ML20237L459
| ML20237L459 | |
| Person / Time | |
|---|---|
| Site: | 07000622 |
| Issue date: | 08/06/1987 |
| From: | Elliott J ARMY, DEPT. OF, ARMAMENT RESEARCH, DEVELOPMENT & |
| To: | Pennington W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 28463, NUDOCS 8709080411 | |
| Download: ML20237L459 (15) | |
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!U DEPARTMENT OF THE ARMY ARMAMENT RESEARCH AND DEVELOPMENT CENTER US ARMY ARMAMLr T. MUNITIONS AND CHEMICAL COMMAND X309tXtv.MKKYNNME Picatinny Arsenal, N.J.
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August 6, 1987 Safety Office J-AUG RETURN.TQ 39$ $$
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Nuclear Regulatory Commission 4
/g Uranium Fuel Section, Fuel Cycle Safety Branch Division of Fuel Cycle, Medical, Academic, and Ccmmercial Use, NMSS 7915 Eastern Ave.
' Dear Mr. W.
Scott Pennington, This is in response to your 15 April 1987 request for additional information regarding Special Nuclear Material License renewal application, License No. SNM-561 (Encl 1 and 2).
The following recent changes in radiation protection personnel include:
1.
Delete - James W.
McCahill and Frank L.
Dunfrund.
2.
Add - Primary RPO - George P. Drucker, (Resume Enc 1 3).
Alternate RPO's Joseph A. Fabiano, Richard W.
Fliszar.
Point of contact for this Command is Richard W. Flissar, 201-724-2858.
3 Encl AMES E.
ELLIOTT Actg Chief, ARDEC Safety Offica CF:
AMCSF-P AMSMC-SF(R)
AMXOS (Director FSA)
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Response to Questions on Department of Army Application
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for License Renewal SNM-561 1
1.
The facility which will use this license is an Anny research instal-lation, 'with 24-hour guarded entrance gates and armed, roving patrols.
j
. Personnel entering the installation must have a picture pass and an au-J thorized, tagged vehicle. Within the installation, rastricted areas J
require further identification and authorization to proceed past the armed
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guards. Entrance to the SNM storage building is through a locked gate in 1
a high fence surrounding the underground building.
Inside the fence which is lit by floodlights at night, is a solid, armor-plate door secured with a high security lock and protected by an intrusion alarm as de n ribed on page 65. The key to the gate and door are locked in a vault under the direct control of the Radiation Protection Office (R.P. Office). For security reasons, a map should not be attached.
2.
The R and D work being performed on the installation covers a wide range of areas of interest to the U. S. Army for defens<r purposes and can not be described here.
In all esses, the SNM material W used as a tool in the studies of other materials or as a means to solve arious problems in weapons tesearch and development. Many of these proce12res involve using radioisotopes in developing non-destructive test techniques. Li-censed materials may be used, under the procedures described in one or more of the laboratory facilities listed on page 51.
3.
The programs taking place at this installation involve not only rou-tine research programs, but some exotic programs and some highly classi-fied defense work. To assure that research personnel, including many at the PhD level, are protected to the maximum extent possible, the R.P.
Office group works as closely as possible with the research staff when preparing a facility or project involving radioactive material. The various laboratories, centers, divisions or directorates have representa-tives serve on the Ionizing Radiation Control Comittee (IRCC), usually personne. : knowledgeable about the projects taking place. The IRCC has a subcommittee composed of three of its members. These three nunbers who usually, though not always, consist of one from each of the two main centers and one from the environmental office, review and coment on the Standing Operating Procedures developed by the using organization to
'nsure the adequacy of the S.O.P.
The committee reviews theses procedures every three years, with the R.P. Office staff, reviewing, checking, and observing S.O.P. procedures during routine surveys or during operations when appropriate. Corrections to the S.O.P.'s are made as needed based on observations, or changes in operations.
S.O.P.'s are also scheduled for annual review by the R.P.O.
A document on how to prepare the S.O.P.'s is provided'to the organization as well as technical support by the R.P.
