ML20248M085
| ML20248M085 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 06/10/1998 |
| From: | Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 70-0398-98-01, 70-398-98-1, NUDOCS 9806120356 | |
| Download: ML20248M085 (4) | |
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UNITED STATE] DEPARTMENT OF COMMERCE
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NationalInstitute of Standards and Technology
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Gaithersburg Maryland 208990001 June 10,1998 4
U. S. Nuclear Regulatory Commission License No. SNM-362 ATTN: Document Control Desk Docket No. 070-00398 Washington, D. C. 20555 Inspection No. 070-00398/98-001 U. S. Nuclear Regulatory Commission Regional Administrator Region 1 475 Allendale Road King of Prussia, Pennsylvania 19406-1415
Subject:
Reply to a Request fe: hfonnation Gentlemen:
This letter is in reply to your letter of May 29,1998, requesting further information on the response to inspection number 98-01.
Enclosed are copies of the safety information previously posted and the new emergency precedures that are now posted at the doors.
With respect to the questions on room entry during a power failure, note that the emergency procedures now call for survey meter use during the first entry during a power failure to insure that j
the source shutter has closed. A check source is located near the survey meter storage position and instructions for its use are posted at that position. The additional monitor is line powered, so it will not function during power outages. Its function is simply an addition to the " defense-in-depth" precautionary mechanisms for safety.
The primary mechanical safety feature is the air pressure system that holds the source shutter open; upon loss of power or upon door opening while the shutter is open, the exhaust valve activates, releasing the air pressure and closing the shutter. Should there be any question of this functioning properly, a valve near the console permits manual release of air pressure to cause shutter closure. A second feature is the radiation monitor that has been mounted inside the room; it souads a buzzer that is checked upon initial setup of the facil ty for an irradiation, and it lights red lights that have a delayed turn-oft so they are visible upon opening the door to the room afler an irradiation procedure.
The lights change from red to opal in a short period following opening the door so it would be g
obvious if an untoward radiation level existed within tlc room. The additional radiation monitor has a
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push-button check for the visible and audible alarm and will be tested semiannually with a radiation source.
l Enclosed is a copy of the amendment request submitted to the license review group at USNRC j[
headquarters. We do not consider these to be corrective actions to the cited regulations; we consider j
them to be requests for exemptions to the regulations. Please note that this request was also USNRC Document Contrcl Desk for easy access.
I 9906120356 99061'0 PDR ADOCK 07000398 C
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If you have further questions about this matter, please contact Mr. T. Hobbs at 301-975-5800, Room Cl25, Bldg. 245.
t-i Sincerely, L. E. Pevey, le Occupational He th and Safety Division L
- (Materials License Manager) l
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U. S. Nuclear Regulatory Commission i
ATTN: Document Control Desk Washington, D. C. 20555 Licensing Branch (T8D14)
Division of Fuel Cycle Safey and Safeguards Office of Nuclear Materials Safety
- and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555May 20,1998 l
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National Bureau of Standards
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23 June 1976 SAFETY INFORMATION Part 20 of the " Code of Federal Regulations" dated 29 April 1976 imposes certain requirements on the users of teletherapy sources, where the radiatioa levels may exceed 500 rems in one hour at one meter from the source.
These requirements, and the devices and actions designed to bring this radiation area into conformity with the requirements, are listed below:
Requirements Device or Action i.
Entrance control device.
Door interlock Entrance control device properly functioning.
Reset light goes out.
11.
Entrance control device Shutter will not open or malfuncti on.
shutter will close.
If shutter does not close red light and buzzer are on.
iii.
Failure of physical Not applicable.
radiation barrier.
iv.
Visible and audible alarm Red light and buzzer.
before source is operated.
v.
Administrative and operating Only trained personnel are to procedures.
use the sources.
Source room must be checked before operation.
vi.
Physical radiation measure-Continuously operating radiation ment of source room prior sensitive monitor in conspicu-to entrance after any use.
ous location.
vii.
Test entry control devices.
Test interlocks.
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a EMERGENCY PROCEDURES SOURCE MALFUNCTION: IF POSSIBLE, CLOSE THE SOURCE SHUTTER.
INSURE THE DOORS ARE LOCKED AGAINST INADVERTENT ENTRY AND MARKED AS MALFUNCTIONING. CALL THE RESPONSIBLE FACILITY OPERATOR AND CALL HEALTH PHYSICS.
