.2.2.1 General License not applicable i
3.2.2.2 Specific Distribution License
$32.53 -
the specific license shall report annually to NMSS quantity of material transferred to 531.7 general licensees with name, numbers, and quantity of tritium or promethium-147 in each device 4
3.2.3 Other a
3.2.3.1 Applicable Regulations
$32.53 -
approval of application for specific license to manufacture, assemble, repair, or transfer material a
$20.402 -
reports of theft or loss 920.403 --
notification of incidents 931.2 -
standard general license regulations apply (10 CFR 31.2), except are exempt from Parts 19, 20, 21 (excepting 20.402, 20.403)
W 49
_y-,
L 3.2;3.2 Special Conditions l.
.does not authorize manufactu're, assembly.. repair,.
531.7(e) -
import,. export ownership, receipt, acquisition, possession or use of promethium-147 contained in instrument dials-l i
'I
-g 4
i b
t 3
4
+
4 t
I I-i f -.
l 50
.,-n
.n-,
yrw a..-
- - - -. - +,.. --.. -,- -
4.0 AMERICIUM-241 IN THE FORM OF CALIBRATION OR REFERENCE SOURCES (631.8) 4.1 LICENSE MATERIAL CHARACTERISTICS
+
4.1.1 General Description
+
Isotope Activity Am-241
<5 pci, total at any one time at any one location 4.1.2 Form source 4.2 LICENSE REQUIREMENTS 4.2.1.1 Leak Test not applicable 6
4.2.1.2 Service not applicable 4.2.1.3 Receipt
$30.51(c)(1)-
receipt records maintained for two years after transfer or disposal 4.2.1.4 Transfer-530.51(c)(3) - transfer records maintained for five years 4.2.1.5 Disposal
$31.8(c)(3) -
shall not dispose except to authorized licensees
=51
4.2.2 Report Requirements 4,2.2.1 General License not applicable 4.2.2.2 Specific Distribution License-not applicable 4.2.3 Other 4.2.3.1 Applicable Regulations
$$32.57, 32.58 & 32.59 - specific license for distribution of generally licensed products 931.2 -
standard general license regulations apply (10 CFR 31.2); note that Parts 19, 20, and 21 apply a
since licensees are under a specific license and therefore must comply 4.2.3.2 Special Conditions
$31.8(a)
.(1) and (2) -
general license issued only to specific licensees in nonagreement states and' government agencies
$31.8(c) -
must be labelled prior to receipt, use and transfer; store source, except when source ~is being used, in closed container which is adequately designed and constructed; source to be used only for calibration of radiation detectors or standardization of other sources 1
52
i
-5.0!GENERALLICENSESFOR' STRONTIUM-90INICEDETECTIONDEVICES($31.10)
{
- 5.1 LICENSE MATERIALLCHARACTERISTICS 5.1.1 General' Description Isotope Activity
~
~
Sr-90 1 50 pci
+
5.1.2 Form sealed source 5.2 LICENSE REQUIREMENTS 5.2.1 Records 5.2.1.1-Leak Test not applicable 5.2.1.2 Service not applicable 5.2.1.3 Receipt
_$30.51(c)(1) - receipt records maintained for two years after transfer or disposal 5.2.1.4 Transfer
$30.51(c)(3) - transfer records maintained for five years 53-
-.---.. ~...- -
t i
5.2.1.5 - Disposal-
~
631.10(3)(1) _must transfer to a specific license or dispose of-in accordance with 20.301.
5.2.2 Report Requirements a
5.2.2.1 General License not applicable 1
5.2.2.2 Specific License not applicable 5.2.3 Other.
5.2.3.1 Applicable Regulations 4
$42.61 -
ice detection devices containing Sr-90; require-ments for license to manufacture or initially transfer I
$20.301 -
waste disposal general requirements l
$20.402 -
reports of theft or loss
$20.403 -
notification of incident 931.2l-standard general license regulations apply (10 CFR 31.2), except are exempt from Parts 19
-20, 21 (excepting 20.301, 20.402, and 20.403) 5.2.3.2 Special Conditions
- 631.10(b)(1) -
if visually observable damage, discontinue use
. until inspected, tested-for leakage, and -
repaired by person with specific license or
-_ dispose of device; labels also maintained 54 m
s I
J
-- _I i
631.10(c) -
- manufacture, assembly, repair, or import not 2
authorized
- $32.61(1) -
device must satisfactorily pass the prototype tests prescirbed in 6 32.103, i
4 m
h 4
J t
4 f
4 5
4 I
9 i.'
55
,,d-,,n.
c, -, -.,
. +..
-n--
6.0 SMALLLQUANTITIES OF SOURCE MATERIAL (640.22) 6.1 LICENSE MATERIAL CHARACTERISTICS 6.1.1-General Description source material - receipt of not"sor'e than 15 lbs at any one time or 150 lbs in any one calendar year S.I.2 Form any 6.2 LICENSE REQUIREMENTS 6.2.1 Records 6.2.1.1 Leak-Test 4
not applicable 6.2.1.2, Service not applicable 6.2.1.3 Receipt 640.61(c)(1) - maintained for five years-following transfer or disposition 6.2.1.4 Transfer
~
$40.61(c)(3) - maintained until the Commission authorizes their disposition 6.2.1.5 Disposal not applicable.
56
._. _ _ _ -, _ ~. _. _.. _ - - _ _
$20.401(c)(3) - Records of disposal of_ licensed material maintained until NRC authorizes disposition (this applies only if a specific' license authorizes disposal; otherwise transfer regulations apply) r 6.2.2 Report Requirements i-6.2.2.1 General License not applicable 6.2.2.2 Specific Distribution License - no license required 6.2.3 Other 6.2.3.1 Applicable Regulations
$40.22(b) -
exempt from all Parts 19, 20 & 21 4
inspection 640.62 modification, revocation, and termination of 540.71 licenses violation
$40.81 6.2.3.2 Special Conditions 540.22(c) -
prohibits administration externally or internally to human beings except as authorized by NRC in a specific license 57
7.0 GENERAL LICENSE FOR USE OF CERTAIN-INDUSTRIAL PRODUCTS OR DEVICES (640.25) 7.1 LICENSE MATERIAL CHARACTERISTICS-7.1.1 General Description depitsed uranium contained in industrial products or devices for purpose of providing a concentrated mass in a small volume of the product or device 7.1.2 Form any 7.2 LICENSE REQUIREMENTS 7.2.1 Records 7.2 1.1 Leak Test 6
not applicable a
7.2.1.2 Services not applicable 7.2.1.3 Receipt
$40.61(c)(1) - maintained for five years following transfer or disposition 7.2.1.4 Transfer
$40.61(c)(3) - maintained until the Commission authorizes their disposition 58-
q.
9
.7.2.1.5 Disposal 640.401(c)(4) - refers to $20.401(c)(3)
$20.401(c)(3) - records of disposal of licensed material maintained until NRC authorires disposition (this applies only if a specific license authorizes disposal, otherwise transfer regulations apply) 7.2.2 Report Requirements 7.2.2.1 General License 640.25(c)(1) - Form NRC 244 sent to I&E (Washington, D.C.) within
~
30 days of receipt; changes in form sent to I&E also within 30 days fg0.25(c)(4) -
report to I&5 within 30 days of transfer with' name and address of recipient 7.2.2.2 Specific Distribution License
$40.35(e)(1) - report to I&E (Washington, D.C.) all transfers
-to general licensees, within 30 days after end of quarter, (negative reports required quarterly) note:
records of these transfers must be maintained for two years
.7.2.3 Other 7.2.3;1 Applicable Regulations-
$40.34 -
cont tions:for specific license distributing to 640.25 general licensees 59
640.25(e) -
exempt-from all Parts 19, 20 & 21 640.62 -
inspection 640.71 -
modification, revocation, and termination of licenses 640.81 -
violations 7.2.3.2 Special Conditions
$40.25(d)(3) - shall transfer or dispose of depleted uranium only by transfer in accordance with provisions in 640.51 (i.e., must verify the tranferee's license authorizes receipt) e
~
t 60
1
,o+
e--A 4
4 4
=---I W
8.0 GENERAL LICENSE FOR CALIBRATION OR REFERENCE SOURCES (570.19) 8.1' LICENSE MATERIAL CHARACTERISTICS 8.1.1 General Description Isotope Activity plutonium-
< 5 pci at any one time and at any one location 8.1.2 Form sealed source 8.2 LICENSE ?.EQUIREMENTS 8.2.1 Records 8.2.1.1 Leak Test not applicable 670.39(c) -
specific licensee must perform dry wipe leak test prior to transfer 8.2.1.2 Service not applicable 8.2.1.3 Receipt
$70.51(b)(1) - records kept showing receipt, ir.ventory, disposal, acquisition, and transfer 670.51(b)(3) - records of receipt, acquisition, or physical
-_ inventory of SNM maintained for five years after transfer 8.2.1.4 Transfer see records above 61
..m
=
- 8.2.1.5 Disposal not applicable (onlyfallowed to-transfer) 8.2.2 Report Requirements-8.2.2.1 General License 670.52(a) -
immediately report losses 8.2.2.2 Specific Distribution License not. applicable 8.2.3 Other 4
8.2.3.1 Applicable Reaulations (as specified in $70.19) 540.32 -
conditions of licenses (not applicable)-
$70.39 -
specific licensee conditions for distribution to 670.19
$70.51 -
material balance,-inventory, and records management
+
g70.52 -
_ reports of loss or theft or attempted theft of special nuclear material
$70.55 -
inspections
$70.56 -- -tests--
- 570.61 -
modification and revocation of. licenses
$70.62 -
suspension-and operation in war or national emergency-
-970.71 -
. violations 62; y
m
,-wr y
e r
r--
m
-w
=*T re,+
T
- e-
All provisions of' Parts-19, 20,-and 21 apply.
8.2.3.2 Special Conditions
$70.19(a)(1)&(2) -
general license issued only to specific licensees in non-agreement states and govern-ment agencies who are authorized to receive, use, and transfer byproduct, source or special nuclear material (SNM) and specific licensees in ar agreement state who is issued a license by NRC to receive, use, possess, and transfer SNM 970.19(b) -
only calibration or reference sources manufactured or transferred in accordance with specifications contained in specific license pursuant to $70.39 or agreement state 4
(e)(2) must bear a label (c)(3) shall not transfer, abandon, or dispose of such source except to a person under NRC license or agreement state (c)(4) must store in closed container (c)(5) use only for calibration or standardization (c)(6)_
no manufacturing, import or export under general license 63
GENERALLY LICENSED DEVICES AND SOURCE MATERIAL cm memn m er norm acimn
. me se/nm
. me se mn 31.5 STATIC EulMTOR H-3 M 50nct 7000 20000 (1963)
Po-210 W 50M DENSITOWETER M-241 W 523 MCI 55 DATA NOT MMLA8.E
[WWr!TER A6$EMEILY 3 6.,
"atu-LLNNOUS DEVICES H-3 1001 7600 10000 (1966)
(NHClYri)
Pm-147
< 300 MCI UQULD SCNTHAT1011 Co-137 W 40uCI 800 1600 (1984)
SPECTROMETENS l-129 1Eba 16-43 10di flICTROSIATIC 16-43 W 10uci 350 MTA NOT MMLASLE VOLTWETER BETA IW*SCATTUt Pm-147 W 900ua 1200 5200 (1962)
Must n-204 m 40uCI Sr-90 W 00uC1 co-137 m 30ml *
~
STATC H-3 2&O J0000 250000 (1985)
QJW9mT0fE/WETERS Pe-210 157md AOt0 GAL Kr-86 10mCl 80 DATA NOT MMLAetE NEUIRALIZERS i
ELECTRON P4-43 15 md 900 DATA NOT MMLABLE CAPTURE DCTECTORS 31.5 Fu. LEE M-241 100mc 6CO 2000 (1983) cAuces HlNNI EllADE Sr-90 50 M 200 DATA NOT MMLABLE NSPECT10N SfSTDAS SELF-LLNNOUS DEVICES H-3 25CI 20000 50000 (1964)
(OOT SICNS)
(IflG STATES)
FUEL ?ENSITCKIER M-241 M 2.5tnQ 200 DATA NOT MMLA0lE EWid1TER X-RAY Fe-55 30 mci 90 450 (1962)
F100lDCENE UNf!3 Cd-109 3tnCI M-241 10 mci Cm-244 30 mci 31.8 CAUBRATION 01 Am-241 MAX.005uCl 30 QATA NOT AVNus2 REFEMNCE 50Uf525 40.22 SMALL QWmit[5 0F 60lbs.
DATA NOT AVAU82 sounct uATuut (Ou)
KEY e - ESTMATED NUMBER
APPENDIX C Samples of Gauge Literature 4
t 64
"The Untouchables" NON. CONTACT Q AGES NEVER TOUCH PROCESS MATERIALS Ohmart's "Untouchables** provido precise, stable, tellable non-contact measurement of liquids, slurries, bulk solids and web or sheet like niaterlats. Since they don't touch materials being rnessured, these advanced-design, on line in6truments and systems are not affected by extremes of temperature, pressure, abrasiveness, corrosion...
Geges precisely Geges occurately indisaie specine DENSITY Indicats the levet gravity et liqu6de Measurement in Vessel of liquids er bulk L6 quid Measurement in Pipe
@ Continuously @ Single Point metertels. Liquid of slutries pese-
--r.=2 level Indicellons ing through proe-g g are made et e eingle ese knee-In most
' * "J,,,.3 point, or continu-esses a pipe. Type.
p t'
ously throughout a cel appucetiene in.
.ef.
range on vessels, stude: eentretung M
[& c, M @
reactors, or tanks:
shemlost protestos,
- p, g.
i x!;
singi. wat...s-curvi.. o...e.,
c @W)W il.
urement le addl.
out N
W.
L 16enetty used on telecting Intettece A
strivelin pipeelnee-1 y hoppere et chutes t
e@
io indicais ebe.nc.
,eeerding,o,..-
~
tueting storms.
Of bulk metoftels.
THICKNESS /
WElGHT MOISTURE Sulk Meternal Measurement on eelt Web Meterial Measurements t
9 ll summma 6
MOISTURE Dulk Meterial Measurement on Belt I
_-E I
A see e occu,siety we gh bui.
2.
on
- n. geging eysieme e,e id.e.
motorials on belt, apron, drog et
{
for Indicating accurote th6ckness screw conveyore. Scales are (beele weight) end/or moteture espoolelly outted to corroelve, hot, in the web industries.Thicknees obrasive meteriete in chernical, food, (besis weight) of meteriale mees-cool, motels, non-meteille m.ntng ured include plastles and films, ladustries, rubber, paper, woven and non-woven libers. Paper, peperboard, and coated paper ere ideal for moisture determinetton-elso, tobacco and synthetic fibere, osges practeoty meepure bulk mateht's moteture using venous technique s, including nuclear end infrered. On-one measuremente are made routinety in pipes, of chutes, btne, and on-belt conveyors.
I
l 6
i The Leadi l
DUST RE ER/
STHTIC ELIMINGTOR 1
4 T
e 9to tllt m w tet
+
~
Ovar 30 years experience in static control and dust control applie:::a,,a g
1 INCH / toll (mottat uodenC2m 3 INCH /tQII(mett4I uodeoCsm -
l
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edjustment j
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- ara see e...... -e ive onne,e l
l 2"."
l cuncter i
a sutiennien a a cumeters I
The 3" wide STATICMASTER Brush is designed to clean j
The 1" wide STATICMASTER Brush neutrallres static larger surfaces gul(kly end effectively, The neutralising l
Ctross a 2" wide area in one pass. It is especially suitable for element, wh% eliminates static across a 4" wide area, is l
use in 35mm photography and for cleaning small diameter ideal 'at 4"> 5" film formats, photo typesetting fonts, and lenses, mirrors, dial covers, etc.
enlartrer condensing lenses. For la ger surfaces, two of three i
Model 3C500s can be easily connected together.
I j
i l
i APPLICATIONS HOW STATICff. ASTER WORKS l
STATICMASTER BRUSHES CLEAN:
Static i:largely responsible for the attraction and adhesion i
j O phoic4rechie neoeitves O pint 6e perss oe sheets of dust, lint and other foreign particles to nonconductive O treneesencia O delicate instruments surfaces. Static charges also cause handling problems and O.aot6nimirrors O rec 6sion esumbhes i.tr': curacy of measurements, STATICMASTER eliminates O beiste pen O film fonto thee charges with a sealed alpha tmitting polonium source.
O diescoveri O microfilm The 10 w energy, non penetrating alpha particles continu-i outly ne,Jttstire itstic electricity by locating the surrounding air t pr vide a e nductive path to' ground.
PRICE LIST STATICMASTER Brushes are handstatted of soft, natural STATICMASTER ORUSHES halt that is safe to use with even the most delicate lens Modet Description coatings or film emulsions, in seconds, without any messy 1C200 1" Brush - 200 microcunes washing, spraying. or rubbing. STATICMASTER neutrahres 1C700R Aeplacement eerst6dge.
static and whisks away the dust it attracts.
30600 3" Brush - boo microcuries The polonium element in the STATICMASTER Brush has a useful life of at least a year and is dated to indicate when it 3C600H fleplacement certridge,
Ceanectot lot joinmg 3" rrodelt should be replaced. The user can easily instal' a new x
U P A Technology, Inca c.ccTaotuc enocess, to 6
i..e9i+i eeauu ammn ec 60 CAK DRIVE sVOS$61, NEW YORK 11791 o
- i.. r... us.n..ieen 0
- i... iom CERTIFICATION LEAK TEST REPET Fm RADI0ISMOPE SOURCES 1
UPA Technology, Inc. certifies that the following radioisotope sources have been subjected to wipe tests to test the integrity of the source seal:
kESULTS. Mfgs Data 1SMOPE MODEL SERIAL NO.
(Microcuries)
^
Pm-147 HH-3
,55254
Background
2/83 T1-204 HH-3 37890
Background
2/,83
. Since the obtained results are less than.005 microcuries, the sources.:
( have been released.
We recommend that they be tested again in sb:
month s.
4 The following sources have been disposed of for the reasons indicated below:
ISMOPE MODEL SERIAL NO.
REASON FE DISPOSAL Pm-147 HH-3 25524 Decayed T1-204 HH-3 47099 Decayed No other certification or disposal receipt will be issued.