Office. Any question, problems, or differences of opinion on the content of the S.O.P. is resolved by the IRCC. The ALARA concept is diligently applied and most local procedures are defined more stringently then Anny regulatory requirements and NRC regulations.
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4 Various Army agencies inspect health physics operations at this facil-ity at one, two or three year intervals, with an average of two or more inspections on some or all phases of the program every year. The frequency of inspection by-the RP office is totally dependant on the type of opera-tion, relative hazards involved, the caliber of personnel working on the project, and the " age" of the operation or number of times the operation has been performed. With new operations, inexperienced personel, rela-tively high hazard operations, the RP staff may be involved daily to provide instructions and to take surveys, swipes or samples. As experience is gained by the personnel on the procedures, the RP staff may visit only weekly. As the operation becomes routine, monthly surveys, swipes, or samples are taken. Where operations are not continuous, surveys are taken before and after the operation and a staff member may be present to review procedures during the operation. When operations are intermittent with long periods between operations surveys and swipes may be taken quarterly or semi-annually.
5.
Any member of the RP Office (the RPO or alternates) can stop any unsafe operation involving radioactive material as mentioned on page 145.
Any member of the installation safety office can also stop any operation or procedure whenever a question of safety arises. These people would then contact the RPO for a resolution of the questions involving radiological safety. Supervisors and fire department personnel also have authority to suspend activities until reviewed by the RP Office.
6.
With an average of about 150 people in the film badge program each month, the annual doses have all been below 0.1 Rem whole body with about 80% of the badges showing no measurable exposure. These records are on file with the NRC in accordance with FCFR 20.407. With our ALARA program, no changes are anticipated in these results.
7.
If this facility is ever decommissioned, insofar as the radioactive materials governed by this license are concerned, it will be done so in accordance with the NRC procedures and guidelines in existence at that time. It would currently be performed in accordance with the 1982 guide-lines entitled " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material." Also, all Army procedures and regulations would be complied with.
8.
The enriched U-235 MTR fuel elements listed on page 5 are further described on page 79 as having an enrichment of 93.27%.
9.
The license should be issued for the standard NRC License time limit of 5 years.
10 At the present time, the U-235 MTR Fuel elements are in storage until funding and project requirements are in place. At that time, an amendment j
will be requested to allow these materials to be used in the research projects to be planned.
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- 11. This is a U. S.' Army installation under the command of the U. S. Army General Off4.cer. The Safety Office is part of the special staff under the office of the Commander. The RP Office is under the Operations Division whose chief normally serves as chairman to the IRCC. This division is one of those under the chief of the Safety Office. The RPO serves as the project leader for the RP Office. The resumes of the RPO and alternate RPO's in the RP Office which is in the Safety Office, are listed in Appen-l dix B, in addition to the changes noted in the cover letter provided here.
I 12.
In the first paragraph of Appendix D on rage 50, the a,econd and. third sentences should read "...within 10%
- 13. Building 3030 is an underground igloo-type magazine designed for storage of explosives.
It has no windows and no ventilation, and is covered with several feet of dirt. The only entrance is through a solid armor-plate. door at one end of the igloo. There are no fire detection or suppressive devices in the building since any fire which could start would be self-extinguishing because of a lack of oxygen in the building. Any disturbance of the door or MTR fuel storage drums would trigger an alarm and response by security forces as described on page 65.
Tested response time of security forces has been about 2 minutes.
Additionally, the fire department is located on a hill above this building, about 1600 feet away.
- 14. Because of the nature of the research Ming done, the variable amount of time of use and the relative amounts of potential loading of the HEPA filter, various procedures are used to determine changing of the filters. For low loading continuous operations, such as radioisotope hoods, a time base such as 6 months or 1 year may be used. For most of the buildings using HEPA filtration systas, differential pressure gauges or magnehelic gauges are us d.
In addition if the air flow through the systs, that is measured at the critical interface, drops below an average of 150 linear FPM, or is below 125 linear FPM at any point, the filter will be examined and evaluated for replacement of the filter media.
- 15. The survey, monitoring and dosimetry equipment listed on pages 44 and 45 are available for routine or emergency use.