POWER FAILURE:
ON THE FIRST RADIATION ROOM ENTRY DURING OR FOLLOWING A POWER OUTAGE, A PORTABLE SURVEY METER MUST BE CARRIED INTO THE RADIATION ROOM TO INSURE THAT THE SOURCE SHUTTER HAS CLOSED.
FIRES:
IF POSSIBLE, CLOSE THE SOURCE SHUTTER.
CLOSE AND LOCK ALL DOORS. PROCEED TO A SAFE AREA, CALL THE EMERGENCY NUMBER, AND AWAIT THE ARRIVAL OF TRAINED RESPONSE PERSONNEL.
INJURIES:
CALL THE EMERGENCY NUMBER. PROVIDE FIRST AID IF TRAINED. OTHERWISE, AWAIT TRAINED RESPONSE PERSONNEL.
Responsible Facility ODerator Emeraency Number Paul Lamperti, ext. 5591 ext.2222 Alternates Health Physics J. T. Weaver, ext. 5586 ext. 5800 Jileen Shobe, ext. 5595 05/15/98
i,,a o* e.Y.1UNITE] STATE] DEPARTMENT OF COMMERCE i
i National Institute of Standards cnd Technology
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May 20.1998
\\'%i'f Gaithersburg, Maryland 208990001 U. S. Nuclear Regulatory Commission License No. SNM-362 ATTN: Document Control Desk Docket No. 070-00398 Washington. D. C. 20555 Licensing Branch (T8D14)
Division of Fuel Cycle safety and Safeguards Office of Nuclear Materials Safety and Safeguards U. S. Nuclear Regulatory Commission Washington. D. C. 20555
Subject:
Request for License A'nendment (Exemption)
L' l
Gentlemen:
We are requesting amendment to our license number SNM-362 to clarify the off-site operating permission now described in our Materials License Document, dated June 19,1997, and to exempt NIST from a number of sections of 10 CFR Part 36.
l The clarification is for item 9 of the existing license, indicating the authorized place of use as our Gaithersburg. Maryland facilities. Section 1.8, page I-1-3, of the NIST Materials License Document requests authorizadon to use radioactive material at off-site locations subject to several provisions relating to the safety of such an operation. We request that Item 9 in the license be changed to reflect the permission for off-site operations by adding a phrase such as "and temporary job sites under NRC i
l jurisdiction."
l l
The exemptions to Pan 36 pertain to our venical beam radiation facility that utilizes teletherapy-style l
source heads that are not used for human exposures. There are three heads: one (1) in Room B034 and
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two (2) in Room B036. with the control console for all units in the middle room. 8035. in Bldg. 245.
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The sources are used for research and development projects, calibration ofinstruments. and inadiations
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of dosimeters and other materials. Customers include medical, commercial, federal and state govemment, and international facilities. The facility was built in the early 1960's and irradiations began in 1965. Through the ensuing years, modifications for operations and for safety purposes have I
been incorporated.
I 1
l Enclosure I shows a plan view of the facility with dimensions. Enclosure 2 shows a plan view of the facility and adjacent areas with results of a radiation level survey of occupiable areas conducted unJer maximum beam scatter conditions. Enclosure 3 shows the safety analysis for the facility, with accompanying emergency procedures. Enclosure 4 is the revised set of pages drafted for the Materials License Document. pending approval of this exemption request. Also included in Enclosure 4 are updated information pages. such as membership in the Ionizing Radiation Safety Committee.
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3 In justi6 cation for the exemption request, we offer the following characteristics and descriptive comments about the various sections of 10 CFR Pan 36 involved in the request.
Section 36.23(a)
Annlicable Portion of Requirement The personnel entrance door or barrier must have a lock that is operated by the same key used to move the sources.
Justi6 cation for Exemption The current procedure requires the console to be active as the personnel entry door interlock is tested.
i The age of the facility and the interconnectivity of the safety features make it prohibitively expensive to modify to meet this requirement. The console key may not be temoved nor may the personnel entrance door be opened without closing the shutter to the source.
Section 36.23(b)
Applicable Portion of Requirement The (backup access control) alarm must also alert at least one other individual who is onsite of the entry.
Justi6 cation for Exemotion The age of the facility and the limitations of the existing site alert system make it prohibitively expensive to modify to meet the response requirement. There are no entry paths other than by opening the personnel entrance door, which will close the shutter to the source. An additionas radiation monitor is being installed inside the entry door that will generate a visible and an audible signal if the door is l-opened AND a radiation level above normal background exists. That installation should be completed by September 30.1998. Until it is operational, a portable survey meter will be used for the Grst i
personnel entry into the radiation room following an irradiation.