RETAIN THIS COPY IN YO!R FILES FOR INSPECTION BY REGULATSY AGENCIES.
by Shaed Dates rebruary 17, 1983 adwiga Strzeiczyk Radiation Safety Officer A
R124
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THE LAB X 2000 SERIES l
1' XRF ELElVIENTAL ANALYSERS A
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, sulphur in oil. lead in gasoline'. copper and zine in alloys. chlorine in urethanes. silicone l
l coatings on paper. lead in paint. chlorine, rotassium and ocbalt in polyalcohols. silicon in l
polythene. 2(nc in polystyrene. Iron, calcium and phosphorus in ores. sulphur in carbon black
. ash contentin coal.
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e IMPORTANT DOCUMENT Kee this certificate and future leak test records for dis lay on request by an inspecting radiation authority.
Fai ure to supply records on request may result in suspension of your Ifcense and/or a fine.
CERTIF!CATE OF LEAK TEST Thit Electron Capture Detector was tested for leakage of its Nickel 63 source and for tritium contamination.
Equipment used:
LS 100 Beckman Liquid Scintillation Counter The total removable amount of activity on the top of the tower cover, tower top and inside (upper part), and upper part of the cell combined was analyzed to be:
.~ 3 63Ni, O 76 X
lO microcuries f!/b fM7 Da te s_
2 -907377-00 Type of K1t d 1 f '[
(
fan Serial Numbe v
NOTE:
W In the US and Canada, the Electron Capture Detector must be leak VARIAN INSTRUMENT GROUP tested in accordance with your 2700 Mitchell Drive specific license, or every three Walnut Creek, CA 94598 years (whichever is shorter).
Consult your ECO Radiation Telephone:
(415) 945-2133 Safety Manual for instructions and regulations.
APPENDIX 0 t
Agreement State Incidents Involving Generally Licensed Devices i
me 65
APPENDIX 0 AGREEMENT STATE INCIDENTS INVOLVING GENERALLY LICENSED DEVICES ALABAMA An out of state representative of a gauge manufacttrier/ vendor serviced a gauge and installed a 100 millicurie casium-137 source without authorization by Alabama.
The vendor was cited for the improper installation and service of the gauge.
A generally licensed gauge containing 200 mil 11 curies of hydrogen-3 in a metal container marked "00 NOT DISPOSE OF - CONTACT B.K. SWEENEY MANUFACTURING COMPANY" was found in a wooded area.
Investigation revealed that the device was sold as surplus property by the Defense Property Disposal Office at Redstone Arsenal.
The device was returned to its original owner, the United States Air Force in Tennessee.
The incident wa's reported to Region II, U.S.N.R.C., as g matter within their jurisdiction.
A licensee reported that a 69 millicurie, krypton-85 gauge was missing.
The last time an inventory was taken was in April 1975.
A search of the licensee's premises and nearby salvage yards failed to locate the source.
Local police agencies were notified and compliance action is pending.
A static eliminator containing 20 mci of Polonium-210 was discovered missing from a licensee's facility.
The item was an air nozzle that had evidently broken off because of vibration of briquetter discharge chute.
It is believed that the air nozzle. broke loose at both ends, slipped out of the locking clip, fell to the floor in the products fires, and was loaded into a tote bin and fed into the melt tank (300'F).
CALIFORNIA A general licensee removed a density gauge to allow a pipefitter to install a "T" junction.
The gauge contained 150 millicuries of cesium-137.
The shutter 66
shielding the source was opened when the gauge was removed and remained open for the four days that the gauge laid on the floor near the work area.
When electricians attempted to reinstall the gauge, they discovered that the wires were too short and sent the gauge to the electrical shop.
Workers in the electrical shop attempted to remove the cover plate from the gauge so that they could get to the internal wires. When they could not do this, they finally read the radioactive inuel I" CAUTION - RADI0 ACTIVE MATERIAL") and notified management.
A 25 millicurie americium-241 source became dislodged from a generally licensed gauge and was returned to the gauge manufacturer.
The incident was apparently the result of a generic defect.
The gauge manufacturer is located in California, and California took follow up action.
FLORIDA A university R5Q reported an 8 mci Ni-63 foil we: appari,.atly lost.
The foil was located in a cardboard box that was aptarently discarded in trash to be buried at a city landfill.
Recovery was na t possible.
KANSAS During the routine operation of a fiberglass web farmer, a polonium-210 static eliminator came loose from its mount and dropped into a farming roll which contained serrated tuck rotating at 2400 revolutions per minute.
The bar was severely damaged, and some contamination occurred.
The areas involved were cleaned by a technical representative of the device manufacturer.
The contaminated machinery and supplies were disposed as required.
An exit sign containing 22.5 curies of hydrogen-3 was stolen from a general licensee's facility.
The sign was not recovered.
An exit sign containing 25 curies of hydrogen-3 was stolen from a general licensee's facility.
The sign was not recovered.
67
i
'\\
A general licensee discovered that a generally licensed air ionizer nozzle i
containing 20 millicuries of polonium-210 was leaking.
The general licensee decontaminated the facility innediately af ter the incident was discovered.
Regulatory officials inspecting the site discovered low levels of decontamina-tion and advised the licensee on further decontamination.
LOUISIANA A general licensee improperly disposed of a 100 millicurie cesium-137 source to a salvage yard who then transferred the gauge to a scrap metal refinery.
1he gauge was discovered missing two years after the gauge was disposed of, making recovery of the gauge impossible.
A 25 millicurie source broke free from its internal source cell in a coke vessel and was reported missing.
After an intense search of the licensee's facility, the source was found in a trash can at the facility.
4 Two density gauges were reported lost (reports within two weeks of each other) by two separate locations (50 miles apart) of the same company.
One gauge (containing 100 mci Cs-137) had corroded and fallen to the ground.
It is presumed to have been placed in a waste container and later hauled off to a land-fill project on the plant site.
It was locked in the closed position and had not been used for some time.
The second gauge (also containing 100 mci Cs-137) had been missing for about a year.
The loss was discovered during the annual inventory.
By questioning employees, it was determined that it had been sold to a local scrap dealer and that the dealer's scrap is shredded and shipped to Japan.
The scrap pile has been turr.ed over at least three times
,since the loss.
The recovery is deemed possible now.
MARYLAND On February 15, 1979 a general licensee called to report an accident while using a 48-inch static bar eliminator containing polonium-210.
The accident occurred when the source became detached and traveled into the rotating 68
cutting head of the sheeter paper machine.
The Division of Radiation Control promptly responded to this call to assess the situation.
Several of the compt.ny's employees were found with varying degrees of contamination on hands, shoes, and clothing.
The machinery and nearby areas were also found to be contaminated.
Division staff succeeded in decontaminating the involved individuals and roped off the area to reduce further spread of contamination.
Tht. cw.p., was then directed to hire a decontamination specialist to clean the machinery and dispose of the resultant waste.
Bioassays conducted on the individuals found to be contaminated revealed no measurable uptake as a result of this incident.
HISSISSIPPI A static control device containing 168 m1111 curies of polonium-210 was returned to the manufacturer in 1981, but the licensee failed to contact the Mississippi Department of Health to terminate its general license.
For three years the licensee paid 2% dollar licensing fee without knowing that the license should be terminated and the Department of Health should be notified of the transfer.
During an inspection conducted in 1984, the inspector discovered that three of five gauges containing 40 millicuries of strontium-90 were not clearly labeled.
The labels had become covered with grime, and in some cases, partially defaced.
Although the manufacturer of the gauges had been performing semiannual inspec-tions (inventory, leak testings, and area surveys), all reports prior to August 15, 1983, had been mailed out-of-state to the company's home office.
In addition to these incomplete records, the licensee did not possess the documents pertaining to the receipt and installation of the gauges.
Locating what docu-mentation was available was extremely difficult, because the plant had closed down the gauge line and laid off the employees familiar with record keeping.
The gauges were stored in place, and the manufacturer had surveyed the devices just after the gauge line was closed.
69
NEBRASKA The Division was notified that an apartment butiding containing three self-luminous radioactive signs had been destroyed by fire.
The signs were manufac-tured by American Atomics Corporation and contained a total of 60 curies of tritium.
The contamination was contained in virtually a six-block area.
Samples of the snow within the confines indicated levels up to 98,000 pel/l of melted snow.
Urine samples were collected from six of the firemen who were present during the fire and showed trace amounts of tritium.
The site received about two feet of snow soon after the fire and the Division considers the con-tamluation diluted to normal background levels.
NEVADA On December 12, 1980, the Radiological Health Section, Nevada State Health Division was notified that an incident had occurred on November 28, 1981, involving the uhauthorized removal of a generally licensed gauge and accidental radiation exposure of personnel at a fossil fuel power generating station.
The gauge was one of approximately twenty gauges used as a level monitor in slurry bins and conveyor belts.
The incident occurred when an unauthorized person removed the gauge containing a 150 militcurie Cesium-137 source from a slurry pipe.
The attached information tag which prohibited removal was ignored.
The gauge was also removed without properly closing and locking the shutter and was placed in the vicinity of several workers on the floor of a work area where it remained for six days.
The gauge was moved to another location where an electrician finally noticed the open shutter.
The shutter was closed and locked, and supervision was notified.
The gauge manufacturer was contacted to perform radiation surveys and wipe tests of the device 7 Exposure calculations indicated that nine employees were accidentally exposed.
The highest exposure received was 490 mR.
The incident resulted from untrained personnel receiving instruction for the gauge removal from a temporary foreman who was not properly instructed that removal., relocation, repair, maintenance, or replacement of the gauge was prohibited and because personnel were negligent in observing information tags attached to the device.
The corrective actions to be taken by the general 70
j licensee include information on gauge safety in new employee orientation, and improved maintenance of the attached information tags on the devices.
P NEW YORK j
There were three incidents involving lost polonium-210 static eliminator bars.
It appears as if the bars were misplaced, but there is a possibility that some pilferage may be involved.
Because of decay, the sources have a useful life of about 1 year.
A report was received regarding a child who was found by its parent chewing on a static-elimination device which contained a Po-210 source.
A subsequent investigation, including analysis of the device, indicated that the child had not ingested any radioactivity.
A 48 inch long static eliminator bar containing approximately 24 millicuries of polonium-210. microspheres was in use on a metallized coating production operation.
About every six months, the bar holder was cleaned in a caustic stripper tank by maintenance personnel.
The maintenance personnel were instructed to remove the static elimination bar before cleaning the bar holder.
However, during the production lull a new employee decided to clean the bar without removing the polonium-210 bar and dissolved off some of the polonium-210, thus contaminating the stripper solution and surrounding area.
Decontamination was performed by the supplier of the static eliminator which had provided the device under a lease arrangement.
An industrial firm reported that two static eliminator airguns which contained polonium-210 source were missing and may have accidentally been disposed of as
' waste.
At the time for the required leak test, an exit marker containing 7.3 mil 11 curies of promethium-147 was discovered to be missing.
A search of the area and circulation of information to the employees regarding its radioactive contents failed to recover the source.
71
A production line which utilized a generally licensed gauge containing 500 mil 11 curies of trypton-85 experienced a sheet break.
As the broken sheet was pulled through the process line, it apparently cut a hole in the mylar window of the gauge.
The broken source was packaged and returned to the supplier, t
NEW YORK A 1 mC1 cesium-137 source at the bottom of a four source level gauge chain dropped onto the coal bin in a foundry.
A thorough survey failed to locate the source and it was assumed to have been melted in iron slag, due to the high temperatures that existed.
With this assumption, a uniform distribution of the source was examined as a worst possible case and the specific activity was estimated to be about 1/10 of the exempt concentration or about 2.26 x 10 8 uCi/g of slag.
Two self-luminous exit markers, labelled as containing 10.5 Ci of H-3 each, were found on a public transit bus.
The sources were retrieved by radiation control personng1 and subsequent wipe analysis revealed no leakage or contamination.
The owner of the sources was not identified.
Ten thickness gauges containing Kr-85 sources were discovered in an abandoned facility formerly owned and operated by a paper processing company.
The sources were removed by a radioactive waste disposal firm.
NORTH CAROLINA In March 1971, during a search for a lost cobalt-60 source, radiation readings were detected at a salvage plant.
A further search uncovered 23 Betascopes belonging to the U.S. Army.
The devices were returned to the Army for proper disposal.
72
l TENNES3EE l
A generally licensed Am-241 gauge was lost by a manufacturing plant, probably 1
during the fall of 1978 during a malfunction of the equipment; however, the loss was not reported to the Division urtti spring 1979.
The gauge spent several months in the plant repair shop following the malfunction.
In April 1979, following determination by shop personnel that they couldn't repair the gauge, it was shipped to the manufacturer, who notified the plant of the missing source.
This Division was then notified and proceeded to investigate and survey the area from which the gauge was removed and the repair shop, but found no increased radiation levels.
It appears that the source was taken to the landfill and buried along with waste material which periodically is removed from the manufacturing area.
On January 12, 1979 the agency was notified that a licensee had performed unauthorized maintenance and modifications on Model 315 Po-210 static elimi-nators.
The damaged static eliminators were returned to 3M Company on December 22,1938.
Physical damage was in the form of ripped screens, missing end plugs, a hole drilled in one device, and evidence that another device had been sawed in half.
Smear tests indicated contamination on three devices in excess of 0.005 microcuries.
On January 8,1979 the Crown-Ze11erbach plant was visited by 3M representatives to perform a contamination survey.
Several spots of contamination were found and decontaminated.
All Crown-Ze11erbach personnel having maintenance duties with the static eliminators were briefed by 3M personnel on proper maintenance techniques.
73
.. _. _ _. ~...._ _.. _ _ _. _ -. _ _ _ _ _. _.._ _ _
l
+8 APPENDIX E A
i i
.i f
Chart and Graphs for I
a)Non-compliance b) Estimated Number of Devices Sold c) Missing Gauge Distribution d) Isotope and Activity Distribution Breakdown e) Number of Specific Licensees f) List of Vendors 9
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RESULTS OF AGREE!iENT STATE P/R't lOIPATION (PHASE l}
PERCEt#/ CE OF FACILITIES INSPECTED 103<
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02<
73<
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43<
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O INDUSTRA ACADtW:C WEC8 CAL PECENTAGE OF FACILITIES INSPECTED l
g $1ATic CUunATORG
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5ttf P96tREDAUMINOU$ DEVICES.54 SPECTRO-CHEW. ANALWERS C3 CAUDRATION 10URCE$.1%
. 30 c.
HEALUPit0/CC+lTROLUH3 DEVICES PERCENTAGE OF NON-COMPLIANCE ITEMS 50<
43, LEGEND 35<
1 - AB5ENCE Of REGULATIONS 2 - UNACCOUttttD FOR DEMCES 3),
3 - DEVICCG N;rT PROPERLY LABELED Ij, 4 - INADEQU ATE LEAK TEST RCSL".TS 23<
5 - lLLECAL TRANSFER 15<
1 10<
S-E E
0 1
2 3
4 5
f40N-00f tPLI AtlCE PERCENTAGES Of GENERALLY LICENSED DEVICES (PHASE!!)
'((;
LEGEND g
ff!
[23 - HQ PERFORMED PHONE SVRVEYS M - HQ PERFORMED SITE SURVEYS to<
[=)- REGIONAL PERFORMED SVRVEYS 0f]
9 OBSERVATIONS 3e<
1 - AWARNESS Of REGULATIONS
- t:
2 - MAINTENANCE OF PROPER RECORDS l5 3 - PERFORMANCE Of REQUIRED LEAK TESTS i
s 4
4 - DEVICES CLEARLY LABELED DEoctei nti taTsVDsx8ur caucus NOTE:
MISSING BARS DENOTE EITHER DATA NOT APPLICABLE OR UNAVAILABLE.
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DEVICES: DETA BACKBCATTER CAUCES DEVIOESi 510= MEDICAL ANALYI1 CAL O.S <
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BREAKOOWN BY TYPE OF ACTIVE SPECIFIC 0!$TRIBilTION LICENSE FOR NRC AND AGREEMENT STATES No. of Specific Licensees That 10 CFR Distribute Generally fart Description Licensed Products 1
"~
31.3 Certain devices and equipment.
1 31.5 Certain measuring, gauging, or control-105 ling devices.
31.7 Luminous safety devices for use in 2
aircraft.
31.8 Americium-241 in the form of 2
calibration or reference sources.
~
31.10 General license for strontium 90 01 in Ice detection devices.
31.11 General license for use of by-40 product material for certain in v4tro clinical or laboratory testing.
35.31 General license for medical use 1
of certain quantities of byproduct material.
40.22 Small quantities of source material 3
40.25 General Itcense for use of certain 01 industrial products or devices.
70.19 General license for calibration or 1
reference sources.
3 Based on discussion with NRC Staff, it is believed there have been no licenses issued in this category.
~
I e
75
.-. ~
ESTIMATED NUMBER OF i
GENERALLY LICENSED DEVICES AND MATERIALS i
~
S6LD PER YEAR BY IS0 TOPE AND ACTMTY 4
IS010PE 01-100 uC 101-1000 u0 1.01-100,mc 101-1000 mC 1 C OR WORE AW-241 60 825 18 91 00-109 25 CW-241 25 CS-137 400 36 24 FE-55 25 12 H-3 24000 2100 27600 1-129 200 KR-85 4900 120 180
- N1-63 890 1100 PM-147 200 P0-210 56000
=
lSR-90' 200 200 1L-204 200 4
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DISTRIBul!0NS TOTAL GAUGES SURVEYED BY PERCENT OCCURANCE i
An-241 Kr-85 Cs-137 Sr-90 Activity 1 to 100 mci 6%
0.9%
13%
9%
101 to 500 mci 11%
10%
25%
0.2%-
501 to 1000 mci 0.5%
6%
4h 0.5%
1001 mci to 5000 curies 0.7%
5%
7%
0.2%
Total a
18%
22%
49%
11%
t M
4 e
h
Gauges that final disposition could not'be determined.
By the Summer Student Employees Prior to IE investigations (69 gauges /Approximately 10% of Total)
Activity Am-241 Kr 85 Cs 137 Sr-90 1
1 t -100 mci 1(1.5%)
10(14%)
4(60%)
j 101 to 500 mci 6(9%)
25(36%)
1(1.5%)
1 i
1 501 to 1000 mci 7(10%)
2001 mci to 5000 curies 11(16%)
O Total 1(1.5%)
17(25%)
42(61%)
5(7%)
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Gauges that final disposition could not be determined.
After I & E Final Search (27 gauges /Approximately 3% of Total) i.
Activity An-241 Kr-85 Cs-137 Sr-90 i
i to 100 mci 1(~4%)
4(~15%)
[
J 101 to 500 eCi 1(~94) 9(~33%)
2(~7.5%)
i i
3 501 to 1000 mci 1(~4%)
1001 mci to 5000 curies 9(~33%)
4 Total 10(~37%)
11(~41%)
6(~22%)
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i IE RESULTS OF THEIR FOLLOW UP ON HISSING GAUGES Region-!