Instruments are calibrated in accordance with regulations established by the Army Metrology System and as stated on page 185, paragraph 29.
The Army Metrology System complies with the NRC Reg. Guides.
Survey / monitoring equipment is calibrated quarterly. Therefore, one-third or two-thirds of the equipment listed is available for um.
calibrated, at all times.
If necessary, the calibration contractor wul repair the equipnent, if possible, or, if not, red tag it to present its use until repaired or replaced. There is more than sufficient redundancy in this equipment to assure availability for emergency use. Porta.le/
survey equipment is checked daily when used.
Film badge dosimeters are received form the Amy's Ionizing,Radiat'on 3
1 Dosimetry Center (IRDC) Lexington, KY.
The badges are issued for a one month period after which they are returned to IRDC for processing. A sufficient reserve of film badges are on hand in the event of an emer-gency.
- 16. With its 5.5 MeV alpha, Pu-238 is leak-tested as described on page 140 and page 176. The swipe is taken as described on page 140 and counted in the HP Lab, Building 320 cn the gas flow proportional counter listed on page 43, using a 4.2 Mev U-238 standard for alpha. This system is more than adequate to detect any leakage of Pu from these batteries. The batteries are checked as sealed sources in storage on a semi-annual basis.
17.
The equipment to be used for leak-test counting as described on page 140, and as listed on page 43 are checked on a daily basis, and can only be correctly used for counting, if they are checked or " calibrated" against a known source at the time the samples are counted. Therefore,
(
the only way this equipment is used is by calibrating it each time a set of samples is run. Absent this procedure, the infonnation attained may not be reliable or accurate. In trost cases, daily statistics are obtained on this equipnent to insure its reliability and function.
18 In accordance with AMC regulation 385-25, on page 176, alpha sources will be leak-tested every three months.
- 19. Any source showing leakages in excess of 0.005 microcuries (11,100dpu) will be reported in accordance with 10CFR 31.5(c) (5). Any source in use which shows above LLD on consecutive swipes and shows a count gradually increasing, is monitored more frequently than six months if it is in use.
If the count rate continues te increase, the source will be removed form use and be placed in storage for future monitoring. In storage, the six month interval is maintained, but results observed to determine if the encapsulation and sealing is breaking down. If this determination is made, the source will be processed for repair, replacement or storage as appropriate, before the.005 microcurie reporting level is reached.
If breakdown is catastrophic and exceeds the
.005 microcurie level, the report in accordance with 100FR 31.5(c) (5) will be made, action taken to secure the leaking radioactive material, and advice obtained on disposition of the source.
20.
The permit system and S.O.P. procedures are described on page 141,1G and 160 with a copy of the permit format on page 153. This format is also used for perm as which do not involve depleted uranium by simply crossing off those words. The S.O.P. format described as " Appendix H" is constantly undergoing improvement and revision and is therefore not a part of the license.
The work permit-S.O.P. system now in place allows one-time, relatively short duration operations to be approved by means of the permit system. Repeat, on-going, continuous type operations shall require a canplete S.O.P. to be written. Operators performing work under a permit receive more innediate direct supoort and service f rom the R.P. Office to 4
f assure safe performance. The IRCC has appointed a sub comittee of three highly qualified members to review S.O.P.'s on behalf of the entire comittee. Coments and recomended change 4 sde by these subcommittee members are reviewed and coordinated by the L.P.O. who then requests the proponent organization to correct the S.O.P. as required, before signature approval is given. This sub comnittee reviews new S.O.P. 's and renewals of the S.O.P.'s every third year. All S.O.P.'s are reviewed annually and may be changed at any time by the using organization, if conditions change and the procedures described warrant change. Minor changes may be approved by the R.P.O. while any significant changes are reviewed by the IRCC sub comittee.
- 21.. The Radiation Protection Office is responsible for the ALARA program.
Normally, this office becomes involved in a project or program near the time of its inception and works closely with the scientists planning the operation.
This usually includes working with the facility engineers in the design of the building, spaces, facilities, utilities and equipment to be used in the project. Personnel to be involved in the project receive training specific to the relative degree of radiation hazards. Close liason is maintained with workers and supervisors on the project.