Sectbn 36.23(c)
Apolicable Portion of Requirement Attempted personnel entry while the monitor measures high radiation levels, must activate the alarm described in paragraph (b) of this section.
Justi6 cation for Exemotion This will be addressed by the comment for 36.23(b), immediately preceding. This will alert the person opening the door of an unsafe condition.
Section 36.23(d)
Applicable Portion of Requirement Before the sources move from their shielded position... the serce control must automatically activate I
conspicuous audible and visible alarms....
Justi6 cation for Exemption j
The small room size and consequential obvious room occupancy to the operator preparing the room l-for source use preclude occupancy during beam operations. This room inspection serve the same
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L purpose as a preliminary visible or audible signal for source exposure. The interlocks on the slidmg lead door and on the entry door, with the associated time-out delay, and the visual inspection of the L
small room by the operator while closing the sliding lead door and then the entry door, offer assurance of safety with respect to inadvertent or even deliberate room occupancy during operations.
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. Section 36,.27(a) and (b)
Anolicable Portion of Requirement -
The' radiation room... must have heat and smoke detectors.... The sources must become fully shielded b
' if a fire is' detected.-
Justification for Exemption
~ The radiation room is provided with a heat detector linked to the central security console in Building 101, Administration. The age of the facility and the interconnectivity of the' safety features make it
. prohibitively expensive to modify to meet this requirement. The signal from a heat-producing situation will alert the NIST Fire Protection Group that will respond quickly. If there is an indication at the room entrance, i.e., lit warmag red lights, that a radiation level above nonnal exists, the responding p
tiremen will stop there and await the arrival of Health Physics. A review by a Captain aad others of g
F the Fire Protection Group confirmed the operations / Health Physics determination that the only potential source ofignition in the room is electrical. Combustibles, flammables, and explosives are administratively controlled in the room so that quantities are insufficient to threaten damage to source encapsulations or shield integrity.
Section 36.31(a)
Apolicable Portion of Requirement The (console) key must be attached to a portable radiation survev meter by a chain or cable... The
~ door to the radiation room must require the same key..
Justification for Exemption
~As described in the response for 36.23(a), above, both'a console key and a room door key are used.
'Since the purpose of this requirement is to assure that no one inadvertently enters a high radiation tield, measurement of radiation levels and indications by means other than with a hand-held survey meter should be acceptable. The current operational radiation monitor, when triggered by a beam ON j
condition, causes the activation of an audible signal and a visible signal within the radiation room. The 4
additional radiation monitor described in the response for 36.23(b), above, will alert a person opening the' door that the shutter is open, providing backup assurance of radiation safety. Until this is installed.
a portable survey meter will be used for the first personnel entry into the radiation room following an -
. irradiation.
i Section 36.51(d)
Anolicable Portion of Reautrement i
The licensee shall conduct safety reviews for irradiator operators at least annually. (with specific topics inclusion, written test. emergency event practice drill)
Justification'for Exemption The operator staffis extremely stable; some of the persons authorized to operate the devices have been
. operating them since the initiation of the facility over thirty (30) years ago. New operators are permitted to function under direct supervision until they complete initial radiation safety training. The 4*
. current license requirement is for biennial training.- We will supplement this at periodic safety meetings
- of the staff with dissemination of topical information, such as changes to the facility, changes to applicable ' rules, or reports of incidents at irradiator facilities.
i Section 36.51(e)1
! Anolicable Ponion of Requirement The licensee shall evaluate the safety performance of each irradiator operator at least annually....
. Justification for Exemotbn
- Direct oversight for new operators until they complete initial radiation safety-training assures safe operations.;The required biennial training includes skills and knowledge testing. Long-term projects
. using th' facility are extremely infrequent, so annual observation of operator performance quality e
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cannot be done.
Section 36.51(g)
Annlicable Portion of Requirement Individuals who must be prepared to respond to alarms required by (various sections of Part 36) shall be trained and tested on how to respond. 2ach individual shall be retested at least once a year.
Justification for Exemntion The existing simplistic procedures, i.e., stop and call the Responsibb Facility Operator or call Health Physics, for response to situations that do not trigger Fire Protection Group response are part of the initial training, and posters at the room entrances advertise this prominently. The training, including tests, for the Fire Protection Group is much more frequent than annual.