Anken Film 3 - 1.2 C1 - Kr-85 Liniek 1 - 500 sci Kr-85 1 - 300 mci Sr-90 Notfar Corp.
1 - 1.2 aci Kr-85 Owen C. Jones 1 - 75 mci Sr-90 US! File 5 - 1.2 Ci Kr-85 Kendal Co.
1 - 1 C1 - Cs-137 1
Region !!
Philip Morris 1 - 10 mci SR-90 Goodrich Gulf Chem.
1 - 500 mci CS-137 Federal Paper Board 1 - 100 mci Cs-137 Norwood Mineral 1 - 100 mci Cs-137 Morgantown Waste Treatment 1 - 200 mC1 CS-137 George Bass Company 1 - 500 mC1 CS-137 Region III Vess Beverage 1 - 3 mci CS-137 Region IV
-Universal 011 Products 3 - 200 mci CS-13 Canan Well Services 3 - 70 mC1 Sr-90 St a Energy Service 1 - 100 mci CS-137 Skn Francisco Co.'
1 - 50 mci CS-137 r96
DEVICE V900R LIST B'l REGION REGION I CONNECTICUT Fisher Technology, Inc.
Beta Backscatter Andrew Soncha 06-19165-02G 750 Marshall Phelps R/..
Gauge (203) 683-0781 Windsor, Ct 06095 Brandhurst, Inc.
Exit Signs Ronald G. Harper 06-20804-02G 87 Sand Pit Rd.
(203) 798-1131 iss. 7/ /84 0:nbury, CT 06810 exp. 7/31/89 FAG Industrial Gauging Gauge Dan Popovich 06-20631-02G 118 Hamilton Ave.
- (203) 327-1960 iss. 6/ /84 P.O. Box 811 exp. 9/30/89 Stamford, CT 06904 Harrel, Inc.
Thickness H.E. Harris 06-16699-02G 16 Fitch Street Gauges Probes (203) 866-2573 iss. 6/23/76 East Norwalk, Ct 08855 exp. 11/30/87*
18M Instruments, Inc.
Electron Samuel F.
06-19675-02G P.O. Box 332, Kenosia Ave Capture spencer iss. 5/18/84 Danbury, CT 06810 Detector (203) 796-2500 exp. 5/31/89 Integrated Industrial Gauges 06-21253-02G Systems Inc.
Craig Godwin iss. 6/01/83 475 Main St.
(203) 265-5684 exp. 5/31/88*
Yalesville, CT 06492-1723 Parkin-Elmer Corp.
Electron J.A. Frattaroli 06-02135-12G Main Avenue Capture (203) 762-1100 iss. 7/15/81 Norwalk, CT 068o6 Detector exp. 7/31/86*
Sikorsky Aircraft (is now a division of Un,ited Technologies.(CT)
United Technologies In-flight Alfonso Rolli 06-02269-04G Sikorsky Aircraft 81ade (203) 386-4000 iss. 9/29/80 6900 North Main Street Inspection exp.
Stratford,-CT 06601-Systems 1381 0 UNDER RENEWAL 78
l i
Device Vendor List-(Cont.)
MARYLAND l
Department of Commerce Calibration TG. Hobbs.
19-23454-02G Nat'l Bureau Standards or reference (301) 975-5800 iss. 10/11/84 i
Gaithersburg, MD 20899 source FTS 879-5800 exp. 10/31/89 Data Measurement Corp.
Gauge-(& Control)Formerly Industrial Gauging Linda Lubitz
-MD-31-088-02 8605 Grovemont Circle (301) 948-2450 iss. 6/20/78
~ Gaithersburg, MD. 20877_
exp. 7/31/89 i
i Design Lite Ind Redistributes Carrie Baker MD-27-032-01 9175 Guilford Rd.-
self luminous (301) 470-3282 Quarry Pk. Place, Suite 209 Devices Columbia, MD 21046-2660 Science Applications Int.
Electron MD-590-0-109G C3rp.
(SAIC)
Capture (301) 977-4480 l
3 Choke Cherry Road Detector i
R:ckville, MD 20850 t.
I 4,
, MASSACHUSETTS-Aeonic Systems Inc.
Gauge Richard Murphy 20-20675-02G The Research Center at (617) 663-2300 iss.:3/27/85 Manning Park exp. 3/31/90 43 Manning Drive Billerica,-MA 01821
- Analyticial Marketing, Inc.
Elemental Michael D. Brown 20-19842-02G 0xford Analytical Division Analyzer James H.Hannon iss. 2/17/83 2 Elm Square Scott S. Dale exp. 2/28/88 Andover, MA _01810 (617) 470-3700
. Environment Devices /Braincon-Gauge
_ Edward A. Mello 20-12721-2G 13 Marconi Lane iss. 1/15/70 Marion,_MA 02738 exp. 7/78 l
- Fcxboro Company Gaege
- H.W. Gebele 20-03683-04G-38 Neponset Ave.
(617).543-8750 iss. 9/69 Foxboro,;MA 02035 exp. 0/85-m
- LFE/ Trace *1ab _
Gauge W. Prendergast 20-01382-16G 1601 Trapslo Road (617) 835-1000 iss. 9/P/69 Waltham, MA: 02154.
exp. 11/i,0/89 79 1
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Device Vendor List (Cont.)
Panametrics, Inc.
Chemical Joris Brinkerhoff 20-0781-04G 221 Crescent Street Analyzer (617) 899-2740 iss. 5/21/74 Waltham, MA 02254 exp. 2/28/90 Radiation Monitoring Gauge William McGang 20-16325-02G Devices Inc.
(617) 926-1167 44 Hunt St.
Waterton, MA 02172 NEW JERSEY-AEG Telefunken Gauge Thomas Kluth 29-21307-0!G Rt. 22 Orr Drive (201) 722-9800 iss. 11/2/83 Somerville, NJ 08876-1269 exp.
12/31/88 E-S Industries Electron Nike Pardovich 8 South Maple Ave.
Capture
-(609) 983-3616 Marlton, NJ 08053 Detector Princeton Gamma-Tech,Inc.
Chemical Roger Greenleaf 29-12783-02G 1200 State Road Analyzer (609) 924-7310 iss. 6/6/75 l
Princeton, NJ 0854g exp. 2/28/86 Taylor Instruments.Sybron Gauge Bruce Gibson 29-08398-02G Avionics Products (716) 235-5000 iss. 4/27/64 72 Eyland Avenue exp. 9/31/78 Succasunna, NJ 07876 Note: License Number 29-08398-02G was TERMINATED on 9/31/78.
U.S. Radium Corp, see Safety Light Corp.
in Penn.
H:ake Buchler Instruments,Inc.
Electron A.D. Basha11 29-23484-03G 244 Saddle River Road Capture (201) 843-2320 iss. 3/22/85 Saddle Brook, NJ 07662 Detector exp. 3/31/90 NEW YORK
' Albany Engr. Systems Gauge Samuel Friedman GL 1432-2107 P.O. Box 310 (518) 793-8801
- iss, Glen Falls, NY 12801 exp.
Amtradair.Ekco Electronics Gauge (212) 736-4545 GL-304 Valley Stream, NY iss. 1/31/68 exp.
80.
Device Vendor List (Cont.)
Brandhurst, Inc.
Luminous Ronald G. Harper 2341-3196 GL Robin Hill Corporate Park Devices (914) 878-2033 iss. 7/20/78 Hugin Building exp. 2/12/85 Patterson, NY 12363 0 Note:
Brandhurst Inc. license, was TERMINATED on 2/12/85 when Brandhurst moved to Connecticut.
Cs. **d Precision Ind. Inc.
Luminous Carl Kreiger GL 1406-1611 630 Fifth Ave.
Devices iss. 6/12/68 New York, NY 10020 exp. 2/28/74 Electronic Automation (EAS)
Gauge Robert Picardi GL 1407-1169 2957 Alt Blvd.
(716) 773-7525 iss.
Grand Island, NY 14072 exp. 6/79 Herbert Products, Inc.
Redistributes John Herbert GL 1430-1950-180 Linden Ave.
Static (516) 334-6500 iss. 9/8/72 P.O. Box 384 Eliminators exp. 4/30/87*
Westbury, NY 11590-0384 For NRD Landis & Gyr, Inc.
Beta Max Birrer GL 143F 1977 45 West 45th St.
Backscatter (914) 592-4400 iss.
New York, NY 100364 Gauge exp.
O Note:
Landis & Gyr, no longer operate under this general license.
Maganaflux Corporation Beta (914) 633-0500 GL 2233-2220 Lcng Island, NY Backscatter iss.
Gauge exp.
Note:
Magnaflux bought out Sigma Labs and moved their business to Illinois.
NRD Division Static Eugen Oleksy 1429-1811GL Mark (4) Industries Eliminator Larry Keating iss. 1981 2937 Alt. Blvd. North J. David McGraw Grand Isisnd, NY 14072-1292 (716) 773-7634 e
81
l i
Device Vendor List (Cont.)
NRO Olvision Luminous Eugen Oleksy 2273-1811GL Mark (4) Industries Devices J. David McGraw iss. 7/10/78 2937 Alt. Blvd. North Larry Keating exp.
Grand Island, NY 14072 (716) 773-7634 Self-Powered Lighting Ltd.
Luminous Bruce Murray GL 1406-1611 Westchester Plaza Devices (914) 592-8230
" GL '1427-1611.
Elmsford, NY 10523 GL 1424-1611 Note:
Self-Powered Lighting also operates under all general licenses at the same time.
Sigma Labs.
Inc.
Beta Donald Wade GL 2233-2220 88-11 31st. Ave.
Backscatter Sam S. Como iss. 7/10/78 E. Elmhurst, NY 11369 Gauge (212) 937-6930 exp.
Note: Sigma Labs. was bought out by Maganaflux Trek, Inc.
Electro Andy Randolph GL 2207-2924 3932 Salt Works Rd.
Static (716) 798-3140 iss.
Medina, NY 14103 Voltmeters exp.
Twin City Int'l Inc.
Beta Serge Joffe GL 14-0208-97 175PineviewOrIve Backscatter (716) 691-8855 iss.
Audubon Industrial Park Gauge exp. 11/87 P.O. Box 248 Amherst, NY 14151-0248 UPA Technology, Inc.
Beta Jadwiga Strelczyk GL 1414-0921 60 Oak Drive Backscatter (516) 364-1080 iss. 8/15/73
'Syosset, NY 11791-4698 Gauge exp.
PENNSYLVANIA Berthold Systems, Inc.
Gauge Bud Smith 37-21226-02G
'79 North Ind. Park' (412) 741-1273 Sweickley, PA 15143 Fairchild Weston/Sangamo Gauge Fred Studer 37-16268-02G W]ston Controls Division
+(717) 876-1500 iss. 3/77 Kennedy Drive exp.
Archbald, PA 18403 82
D:vice Vendor List (Cont.)
H:wlett Packard Co.
Electron J.V. Wisniewski 37-07002-03G i
Avondale Division Capture (215) 268-2281 iss. 3/81 i
P.O. Box 900 Detector exp. 4/30/86*
Rt. 41 Avondale, PA 19311-0000 l
i MPSI Techn logies, Inc.
Gauge 0.1Leci Devins 37-20658-02G 240 Arch su tot (717) 843-8671 iss. 6/4/84 P.O. Box M-312 exp. 6/30/89 i
Ycrk, PA 17405 Nuclear Research Corp.
Gauge T.W. Schwager 37-02401-04G 125 Titus Ave.
(215) 343-5900 iss. 7/26/73 Warrington, PA 18976 exp. 4/30/83*
Note:
Nuc. Res. Corp. had two other licenses:
- 1) 37-02401-03G iss. 9/9/69 exp.
- 2) 37-02401-02G iss. 8/8/69 exp.
- Safety Light Corp.
Luminous Jack Miller 37-00030-09G 4150-A Old Berwick Rd.
Devices Cindy Litterer iss.
Bloomsburg, PA 17815 exp. 10/31/G3 previously known ast (717) 784-4344 U.S. Radium Corp.
P.O. Box 246 Morristown, NJ 07960 Safety Light Corp.
Luminous Jack Miller 37-00030-10G 4150-01d 8erwick Rd.
Devices Cindy Litterer iss. 4/22/85 81oomsburg, PA 17815 (717)784-4344 exp. 4/30/90
't Shielded Source Luminous William Hagerty 37-23660-01G 2 Pennsylvania Ave.
Device Malvern, PA Weston Controls (See Fairchild West'.e/Sangamo-same State)
Isolite Triluzco, Inc.
Redistributor C. Richter White 37-23527-01G 110 West Lancaster Ave, of
- (215) 688-2800 iss. 8/21/85 Wayne, PA 19087 Luwinous Nancy Montgomery exp. 6/30/90 Devices 83
Osvice Vendor List (Cont.)
' Barb.-Colman Indev.
~
y Co-%rol Systems (401) 438-9730 (was 38-18290-02G
.- vofd Ave.
iss. 11/78 E Providence, RI 02914
~~
exp.
REGION II ALABAMA ICN Micromedial Systems 1.iquid Ed Johnson 480 330 W9nn Dr.
Scintillatron (205) 859-8600 Huntsville, AL 35805 FLORIDA PCP, Inc.
Spectrometers Charlene Wernlund 11321-1-GL 2155 Indian Rd.
(305) 683-0507 iss. 1/2/81 West Plam Beach, FL 33409-3287 exp.
Stock Equipment Co.
Gauges Griffin Mitchel 1370-1-GL P:st Office Box 5 (904) 265-3611 iss. 10/25/79 Arthur Dr.
exp. 10/31/89 Hugh Nelson Ind. Park Lynn Haven, FL 32444
-Barry Webmiller Sealed 1447-1-GL Electronics Sources iss. 6/3/85
- 13327 U.S. 19 South exp. 2/28/86 Clearwater, FL.
33446 84'
):vice Vendor List (Cont.).
GEORGIA' Ahlstrom Automation. Inc.
Beta Gary L. Caines GA 832-1 5555 Oakbrook Pkwy._
Backscatter (404) 440-1396 iss. 10/24/84 Norcross, GA 30093 Gauge exp. 7/31/88 Note: Ahlstrom Automation was previously Robin Process Management Systems with the same address Lcster Labs, Inc.
Redistributes James Faulkner GA 645-1G 2370 Lawrence St.
Static Eliminators (404) 767-0277 iss. 10/2/81
. Atlanta, GA 30344 made by 3M exp. 11/30/82*
Robin Process Management Sys., see Ahlstrom Automation Inc. (same state)
Valmet-Sentrol Systems, Inc.
,Geoffrey Leighton GA 458-4G 841-8 Livington CT.
(404) 426-5584 (was GA 458-3G)
Marietta, GA 30067 iss.-6/75 exp.
KENTUCKY 4
Ronan Engineering, Co.
Gauge Jacqueline Garmany IND-267-95G 8050 Production Dr.
(606) 342-8500 iss. 2/23/82 Florence, KY 41042 exp.
NO3D1,gAfC LINA Ameriert 'Juesburg Bosson,Inc.
Gauge Jack Boyer 060-676-1GL 1070-L aouth Commerce Blvd.
(704) 588-7300 iss. 1/8/82 P,0. Box 7067' exp.
Charlotte, NC 28217 Humphrey Associates Redistributes 8.G. Humphrey 036-521-IGL 101 South Gaston Ave.
NDC gauges (704) 922-8631 iss. 11/81 P.O. Box 636 exp.
D:llas, NC 28034 85 i
Device Vendor List (Cont.)
Stunders-Roe Develop.
Luminous Eric J. Paisley 034-534-2
-P.O.
Box 5536 Devices (919) 765-4521 iss. 8/17/77 2580 Landmark Drive (Ms) J. Stevens exp.3/87 Winston-Salem, NC 27103 Note:
Brandhurst of Conn. now distributes Saunders-Roe Products SOUTH CAROLINA Mahlo-America Inc.
Beta Jutta Koehler GL 142-02 P.O. Box 1352 (803) 576-6288 iss. 11/22/71 Spartanburg, SC 29304 exp.
Mar-Chem Inc.
Redistributes Pres./RSO GL-0131 1011 Grove Rd.
NRD Static (803) 277-1152 iss. 5/4/71 P.O. Box 2311 Meters exp. 8/31/79 GKenv111e, SC 29605 TENNESSEE Industrial Services &
Gauge John G. Graves GL 9651-K5 Sup. Co.
(901) 372-0828 iss. 10/8/80 2322 Carro11 wood Lane exp. 10/31/85 C:rdova, TN 38018 Gull Engineers R-0149-Al (GNL-Associates) iss. 1/10/85 11020 Solway School Rd..
exp. 1/31/91 Kn:xville, TN 37931 R-0138-17 iss. 9/14/82 exp. 9/30/87 VIRGINIA Molins Machine Co.
Gauge Philip Theurer, Jr. 45-02429-02G 3900 Carolina. Ave, (804) 329-9081 iss.
P.O. Box 6159-exp. 9/30/89 Richmond, VA 23222 65
Device Vendor List (Cont.)
REGION III ILLIN0IS
~ Amersham Corporation Static Lew Henderson 12-12836-06G 2636 S. Clearbrook Dr.
Eliminator (312) 593-6300 iss. 9/24/81 Arlington Heights, Il exp. 9/30/86 60005-4692 CMI International Corp.
Beta Jack Montgomery 12-24607-01G 2301 Arthur Ave.
Backscatter (312) 439-4404 Elk Grove Village, IL 60007-6089
&L-01010-02 Kay Ray, Inc.
Gauge Al Peterson IL-01010-2 516 West Campus Dr.
(312) 259-5600 (12-11184-02G)
Arlington Heights, IL 60004 iss. 3/69 exp. 4/30/84 Magnaflux Corp.
Beta Earl Banfield 12-00622-10G 7300 West Lawrence Ave.
Backscatter (312) 867-8000 iss.
Chicago, IL. 60656*
exp.
Nuclear Chicago Gauge GL-130 333 East Howard Ave.
iss.
Des Plaines, IL 60018 exp. 1967 Packard Instrument Co. Inc.
Liquid Georgia Russell 12-04933-04G of United Technologies Corp.
Scintillation (312) 969-6000 iss. 9/29/69 2200 Warrenville Rd.
System &
exp. 7/31/90 Downers Grove, IL 60515 Electron Capture Detector Western Brush Co.
Gauge 12-13535-01G 215-219 S. Western Ave, iss. 12/12/69 Chicago, IL 60612 exp. 11/30/83 Note: WESTERN BRUSH Co. LICENSE REV0KED 6/17/80 DUE TO LACK OF PAYMENT OF LICENSING FEES-87
i i
. Device Vendors List-(Cont.)
i INDIANA-Ball Corporation Gauge Kent Bickell 13-02557-03G P.O. Box 5000 (317) 747-6100 iss. 9/11/69 1509 S._ Macedonia Ave.