Proce-dures, S.O.P.'s and operations are jointly derived and coordinated. Con-tamination control, personnel protection, and procedures are worked out to keep protection as high as possible and conta:rination as low as possi-ble--based on the operation and the reasonable ability to do so.
Contami-nation levels are established well below allowable limits. Personnel are trained to keep these levels low. Personnel protection procedures are also usually established well on the side of safety to preclude potential problans even for low probability incidents. Part of the logic in this involves the inherent problems in doing original research in areas that have not been touched before, thus not having well defined limits of potential problems. These procedures are cooperatively arrived at with the R.P.O. and the working organization, reviewed by the IROC and, thus, u'timately approved by the comand group.
22.
Radiation workers receive initial training, usually one-on-one or in small groups, given by the R.P.O. staff, based on the particular project or needs of those individuals or groups. Currently, annual re-training is I
being done under contract with Battelle, PNL. This annual re-training also involves anergency (fire department) and security personnel, as appropriate. The fire department also is provided annual refresher training by the R.P.O. staff. Records are maintained for the training provided an individual.
The radiological protection staff normally receives one to three weeks of specialized training, usually consisting of 5 days in a subject area, depending on current organizational requirements and needs. This training may also consist of attendance at the Health Physics Society annual meeting. The special courses may be sponsored by the U. S. Army, universities or colleges, or special contractor-provided programs.
A major component of training throughout the Anny is on-the-job training which is on-going and continuous.
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- 23. The usual method of assuring that training is understood is by means I
of a written test which is one of the methods used in the annual retrain-ing program.
(An example of such a test is in Encl 2.)
On-the-job train-l ing is monitored by the R.P. staff during routine surveys and when observing operations and procedures. Questions may be asked of individuals to assure awareness of the S.O.P. and other operating procedures. The RP staff is readily available by phone and is in constant communication with operating personnel who, apparently based on calls received, are willing to call for any problem, real or perceived. For training and the ALARA concept, a very open communication system exists between the workers and the R.P. staff, based on the ability and willingness of the R.P. staff to assist in solving problem areas.
- 24. This installation uses the U. S. Army Film Badge Program from the Lexington Ionizing Radiation Dosimetry Center (IRDC) in Kentucky, as found on pages 113, 169 and 170. The Lexington IRDC film badge program is certified by the National Voluntary Laboratory Accreditation Program. The film is Kodak Type 3 film packets in Tenite II plastic holders. Film badges are standard beta-gama and standard neutron _ film badges as used throughout the U. S. Army under its various NRC licenses.
TLD badges (Panasonic UD-802AS dosimeters with UD-874A hangers) are currently being studied by the Army for the possibility of converting from film badge to TID badge. This installation is part of that study, and both badges are currently in use during the study. The film is good from about 20 KEV up and is sensitive enough to detect about 2 mr of x-rays, 5 mr of gama and 10 mr of beta. The TLD is more sensitive to lower ener-gies and may eventually be used army-wide.
The neutron badge can measure neutrons from 800 Kev to 14Mev and is cali-brated with a Pu-Be 4Mev average energy source. Badges are exchanged on a monthly basis.
- 25. While there is little, if any, radioactive waste generated under this license, the materials generated would be handled as they are under the other licenses. All materials are currently stored on site in approved facilities. A new storage facility will soon be available to house radioactive materials, including waste. Currently, these are stored in the vault in D-320, page 52, in the magazine, B-3030, page 65, or in the warehouse B-55, page 65.
Also, see page 113. This installation would request disposal instruction and final transfer to a licensed burial site through AtCCOM, Rock Island, Illinois.
26.
The transfer of any unwanted radioactive materials or waste to Building 3030 is controlled by the RPO or alternate RPO. The only keys for Building 3030 (sm Page 65) are housed in a vault under the control of the R.P.O. and only the RP staff has access to that building.
- 27. The Army regulation cited as subparagraph F nn page 32(sic) (page 176) is the governing regulation for Army dosimeters, requiring the action described for all Army organizations. The calibration procedure on page SG and currently in use at this installation is under a contract providing for a lower limit than that of the regulation, i.e. 2% instead of a 6
d regulatory 5%.