Section 36.67(a)
Annlicable Portion of Reauireg Upon first entering the radiation room of a panoramic irradiator after an irradiation, the irradiator operator shall use a survey meter to determine that the source has returned to its fully shielded position.
Justification for Exemption The room is interlocked to prevent entry unless the source returns to a shielded condition. The existing radiation monitor gives visible and audible warnings of high radiation levels. The radiation monitor to be instailed. Jescribed in the response to 36.23(b), above, will provide additional assurance that the shutter has closed. Until the monitor is installed, a portable survey meter will be used for the initial entry following an irradiation procedure.
If you have further questions about these requests, please contact Mr. T. Hobbs at 301-975-5800.
Room C125. Bldg. 245.
Sincerely, L. E. Pevey. Chief Occupational Health and Safety Division (Materials License Manager)
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- enclosure'3 VERTICAL BEAM IRRADIATION FACILITY SAFETY ANALYSIS
. This safety analysis is for the facility with teletherapy-style source heads that are not used for human exposures. There are three heads: one (1) in Room B034 and two (2) in Room B036, with the control console for all units in the middle room, B035, in Bldg. 245. The sources are used'for research and development projects, calibration of instruments, and irradiations of.
dosimeters' and other materials. Customers include medical, commercial, federal and state government, and international facilities. The facility was built in the early 1960's and irradiations began in 1965. Through the ensuing years, modifications for operations and for safety purposes have been incorporated.
- I. Access Control
' Keys to the Control Room, B035, and to the beam rooms are restricted to members of the Radiation Interactions & Dosimetry Group of the Ionizing Radiation Division and Health Physics. Access to keys to the operating console are restricted to authorized operators of the.
' units.
1 II. Source Storage and Operations
- For situations other than normal irradiation procedures, e.g.,' for maintenance, the Responsible Facility Operator will record specific conditions and characteristics for the special circumstance in the log book kept at the console.
Prior to initiating an irradiation, the console key will be inserted in the console and the panel activated. The operator will ascertain that no person remains in the radiation room by
- visually examining the entire area before pushing the inspection interlock, located just inside -
the sliding lead door. Within thirty (30) seconds, the operator will slide the lead door shut and leave the room, closing the personnel entry door. The operator will open the shutter, go to the personnel entry door. listen to assure that the warning buzzer is sounding within the radiation
. room, and look up to see that the radiation lights are lit. Opening the door and quickly looking at the set of two (2) red and two (2) opal lights just outside the sliding lead door, the operator will assure that the red lights go off and the opal lights come on, indicating that the -
source' shutter has closed and that the interlocks have functioned correctly. If these conditions m
3 are not met, the operator will implement the Emergency Procedure for malfunctions. A single test will suffice for a series ofirradiation procedures with no intervening period of non-operation.
Following the safety check assurances, the operator closes the doors, as above, and the i exposure procedure is initiated.
- III. Fire Safety The Fire Protection Group has confirmed that the only source ofignition in the room is electrical. The Responsible Facility Operator must assure that no flammables, explosives, nor j
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other combustibles are present in the radiation room that can threaten the integrity of the source capsules o'r the shield. Heat ' etectors are mounted at the ceiling level. These signal the -
d security console in Bldg.101 and at the Fire Station console for heat overloads. The fire i
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protection personnel responding to a signal will stop at the personnel _ entry door if an ind.ication of unshielded sources is noted, and call Health Physics. If no such indication is noted, the responding fire protection staff will proceed to enter the radiation room and remediate the condition' causing the heat overload.
IV. Other Hazards An individual may not work alone in the radiation room when the beam catcher pit is uncovered. Safety shoes may be considered to help avoid toe or foot injury from falling objects.
V. Posting and Labeling The source heads will be labelled with CRM signs with nuclide and dated quantity information. The personnel entry door will be labelled with CRM and with " Grave Radiation Danger" posters. Two (2) red and two (2) opal lights will be inside the personnel entry door, to indicate shutter closed (opal) or shutter open (red) condition. At least one (1) red light will be visible outside the personnel entry door to indicate shutter closed (light OFF) or shutter open (light ON) condition. The lights are triggered by a radiation monitor within the radiation room but not in the direct beam.
VI. Facility Supervisors The Responsible Facility Operator is Paul Lamperti, ext. 5591. Alternates are J. T. Weaver, ext. 5586, and Jileen Shobe, ext. 5595.