(317) 747-6577 exp. 3/31/84 Muncie, IN 47302-MICNIGAN Lcuren Associates, Inc.
Redistributes Coleman Watkins 21-23368-01
- Box 308A Luminous (313) 642-9330 iss. 8/9/84 Birmingham, MI Devices exp. 8/11/89 L80-Associates Luminous Richard Linnell 21-19843 710 Livernois Devices (313) 939-5080 iss. 11/24/81,
Fcrndale, MI 48220 exp. 11/30/86 Note:
License #21-19841-01 was revoked on-7/05/83 due-to failure.of payment-for plant inspection.
4 M,INNESOTA Dart Enrivonment and-Aerosol Ralph 0. Wollan 22-12529-02G S rvices Company generator Fred W. Broling iss. 10/3/67 ERC/LANCY Division containing Dr. C.M. Peterson exp. 10/31/84 3725' North Dunlap St.
Han ion Leonard R. Graf St. Paul, MN 55112 generator (612) 484-8591 Note: This company is out of business Honeywell, Inc.
Fuel Dennis Rasmussen 22-19422-02G Military Avionics Div.
Gauge (612) 378-5656 iss.;6/30/80
.2600 Ridgway Parkway exp. 10/31/85 P.O. Box 312 Minneapolis, MN-55440 (See also-Honeywell in Arizona)
Minnesota Mining Static-Robert J. Kunz 22-00057-32G and Mfg. Co (3M)
Eliminator-(512)-834-3129 iss. 7/12/65 2501 Hudson Road exp.
L St.EPaul _MN' 55101' i
L Minnesota Mining Static Dorothy Coffield 22-00057-34G l
and Mfg. Co. (3M)-
monitors Robert J. Kunz iss. 11/21/69 L
3M Center; meters, and (512) 834-3129
~ exp. 6/30/86 St. Paul, MN :55119 readers 88 l
b
! Device-Vendor' List.(Cont )--
Thermo-Systems,Inc.((TSI)
Aerosol Gilmore Sem 22-12602-03G P.O. Box 64394 Detector-(612) 483-0900 iss. 5/7/75-500 Cardigan Rd.
exp.
J
- St.LPaul, MN _55164 i
. Accu-Ray Corporation Gauge:
Donald Stephens 34-00255-06G 650 Ackerman Road (614) 261-2000 iss. 1965-P.O.-. Box 02248 exp. 2/29/84
-C31umbus, OH --43202
- Dosimeter Corporation-Dosimeter William Connell 34-13477-02G~
--P.O. Box.42377-Calibrator (513) 489-8100 iss.
11286 Grooms Road exp.
Cincinnati, OH.45242-1428-Gene Lowey, Inc._
Gauge-34-11231-02G.
3042 Symmes Road iss. 9/29/69
-Hamilton, OH 45014 exp. 9/S0/73 Harshaw/Filtrol Partnership Liquid David Tucholski 34-06558-07G Crystal & Electroni8 Scintillation William King iss. 9/23/69 Products Department' (216) 248-7400 exp. 12/31/89 6801 Cochran Road--
Scion,-OH_ 44139
'previously:-Harshow Chemical Co.
- Mick Electric Company Redistributes William Miller iss. 8/9/84 3219 South-Avenue.
Luminous (419) 385-6604 exp. 8/31/89 Toledo, OH-43609 Devices i
Ohmart Corporation-Gauge-Paul Sieck 34-00693-03G-
--4241 Allendorf Dr.. -
(513) 272-0131-iss. 9/69 Cincinnati, OH7 45209 exp. 2/28/85*
Note:
0hmat Corp. had two other general licenses :
-1) 34-00639-04G.. Liss. 12/69 exp.-
2); 34-00639-02G is s. -_02/09/59 exp.-
-Victoreen,.Inc. -
' Dosimeter _
Barbara McVey-34-00486-13G 10101 Woodland' Ave.
Calibrator (216) 795-8200
--Cleveland, OH 44104 e
89-x
.-.- - a
Device Vendor List (Cont.)
WISCONSIN Arjay Sales. Inc.-
Luminous Russell M. Card 48-19440-01 3832 N. Hubbard.St.
Devices iss. 1/6/83 Milwaukee, WI 53212 Note:
Arjay Sales apparently went out of buna. in Eatiy 1983.
Krones, Inc.
Gauge Robert Schwarz 48-20448-02G P.O. Box 32100 (414) 421-5650 9600 S. 58th Street Franklin, WI 53132-0108 JMJ Sales, Inc.
Redistributes 48-23534-01 2237 North Lake Dr.
Self luminous (414) 272-4566 Milwaukee, WI RlGION IV COLORADO 4
Outokumpu Engr., Inc.
Gauge Mr. Terry Braden Colorado P.O. Box 16573 (303) 371-0540 G 455-01 4700 Packinghouse Rd.
iss. 3/31/81 Denver, CO 80216 exp. 3/31/86 B.K. Sweeny Mfg. Co.
Static E.T. Able Colorado 6300 Stapleton South Dr.
Eliminators Mr.-Fitzgerald GL-128 0:nver, CO 80216-4699 Static iss. 7/1/G6
-Monitors exp. 7/31/79 Note:
B.K. Sweeny Mfg. Co. was bought out by 3M in early 1981.
- Champion International Corp.
Gauge Lon. M. Schroeder 29-19688-01 Mill Operations / Packaging (406) 626-4451 iss. 6/1/81 Division-ext. 242 exp. 6/30/86 Drawer 0 Missoula, MT 59806 (AKASTONE CONTAINER CORP) 90
J D:vice Vendor. List (Cont.)
OKLAHOMA Fife Corporation Gauge R.J. Everett 35-15511-03G
~.P.O. Box 26508-(405) 755-1600 iss. 10/78 Oklahoma City, OK 73106 exp. 3/31/89 Note:
Fife Corp. has another general license,
.35-15511-02G, iss. 7/73 exp. 8/78 Fife Corp. was bought out by Data Measurement Corp. In
' Maryland (1986)
H 111 burton Services Gauge Dan Kelly 35-00502-04G 1015 Bois D' Arc-(405) 251-3749 iss. 9/10/69 Drawer 1431 exp. 10/31/84 Duncan, OK 73536 TEXAS
~
ASOMA Instruments X-Ray Scott Little 6-2788G Div. of Assoc. Metals Fluorescence (512) 258-6608 iss. 10/7/81 and Minerals Corp.
Analyzer exp.
1212H Technology Blvd.
Austin, TX 78727 4
C21umbia Scientific X-Ray-John Rhodes G-2035 Industries Corporation Fluorescence Pamela Firestone iss.
11950 Jo11yv111e Rd.
Analyzer (512) 258-5191 exp. 9/30/88 P.O. Box 203190 Austin, TX 78720
-Tcxas Nuclear Gauge Jack Hendrick 6-1105 GL (Ramsey Engr./ Robertshaw)
(512) 836-0801 iss.
-P.O. Box 9267 exp. 10/88 Austin, TX 787-66-9990 Tracor Inc.
Electron Carlton Lorfing 6-3389 GL
-6500 Tracor Lane Capture (512) 929-2051 iss.
Austin, 1X 78725-2100 Detector exp. 12/29/88 Valco Industruments Co., Inc.
Electron
-. Stanley Stearns 11-1572 G P.O.-' Box 55603 Capture Jim Whitford iss.
Ilouston, TX 77255-Detector (713) 688-9345 exp.
ARIZONA-
-H:neywell-Gauge-Eugene Gazzola 7-316 Automics Systems _
(202) 869-2311 P.O. Box'2111
0:vice Vendor List (Cont.)
NEW MEXICO Lcs Alamos Diagnostics, Inc.
Calibration Betty Strietelmeier P.O. Box 1221 Source (505) 662-0003 2470 East Road Lcs Ale.mos, NM 87544 American Atomics Gauge Parker D. Perry GL-254 425 S. Plumer Avenue GL-246 Tucson, AZ 85719 (Note: Out of Business)
REGION V ALASKA Debenham Electric Supply Redistributes Gregg Harnish 50-23228-01 4502 Lois Drive Luminous (907) 562-2800 Anchorage, AK Devices ElectricDietributois,Inc.
Redistributes E. Don Butts 50-19429-01 1884 E. Third Avenue Luminous (907) 277-5678 iss. 12/06/82 P.O. Box 1728 Devices for Self-exp.
Anchorage, AK 99501 Powered Lighting Stolt Electric Supply Redistributes Mike Tittle 50-23453-01 Company, Inc.
Luminous Edward G. French iss. 1/10/85 550 W. 64th Avenue Devices (907) 561-5500 exp. 1/31/90 Anchorage, AK 99502 Stusser Electric Co.
Redistributes Vincent Dodge 50-23255-01 411 East 54th Avenue Luminous (907) 561-1061 Anchorage, AK Devices (800) 478-1061 CALIFORNIA Acurex/Icore Gauge
'Joan Hughes 2715-59 GL 485 Clyde Ave.
(415) 964-3200 iss.
Mountain View, CA 94042 exp.
8:ckman Instruments Inc.
Liquid Joseph Palmerino GL-1313-30 2500 Harbor Blvd.
Scintillation (714) 773-8025 0441-30 P.O. Box 3100 Devices iss. 8/2/63 Fullerton, CA 92634-3100 exp.
92
- -.=
'e DiviceVendorList'(Cont.);
-i; C:nrac Corporation--
1242-70 GL
[
(Note: Out of_ Business)
-Delphi-Instruments Inc.
Detector-Alfred Robinson' 4144-70 GL 3030l Red Hat Lane -
Cells
.(213) 692-9023-iss'. 4/18/83 Whittier,.CA: 90601 exp. 4/18/90 t-
- Gamma Instruments Gauge
-Michael Bertin 3963-30 GL.
- 1290-B Hammerwood Ave.
-(408) 734-8211 iss.. -3/29/82 Sunnyvale, CA 94089 exp. 9/25/88
-General Means Instruments Gauge G.'Garcia 1817-70 GL-1944 Turnball-Canyon Rd.
-iss. 12/27/68-Hacienda' Heights, CA 91745-exp. 12/20/79-Note: This license was terminated on 12/20/79 General: Nucleonics, Inc.
Gauge D.W. Blincow 2498-70 GL 2807 Metropolitan Place iss. 10/11/73 Pomona,.CA 91767 exp. 10/11/87 ICN Ches & Radioisofbpe Calibration-A.L. Baietti-2167-59 GL
- 2727 Campus Dr.
(714) 833-2500 iss.-3/23/71
-Irvine, CA' 92715 exp. 3/23/78 Industrial Automation Gauge Michael M. Dunn 2424-GL P.O. Box 1208-(805) 968-1580
.iss. 3/3/73' 6155 Carpinteria Ave, exp. 3/3/86
.Carpinteria,.CA 93013 Industrial Dynamics'Co. Ltd Gauge Fred Calhoun GL 1586-70 3
Filtec-(213) 325-5633 (1389-59 GL) 2927 Lonita' Blvd.
iss. 5/26/66 P.O.. Box'2945:
exp.
- Terrance,-CA 1 90509-2945
- Measurex' Corporation Gauge-Lyne11.Lyon
'1856-43 GL
.One.Results:Way-
'(408) 255-1500
-iss.
!Cupertino, CA.95014 exp.
Meteorology Research,-Inc.
Aerosol-
-John A. Wells 3376-70 GL
.464 W.- Woodbury Rd..
Monitor 1 iss. 5/12/76 Altadena,;CA 91001' exp. 5/12/83 193
-v
~ _
. - ~.~
d i:
' Device Vendor _ List (Cont.)
NOC: Systems Gauge =
-Mr. Fishman GL-1933-70
- 730 East Cypress Ave.
-(818) 358-1871 iss.
Monrovta, CA_ 91016=
I Nuclear Products Company Static Richard Eyleth 04-01100-01G-2519 North Merced Ave.
Eliminators (213) 283-2603 iss. 10/29/56-L S. El Monte, CA 91733-exp,-
Nucleonic Data Systems
. Gauge Randall Harman 2093-30 GL 18061 Fitch Ave.-
'(714) 979-1922 2630-59 GL-Irvine, CA2 92714 (714) 863-1922 2630-30 GL~
(Note: All four of;these licenses were issued on 6/69).
1753-59 GL-Paco Controls Corp.
Gauge Ray Babb 3832-43 GL
~
L 450 Montague Expwy.-
-(408) 262-4050 iss. 3/12/81 Milpitas, CA 95035 exp. 3/12/88-Photo Research Photometers Karoly I.
2189-59 GL Div. of Ko11morgen Corp.
Ponyvesi-iss.-1/30/80 3000 N. Hollywood Wh (818) 843-6100 exp.
Burbank, CA 91505 Radtronics/ Jordan Nuclear Co.
Detection Edward A.
GL-1666-70 3244 Arroyo Seco Ave.
- Instrument Manughian iss. 2/9/68 Les Angeles, CA 90065 (213) 222-8141
-exp. 2/9/87 Science Applications, Inc.
Light David C. Shrove GL-2703-80 t
Sen Diego, CA 92123 _
Source _
(619)-453-0060-iss. 10/23/74-
'8953 Complex Dr.
a Systems, Science and Software Electron :
William G. Stevens 3152-80 GL
- (AKA)-S-CUBED
-Capture
'(619) 453-0060 iss. 12/27/83 exo. 12/27/87
- 3398 Carmel Mountain Rd.
Detector Stn Diego,JCA 92121-
- Varian Instruments Div.
Electron J. Van' 3092-07 GL a
' P.O.. Box.9016 Capture Osenbruggen iss. 10/5/76 2700 Mitchell. Drive Detector (415) 939-2400 exp.
- Walnut Creek,_CAf 94598 i
94=
._,...--.-a....e--.-.
iDOvice Vendor List (Cont ) -
Xon Tech. I'nc.
. Electron.
Gary W. Watson 3476-70 GL 6862 Havenhurst Ave..
Capture (818) 787-7380 iss.
Van Nuys, CA-91406 Detector.
exp.
HAWAII Pacific Electrical Sales Luminous 53-23631-01 Agenc',, -Inc.
Devices
. (AKA PELSA) 307-A Kamani Street.
Honolulu, HI 96813 WASHINGTON Acrowood Corporation Gauge Darrell Halgrimson WN-10253-1 P.O. Box 1028 (206) 258-3555 Everett, WA 98206
+
=
M e
I s
95.
APPENDIX F Applicatlon Form 40.25 9
e 97
U,S, NUCLE AR REGULATORY COMMIS$10N APPROVED SY OMB NRdFOA8dgy 3M20 (1042) 10CFM 40 REGISTRATION CERTIFICATE-USE OF DEPLETED URANIUM T
,,_._ j UNDER GENERAL LICENSE 5ection 40.2$ of 10 CI'R Part 40 estabbshes a general hcense authorsalog the use of depleted uranium rentained in industrial products or devices for masaolume ac'plicatiom This NRC Form 244 shau li submitted within 30 day after the first receipt or acquisittor of such depleted uranium, 3, I hereby file NRC Form 244 pursuant to i 40.25 of 10 CFR Part 40, for use of depleted uranium contained in ind"'*t I products or devkes for massolume applications,
- 4. To be co.npleted by the Nucleas Regulatory Commission.
INSTRUCTION!
I, Submit this form in triplic;te to:
FILE NUMBER:
U.S. Nuclear Regulatcry Commission Duestor of Inspest!on and Enforcement Washington,D.C. 20553 (L eon tMe apete blenk-number to be asagned by NRC)
- 2. Plesw print or type the name and address (including ZIP codel of the registrant for whom this form is fUed. Position the first letter of the address below the left dot and do not entend the address beyond the right dot. (At NRC, a fue nnber will be assigned and a copy of NRCgorm 244 will be returned.)
3, Name and/or title, address, and telephone number of the individual duly authorized to act for and on behalf of the rgistrant in supervising the procedures identitled in 10 CT R 40,25ienlHilt
- 6. Certifkation I hereby certify that;
- a. All information in this registration certifkate is true and complete,
- b. The registrant has developed and will maintain procedures designed to estabush physical control over the depleted uranium (escribed in 10 CTR 40.25(a) and designed to pravent transfer of such depleted uranium in any form, including mett.1 scrap, to persons not authortred to receive the depleted uranium,
- c. I underst,and that Commission regulations require that any changes in information furnished by a registrant on this registraiion certifkate be reported in writing to the Director of inspection and Enforcement within 30 days after the effective date of such change,
- d. I understand that the registrant is required to comply with the provtsions of !iection 40.25 of the NRC's regulstion 10 CFR Part 40 (reprinted on the reverse side of this form) with respect to all depleted uranium which the registrant receives, acquires,uses,or transfers under the general license for which this registration certificate ls fued with the Nuclear Regulatory Commission, DATE:
BY:
isognatuow of person fuhng forms (Pronted esame end tithe of persos, fehag form)
~ DARNING: 18 us.c., secoon tool, Act of June 25.1948. 62 Stat. 749, makes it a criminal of fense to make a willfully falso statement or representation to any department or agency of the Unsted $tatM as to any matter within lts jurisdiction.
i 40.25 General hcense for use of certain industrul produets or (2) The registrant possessing or unns depleted uranium under the get general hcense estabhshed by paragraph (a) of this section shall report in writing to the Director of Inspection and Enforcement,any changes tal A general hcense is hereby hsued to receive, acquire, poness, in information furnished by him in the NRC Form 244 " Registration use, or trander, in suordance with the provisions of paragraphs (b),
certificate.Use of Depleted Uranium Under General License." The re e i
tel. Id), and (el of this sechon, depleted uranium contained le indus-port shau be submitted within 30 days after the effective v%.rrNc taal prod; cts or devkts for the purpose of providing a concentrated c hange.
1 mass in a smaU volume of the product or device.
(d) A person who receives, acquires, posesses,or uses depleted ura-(b) The generallicense in paragraph (s)of this section apphes only nium pursuant to the general heense estabhshed by paragraph tal of this o tedct:1 products or devices which have besn manufactused or inittuy uansferred in accordance with a specific bcense issued pursuant (1) Shan not introduce such depleted uranium,in any form. into a to i 40.34(a) or in accordance with a speafic bce'sse haueJ by en casemical, physical, or metaDurgical treatment or proass, encept a treat-Agreement State whkh authorues manufacture of the products or de-ment or process for repair or restoration c,( any plating or other cover-ing f the depleted uranium, vices for distributson to persons generany bcensed by the Agreement (2) Shau not abandon such depleted uvantum.
