ML20237G600
| ML20237G600 | |
| Person / Time | |
|---|---|
| Site: | 07000622 |
| Issue date: | 08/18/1987 |
| From: | Pennington W, Swift J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20237G516 | List: |
| References | |
| NUDOCS 8708240141 | |
| Download: ML20237G600 (8) | |
Text
m A0G 181987,
s IMUF:WSP
)
DOCKET N0:
70-622 LICENSEE:.
Department of the Army
- FACILITY:
U. S.. Army Armament Research and Development Center Dover, New Jersey l
l
SUBJECT:
SAFETY EVALUATION REPORT; RENEWAL APPLICATION DATED J
AUGUST 22, 1984, AND SUPPLEMENT DATED AUGUST 6, 1987 1
1.
BACKGROUND By letter dated August 22, 1984, the U. S. Army Armament Research and Development Center (ARDC) submitted a renewal application for Materials License No. SNM-561.
The application was filed prior to the license expiration date of September 30, 1984, and.the existing license remained in effect in accordance with the timely renewal provision of 10 CFR 70.33(b). The licensee requests authorization to possess, use, store, or transfer special nuclear material at the ARDC located in Dover, New Jersey. The material will be stored or used for military research and development projects as defined in 10 CFR 70.4(j) and Section 31 of the Atomic Energy Act. Upon completion of the initial application review, by letter dated April 15, 1987, the staff requested additional information from the licensee.
By letter dated August 6, 1987, ARDC submitted supplemental information in response to the staff's request.
The original license was issued in January 1962 and authorized the use of an encapsulated 5 curie Pu-Be neutron source for research. The license has remained active via renewal and amendments. By amendment datd August 11, 1981, the licensee received authorization to possess and use Pu-238, Pu-239, and Np-237 as check sources and activation foils, as well as store.1,716 grams of U-235 in the form of Material Test Reactor (MTR)-type fuel elements (sealed sources of uranium / aluminum alloy clad in aluminum). The possession limits also include 4.8'gramsofPlutonium-238containedinneutrongenerators(batteries).
II. SCOPE OF REVIEW The safety review of ARDC's renewal request includes a review of the application dated August 22, 1984, as supplemented August 6, 1987, crd the licensee's compliance history.
The topics of review include an evaluation of the applicant's organization, procedures, and radiation and nuclear criticality safety programs. Comments on the renewal application were received from Mr. J. Roth, Region I Inspector, and are addressed in this review.
8708240141 870818 PDR ADDCK 07000622 C
MG 181987 III. DISCUSSION ARDC's renewal application and supplement demonstrate that there is adequate technical staff with qualifications to administer an effective radiological safety program.- The following sections contain a description of the applicant's requested material, organization, and safety programs, along with additional license conditions developed by the IMUF staff.
Possession Limits: ARDC has requested the following nuclear material for their.
activities:
Material Form Ouantity A. Plutonium-239 A. Sealed Pu-Be A. Sources not to l
neutron sources exceed a. total of 100 grams.
B. Plutonium-239 B. Sealed sources B. 2 milligrams total C. Plutonium-238 C. Neutron C. 4.8 grams generators (batteries)
D. Plutonium-238 D. Sealed sources D. I microgram E. Neptunium-237 E. Sealed sources E. 15 milligrams F. Uranium enriched F. Sealed MTR-type F. 1,716 grams-to 193.27 wt percent fuel elements of U-235 in the U-235 isotope The material described in Items A thru E will be used for research and development as defined in 10 CFR 70.4(j). The material described in Item F-will be stored in Building 3030. The entire inventory of material will be used/ stored at the U.S. Army Armament Research and Development Center, Dover, New Jersey. In order to clarify the authorized use of the requested material, the staff recomends the following conditions be added:
Authorized Use: For use in accordance with the statements, representations, and conditions specified in the licensee's application dated August 22, 1984, and supplement dated August 6, 1987.
Author'ized Place of Use: The licensee's existing facilities at Dover, New Jersey.
Organization The Commander of the ARDC is responsible for the installation and its activities.
This responsibility includes establishment of a formal radiation safety program; appointing the Ionizing Radiation Control Committee (IRCC) and the Radiation
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Protection Officer (RPO); and assuring compliance with federal, state, and local regulations. There are two levels of management between the RP0 and the Commander (Chief, Operations Division, and Chief, Safety Office).
The RP0 is responsible for implementing the radiation safety program which Operating Procedures (SOP)g and proposed radiological operations and Standing includes reviewing existin
- maintaining radiation protection records; providing
. training and support to visitors and radiation users; investigating radiation accidents and incidents; and reporting the findings of investigations to those involved, the administrative staff, and IRCC.