VII. Operator Training Operators will be trained by the Responsible Facility Operator or a designated alternate.
Training will include safety features such as safety interlock a surance testing, emergency procedures, and contact lists for response personnel, e.g., Health Physics. A list of current trained operators will be maintained at the console, with annual updating. The Responsible Facility Operator will assure that interim training information on such matters as facility or operational changes, reports ofincidents from this or similar irradiation facilities is h
transmitted to trained operators to supplement the biennial training required for radiation work.
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i 05/14/98 i
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EMERGENCY PROCEDURES I
SOURCE MALFUNCTION: IF POSSIBLE, CLOSE THE SOURCE SHUTTER.
INSURE THE DOORS ARE LOCKED AGAINST INADVERTENT ENTRY AND MARKED AS MALFUNCTIONING. CALL THE RESPONSIBLE FACILITY OPERATOR AND CALL HEALTH PHYSICS.
POWER FAILURE:
ON THE FIRST RADIATION ROOM ENTRY DURING l
OR FOLLOWING A POWER OUTAGE, A PORTABLE l
SURVEY METER MUST BE CARRIED INTO THE RADIATION ROOM TO INSURE THAT THE SOURCE SHUTTER HAS CLOSED.
FIRES:
IF POSSIBLE, CLOSE THE SOURCE SHUTTER.
CLOSE AND LOCK ALL DOORS. PROCEED TO A l
SAFE AREA, CALL THE EMERGENCY NUMBER, i
AND AWAIT THE ARRIVAL OF TRAINED RESPONSE PERSONNEL.
INJURIES:
CALL THE EMERGENCY NUMBER. PROVIDE FIRST AfD IF TRAINED. OTHERWISE, AWAIT TRAINED RESPONSE PERSONNEL.
Responsible Facility ODerator Emergency Number Paul Lamperti, ext. 5591 txt.2222 Alternates Health Physics J. T. Weaver, ext. 5586 ext. 5800 Jileen Shobe, ext. 5595 05/15/98
This enclosure is in two (2) parts: one (1) section has material to be deleted lined out and material to be added in bold italic print. The second section is a set of the pages to replace existing pages in the Materials License Document dated 6/19/97, i.e., with the material either deleted or added, as appropriate.
PAGES INVOLVED I-1 -3 I-2-3 I-2-4 I-3-4 II-8-2 II-8-3 I1-8-4 (new)
II-9-3 II-10-2 I1-10-3 II-l 1-3 II-l 1-5 i
&w---------_____
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PAGES WITH MODIFICATIONS SHOWN l
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Among the types of activities that may be authorized, the following topical list illustrates typical projects that may exist. Also listed are those buildings that would most probably be involved in a particular type of activity, although special authorizations by Health Physics could alter the locations listed.
materials and equipment irradiations - Bldgs 235 and 245 a
source preparations - Bldgs 220-226,235, and 245 m
source calibrations - Bldgs 220-226,235, and 245 m
instmment calibrations - Bldgs 220-226, 235, and 245 e
sample assays - Bldgs 220-226,235, and 245 m
source characterizations - Bldgs 220-226,235, and 245 m
instrument and device characterizations - Bldgs 220-226,235, and 245 m
reference or counting source uses - Bldgs 101,220-226,235, and 245 m
radiochemistry - Bldgs 220-226,235, and 245 m
general research and development - Bldgs 101,220-226,235, and 245 m
sources incorporated into devices or equipment - Bldgs 101,220-226,235, and 245 m
miscellaneous, e.g., static elimination - Bldgs 101,220-226,235, and 245 a
1.8 Special Authorizations We request that radioactive material use be authorized at off-site locations subject to the a.
following provisions:
the proposal is reviewed and approved by Health Physics and, if required, by the Ionizing a
Radiation Safety Committee.
NIST is responsible for the safe use of the radioactive material, which is controlled by m
an authorized individual who possesses written operating instructions while engaged in the project.
the radioactive material is ar, integral part of a measurement instrument or a contained a
source, such as a check or reference source.
lead-in-paint detectors may not exceed 100 millicuries ofcadmium-109 or americium-241 a
as sealed sources in each device, otherwise the total quantity of radioactive material for a single authorized use may not exceed ten times the activity listed in 10CFR20, Appendix C, or, for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity.