II*
t)) Shau cansfer or dispose of such depleted uranium only by (c)(1) Persons who receive, Multe, poness, or uw depleted ura-transfer in accordance with the provhlons of g 40.51, in the case where nium pursuant to the general heenie estabhshed by paragraph is) of this the transferee receives the depleted uranium pursuant to the general section shan fue NRC Form 244," Registration Certificats-Use of De.
hcenu established by paragraph tal of this section, the transferor thaU phled Uranium Under Cineral 1.icenie," with the Director of Inspec.
furnish the, transferee a copy of this section and a copy of NRC Form tion and Enfortement U.S. Nuclear Regulatory Cor mission, Washing.
244, in the case where the transferee reestves the depleted uranium pur.
lon, D C. 20553. The form shan be submitted within 30 days atter the suant to a gertral beense contained in an Agreement State's scgulation first recCt or acquisition of such depleted uranium.The registrant shan equivalent to this section, the transferor sh U furnish the tranderte a furnish on NCR For'n 244 the fouowing information and such other copy of this section and a copy of NRC Form 244 accoms,anled by a t;hrmation as may be required by that form:
note emplaining that uw of the product or device is regulated by the (i) Name and address of the registrant:
Agreement State under requirements substantiaUy the same as those in till A statement that the reghtrant has developed and willmaintain this section, procedures designed to estabbsh physical controlover the depleted ura.
(4) Within 30 days of any transfer, shaU report in writing to.the DF tium descalbed in paragraph (a) of this section and designed to prevent rector of Inspection and Enforcement the name and addren of the pet.
transf:t of such depleted uranium in any fonn, including metal scrap, son receiving the source material pursuant to such transfer.
- ) persons not authorized to receive the depleted uranium; and (e) Any person receiving, acquiring, possessing, using, or transfer-(ui) Name ahd/or tale, address, and telephone number of the indi-ing depleted uranium pursuant to the general License estabushed by vidral duty authorued to act for and on behalf of the registrant in paragraph (a) of this section is exempt from the requirsments of Parts supiryhing the p *edures identified in paragraph (citil(ii) of this 19,20, and 21 of this chapter with respect to the depleted uranium sectiot g
covered by that generallicense.
PRIVACY ACT STATEMENT Pursuant to 5 U.S.C. 552ste)(3L easeted into law by sectior. 3 of the Prucy Act of 1974 (Public Law 93-579), the following statement is furnished to indivktuels who nuopsy information to the Nucteer Regulatory Commission on NRC Form 244. This information is maintained in a system of re-cords deagnated as NRC 32 and described at 41 Federal Register 42340 ISeptember 27,1978).
- 1. AUTHORITY. Coctions 63,65, and 161(b), (i), and (o) of the AtorvJe Energy Act c,f 1954, as amended (42 ES.C. 2093,2005,2201(b), (il and
- till, 2, P%!NCIPAL PURPOSE (Sh The information is evaluated by the NRC staff to Jetermine whether the registrant understands that he is required to comply with the prtwisions of 10 CF R 40.25 with respect to all depleted uranium which he recobres, acquires. uses, or transf ers under the general hcense for which the registration certificate is filed with the NRC. The information will also facilitate subsequent communication with the general lecensee.
3 T.OUTINE USES, The information may be used to provide records to State her.ltn departments for their information and use. The information may also be disclosed to appropriate Federal, State, or local agencies in the event the inf ormation indicates a violation or potential violation of law and in the course of an adminittrattve or judicial proceeding. In addition, this information may be transferred to en appropriate Federal, State, or local agency to the estent re6 event and necessary for en NRC decis,on or to en approonate Federal agency to the entent relevant and necesary for that egency's decision about yco.
- 4. WHETHER DISCLOSURE IS M ANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVIDtNG INFORMATION.
Disclomare of the requested information is mandatory. If the requested information is not furnished within 30 days of receipt of depleted urans-um by the person possess'ng asch depleted uraneum, he is sublect to criminal penalties under Sectiog 223 of the Atomic Energy Act of 1954. as amended, and to cMt penalties under Section 234 of the Act.
- 5. SYSTEM MAN AGE R(S) AND ADORESS Director, DMsion of Fuel Cycle and Material Safety. Office of Nucacar MaterialSafety and Safeguards, U S. Nuclear R egulatory Commission, Washington, O C. 20555.
APPENDIX G General License Study Analysis of Hazard 4
98
f f
APPENDIX G 1
GENERAL LICENSE STUDY - ANALYSIS OF HAZARD BASIS FOR ESTIMATING POTENTIAL HAZARD TO THE PUBLIC Estimation of the Ssnger to people that may' result"from misuse of harmful substances is an inexact process.
The process frequently involves the assumption of attributes and of a cm.in of events that are intended to circumscribe the effects.
In order to assure that no actual effect could exceed the estimation, upper bound values are assigned to the independent variables.
This inevitably
-leads to a " conservative" estimate of consequence that has little, if any, basis in reality.
In the case of missing gauges, we have chosen a more credible approach to the estimation of hazard to the public.
This credibility is made possible by an inventory of data from actual incidents that was used as a basis for our estimates.
Theedata are compiled in surveys of missing gauges, licensee incident reports, IE Information Notices and circulars, and the Honreactor Event Data Base.
Enough information is contained in these several sources of data to permit a determination of the potential hazard to the public from missing pauges.
The purpose of the following analysis is to estimate the range of effects that may arise from loss or misuse of industrial gauges containing radioactive sources.
The fate of these gauges is judged, on the basis of reported incidents, to advance through a credible course of events to an ultimate disposition.
We feel that the most probable consequences lie within the estimated range of
, effects.
A survey of missing gauges revealed that sLventy percent of them contained Cs-137 in quantities of 1 mci to 1000 mC1.
Since gauges containing Cs-137 comprise about one-half of the radioactive gauges in the field, it is expected that the number of those lost would be dominated by gauges containing cesium.
-Therefore, the following analyses are based mainly on the. fate of lost gauges
.containing 1000 mci Cs-137.
99
A ~ spectrum of occurrences involving misuse of gauges containing radioactive cesium has been selected.
These occurrences assume exposure to gauges under the following conditions:
1.
An intact gauge with shutter closed a.
Disposci in landfill, b.
Dissolved in a smelter; 2.
An-intact gauge with shutter open a.
Disposal in landfill,.
b.
Dissolved in a smelter.
The following Table is a summary of the potential hazard to the public that may accrue from the disposition of an industrial gauge that contains a one curie source of Cs-137.
The calculated doses are the maximum for a class of individuals who may be exposed to the gauge during the chain of events leading to the ultimate disposition.
4
=
100
J l
Estimates of Maximum j
Summary of Radiation Expnsure to People-From:
Mishandling the Disposal of General License Gauges Containing-a 1 Ci Source of Cs-137-I Typelof Case, People Expoced Estimation Radiation Exposure Intact Gauge w/ Shutter Closed Annual dose to worker 15.2 mrom whole body
[
Intact Gauge w/ Shutter Closed Disposal in Landfill-One-time' dose to millwright 0.3 mrom whole body Intact Gauge w/ Shutter Closed Dissolved in Smelter-One-time dose to millwright 0.3 mrom whole body One-time'dgse to smelter operator
<0.001 arem to critical organ One-time dose to populace negligible (<10 8 MPC in plume)
Annual dose to waiter / waitress
<7 mrom whole body One-dose to ironworker 100 arem whole body i
Intact Guage w/ Shutter Open One-time dose to maintenance / cleanup worker <100 mres whole body Intact Guage w/ Shutter Open Disposal in Landfill One-time dose to millwright 85 mrem whole body Intact Guage w/ Shutter Open Dissolved in Smelter One-time dose to maintenance / cleanup worker <100 mrem whole body One-time dose'to millwright 85 mrem whole body
'One-time dose to smelter operator
<0.001 mram to critical. organ One-time' dose to populace.
negligible (<10.s MPC in plume)
Annual dose to waiter / waitress
<7 mres whole body-One-time dose to ironworker 100 mrem whole body 4
101'
= -.
Following is a detailed description =of the scenarios that result in the estimated exposures tabulated above.
4 INTACf GAUGE _WITH SHUTTER CLOSED The Federal Regulations that govern the use of byproduct material contained in yougiseg" devices are incorporated in 10 CFR 31.5.
Section 31.5 invokes 10 CFR 32.51, which limits approval for use under ordinary conditions to 10 percent of radiation dose specified in 10 CFR 20.101(a).
Thus, the total occupational dose is limited, by regulation to 125 mrem whole body per calendar
. quarter.
In reality,_of course, the dose to workers in close proximity to such gauges is far less than the regulatory limit.
Measurements or radiation from industrial gauges have ranged between 0.2 mr/hr and 70 mr/hr at the surface of the shield.
Using the inverse square rule and a 2 cm separation between
- monitor and gauge surface, 70 mr/hr translates to about 0.08 mr/hr at 2 ft froin the gauge.
Thus, if a worker spent 10 percent of the 500 hrs of a working
. quarter 2 ft from the gauge, he would accrue a whole body dose of about 3.8 mrem in ne calendaraquarter, or about 3 percent of the regulatory limit.
INTACT GAUGE WITH SHUTTER CLOSED Disposal in Landfill Gauges used for level or flow measurement in heavy industrial applications typically weigh in the range of 100 to 700 pounds - too heavy for the average man to carry about.
Thus, our analysis assumes that a gauge destined for a landfill is handled and transported using such devices as chain falls,-fork lifts, and multi-ton trucks. We estimate that about six percent of missing gauges may_have been buried in landfills, but there are no actual measurements of personnel exposure during the transition from use to disposal.
Therefore, this part of our analysis is based on supposition.
In this case, we assume about two hours spent by two millwrights to disconnect and place a gauge on a pallet.
Of these two hours, 1/2 hr is spent at 1 ft from the gauge at 0.30 mr/hr and 1-1/2 hr at 2 ft from the gauge at 0.08 mr/hr.'o= a total dose to each worker of about 0.3 mrem whole body.
A forklif t operator who transports the
-gauge to a truck or staging area would be perhaps six feet away from the gauge 102
and receive less than 0.002 mrem during the 10 min required to load and off-load the gauge.
If the gauge is left in a warehouse for staging, no significant dose to man is assus.ied.
The driver of a multi-ton truck that transports the misplaced gauge to a landfill is assumed to be six feet away from the gauge during a one-hour trip.
During the one-way trip the driver will receive a total of about 0.012 mrem whole body dose.
Any member of the public exposed to the cargo along the route would accumulate a negligible radiation dose.
The bulldozer operator, who ultimately buries the device, will receive less exposure than the truck driver due to the shielding effects of the steel blade and massive structure of the bulldozer and the increased distance from tha gauge.
Thus, in this example, the maximum whole body dose to an individual.;, calculated to be about 0.3 mrem to a millwright.
INTACT GAUGE WITH SHUTTER CLOSED Dissolved in a Smelter This example of,the effects of loss of control of licensed material builds on the above case and measurements made in actual cases of contaminated steels.
It is assumed that the handling of the gauge from disconnection through delivery to the scrap steel yard is the same as that to the landfill.
Therefore, the exposure history is the same, resulting in a maximum whole body dose to an individual of about 0.3 mrem.
Added to these effects are those associated with the smelter and the resultant contaminated product.
Two well documented cases that involve dissolution of radioactive sources in a smelter have been reported.
These relate to a contaminated Mexican steel incident and a contamination of the Auburn Steel Company property.
Together they serve as a real, rather than postulated, basis for the estimation of the
' effects of similar events.
In both cases, the radioactive contaminant was cobalt-60, which is a common element in steels.. In the example case, cesium chloride is the contaminant, which upon melting, probably acts as a flux and ends up immobilized in the glassy slag or dross.
Or one may reason that, since the boiling point of CsC1 is 1290 C; and the melting point of ferritic steels is about 1375 C, the cesium is vaporized out of the melt.
Theorizing on the fate of milligram quantities of salts of cesium in ton quantities of molten 103
steel scrap is-highly speculative.
So for this analysis we assume that, on a weight basis, the cesium is distributed in the same way as the cobalt was in the real cases.
The events leading to introduction into the smelter are assumed to be dis-mantling, handling, :nd transportation, and are assumed to have the same consequence as the case of disposal to landfill.
Thus, the maximum whole body dose to an individual from handling is taken to be about 0.3 mrem.
It is common practice at a scrap yard to reduce scrap by shearing or oxy-acetylene cutting into sizes convenient for handling.
The shape of a gauge is such that size reduction by manually operated equipment would be performed by cutting the gauge away from the component to which it is attached.
In this case an intact gauge would be loaded to a smelter.
In some cases size reduction-is carried out using automated equipment.
This involves feeding scrap to a shear and taking sheared scrap away by way of conveyor systems.
In this case there is a remote possibility that the source could be sheared through.
The' product of the arobabilities:
of losing a gauge, of the lost gauge being sent to a scrap pile destined for smelting, of the scrap being sheared automatically, and of shearing precisely through the small source, is considered to be an exceedingly small quantity.
For this reason we have not estimated the conse-quences of this series of mishaps. We do note, however, that if cuch a low probability event did occur a costly cleanup operation may ensue, albeit accompanied by minimum exposure to personnel.
Once in the smelter, the radioactive contaminant may contribute to two exposure pathways. One is the inhalation pathway due to contaminated fume, the other is related to exposure to the contaminated product.
The exposure from inhala-tion may be estimated from the Auburn Steel Company experience.
The NRC Information Notice No. 83-16 that summarized the incident stated that 25 curies or more-of Co-60 was introduced to the scrap steel.
An estimate derived from analyses taken by New York State Health Inspectors shows that about 38 Ci of Co-60 was distributed throughout about 100 tons of product.
Therefore, we have assumed for this analysis that 50 Ci of Co-60 was involved.
Fifty Ci of Co-60 is equivalent to about 44 mg of Co-60.
Since 1 Ci of Cs-137 is equivalent to about 11 mg of Cs-137, and thus is comparable to 50 Ci of Co-60 on a weight 104
basis, we feel that an analysis normalized on a weight distribution basis is reasonable and have adjusted the Auburn Steel Company findings accordingly.
The maximum concentration of radioactive contaminant reported in a dust sample from inside the Auburn Steel Plant was 2900 pCi of Co-60 per gram of dust.
For Cs-137 contamination from a 1 Ci source the equivalent level of contamination would be about 60 pC1 per g of dust.
Process dust concentrations may run as high as several hundred grains per cubic foot, although usually not exceeding 20 grains.
Dusty factories or mines may be expected to have dust concentrations 8
of from 4 to 80 grains per 1000 cubic feet (9.2 to 184 mg/m ).
If one assumes that the maximum concentration of radioactive contaminant reported in a dust 8
sample existed in a dust concentration of 200 mg/m, the contaminant concentra-tion in plant would be about 1.2x10 12 pCi Cs-137 per al of air.
Cesium is the most active of the alkali metals and its salts are, in the main, soluble.
- The, 10 CFR 20 Appendix B maximum permissible concentration in air for soluble Cs-137 in unrestricted areas is 2x10 8 pCi/ml.
If a smelter operator breathed unfiltered air for one 8-hour shift at the calculated contaminant concentration he may be expected to receive a dose of less than 0.001 mrem to the critical organ.
The effects of deposition and resuspension are not considered here, because they usually add little to the primary effects.
Composite amples near the outlet vent of the Auburn Steel Company ventilation system showed a concentratien of 540 pCi Co-60 per g of dust.
With a conserva-tive aeolian dilution of a factor of about 1000, this would yield an equivalent unrestricted area concentration in the plume of about 2.3x10.is pCi Cs-137/ml of air.
This is less than one millionth of MPC for the unrestricted area and is considered negligible for the purposes of this analysis.
It is recognized that secondary effects evolve-from plant and product decon-tamination and disposal.
Since cleanup is carried out under controlled condi-tions that are intended to minimize exposure to' personnel, the consequence of-such actions is considered small relative to the initial accidental exposure.
However, the monetary costs may be significant.
As a case in point, Auburn Steel estimated that plant decontamination would cost 1.2 million dollars.
105
The Auburn Steel-Incident shed little light on the effects of distribution and use of the contaminated steel products.
One can calculate that one curie of
-Cs-137 homogeneously distributed in 100 tons of steel will yield a concentra-J tion of 11 nCi per g. of steel.
More instructive in this regard is the experience related to the contaminated Mexican steel incident as reported in NUREG-1103.
In this case it was found that the radioactive cobalt contaminant-was contained in minute " hot spots" of random location and intensity found in table pedestals and reinforcing bar.
One has little basis for assuming that small amount of cesium charged into tons of scrap steel for remelting would 4
behave differently.
The nature of the articles made from the reclaimed Mexican steel probably span the range of likely effects from the use of contaminated products.
In one case, the reinforcing bar, the dose to the user is a one-time experience; once covered with concrete the surface radiation levels are significantly attenuated.
In the case of the contaminated table bases, a continuous exposure of waiting personnel is experienced.
4 Although no estimate of average contaminant in the Mexican steel was given in NUREG-1103, one can calculate a greatest upper bound.
At the time of the incident, the source activity had diminished to about 400 curies of Co-60.
If one assumes that all of the source material was distributed in the estimated 500 to 930 tons of contaminated rebar that entered the United States, an average contaminant concentration of about 470 to 880 nCi of Co-60 per gram of steel results. We know that these numbers are overestimates because not all of the source material was introduced into the scrap and not all the reclaimed steel was processed into reinforcing bar.
However, _ the numbers compare favorably with the estimated 420 nCi of Co-60 per gram of steel contained in the Auburn Steel Product.
The non-contact exposure.to radioactive materials comes from the gamma emission that is coincident with decay. Although it is recognized that the energy of the gamma field is a consideration, it is conservative for purpose of our estimates, to consider that the gamma field is proportional to the curie content of the o
radiator.
If an industrial gauge containing one curie of Cs-137 were introduced 106
~
1 Into a smelter of 100 ton capacity and all the Cesium stayed in the steel, an average concentration of about 22 nCi/g of steel results.
This compares with our estimates of 470 to 880 nci Co-60/g of Mexican steel.
The contamination in products formed from the reclaimed Mexican steel was not homogeneously dis-tributed, instead it was in the form of radioactive specks.
Therefore, we feel that it may not be appropriate to normalize estimates of radiation dose on the basis of the curie content of the product.
We are confident that the radiation dose from products containing 470 to 880 nCi/G would not be exceeded by exposure to similar products containing 22 nCi/g.