The IRCC is responsible for making recommendations to the Commander regarding policies and actions for the safe use, handling, storage, transport, receipt, shipment, and disposal of radioactive materials. The IRCC is authorized and rerpcr,sible for reviewing proposals for the procurement and use of radioactive materials, proposed modifications to existing. radiological activities and operating procedures, and qualifications of workers.- Reports of radiation accidents and incidents are reviewed by the IRCC to determine the cause prior to recommending corrective actions to the Commander.
Qualifications The licensee's present RP0, Mr. George P. Ducker, has sufficient formal training and experience in radiation protection. However, because there is no license requirement sperifying minimal experience to ensure that a future individual holding this position is qualified, the following condition is recommended:
The minimum technical qualifications for the position of Radiation Protection Officer shall be a bachelor's degree in health physics, physical / life science, or engineering and 2 years of experience in applied radiation safety.
The IRCC has the authority and responsibility for reviewing and approving all operations and programs involving radioactive materials. The committee meets at least quarterly. The IRCC members are appointed by the Commander. Replace-ments and alternate members are designated by the IRCC. The Commander ultimately approves a designee by reviewing and approving the minutes of IRCC meetings.
The members of the IRCC, listed in the application, have sufficient training and experience in radiation or nuclear safety; however, the application does not specify the minimum qualifications necessary for committee members. Therefore, the following condition is recommended:
The minimum technical qualifications for three of the Ionizing Radiation Control Committee members shall be a bachelor's degree in health physics, physical / life science, or engineering and 2 years of experience in radiation 'and/or nuclear safety programs.
Operating Procedures The applicant has committed to having procedures, facilities, equipment, and trained personnel to assure the safe use of materials.
Failure to meet these requirements will result in cessation of operations or delay in startup.
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The staff of both the Safety Office and Radiation Protection Office, as well as supervisors and fire department personnel, are authorized to suspend any experiments or operations. The Radiation Protection staff specifies conditions under which an experiment or operation may be resumed.
Prior to the start of any operation involving radioactive material or possible exposure to radiation, a Standard Operating Procedure (S0P) is required for review by the IRCC and the RPO. The 50P contains, as a minimum, personnel responsibilities, maximum permissible levels of radiation in the areas concerned, location of the operation, type and output of sources, manufacturer and model number (devices only), protective clothing and equipment, storage of sourccs, procedures regarding the operation of the source, dosimetry, decontamination, and emergency procedures.
The work permit system allows the use of radioactive materials for short-term, one-time operations under the supervision and control of the RP0 without requiring users to provide a 50P. All issued work permits require RP0 tothorization and are provided for IRCC review at the next quarterly meeting.
Inspections The applicant has committed to having radiological operations and programs reviewed by the Ionizing Radiation Control Committee to ensure regulatory compliance. The Army conducts yearly an average of two or more routine inspections of the radiation safety program. The staff of the Radiation Protection Office conducts inspections of operations with a frequency dependent on the type of operation, relative hazards involved, experience of workers, and past history.
Personnel Training Personnel, including visitors, who may be exposed to radiation and/or radioactive materials are required to participate in a radiation protection training program.
Radiation workers will receive training in maximum exposure and contamination levels, safe nethods of performing work, and procedures to minimize contamination and to secure sources of radiation from unauthorized use.
An individual is required to work under the direct supervision of an authorized user until the individual demonstrates his ability to safely perform his work.
Fire department personnel are trained and equipped to cope with radiological hazards that may be encountered in the performance of their duties.
The applicant has committed to retrain on an annual basis, fire department and security personnel, radiation users, and the Radiation Protection Office staff.
Upon completion of initial training or retraining, a written test will be administered to each individual to determine his level of competence.
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AUG 181987
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Calibration of Instruments The licensee has a range of radiation monitoring and measuring instruments which are listed in the renewal application. The licensee has committed to calibration of the. radiation detection instruments on a quarterly basis and/or.
after each maintenance or battery change, and pocket dosimeters on a semiannual basis. Smear counting equipment is calibrated with each batch of smears counted.
Records The applicant has committed to maintaining all documents produced for the radiation protection program in accordance with Army regulations and 10 CFR Part 20.
Radiation Safety Control Radiation Surveys Monthly surveys of each area where radiation sources are used and/or stored are performed by or under the direction of the RPO. Radioactive material storage areas may be exempted from monthly surveys at the discretion of the IRCC; lowever, the interval between surveys in storage areas will not exceed 3 months.
Control of Personnel Exposures External exposures are controlled and evaluated by assigning dosimeters to individuals who are likely to be exposed to radiation or radioactive materials.
The licensee has committed to a monthly frequency for turnover and evaluation of personnel dosimeters.