- b. We request authority to release contammated equipment to uncontrolled areas in accordance with the USNRC's April,1993 " Guidelines for decontamination of facilities and equipment prior to release for unrestricted use or termination oflicenses for byproduct, source, or special nuclear material."
We request exemption from 10 CFR Part 36, Sections 23(a), 23(b), 23(c), 23(d), 27(a),
c.
27(b), 31(a), Sl(d), Sl(c), 51(g), and 67(a). The age of thefacility utili:.ing teletherapy-style source heads and the expense ofmodifying thefacility, coupled with existing safetyfeatures such as stability of permanent operating staff; multiple redundant interlock and radiation monitor systems to close the source shutters when activated, and the addition ofan audible and visible radiation field monitor that will warn of high levels upon entry should the shutter closing mechanism fait provide adequate assurance ofpersonnel safety.
05/20/98 l-1-3
2' understariding is by performance observations, dosimetry reviews, personal interviews, prior work experience, or similar evaluation methods. Should safety-related changes be made in operations, or should any employee be reassigned or remrn after extended absence, the Division Chief determines the need for retraining.
Health Physics technicians are trained in fundamentals of radiological safety commensurate
- with their levels of responsibilities. Topics for this training might include the following:
' basic principles; particle and photon properties; dosimetry concepts and practices; shielding; biological effects of radiation; protection standards; instrumentation and equipment concepts and practices; and
- operations for which specific responsibilities are assigned, such as radioactive materials, and personnel or environmental dosimetry.
All individuals who work with radioactive materials and the Health Physics technicians are required to participate in biennial radiological safety training. The Chief of Health Physics assures that training programs are available as required.
I
' At intervals such as ut the periodic safety awareness meedngs for staff personnel, informadon on such topics as facility changes, operadonal changes, reports ofincidents at similarfacilides, and other peninent matters will be disseminated to appropriate personnel 2.7 Operating Procedures Written operating, maintenance, and test procedures for work with licensed radioactive materials are developed and followed. Those generated by the prospective radioactive material user are reviewed by Health Physics. Following the review and upon agreement on the safety practices to be observed, a Supervisory Health Physicist or a person with the same qualifications i
approves the proposal, subject to review if necessary by the Ionizing Radiation Safety Committee.
Similarly, proposals for radiological safety-related changes in existing procedures, equipment, or facilities also require Health Physics review and approval, subject to Ionizing Radiation Safety Committee review if necessary. Health Physics review addresses compliance with regulatory requirements and limits, ALARA commitments, monitoring concerns, emergency planning, and training needs. Any required Health Physics surveillance and observations of procedures, including frequencies, are specified. Health Physics surveillance of radiation and radioactive l
material control during operations indicates if there is a need for any procedural updating and i
review.
Health Physics operating procedures and major changes proposed for those procedures are reviewed and approved by the Chief of Health Physics. Health Physics procedures will be observed and followed.
2.8 Audits and Reviews lonizing Radiation Safety Committee representatives other than Health Physics staff annually audit the performance quality of operations that provide radiological safety assurance, reporting to the Committee and indicating necessary actions and follow-up audits. At least annually, Health l~
05/2038 123 l
L___--____-_-______-_---_____-
Physics st'aff members review surveillance techniques and results to assure compliance with applicable protocols, documenting results and follow-up actions and results.
Supervisory Health Physicists or persons with qualifications equivalent to those of a i
Supervisory Health Physicist conduct radic. ion workplace safety observation tours at least quanerly for those workplaces that pose significant potential for radiation exposures or releases of radioactive materials, following written plans. Results of the tours are documented and corrective action needs found during the tours are transmitted to workplace supervisors in a
. timely fashion.-
l 2.9 Investigations and Reporting of Off-Normal. Occurrences Health Physics, based on repons from Division Chiefs or workers, or on results of monitoring or surveillance, investigates suspected off-normal occurrences. The Chief, Occupational Health and Safety Division, reports these conditions to authorities and to management, as required by l
applicable regulations, procedures, and license conditions.
2.10 Records Health Physics maintains documentation on the results of required monitoring and surveillance, the results of approved proposal reviews, off-normal occurrence investigations, and other radiological safety program information, sufficient to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee documents and retains f
information on audits and provides reports to management as required. Retention times for
-documents are as required by regulations or for at least two years.