Therefore, we feel justified in using the estimates of radiation dose contained in NUREG-1103 as an upper bound of the effects of use of steel products contaminated through the recycle of scrap i
containing industrial gauges.
In NUREG-1103, the NRC staff concluded that it was unlikely that any person who came in contact with, or spent time 17 the vicinity of, the contaminated rebar or table pedestals received a radiation dose above the accepted limits for radiation exposure to the general public or above 00T limits to transporta-tion workers.
{nthecaseofexposuretotablepedestals,awaiterorwaitress would receive a more likely dose of less than 1 mrem for a 32 day exposure, which equates to less than 7 mrem in a working year.
For an iron worker installing reinforcing bar in home basement slabs a one-tir.;e dose of about 100 mrem in a year would be received if he worked on four basement slabs containing con-taminated reinforcing bar during that year.
INTACT GAUGE WITH SHUTTER OPEN The determination of hazard to the public from an industrial gauge containing a 1000 mci Cs-137 source whose shutter is stuck open has a basis In an incident that occurred at U.S. Pipe and Foundry Company.. That incident involves a gauge with an 0.8 Ci Cs-137 source whose shutter was stuck open.
The removal of the gauge and handling during diagnosis of malfunction were carried out without knowledge of the true nature of the malfunction.
Subsequently, dose measurements and surveys provided a reliable basis for the estimate of exposures.
This exoerience an'd the conditions assumed in the case of an intact gauge with the shutter closed are the bases for the following analysis.
107
- _~
i Periodic maintenance of systems adjacent, or attached, to industrial gauges is assumed in this case, as is weekly cleanup activity.
Using the U.S. Pipe and Foundry experience, which includes radiation surveys of the malfunctioning gauge, these activities would result in less than 100 mrem of whole body exposure to any individual engaged in maintenance or cleanup activitie:.
In the case of maintenance activities such exposure would be infrequent, perhaps
"~
once every four to six months.
In the case of weekly cleanup activities we assume; due to personnel rotation, shift tours, vacations, etc., that a particular individual's exposure might occur once every month.
If one further assumes that the malfunction is discovered one month after it occurs, the maximum exposure to an individual engaged in either maintenance or cleanup is less than 100 mrem.
J INTACT GAUGE WITH THE SHUTTER OPEN Disposal In Landfill 4
In this case weeassume two hours spent by two millwrights to disconnect and place a gauge on a pallet.
Of these two hours, 1/2 hour is spent one foot from the gauge at 100 mr/br for a total dose to each worker of about 85 mrem whole body dose.
A forklift operator who transports the gauge to a truck or staging area would be perhaps six feet away from the gauge and receive less than a 0.5 mrem dose during the 10 min required to load and off-load the gauge.
If the gauge is left in a warehouse for staging, no significant dose to man is assumed.
The driver of a multi-ton truck that transports the misplaced gauge to a landfill'is assumed to be six feet away from the gauge during a one-hour trip.
During the one-way trip the driver will receive a total of about 3 mrem whole-body dose.
The bulldozer operator, who ultimately buries the device, will receive less exposure than the truck driver.
Thus, in this example, the maximum whole-body dose to an individual is calculated to be about 85 mrem.
108
INTACT GAUGE WITH THE SHilTTER OPEN Otssolved-in-Smelter This case is identical with the case of the Intact Gauge With the Shutter Closed Dissolved in Smelter.
EFFECTS OF ISOTOPIC SPECIES Althoup the probabilities of a missing gauge containing Cs-137 are greatest, there is a significant probability, albeit smaller, that a missing gauge may cont.ain Am-241, Kr-85, Cd-109, Sr-90, Co-60, or Ni-63.
The exposure rate, expressed as R/hr at im/C1, for Co-60 is at least 4 times the rate for any of these other isotopes.
The exposure rates and doses given in the foregoing analyses are based on emission from co-60. -Thus, the non-contact exposure for any of the isotopes of interest will be equal to, or less than, those given.
Thereremainstgeconsiderationofcontactexposure,whichinthesecasesis assumed to arise from inhalation.
The exposure of the population to radioactive aerosol from a smelter was attributed to the release of Cs-137 at a concentra-tion of 10 8 MPC in the plume.
This was normalized on a weight basis using the Auburn Steel experience as a premise.
The most restrictive concentration associated with the isotopic species listed above is attributable to Am-241.
On a comparable weight basis assuming a 1 Ci source of Am-241, the unrestricted area concentration in the plume would be about 8.5x10.ta pCi Am-241/ml air.
This is less than one ten-thousandth of MPC for the unrestricted area and is thus considered negligible for the purposes of this analysis.
OTHER OCCURRENCES The foregoing analysis has been limited to an estimate of the cost probable
. consequences.
They may be ascribed to a credible course of events involving-lost or_ missing gauges. - One may speculate that more drastic events would give rise to great'er consequences.
However, experience belies that position.
109
m..
h i
I Industrial gauges have survived, with source intact, such assaults as fire, dust explosion followed.by fires, and being run over by earth moving heavy equipment.
Thus,.it is our judgment that the consequences reported exceed the effects of what may be viewed as more stressing events, 4
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APPENDIX H Compatison to Specific Licensees e
111
l Comparison to Specific Licensees Similar and in some cases the same types of gauges are used by specific j
licensees.
These devices are normally constructed and installed by the same methods used for the general licensed gauges.
Users of specific licensed i
gauges must have a two to four hour radiation proter, tion course before they will be licensed for use by a regulatory body.
These rsers are not usually required to have personnel monitoring or survey instruments and are hound by similar licensing requirements as the general licenses, f.o., perform leak tests restricted relocation and disposal.
Probably the big';est difference between the two types of licenses is that specific licenses have named users for supervising and controlling the use of the licenstd gauging.
A survey of 359 inspections reports on specific licensees was done.
The inspections occurred between 1974 - 1984 and were for ifconsed fixed gauge installations.
Below is a list of deficiencies and the frequency of non-compliance areas stop which they were started.
4 0 Performing unauthorized service / maintenance on a gauging device 10%
0 Transfer of a gauge to persons other than a specific licensee 6%
0 Performing unauthorized relocation of a gauge 9%
0 Failure to dispose of the gauge by transfer only te a specific licensee.
(The final disposition of these gauges could not be determined by the general licensee or the NRC.)
2%
Failure to maintain records 17%
Failure to leak test at the correct time interval 45%
During the specified time frame 7 gauges were lost representing 2% of the survey populace.
They were:
Number Activity Range Isotope 3
unknown isotope and activity believed to be Cs-137 100-500 mci 112
.e APPENDIX I Information Notes Sent to General License Users and Vendors
'see 113
l g
UNITED sTATss
[
NUCLEAR REGULATORY COMMIS810N s
WAeHINGTON, D. C. 30006 JAN 811985 j
l l
BYPRODUCT MATERIAL LICENSING INFORMATION NOTICE
(
)
Addressees:
All persons possessing gauges and similar devices containing radioactive material covered by the Nuclear Regulatory Commission's general license in 10 CFR Section 31.5.
Purpose:
To resrind all persons possessing gauges and similar devices containing radioactive material that there are NRC requirements for testing, maintenance, transfer or disposal 1
of these devices.
I Discussion The Nuclear Regulatory Cosmission (NRC) has provided in its regulations 4
under 10 CFR Part 31 for a general license allowing commercial and industrial devices contFining radioactive, i.e. purchase and use gauges and similar, by without applying firms, institutions and agencies to for a specific NRC license. The provisions of.their general license in Section 31.5 require that the manufacturer of the device have a specific license and that the purchaser accept certain responsibilities detailed in the general license.
persons utilizing this general license have important responsibilities. For instance, they must (1) assure that leak testing is performed at the speci-fledintervals;(2 ma9ntain labels in legible condition (not removed or painted over); (3))make sure tivat the initial installation of the device Plus the leak testing a.1d any subsequent moving or servicing involving the i
radioactive material, the shielding, or the containment are performed by a
, person holding a specific license to perform these activities; (4) transfer i
the device only to persons holding a specific license or to another poneral i
licensee if the device remains in use, or stored for future use at the same location; and (5) dispose of the device after Its useful life only by transfer to a person with-a specific license covering the possession of
.i byproduct material or the disposal of radioactive wasta.
'k Problem Areas L
-In a survey conducted in 1984, the NRC staff found that general licensees have at times failed to meet certain requirements in Section 31.5 and thus j
caused unnecessary risk to public health and safety. Examples of some i
risks caused by improper activities are given below:
l
-2 JAN 31 f985 Egloyees of one general Itcensee performed unauthorized maintenance o
on a gauging device, Employees who lack training in dealing with radiation and radioactive materials and who do not have proper radiation instruments can cause unnecessary exposure to themselves and other egloyees within the area, In another case egloyees relocated the device within the plant.
o There may be exposure risks to the workers and other egloyees in the area during the move, and risks are greater if workers lack training and proper equipment.
In the new location, the gauging device may not have the same shielding it had before and may have areas of high exposure.
Also, the new location may involve conditions of temperature, dust, or corrosive environment which have a deleterious effect on the gauge.
Trained workers and special equipment are needed to measure the radiation levels around the gauging device during the move and after the new installation, A person utilizing a gauging device did not follow the instructions o
~
prescribed by the gauge supplier.
This resulted in failure to (1) test for leakage of radioactive material at specified intervals (2) perfonn tests at specified time intervals to determine proper operation of the on-off mechanism and indicators, (3) assure that the labels. affixed to the device remain legible and 31.5 generale1Icense.(4) assure compliance with all other terms of the Section Failure to meet these requirenants means that radioactive material could have leaked from the device or faulty operation could have caused unnecessary risks to health and safety over extended periods because the hazards were not detected.
The original owner of a gaugin o
sale of the plant and equipment (g device did not notify the NRC of the including the gauging devices) to a new company. When contacted by the NRC during the general license study, the new owner had egloyed a contractor to remove the old equipment and had no idea where the gauging devices were.
In uncontrolled surroundings, where the presence of radioactive material may not even be known, the unidentified gauging devices could cause radiation exposures to members of the general pub 1< c.
The NRC staff has found that some gaugin'g device users did not even o
know the location of their gauging devices.
In many casts, they assumed that the devices had been disposed of but did not know where or how.
The NRC has learned of disposal methods that included on-site burial, off-site burial, or removal as scrap steel by recycling coganies.
Since persons receiving material for disposal or scrap recycle do not
&J test incoming materials for the presence of radioactivity, they may not be aware that it is present.
If the device follows one of the above pathways and is damaged in handling, it could cause contamination of the receiver's equipment, or of nis plant, his egloyees, or his product.
This contamination could beco'me widely distributed before being detected, possibly causing serious risks to public health and safety.
D<sposal of gauging devices after their use MUST be entrusted only to someone specift-cally licensed for this activity.
In most cases, the gauging devices should be returned to the manufacturer for disposal.
r
l JAN 811906 3-We strongly suggest that you review the above incidents and the instructions provided to you b,r the device supplier to determine whether you are in compliance with t w Section 31.5 general license, a copy of which is attached.
j If you find items of non-coupliance, they should be corrected inmediately, i
If you have questions about the devices, the regulations, or your proposed j!p correction method, you should contact the device supplier or one of the NRC Regional Offices listed below:
U. S. Nuclear Regulatory Commission Req 1onal Administrator, Region 1 i
63' Park Avenue King of Prussia Penns;rivania 19406 l
Telephone (215),337-502
)
U. S. Nuclear Regulatory Commteston i
Regional Administrator, Region !!
101 Mar 16H Street, Suite 3100
~
Atlanta, b % ic 10303 l
Telephons U4d 121-4503 U. S. Nuclear Regulatory Connission Regional Administtator, Region !!!
i 799 Roosevelt Road Glen Ellyn, Illinois 60137,,
Telephone (312) 790-5500 U. S. Nuclear 2egulatory Consission Regional Administrator, Region IV Parkway Central Plaza Building 611 Ryan Plaza Drive. Suite 1000 Arlington,(Texas 76011817) 860-8100 Telephone U. S. Nuclear Regulatory Connission Regional Administrator, Region Y 1460 Maria Lane, Suite 210 Walnut Creek, California 94596 Telephone (415) 943-3700 q(
If you have any questions about this information notice, please contact Nr. Steven Baggett, Naterial Certification and Procedures Branch, U. S.
Nuclear Regulatory Consission, Washington, D. C. 20555, or telephone m
(301)427-9005.
yMfA= -
b ichard E. Cunningham, Didctor Division of Fuel Cycle and Naterial Safety, M455
Enclosure:
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APPENDIX J
" Photographs" 1
114
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.2-STATIC ELIMANTOR 4
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g CARPET MILL EQUIPMENT ':
FOR SALE LIQUIDATION EQUIPMENT OFFERE 0F EQUIPMENT DEPENDENT ON COU PARTIAL LISTING... BUILDINGS AN FIVE DISTRIBUTION CENTERS. CHEM TEX Ll0VIDATOR FOR TREND MILLS, WWG, INDUS l
g4 g, p fs ' ~
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LEE Prontmaster Coater Control System M
Warper.Hanson Model'XI.with croel model 5arit seams.32, w 30 es,26 wbod S WeTFood Shear,large Revch, Ant Beams.28' & 30 alum.
Head Shear, Ent system be Singer 1/10 ga. level loop with beam rack Dye Beds 12 R.15 ft, and Jumbo TUFTERS and roikJp
. Singer.006 ga. level loop with beam rock P A S Dryers Southem 1110 ga. level loop with beam rack and rolkip 10 loop Accumulator Carpet Cut Head, Ron-up & Wrap Unit Cobble 1/6 ga, level loop with beam rack and 8 Color Flat Bed Printer with steamer and rolkJp rollup 6
Card 5/32 ga. cut pile with croel and to#4pKuster une with (2) Double TAK, Chemical Cobble 5/32 ga. level loop with beam rack Pad, Wash Box, Steamer, Dryer
~mnd rulisp Southem 1/6 ga. cut pile Scio!! with creelSample Kuster Pad Sample kuster Double TAK Card 1/10 ga. cut plie, Hydra Shltt, creet and 405 Sections of Racks 22 ft. high,10 ft.
andtonsp Cobble 1/10 ga. cut pile, Super Shifter, creel wide,6 Shelves rolR8p i
and rolk8p MOR Cut Order System with S!!tter Southem 5/32 ga. cut pile, creel and ron-up Southem 3/16 ga. cut pile, creel and roll-upMOR Random Order System 16 bay with Southem 5/t6 ga. cut pile, creel and roll up carts Card 3/16 ga. cut loop, croel and ron-up Sample Equipment AllTypes Card 1/4 ga. cut loop, creel and ro# up Shop Equipment AllTypes l
Air Compressors. 5 H.P. to 60 H.P.
-Bollers. Keystone 60,000 lb/hr. WT. D.A.
Latex Compound System with Silo, UrethancSystem Water Softner System System
/
Office Equipment 30 ft. 3 pass toam Oven 150 ft. Latex Oven run speed 100 ft/ min EQUIPMENT SHOWN BY APP 0I CHEM-TEX MACHINERY, INC I
n O
P.O. Box 460
- CHATSWORTH, GEORGIA 30705 v
404-695 6247 or 695 9311
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i APPEN0!X K-l
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. c t
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e Distribution and Redistribution
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t s. nucle An ntoutAtony couurssiow hiAILRIALS LICENSE knendment No.
(l Pursuant to the Atomic l nergy Act of 1954, as amended, the 1 nerry lleorganization Act of 1974 (Pubhc law 93 - 438 4
Code of I ederal Hegulations, Chapter 1. Parts 30,31,32,33,34,35,40 and 70, and in reliance on statemen
.j heretofore inade by the hu ntee, a hcense is hereby issued authoniing the licensee to re(che, acquire, possess, and transfer byproduct. N j
source, and spenal nuclear material designated below; to use such material for the purpose (s) and at the place (s) designated below;to if i4 dehver or transfer such material to petsunt authorited to receive it in accordance with the regulations of the apphcable Part(s) 1 his %
hante shall be deemed to contain the conditions specified in Section 183 of the Atomic inergy Act of 1954, as amended, and is h subject to all apphoble rules, scrulatio's and orders of the Nuclear Regulatory Cornmission now or hereafter in effect and to any %
q y
conditions speufied below.
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IAenter q
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any town U.S.A.
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- 5. Docket or f'\\'
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Reference No.
p 7, Chemical and/or physical Q.,Maxbnum amount that licensee
- 6. liyproduct, aource, and/or special nuclear insterial form
', inay possess at any one tirne
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V sfqder this license 1j
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Sea $e Sourcedoda.1$t[,
A. CNot to exceed il A.
Isotopes:
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Authorized use g
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Pursuant to 10 CFR 32I51, the licensee is authorizedt to ' receive, store, p
C demonstrate, and redistribute devices containing sealed sources listed in l
Section 10 of this license to, general licensees.as defined by 10 CFR 31.5 or equivalent provisions of an Agreement 1~.5 tate.
!1 S
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CONDITIONS X.-
ig l
10.
The following sources or devices inay be distributed to the tenns and conditions lb!
of this license:
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DEVICE MODEL SOURCE MODEL NUMBER TYPE OF DEVICE MAXIMUM TOTAL ACTIVITY:
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11.
Licensed material shall be located only at:
(Authorized site address) d
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MATERIALS LICENSE
- $UDLEMENTARY SHEET l
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CONDITIONS (Continued)
- 12. Licensed material shall ha cwrolled by, or under the supervision of, l
?
- 13. Sealed sources and devices containing licensed material shall not be opened.
n 14.
The licensee shall assure that each device distributed contains instructions and i
Isbels as required by 10 CFR sections 32 Labels and instructions provided by the manufacturer'.wjthi sealet,t51 and 32.51a.sodrcjejnddevice*
l removedoralteredbytheilihnsee.
4,4 with the provisions of Tit 1, Code of Federal
- 15. The licensee shall c ReRulationsg Part 19) " Notices, Instructions, and Repoft to Workers, i
Inspections, an art-20, " Standards for Protectigngga t Radiation".
~
3 The licensee shdif mainEa'ihEransfer records afi it qu'ai erly transfer 16.
reportstoNRC,'andAgreementtlStdes Wecco ange.With 10 Cf Section 32.52.
The licenseess6N1 -conduc ice's rg eied and,p~opsesse psica'k inhent 17.
e a
for all source -and/or(dev v
each inventory jriventorths shalb e piMtainedlfbr, d(kinds of' byproducttwas(2 Records of the and shajhincInde the quahtities an i
material, locat{og of sea % sourci@(Nektgq p e datslof'the intentory.