For purposes of the license limits, the 5% figure should be used, but for local operations, the 2% figure will r eain as a local action level.
- 28.
The records described in AMCR 385-25 (Page 191) have been kept for different time limits in accordance with Army Regulation AR 340-18-6.
The Army record-keeping system was changed on 15 October 1986 and now must comply with Army Regulation 25-40J-2. The records listed are kept for varying time limits from 2 years to 75 years, depending on the type and importance of the record. Record retentions are for time periods in accordance with requirements in 10CFR Part 20.
Applicable sections of Army Regulation 25-400-2 include, but are not limited to requirements for radiation protection surveys, radiation SOP's, personnel dosimetry files, Radiation Protection Conmittee files, radiation incident cases, instrument calibration files and radiation' facilities.
In the event of an abnormal occurrence an investigation is immediately initiated. Radiation survey findings, personnel dosimetry results, sployee statements are documented and an incident report is written. All records relevant to the incident report would be retained 2
- years minimum to indefinite, as applicable.
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Name SSN f
Date ll RADIATION WORKER TRAINING FINAL EXAMINATION PART I l
True or False If the statement is fundamentally true, circle the word TRUE.
If it is false, circle the word FALSE. These questions are to test your under-standing and are not intended as " trick questions."
1.
TRUE FALSE Radiation cannot be seen, smelled', tasted or felt.
- 2..TRUE FALSE An area where the airborne radioactivity. level is greater than 25% of the MPC must be posted as an airborne radioactivity area.
j 3.
TRUE FALSE A radiation dosimeter should be left in the change room at all times to prevent it from becoming contaminated.
4.
TRUE FALSE Radiation causes ionization.
5.
TRUE FALSE The primary purpose of radioactive contamination control is to reduce the potential for ingestion of radioactive material.
6.
TRUE FALSE A facility with a source materials license may use any designation they chose to indicate where radioactive materials are used.
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The. source materials license urder which the Dept. of Army
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TRUE FALSE operates was issued and is e.iforced by the D0A &.the NRC.
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Much of the radiation ~ that you will receive in your 8.
TRUE FALSE lifetime will come fror, background radiation, medical and.
dental x-rays and othe sources that'are not related to your occupation.
Filter type respirators are designed to provide protection 9.
TRUE FALSE against radioactive gases.
As the distance from a radioactive point' source increases,
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- 10. TRUE,, FALSE the exposure. rate decreases.
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PART 11
' Multiple choice - circle the correct answer.
1.
What is the regulatory limit for whole body external radiation exposure if past exposure' history is not known?
a.
50 rem /yr b.
1.25 rem / quarter c.
5 rem / quarter d.
3 rem /yr 2.
What is the recommended radiation exposure limit to the fetus?
a.
I'.25 rem b.
5 rem c.
500 mrem d.
10 rem 3.
ALARA means:
a.
All laboratories are required authorization b.
All laboratories are requested annually c.
As low as reasonably achievable d.
Alarm located at reactor areas 4.
What is radioactive contamination?
Any radioactive material in a location where it is not wanted a.
b.
Throium daughter products c.
Radioactive material in the environment d.
Radioactive material in the air 5.
The primary purpose of protective clothing is:
a.
Shield gamma radiation b.
Make people easier to see c.
Minimize the amount of wear and tear on personal clothing d.
Provide a barrier between people and contamination I
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- e 6.
What is the purpose of wearing a respirator?-
a.
Make it' easier to work
-b.
Reduce the amount of time to do a job c.
Reduce the amount of radioactivity in the room air d.
Reduce the amount of radioactivity breathed into'the lungs 7.
.The time required for any given radioisotope to decay to one-half the original quantity is called the:
a.
half life b.
activity c.
half value layer d.
response time
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e.
none of the above 8.
A personnel dosimeter:
a.
Protects you from radiation b.
Gives immediate reraout of radiation dose c.
Provides a legal record of a workers exposure d.
Turns red when rxposed to significant amounts of radiation 9.