2.11 Fire Protection A Fire Protection Semees gGroup in the Facilities Services Division provides a trained fire and emergency. response organization. Any proposed laboratory or facility construction or modification must be reviewed by and have the approval of such management interests as the head of the Safety Office, i: Chief f i: Fi : "= ::::: S rci:n, and the Chief of the Plant Division or his designated representative. Members of the staff of the Fire Protection Seevices gGroup are trained to the equivalent of Fire Fighter III level. Maintenance of fire fighting equipment is conducted according to written procedures. Extensive pre-fire plans exist, with information on locations of radioactive materials, flammable materials, and other hazardous materials, and includes fire fighting protocols for those areas. The plans include locations of water su.pplies, storage areas, and other appropriate information. The Fire Protection S:rvies Group maintains extensive documentation on maintenance and deployment of equipment, pre-fire planning, facility characteristics, training, results of actual occurrences, etc.
I 1
05/20/98 l-2 4
- 2. The periodic leak test required by this section does not apply to sealed sources that are stored and not being used. Prior to any use or transfer to another person, the source shall be leak tested within 6 months prior to the date of use or transfer.
B. The test shall be capab!e of detecting the presence of 0.005 microcuries of radioactive material on the test sample. The sample shall be taken from the sealed source or appropriate accessible surfaces of the container or from the device where the sealed source is mounted o stored in which one might expect contamination to accumulate. Records ofleak test results shall be kept in units of microcuries and maintained for inspection by the USNRC.
If the test reveals the following:
1.
17tr presence of 0.005 microcuries or more of removable contamination from the sealed scerces other then described below, or 2.
"c.: pr:x:= cf 0.05 =!=c:=ic :: =::: cf ::=:=bk :: 29r:i:: far., $
- kin py =
d ;;= :, =
- 32. An indication that the i=dk::: sealed source which is stored in the water pool for shielding purposes is leaking, then l
NIST shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed ofin accordance with USNRC regulations.
Within 5 days after determining that any source has leaked, NIST shall file a report with the Division of Fuel Cycle Safety and Safeguards, USNRC, Washington, D. C. 20555, describing the source, test results, extent of contamination, apparent or suspected cause of source failure, and corrective action taken. A copy of the report shall be sent to the Admmistrator of the NRC Regional Office for Region I.
1 l
05/20/98 1-34 l
________2
I:
l 8.4 Maps, Buildings, and Site Information
' Attachment I contains a NIST site plan and a topographical representation, building locations on site, and floor plans for buildings. The site exhibits a gently rolling topography and contains l
lboth open and wooded areas. Buildings include a central complex of the main administration building and several general purpose buildings designed to contain laboratories that accommodate customary scientific research and development functions, buildings that house the support functions ranging from grounds management heating and air conditioning, and the like, to procurement, and special purpose laboratory buildings that are dedicated to specific research and development functions. This last category includes the Reactor and the Radiation Physics Buildings, where the majority of the work involving radiation and radioactive materials is conducted.
8.5 License History
' Table II.8-2 shows a chronological ordering of licensing history at NIST for radioactive materials. This history tracks licenses to the most recent renewal. In some cases, e.g., for 08-00566-05, the byproduct material license, a full history would extend to more than thirty years with many amendments and renewals. In 1980 a Materials License Manager was named to bear responsibility for licensing other than for the NIST Reactor. In 1985, five major licenses were consolidated into the single SNM-362 license.
l l
i l
i 05/20/98
!!-8-2 L________
4
' TABLE II.8-2 NIST MATERIALS LICENSING
SUMMARY
YEAR LICENSE ACTION (identifier) 1997
~SNM-362 renewal 1990 -
SNM-362 amendments 1 - 4 l
1994 I
1985 -
SNM-362 amendments 1 - 4 1990 1985 08-00566-05, 08-00566-10, 08-consolidation, incorporation into 00566-12, SMB-405, SNM-362 License No. SNM-362 1983 08-00566-05 Class I irradiator request I
1982 all Ionizing Radiation Safety Committee 08-00566-05 change in limits (byproducts) all personal dosimetry technique 1981 SNM-362 filter process (SNM)
SNM-362 change in limits 1
08-00566-10 renewal (teletherapy) i 1980 SMB-405 license manager named (source) l 1
1979 SNM-362 renewal 08-00566-05 change in limits l
1978 SMB-405 renewal 08-00566-12 renewal (irradiator) 1977 08-00566-05 renewal I
05/20,98 11-8-3
l 8.6 Changes in Procedures, Facilities, and Equipment
_'NIST employees and other individuals working on the NIST site are responsible for l
obtaining authorizations from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiological safety, or for disposition of radiation sources. Division Chiefs are responsible for ensuring that staff members comply with radiological safety rules and that staff members are aware of radiological safety procedures. The Chief, Occupational Health and Safety Division, is charged with managmg i
the radiological safety program and with representing the National Institute of Standards and i
l Technology in all matters relating to materials licensing. The Chief, Health Physics, is charged with administering the radiation safety program at NIST, including maintaining i
L documentation to demonstrate the adequacy of the radiological safety program. The Iomzing I
l-Radiation Safety Committee is responsible for reviewing major radiation facility proposals L
and significant proposals for use of radiation, including modifications to existing facilities, i
l and for assuring the performance quality of operations that provide radiological safety l
assurance.