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Except as specifica'11y pr9
. otherw he licensee shall conduct its progreg'1i accordahceCwi$ise in' thiplicente 18.
s
/
theist 4tepients..re resentations, and in, the documents IMiuding'any encjosures listed below.
procedures contained,i"Copuission's re'gulations shalt govern unless the l
The Nuclear Regulator correspondence are mord' rest,rjetive than the re ulations.
.A.
Application dated:
Y k "$' I i 1
I FOR THE U.S. NUCLEAR REGULATORY COMISSION
'~
DATE BY Medical. Academic, and Comercial Use i -
Safety Branch i
Division of Fuel Cycle. Medical, Academic and Coisnercial Use Safety Washington, D. C.
20555 t
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3 li PAGE
- or PAGr5 4 rn ser U.S. NucLt AR REGUt.ATORY COMM11&lON l
M AT ERI AL.S l.lCENSE Amendment No. 04 l
l Pursuant to the Atomic l'.nergy Act of 1954, as amended, the Energy Reorganintion Act of 1974 (Public Law 93-438), and litle 10, 4
Code of Federal Regulations, Chapter 1, parts 30,31,32,33,34,35,40 and 70, and in reliance on statements and representations
'p q
heretofore made by the thensee, a license is hereby issued authorldng the licensee to receive, acquire, possess, and transfer byproduct. l>
source, and special nuclear material designated below; to use such material for the purpose (s)and at the place (s) designated below; to )
4 deliver or transfer such maternal to persons authorized to receive it in accordance with the regulations of the apphcable Part(s). This >
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hcense shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is f
subject to all applicable rules, regulations and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any q
conditions specified below.
')
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In accordance with letter dated i)l 8
September 21, 1983 I,
Fife Corporation
- 3. Ucense number 35-15511-03G is amended in l
222 West Memorial Road its entirety to read as follows!
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4l 'EipIr ti[nd te, March 31, 1989
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- 5. Docket or
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Reference No, p
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- 6. liyproduct, source, and/or A
- 7. Chemical and/or physical
- A Maximum amount that !!censee i
.fnay possess at any one time 1
I special nuclear material form r
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,C) dpder this license l
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-i(,Conditio}fi d'i n i A.) Not applicable l
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As specified in i
Conditiony0.\\
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Authorized usg sj
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Pursuant to Section.32.51] 1(CF,R{ ?4rt! 32x the,li',ensee $,
V,, t, ;la. g4' j g i if a 1
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c is authorized to i
I distribute theldevices conta'ining; seal'hsources specified in Condition 10.
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of this license to persbns tgenprally:licensedjursuantdo Section 31.5,10 CFR Part 31 or egyivalent prov1p% (ofc'theDgulattoi s of any Agreement io
?
b State.
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CONDITION %,-
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l 10.
Each device distributed pursuant tofthe'tenns and conditions of this license
!,p shall be in accordance with the following table:
ln s
l Source Holder Source Model Maximum Activity Per lb i
_Model Number Number Isotope Source (millicuries) f>
a l
Fife Model SHR-1 Amersham Corp.
Krypton 85 100
$l Model KAC.4 p
l Fife Model THR-1A Amersham Corp.
Krypton 85 100 h
1 Model KAC 4 i
l Fife Model SHR-1 Amersham Corp.
Strontium 90 10 SIC /W33 or SIAI I
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it' h
4 ih 4
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pranyTn*1'2'as IPO%*1*T3'1"E*1*mT3"30E*M*1Wa*3M*A*M*A'Wif3"MONAT1*1V'1"13 4
N:c r..- a t 4 A u.s nuctr An atcutAtony commission 3
y gt og qqt 4
o sai luenu number 4
35-15511-03G
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MATERIALS LICENSE I
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$UPPLEMENT ARY SHF ET l
4 d
Amendment No.,04 i
4 4
l CONDITIONS I
(
10 continued 1
i 3ource Holder Source Model Maximum Activity Per I
l Model Number Number Isotope Source (millicuries) n a
Fife Model SHR-1A Amersham Corp.
Strontium 90 10 l
t SIC /W33 or SIAI i
8 i
8 Fife Model SHR-1 Amersham Corp. r. PrQmethium 147 200 i
l (modgiedPHC.16) C ' j [>> (.
PHC/Q880.x 0 s l
i 3
a V
'fA I
Fife Model SHR-1A Amersham Corp.
Promethium.f47 200 i
PHC-Q880-
\\
(modified PHC.16)
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0
's
( /;
,,/
l 8
i Fife Model SHR-5)
New Engiqnd Krypton,85' 1000 l
l r,
Nucles r+]iE8-585p., s [ '/;[
O I
K tonb5 O
FifeModeleSHR(5 Newbnglnd
[1 %rG ;/a,'
600 l
4 i...
Nuclear;NER-586 f
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Ambrsham-Corp'.l rl > St'rontiurii 90 '
42 50 I
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Fife Model SHR6 SIF 01'(formerlyl 4K e,'
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y SIF.1177)R.i)i),)\\ ic;p, ' '
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,,i Fife Model SHR-5) AmerihadCorp' /,,' ' Krypt' h 85 o
'O 600
$1 i'
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- KAC.03 W 4; Q'
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, -l J 11.
This license does not adthorize possession or uselof licensed material.
I
- 12. Af ter installation by the liceris' e o'fe cacti d vice distributed to persons
~
generally licensed pursuant to S ction 31.5 of 10 CFR Part 31, the licensee p
shall conduct a radiation survey and shall assure that the levels of radiation p
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do not exceed those specified in the license authorizing the manufacture or i
4 distribution of the installed gauge.
The licensee shall furnish the general l
q licensee a copy of the radiation survey report.
l I
13.
The licensee shall file periodic distribution reports in accordance with 10 CFR 4
H Section 32.52.
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4 35-15511-03G
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t uenu numwr W
M ATERIALS LICENSE
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SUPPLEMEN T AnY $HE ET b
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f ll Amendment No. 04 4
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COND1110NS jb
- p (continued) l l
14.
The licensee shall test each device distributed under this license for leakage l
or contamination of radioactive material and proper operation of the "on-off" j)
W mechanism and indicator, if any, at the time of installation of the device.
Il a
il 8
15.
Except as specifically provided otherwise by this license, the licensee shall
}
possess and use licensed material described in Items 6, 7, and 8 of this license p
l in accordance with statements V represehtitJqns and procedures contained in p
q applications dated Febrbarye12,1973, February / 20,1973 February 21, 1973, h
March 6,1973, June.'end SeptemberIu1973 June 6, 1973 June'2 f
I a
September 19, 1978,s 28, 1978; and letters dated February 27, 1980, i
4 Oct'ber 12, 1978, December 9,1981,' arid September 21, 1983, l
8 August 11,1981,fatory Connission's regulations shal) g@ern the licensee's o
l The Nuclear Regu y
statements in applicat.fons or letters, unless,the~ statemehts are more p
4 restrictive tharp the regulations.
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i Date:
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- Medica b and Coninercial Use Safety Branch b
'J.. p'p~, Division of*'IndustriaV and Medical i
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('/, ; " Nuclear; S)D.C. - 20555 l
\\S fety, NMSS 4
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TMT1*A*1 TAT &T. EfMMM14NTOTE1TMEMA*1TM'GT1*A*EI?11?A"1*1'XiEf@%I%*3E*J 4
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' is 444 U.S. NUCLE AR REGULATORY COMMIS$l0N O' -
"#0I8 j Amendment No. 04 j
MATERIALS LICENSE Pursaani to the Atomic Energy Act of 1954, as amended, the Energy Reorgantiation Act of 1974 (Pubtle Law 93-438), and Title 10, Code of federal Regulations, Chapter I, Parts 30,31. 32,33,34,35,40 and 70, and in reliance on statements and represe heretofore made by the hcensee, a license is hereby issued authorizing the licensee to recche, acquire, possess, and transfer byproduct, g source, and special nuclear material designated below; to use such material for the purpose (s) and at the place (s) designated below;to h dehver or transfer such material to persons authortred to receive it in accordance with the tegulations of the applicable Part(s). This 1 heenu shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is J subject to all appikable rules, regulations and orders of the Nuclear Regulatosi Commisuon now or hereafter in conditions specified below, g
in accordance with application dated j
unnue January 9,1986, a
j 1.
Princeton Gansna-Tech, Inc.
3 Ucenu number 29-12783-02G is amended in ill 1200 State Road its entirety to read as follows:
Princeton, New Jersey 08540 p
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4; Expira'tlo'n date May 31, 1991 i
I Yd30-10673
- 5. Docket or I
,T.
Reference No, l
- 6. Dyproduct, source, and/or
- 7. Chemical and/or physical a d., Maximum amount that licensee I
special nuclest material form f
i
' ;.may possess at any one time l
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'G uqder this license rij e
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' O As 'siedified irt }[
A I
A9 Not applicable A.
As specifled in I
G / Condition 10' }
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Condition 10 e 1
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9.
Authorized use i
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Pursuant to Se)ction
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- r 32.'51, 10 CFR Part: 32, the licensee'is, authorized to I
A.
distribute the devices containin'g' sealed sources specified in Condition 10. of I
this license to personsigenerally licen"ed pursuant to Se'ction 31.5,10 CFR Part 31 or equivalent provisionsgof the regu.atio,ns of any Ag'reement State.
(i y
y, COND)TIONS
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g
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10.
Each device distributed pursuant to the terms and conditions of this license k
shall be in accordance with-the,following table:
.> 1
- (
5 Device Model Source Model Maximum Activity l
Number Numbers Isotopes Per Source g
Princeton Gamma-Amersham 13145 Americium 241 30 millicuries i@k Tech Model 100 or AMCL or Dupont Chemical Analyzer (NENProducts) l i
NERL 478C
(
Princeton Gamma-Amersham 13053 Cadmium 109 5 millicuries Tech Model 100 or CUC DIN or 4
ChemicalAnalyzer Dupont(ilEN Products)NER-465 i
1 Arnersham IEC-1336 Iron 55 50 millicuries orDupont(NEN 4
Products)NER-460A, 4
i lJ NER-4608, or NER-462 k
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l N*C f cem 374 A U.S. NUCL t An CEGULATORY COMMiss60N 2
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pang op p3gg g
it e s t L4 ten,e number i
29 12783-02G i
MATERIALS LICENSE pa,i ot nererente asE l
SUPPLEMENTARY SHEET 030-10673 I
I Amendment No. 04 I
I i
CONDITIONS I
I (10. continued) i I
Device Model Source Model Maximum Activity l
l
_Numbe r Numbers Isotope Per Source I
i Amersham CLC 13044 Curium 244 10 millicuries I
or Isotope Products I
PH1244-10 t
l Outokumpu Elec-AmershamANO62 b d.r(ciym 241 30 millicuries i
tronics Model 840 capsule X10/0 or L.,o l
Portable X-Ray
.V" 7p i
l Analyzer g4 g
l Dupont(NENProd.) Americium 24) %
10 mil 11 curies I
~
- 478' capsule LE316 or
). 2,7 J-.
i
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Isotope' Products
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l ca O
l i
e PH-241-f %
)psuleJXfjl $ 3.
Q
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AmershaMCUC 13052{Cadmfym-109 20 millicuries l
l 3 capsules 130 a"
.Du ant t (NEN p/S~or" Y'dv.
r j,
t l
l net 465'capsd;LEp6#pM,,./ 4 ?
oducts) l
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or Iso, tope Prodilett jh;' 4J 9'
N l
i
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PH-100capsu)4MFB(1
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" Amer'shamI"113044( (uri $ 244
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,-Nig s
., d 100 mil 11 curies I
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capsuleX130(4Jje g-l Am$'r'shamIECor Iron 55 h 40 millicuries I
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Dupont'(NENdroq.*7JFon55 10 millicuries s
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I NER-460A capsule n
I LESSD or Isotope I
Products PH-55 i
capsule XFB l
l
- 11. This license does not authorize possession or use of licensed material.
or $enerally licensed device shall be installed by the licensee in such a manner 12.
No j
n such a location that any person could receive more than 0.5 rem in a i
mdar year under ordinary circumstances of use, l;
13.
The licensee shall furnish to each general licensee to whom he transfers a devices pursuant to this license, a copy of Section 31.5,10 CFR 31; Sections I
p.
I 30.34 and 30.51, through 30.63,10 CFR 30; Sections 20.402 and 20.403,10 CFR i.
l 20, and-Appendix 0., 10 CFR 20.
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M ATERIALS LICENSE gjiggig;;;gg,m, SUPPLEME NTAnY SHEET 030-10673 Amendment No. 04
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E d
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CONDITIONS W
k (Continued) 4 d
- 14. Af ter installation by the licensee of each device distributed to persons l
generally licensed pursuant to Section 31.5 of 10 CFR Part 31, the licensee i
shall conduct a radiation survey and shall assure that the levels of radiation i
e do not exceed those specified in the license authorizing the manufacture or l
distribution of the installed gauge.
The licensee shall furnish the general licensee a copy of the radiation survey report.
p The licensee shall test each dqIfte diskr'i$uf d.under this license for leakage 15.
or contXination of radigqc't ye material and'hrop operation of the "on-off" 1
mechanism and indicat6 t if any, at the time of i,egtajlation of the device.
l.
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16.
A.
Each device dis ributed under this license sha car a durable, clearly l
visible and legible label or labels containing3the)followingor
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substantially simila statements:
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i
" Receipt, possess grg use and,trp/'[(/
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[,
I s
nsfeb of this dd. ice are subject to a q
1.
general license'or equivalent'and regulations oGe U.S. Nuclear (g
4 ggul,atory Conniiss n or/an Agreement State."
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specificallytlicensed.b). prohibited 1Unless,,transfeYredtopersons "Abandonmenthor disposh j
'thejU.kNuclear Regulatory Comission or an Agreement Stat ( A y.,l d.)t)i,',1 A D
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4
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" Operation prohilif tnd if there is indication ofifailure of or damage l
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to shielding,' source containment or o'n-off mechanism."
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4.
" Installation' dismantling', relocation, ma(in'tenance, repair and q
testing involving the radioactive materiai, its shielding or l
W containment shall be pqrformed by p'efsons specifically licensed by the p
4 U.S. Nuclear Regul& tory lComission or an Agreement State."
p d
5.
"The device shall be tested for radioactive leakage and proper k
i functioning of on-off mechanism and indicator, if any, at t
l installation, at source replacement, and thereafter at no longer than F
q six (6) month intervals."
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6.
" Loss, theft, or transfer of this device and failure of or damage to p:
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the shielding, the source containment or the on-off mechanism must be L
4 reported to the U.S. Nuclear Regulatory Comission or an Agreement i:
State.
fit B.
Each device distributed under this license shall bear a durable, clearly I
visible and legible label or labels containing the device model and serial y
number, tne radiation symbol in colors magenta or purple on a yellow i
background, the words " CAUTION, RADI0 ACTIVE MATERI AL" or " DANGER, k
RADI0 ACTIVE MATERIAL " the quantity, identity and date of measurement of A
the radioactive material, ano the name of the distributor of the device.
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VV1ntW1TFMWCWMLWMIGWR3WR&TRIXWR@WWAWRRFL**%'OW*WA'KMWW g S c,.. u.4 u.s nucts An moutAto.w couMission 4
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4 w sal Laenu numter n
's 29-12783-02G L
q M ATEltlALS EICENSE 3,a, g, prm nc,,,,g,,,
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$UPPLEMENT AnY SHE ET 030-10673 j
j Amendment ho. 04
[
f CONDITIONS I
(Continued) w 8
C.
Each label required by this condition shall bear the statement, " Removal of [
l this label is prohibited."
p l
- 7.
The licensen shall report to the Medical and Comercial Use Safety Branch, I
(
Division of Industrial and Medical Nuclear Safety, U.S. Nuclear Regulatory d
Connission, all transfers of devices distributed under this license to persons 8
generally licensed under Section o'1.5, 10 0FR 31. Such report shall identify l
each general licensee by name and address,.,the type of device transferred, the 4
quantity and type of licensed' material 8contginef in the device, &nd the specific y
location where each device.is installed.
The' report shall be submitted within thirty (30) days after. th~e end of each calendar quartpr in which any such device d
is transferred to a generally licensed person.
'O 8
18.
Except as specifically provided otherwise'in this,licen,b the licensee shall l
conduct its program in accordance with the statgment's, rehresentations, and procedures contained in the documents inclupipb&ny enclosures, listed below.
The Nuclear Regdlatory Connistion's statements, rep.'resentationf hnd proc.regula}tions.s' hall gov'edn unless the edubes ih 'th'e licensee' l
correspo idgncet,are more rest (ictive, ths,n thej {eg'ulations.'";3 applica i
LetterdatedApril21o19'7h,),.,-.-
, ', /,'
8 A.
8 Application dated January',19.198pi it'g iRp' d
B.
1 836
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.~FOR-TiiE.U.S.NUCl.tARREGULATORYCOMMISSION l
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h Date:
( By:
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.( Medical and comercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
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Washington, D.C.
20555 L
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l APPENDIX L Industry Environment t
116
APPENDIX L In response to the problems encountered with radioactive devices ending up in recycled scrap, several state and private organizations have initiated radiation detection programs.
A steel scrap dealer in Pennsylvania, for example, installed radiation monitoring equipment as a direct result of the Mexican steel incident.
The equipment later detected a st.at'ic eliefnator containing radium-226 in a load of scrap that was about to be used as a feed stock by the plant.
Several states have also initiated their own radiation monitoring programs.
-Illinois currently has 45 state enforcement patrol cars equipped with scintillation type monitoring systems and plans to purchase 20 additional units for installation at fixed monitoring sites in weigh stations throughout,
the state.
All state troopers using the monitoring equipment must take a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> training course which teaches basic rad,'ation physics and monitoring techniques.
California operates about 40 similar monitoring stations and maintains sever 61 hazardous cargo patrol trucks equipped with radiation detection equipment that is in continuous use when the truck is being used.
Los Angeles also operates five detection systems at control points for their sanitary landfills.
Other states that have studied or set up monitoring programs include Florida, Mississippi, Georgia, Maryland, South Carolina, Kentucky, and Michigan.
Although most states have some type of radiation monitoring capability, this equipment is usually reserved for response to specific incidents or in con-nection with radiation control regulations and enforcement programs.
- However,
.various contaminated steel incidente hwe raised the general awareness and interest of a number of state and commercial or'ganizations in developing and installing radiation detection systems. 'This interest was reported by several equipment vendors that were surveyed during an NRC sponsored study of the feasibility of detection systems (NUREG/CR-9357, 85).
4 Several companies offering environmental monitoring and detection systems a re also surveyed.
The purpose of the surveys was to determine what type of I
monitoring equipment and services were available to scrap dealers, and whether 117
=_
=.- -
dealers were using the services.