The primary types of ion'izing radiation of concern 'to radiation workers are:
a.
x-ray, gamma, photons, mesons j
b.
alpha, beta, gamma, neutrons c.
deuterons, photons, mesons, exxons
- 10. Which of the following are required before a licensee, such as D0A, can take credit for the fact that an employee was wearing a respirator:
a.
The respirator must be a NIOSH approved type.
b.
The worker must be tested to make sure that it fits properly.
c.
The respirator must be cleaned and inspected between uses.
d.
The worker must have had a physical examination to assure that he/she is physically fit to wear a respirator.
e.
All of the above.
f.
None of the above.
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q Resume of George Drucker I
DECREE 4
The Cooper Union for the Advancement of Arts and Sciences New York, NY 1953 -1962 (Evening course)
B.S. - Mechanical Engineering ADDITIONAL EDUCATION Radiation Physics (at Picatinny Arsenal)
New York Institute of Technology, Brooklyn, NY July 1973 Basic results from rela tivity and atomic physics. Pho tons and photon interaction processes. Nuclear structure. Reac tions,
sources, and doses.
Nuclear Engineering New Jersey Institute of Technology, Newark, NJ February 1971. June 1971 Production, detection and interaction of neutrons with ma tter. Nuclear reac tor theory. Radia tion shielding.
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Reliability Analysis i
New Jersey Ins t. of Technology, Newark, NJ November 1969 Probability; distributions; hazard functions; failure mod-i els; drif t failure.
Engineering Probability New Jersey Inst. of Technology, Newark, NJ August 1969 Concepts of probability and random variables with applica-tions to reliability, s tatistics, and other areas of engi-
[
neering.
l i
TRAINING Neutron Radiography Aeroje t-General Nuclear Reactor, San Ramon, CA May 1971 Theory and practice of neutron radiography employing reac-tors and neutron-emitting nuclides. Health physics.
g Included time on the reac tor and associated f acilities.
Refresher Training in Radiological Health and Safety Safe ty Of fice, Picatinny Arsenal, Dover, NJ November 1978 Enc /
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Ionizing radia tion (x-rays): properties and production;
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detection ins trumenta tion; biological effec ts; pro tection.
Opera tion of the " Gamma tron 100" F.L. Clif ton Associa tes (at Picatinny Arsenal) j March 1976 Operation and protec tive procedures for the employment of this cobalt-60 exposure device.
Radia tion Assis tance TYaining Safety Office, Pica tinny Arsenal, Dover, NJ Oc tober 1976 Emergency procedures for detecting and neutralizing a radiological source which has been accidentally exposed.
Accident Reporting Sa fe ty Of fice, ARRADCOM, Dover, NJ July 1982 Training in accordance with Title 29 Code of Federal Regu.
la tions Part 1960.55 and AR 385 10.
Radiographic NDT Orientation Prod. Assur. Dir., Pica tinny Arsenal, Dover, NJ August 1974 Audio / visual presentation on industrial radiography includ.
ing opera tional sa fe ty.
RELEVANT EXPERIENCE Prod. Assur. Dir., Picatinny Arsenal (and Loccessor organi.
za tions)
November 1970 - March 1985 Radiology Group Engaged in the design and execution of NDT programs employ.
ing penetra ting radia tion, including x-ray, neutron and gamma ray sources. Extended involvement in neutron radiography using californium-252, included calculations for modera-tors and shielding, and the use of neutron and gamma ray de tec tors. Was project engineer on the AIDECS program whose purpose was to develop a filmless, automated inspection sys.
tem to evaluate artillery shell in real-time.
Formulated radiographic test requirements for inclusion into
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military spec 8. fica tions.
Visited Army ammunition loading plants to assist with any radiographic problems encountered I
in those areas. Served a t various times as the acting chief of the Picatinny Radiographic Facility.
Have been alterna te Product Assurance member of Ionizing Radiation Control Committe (formerly the Radiant Energy Board) for the Ins talla tion since Oc tober 1974.
Am collateral duty safetry coordinator for building 1090, the loca tion of our 1s t genera tion AIDECS sys tem.
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