Exposures at ARDC are minimal. The application, as supplemented, states that approximately 80 percent of the 150 individuals assigned dosimeters receive no measurable exposures. The annual whole body exposures of the remaining individuals are less than 0.1 rem.
The applicant has committed to the majority of the occupational exposure limits of 10 CFR Section 20.101 for normal operations; however, a provision has been included to allow the Conmanding General to approve personnel exposures in excess of the 10 CFR Part 20 limits. Therefore, the staff recommends the following condition:
Notwithstanding the provision of paragraph b. on page 167 of the application, the licensee shall maintain personnel exposures in accordance with 10 CFR 20.101.
Control of Contamination l
)
The licensee has requested authorization to possess materials as sealed sources, clad fuel elements, and neutron generators (batteries). Since the materials are l
contained and nondispersable, contamination and internal exposure hazards are 1
negligible.
In addition, the applicant has committed to leak test sealed sources 1
6 Agg i g ;gg7 and neutron generators every 6 months and alpha sources every 3 months. The staff recommends the following conditions which specify criteria for leak testing of plutoniun' sealed sources and alpha sources:
Sealed plutonium sources shall be subject to the leak testing and actions specified in the attached Annex, " License Condition for Leak Testing Sealed Plutonium Sources," August 1987.
Plutonium alpha sources shall be subject to the leak testing and actions specified in the attached Annex, " License Condition for Plutonium Alpha Sources," August 1987.
Effluent Control The radioactive wastes generated at ARDC are minimal. Because of the nature of
'the requested material, liquid and gaseous effluents as well as airborne radio-activity are of no concern. Prior to transfer to a licensed burial site, radioactive waste generated by ARDC activities are stored onsite.
Nuclear Criticality Safety In a conversation on March 11, 1986, Mr. Frank Dunfrund, Alternate RPO, confirmed that the application is for storage only of the 1,716 grams of U-235 as sealed MTR-type fuel elements. The fuel is being stored in Bunker 3030 inside a locked steel cage which has a security alarm. The fuel elements are stored in their original shipping container, a 55-gallon DOT 6M drum. The staff believes that the criteria for the-storage of the MTR-type fuel elements is adequate. Because criteria for use was not provided, the staff recommends the following condition:
The possession and use of U-235 in MTR-type fuel elements shall be limited to storage only in the shipping container in Building 3030.
Furthermore, the staff feels the requested exemption from 70.24 requirements is reasonable and should be granted as long as the use of the U-235 fuel is limited to storage in the shipping container. The several grams of plutonium (mostly Pu-238), even if in contact with the shipping container with the MTR-type fuel elements, cannot be made critical. The staff recommends the following license condition:
The licensee is hereby exempted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under the license.
Environmental Protection In accordance with 10 CFR 51.21, the staff has prepared an assessment of environmental impacts for continuing operations. The Environmental Assessment was prepared and issued on December 11, 1985. This assessment supports a Finding of No Significant Impact which was published in the Federal Register on December 19, 1985.
7 AVG 181987 Emergency Planning Because of the physical forms and storage conditions of the requested material, the staff has determined that a Radiological Contingency Plan is not required; however, activities at ARDC not involving radioactive materials require pro-visions for emergency preparedness.
Fire department personnel who would respond in the event of an emergency are trained in radiation hazards and procedures for handling radiation emergencies.
If RP0 staff is unavailable, the fire department controls the emergency situation until the RP0 or other radiation safety personnel can respond.
Compliance History A review of the record of inspections by Region I for the past 5 years shows that one inspection was made in 1984. There were no items of noncompliance found during the inspection.
IV. DECOMMISSIONING PLAN The applicant has committed to decommissioning at the end of facility life and the release of items for unrestricted use in accordance with " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" dated 1982. The staff recommends the following condition to ensure the guidelines are current:
Upon termination of operations or prior to the release of equipment for unrestricted use, the facility and equipment shall be decon-taminated in accordance with the attached Annex, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," August 1987.
V.
CONCLUSION AND RECOMMENDATIONS Upon completion of the safety review of the licensee's application, as supplemented, and discussion with the Region I Inspector regarding the licensee's compliance record, the staff concluded that the licensee has the necessary technical staff to administer an effective radiological safety program. Conformance by the licensee to their proposed conditions as well as to those established by the IMUF staff, should ensure a safe operation and a quick detection of unfavorable trends or effects, resulting in corrective actions being taken.
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i Based on this conclus' ion and.the discussion above, it is recomended that the license be renewed for a 5-year period in accordance with the application as supplemented and subject to the conditions developed by the staff.
At4alS1sn007:
W. Scott Pennington Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and 4tisical signed Ryr Medical Nuclear Safety, NMSS Approved by:
Jerry J. Swift, Section Leader Uranium Fuel Section 0
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. DATE:08/r7/87
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