The surveys revealed a wide range of sophistication of equipment and methods.
The most basic detection device is the Geiger-Mueller detector.
These detectors are useful for scanning areas of objects suspected of radioactive contamination.
They are able to detect radiation levels of about.1 millirem.
Laboratory analysis services are available for checking for radioactive contamination by wipe tests or by sac;ies of air, water, and soil.
These methods are capa~ble'of detecting radioactive contamination in the picocurie range.
When asked if they could mcet the monitoring requirements of a scrap dealer who suspected that his plant contained radioactive material, most of the surveyed companies said that they could.
Only one company, however, has been solicited to do such work.
This company reported that it is doing some detect (on and cleanup work ic local scrap yards, as well as offering survey meters to inspect incoming scrap and offering training courses in the use of the meters.
Commercial organizations are also looking into the problem of detecting radioactive materials.
The Institute of Scrap Iron and Steel worked with the NRC-in developing an information bul'etin alerting scrap yard workers to the common types of gauges and devices that end up in scrap yards.
The Institute is also looking into feasible detection systems that could inspect all incoming scrap for radioactive materials.
However, the large volumes of incoming scrap and the relatively hazardous environment of the scrap yard has made it difficult to find an accurate, reliable, and economic detection system.
Any surveying being done by scrap dealsrs, therefore, is being done individually and voluntarily.
)
4 118
APPENDIX M Procedures to Handle 31.5 and 32.51 Reporting Requirement Input 4
119
APPENDIX H PROCEDURES TO HANDLE 31.5_and 32.51 REPORTING REQUIREMENT INPUT I._
Incomino a.
Determine if it is a noCice 'of transfer or a quarterly report, b.
Determine if the report has all the information required by the regulations.
1.
Quarterly reports sent in by manufacturers / distributors must meet the re-quirements of Section 32.52, 10 CFR.32. The requirements listed below are needed for each general licensee:
Hame Address 4
Individual Hame/ Position that constitutes a point of contact.
How many detrices?
Isotopes and activity of each device.
A listing of any intermediate person who will temporarily possess the device prior to transfer to the general licensee.
- 2.
_ Transfer reports sent in by the general licensee must meet the requirements of Section 31.5(8), 10 CFR 31.
These requirements are as follows:
The model number and manufacturer of the device.
The name and address of the person receiving the device and the name and position of the individual who constitutes a point of contact.
120
3.
What if the incoming does not meet the requirements listed aoove?
1.
For quarterly reports use the attached form letter #X.
Check the box '
thLt describes what is deficient and send the letter to the manufacturer / distributor.
2.
Ebr cransfer reports send the deficiency letter to the general licensee who is making the transfer.
If the licensee that is trans-ferring the gauge cannot be reached then send a letter to the person that the device was sent to. Attached is an example of the deficiency letter.
II.
Data Input Refer to the systems users manual for further information.
III.
Quality Control a.
It cannot be stressed enough how important a quality program is to the successfuleand long term operation of the system.
The data must be checked when you are entering it and again by hard copy, this is necessary to demonstrate that the system has all the necessary data.
4 b.
A log book is to be established that indicates the date the data was put into the system and the date that the quality control checks were performed.
IV.
Incomina Volume Reduction a.-
All reports will be placed in an orderly fashion into the archives storage area.
Enter box number, contents in box, and date: sent into the log book.
~
Copies of the reports WILL NOT go into the file folders.
This will reduce b
unnecessary file handling time and will allow us to rapidly locate the records for a given company.
V.
Generatina Reports 4
a.
See systems user manual for further-information.
121
i b.
Reports that are needed by the staff should be tracked.
This will allow
-us to budget the use of time for the system and identify who was given the.
report.
Since the data in the system is proprietary, a record of who requested the data, when they were given the report, and indicate if they were told of the proper handling and disposal of the report.
These reports ARE NOT to be given to any person outside the Agency.
Reports given to persons in-house should be clearly labeled and handled as a proprietary document.
Make the requester aware of that fact.
A 4
4 m
i 4
4 122
Incoming-Quarterly Reports-and Notices of Transfer n
lf Controller Send Deficiency Problems with the Incoming Letter g
Yes No vResponse.
Not OK OK Input Data Into GRGL Computer S
/ ystem
/
_ Quality Control Check
+ Paper Filed in Archives
- to make sure data is entered and received by the System correctly.
e i
Generate Reports *
~
As needed by the
- NRC Staff
- Keep log on Action Dates.
123 i
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~
-Company Name:
4 Contact' Person-Address =
-Dear This refers _to your. license #'
-G authorizing distribution of devices-
~to persons who hold a general-license under Section-31.5.. A check of your files c
-appears to-indicate <that the following discrepancy (fes) exist (s) with the material-transfer. report (s) for the reporting period (s)
-Has not been provided'to this office.
'Does not contain individuals by name and/or position who may constitute a point of contact between the commission and.the general--
licensee.
-Does not contain one or more of the following:
the type _and model number _of devices transferred, and the quantity and type of byproduct material contained in the device.
Has..not been' addressed correctly.
Correct Mailing address:
Director,of the Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 This-is a-possib' violation of the terms and conditions of your distribution license as specified in Section 32.52(a).
Please send the appropriate-information-to the attention of the undersigned.
t.
6
.Your cooperation in_ correcting this is appreciated.
If you have;any questions, please contact me at-(301) 427-9005.
Sincerely, Division of-Fuel _ Cycle.and-
-' Material Safety 9
+
+
124
.)
_~ _
1 F
Accountability System We strongly believe that an accountability system is the key issue in increasing NRC_ visibility with the general licenses and attempting to drastically reduce the number of non-compliance issues and particularly gauge unaccountability.
In developing the accountability concept we reviewed registration type systems.
Registration may be categorized according to the time of filing with the Regula-tory Agency as compared to the time of receipt of the device or material, e.g.,
(a) prior to receipt of the device material (preregistration), (b) at time of receipt, or (c) within a specified time period after receipt (postregistration).
A preregistration system functions in many respects like specific licensing, e.g., file certain uiformation with the Agency, receive a registration number,
and possible set of regulations in return.
The distributor then asks for the registration number before he will ship.
A possible disa(yantage of preregistration is the pressure which it places on the regulatory agency to rapidly " move paper" in order to augment ordering and shipment schedules.
Preregistration provides' direct communication between the general licensee and his regulatory agency.
It may eliminate dependency on the manufacturer to supply copies of regulations to the general licensee and to submit quarterly reports to the agency.
This elimination would not preclude imposition of a requirement that the manufacturer develop informational material of a universal nature describing regulatory requirements applying to his device or product and to the distribution of the radioactive material with the device or product.
Registration at the time of receipt of the device could remove the possible
' pressure for rapid agency action in order to avoid interference-with shipments.
As compared with preregistration, it may provide less certainty that registra-tion will in fact, occur; however, this might be overcome if the distril' tor played an active role.
The certainty that time-of-receipt registration would occur would l'argely.be contingent upon how cognizant or how closely regulated the distributor is to the CSER.
125
Post-registration, coupled with quarterly reports from distributors, is prac-ticed in the States. Many of the States' regulations provide for registration within 10 days after receipt of the device.
In practice, that period of 10 days is frequently not met by the licensee and an agency follow-up is required upon receipt of the distributor's quarterly report.
Accordingly, quarterly reports should be considered essential with post-registration.
Modified Registration, since we are dealing with a different type of licensee, i.e., one who has no training in radiation safety, as compared to a specific license whc have knowledge of radiation safety and the NRC.
The study group suggests the use of a modified preregistration system that will increase NRC visibility without seeming cold and bureaucratic.
This we hope will develop a working rapport with the general licenses and allow for a free flow of infor-mation to and from the licensees.
Written notification would be requested from the general licensees stating that they have purchased a device containing byproduct material under the general' license.
This would contain the information as follows:
Name of Company Individual responsible for the device and title Phone number of responsible individual Street address of Company State, City and Zip Code Delivery date, isotope, activity, manufacturer and model number of the device Upon receipt of such a notification we would generate, by computer, a response franked card / letter.
This response would tell the users they are a general licensee and have them double check the information, as we have it, they provided.
Additionally, we would require a signature of the individual stating the information was correct and that they have read and understand their obligations under the section 31.5.
126
l
(
l Once signed the franked card / letter would be returned to NRC for automated data processing.
This automated processing is necessary because of the large number of general licensees.
The data base would be updated to reflect changes /
corrections made.
A letter would be sent by the NRC every time the user purchcsed a device under a general license.
Because of the increased pressure on the Agency to rapidly
~
move paper and to avoid interfering with the shipment and receipt schedules, we do not intend to grant the applicant permission or a registration ID number to accept and use the gauge.
We would continue to request quarterly reports from the initial transfers.
This will allow us to perform quality control and check the information pro-vided by both parties to see if they coincide.
- Periodic accountability.
To keep the system current a periodic mass mailing would take place.
This would require all licensees to report to us on the condition of thg equipment they possess and determine if it is the same equip-ment we have in the data base.
The franked card / letter would be returned signed by the responsible individual to the NRC for automated data processing.
Frequency accountability. We propose a one year time interval for the mass mailing during the 1st two years of the system.
This will allow us to QA the computerized system. After the QA program is completed the interval of periodic status reports will be established by potential health hazards to the public.
That is to say a gauge user wouiu be on a yearly status report period while a gas chromatography user, having a much less potential health hazard to to the public, may be on a 2-3 year reporting interval.
The franked card / letter response would be returned and signed by the responsible individual to the NRC for automated processing.
l 4
l 127
-1 1
- 1. e i
Document-Name:--
GENERAL LIC STUDY ATT 3-
~
Requestor's ID:-
KIMINAS-
' Author's Names
.BAGGETT S.
Document Comments:-
~ ~ ' '
SPE 6/28/88 - CRESS REVISIONS 1
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UNITED STATES -
8" NUCLEAR REGULATORY COMMISSION o
I WASHINGTON, D. C. 20845 g
October 31, 1988 1
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D'e Cno%v d MEMORANDUM FOR:
Bill M.-Morris, Director Division of Regulatory Applications, RES h kNd
'e FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
TRACKING 0F DEVICES CONTAINING BYPRODUCT MATERIAL Enclosed is a paper given by the Stau of Iowa at the All Agreement States Meeting in October 1988 regarding their annual mail-in inspection program.
While that program is aimed at tracking specifically licensed devices, as the author points out, the program could be extended to generally licensed devices.
The Iowa program is germane to the memorandum on " User Need Request for Rulemaking on Certain General Licenses" that Hagh L. Thompson sent to Eric Beckjord on July 6, 1988.
I would suggest that the experiences of Iowa be factored into this rulemaking effort. NMSS is undertaking a broader examination of the general license program and we would appreciate receiving from you the schedule for the rulemaking we requested in the July 6,1988 memorandum.
4
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.l Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated cc:
H. Thompson E. Beckjord*
V. Miller S. Baggett i
/
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state of Iowa Fixed Gauge / Gas chromatograph Mail-In Inspection Program Bruce Hokal october 5, 1988 Unreported incidents involving lost or stolen gauges that were never recovered, as outlined in the NRC's Information _ Notice No.
88-2, February 2,
1988, definitely got our attention.
This information, coupled with the fact that the inspection frequency on fixed gauges
- and gas.chromatographs is seven years are the two main factors influencing our decision to develop and implement an annual mail-in inspection program to supplement the seven year on-site inspections.
Although on-site inspections done since 1986 have not revealed any problems with lost or stolen devices or sources, we still wanted to obtain a better overall picture as soon as possible.
l Our main goal, of course, was accountability of sources contained in fixed gauges and gas chromatograph devices.
Gas chromatographs were included because of the seven year inspection frequency.
Other goals were to identify any problems with the license and to " touch base" 1
with licenees on a
more frequent
- basis, thus causing persons responsible f%r radiation safety.to evaluate their programs more often
- than every seven years, and increasing information flow between the licensees and our agency.
We attempted to - encourage truthfulness ' on the part of licensees by pointing out in the. cover letter that the inspection is indeed an enforcement action and that data submitted would become a permanent part of their license file and would be verified during the on-site inspection.
The state of Oregon did a mail-in program in the past.
We obtained a L
copy of their inspection form to help develop ours.- We modified their form to come up with our own, which is designed not to be a thorough inspection, as much as to obtain specific items of information.
I will goLthrough the form very quickly to show you what we asked for.
If you~would.like copies of this form, I have some available.
Inspections-were sent to 38 fixed gauge licensees and 12 gas chromatograph licensees -in early May.
Licensees were requested to i
reply within 30 days.
As inspections began to come back in we realized very quickly that we had made the error of not addressing i
them specifically - to - the person in charge of radiation safety, but simply-to the address on the licenke.
Some forms came back obviously filled out by persons who knew nothing about the gauges.
This problem
(
became more apparent -when after fa 30-day period had elapsed and we began _ making phone calls.
The radiation safety officer would - often say_he hadn't received the inspection.
For the most part we received a very positive response from-licensees: 86% (43/50) responded on time 3
s
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4 and many provided more information than we asked for.
In order to stimulate a response by the seven "no shovs ve sent a letter stating a
that we would have to do an on-site inspection if we didn't hear from them in 15 days.
The following group of slides is a summary of the results of the questions we asked on the inspection reports.
I will briefly explain the results and findings thereof.
We believe this pilot inspection program in Iowa was definitely a success.
According to statements made by licensees, it appears that there are currently no specifically licensed guages in Iowa that are unaccounted for.
In addition, many problems in the licensing area have been identified and dealt with accordingly.
I feel most licensees responded favorably, based on the quality of material submitted to us.
In the future we plan to ask different questions to prevent duplication of effort by licensees, to go into more depth in some areas (nuch as in reference to stored sources), and to uncover other problem areas.
The primary goal of source accountability will remain the same.
If the benefits from the program drop off significantly, we may extent the inspection frequency or eliminate it all together.
There is speglation that we may increase the on-site frequency to three or four years.
I am also considering developing a similar program for generally licensed gauge users in Iowa.
I would very much appreciate your comments or suggestions on this program.
Thank you.
Il
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-l tt00v t. ana8sTAp. novo oa DEPARTMENT OF Pus iC MALTH wan% ri.La.e accesa To All fixed gauge and gas chromatograph licensees Deor Licensee:
Tho current inspection frequency for licensees of fixed! gauging dovices and gas chromatographs is seven (7) years.
Bessmuse of nuterous problems, nationwide, related to loss, theft, or; improper dicposal of sources in these devices in recent years, tite seven-yocr inspection cycle for these devices will now be supplesmented by en annual mail-in inspection.
The seven-year inspect: Hon will centinue to be qpnducted when due.
P1 case complete the enclosed inspection form, providing accurate and current data on your devices and radioactive matarlials, and roturn the completed inspection form within 30 days aftear receipt of this letter.
The completed forms will be made a pernament part of your file and will be rev_ieved during the on-site ~inspnection of your program.
Any questions regarding this enforcement action should be addressed to me or Donald A.
Flater at (515) 281-3478.
Sincerely,
& W.
Bruce W.
Hokal, Supe isor Radioactive Materials Program Eureau of Radiological Health (S15)281-7007 BWH:emb 4
Enclosure:
Yearly Inspection Form
p 4
w IONA DEPARTMENT OF PUBLIC REALTE BUREAU OF RADICIDGICAL REALTH RADIOhCTIVE MATERIAL 8 PROGRAN EDCAS STATE OFFICE BUIIDING DES NOINES, IA 50319-0075 FIEED G1DSE/SAS CEROMETOJR175 SNMmL M1IL-II IESPECTION Licensee (Name and Address):
1 i
Telephone Number License Number 4 -
Provide complete and accurate responses to each iten below.
If cdditional space is required, use attachments with reference to the cppropriate iten.
Include drawings or sketches as necessary.
4 1.
Sealed sources currently on hand:
Isotope.
Source Source Source Holder Manufacturer Model i Mfr./Model.#
m:-
[
2.
Describe how radioactive material is used.
3.
Name of radiation safety officer (RS0):
4.- Training. Specify what training the RSO and any other personnel working near gauge have had:
t 1
588-2619
4 5.
Are any sealed sources being stored?
E3 E3 Yes No.
6.
Do you service your devices (i.e., install, perform initial radiation surveys, relocate devices, ship devices)?
Yes No.
7.
If "yes" to No. 6:
Survey instrument (s) available?
Yes No Date of Calibration Manufacturer Model f 8.
If "yes" to No. 6:
Personnel honitoring available (TLD, Film Badges)?
Yes No
- a. Supplier
- b. Frequency of exchange
- c. Maximum quarterly exposure i
9.
Describe your procedure to safeguard radioactive material from unauthorized personnel:
- 10. How is radioactive material secured from loss or theft?
. 6
- 11. Radioactive material labeling on gauges and/or source holders is plainly visible and in tact?
O Yes No.
- 12. Leak tests: (Provide the last year's information.)
Who does leak tests?
Source Model No.
Date(s) of leak test (s)
Results
- 13. Any sources disposed of ?
Yes No.
If "yes" qpscribe method of disposal:
4
- 14. Is any matarial unaccounted for?
Yes No If "yes" give details:
Please attach any questions or comments you ray have or any ether information you deem significant.
signature of person preparing form Date
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- 6. Licensee has some sources in storage?
yes-22%
no 78%
- 7. Licensee performs services on gauges?
yes-17% (All authorized by license.)
no-83%
- 8. Licensee uses nnel monitoring?
so 9o maa.
o - mo.
- 9. Licensee possesses survey meter?
yes-19%
no-81%
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- 10. Security appears adequate I
+
yes-100%
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- 11. Proper labeling?
i yes-95%
no-5%
e Due to dirty og corroded labels.
l
- og UNITED STATES
'l l
[
g NUCLEAR REGULATORY COMMISSION WASHING T ON, D. C. 20656 4
9.....
_.n MEMORANDUM FOR:
Richard E. Cunningham, Director, Division of Industrial and Medical Nuclear Safety, NHSS FROM:
Bill H. Morris, Director, Division of Regulatory Applications, RES
SUBJECT:
USER NEED REQUEST - RULEMAKING ON GENERAL LICENSES In response to your memo dated October 31, 1988, which requested a schedule for the subject rulemaking, I can advise you that t!rls task has been assigned to the Regulatory Development Branch.
RDB staff are currently meeting with NHSS counterparts to further define the scope of rulemaking required and will be requesting approval to initiate rulemaking shortly.
The earliest date for-initiation is projected to be March 30, 1989.
The Task leader will be Joseph Mate and the cognizant Section Leader will be Tony DiPalo.
Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research cc:
E. Beckjord D. Ross
-fE9N?OVC,:$~
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