I l
8.7 Examples of Operations That Might Be Conducted As an example of the miscellany of types of work done at NIST, consider NCRP Report No. 58, A handbook ofradioactivity measurements procedures. second edition. Of the fifteen consultants listed in the preface to the first edition, ten were from one working group within l
NIST (then NBS), as well as the chairman of the scientific committee. The preface to the j
second edition names twenty-four persons who made contributions to that edition. Of those, l
fifteen were NIST (then NBS) personnel, including Health Physics staff members. The wide variety of operational activities and of radionuclides described in the publication, essentially the product of only one of the groups at NIST, illustrates the extremely broad scope of work done at NIST.
a l
For the specific nuclides listed in Table I.1-1, the following examples of research, development, and other activities will suggest the variety of operations involving radioactive materials at NIST. Uranium at any enrichment. from depleted through 99.9% 2'!U, 23'U, any l
nuclide of plutonium, and thorium, might be used in metallurgical research, for beam transmission studies, in neutron beam research, for check sources, or as beam filters. Scaled sources of 23 Pu are used as thermal sources. PuBe, PuLi, and other sealed Pu-X sources are used in neutron research and are calibrated for customers. Scaled sources of"Co, SCs, ziopo (sometimes as PoBe),2Am,32Cf, or "Sr might be used in research requiring photon, neutron, or beta radiations, for instrument calibrations, in neutron physics research, medical p
device (implant seeds, eye irradiation applicators, etc.) calibrations and research, or basic l
nuclear chemistry and physics research such as half-life studies. Miscellaneous byproduct materials, including materials and containers irradiated in the NIST Reactor and brought out i
of the Reactor licensed area, might be used as check sources, in laboratory intercomparison tests and studies, for light sources, for basic radiochemistry and nuclear physics research, for sample preparations for authorized customers, or in research for medical or other specific laboratory types.
05/20/98 11-8 -4
Wastes with short half-lives are treated by decay-in-storage. Disposal of decay-in-storage waste, as provided in 10CFR20.2001(a)(2), is in accord with conditions given in 10CFR35.92.
9.5 Chemical Systems Nonradioactive chemical operations are the responsibility of the Environmental Compliance Group of the Occupational Health and Safety Division. Any facility or operation involving toxic materials is reviewed to insure compliance with appropriate regulations.
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9.6 Fire Protection r
t 0100/97 1193 l
i
__d
o The buildings andfacilities et NIST were constructed in accordance with applicable l
regulationsfor Federalfacilities in effect at the time of construction and are maintained under thefire protection auspices of the Fire Protection Group of the Facilities Services Division. The coverage by this t~ainedfire and emergency response group includes around-the-clockfire, emergency medical, and hazardous material response capabilities.
The Fire Protection Group reviewsfacility plans, including locations offire hydrants, sprinkler systems layouts, access pathways, and other layout information related tofire fighting. The plans are maintained in the offices and workspace of the Fire Protection Group work area. Training offirefighters is according to the State ofMaryland and local i
County having authorization, in conjunction with NFPA. Materials and equipment available to the Fire Protection Group include appropriate vehicularfirefighting apparatus, water supply systems, 4 stomatic sprinkler systems, portablefire extinguishers, protective i
clothing, and tools used in fighting a variety offires, e.g., structural, vehicular, etc.
1 Maintenance and deployment offirefighting equipment is in accordance with NFPA codes.
Extensive pre-fire plans have been developed incorporating information on location of radioactive materials, fiammable substances, and hazardous materials storage areas. The plans includefirefighting protocols for those areas, with locations of water supplies, automaticfirefighting response mechanisms that might be employed, and other pertinent information. The Fire Protection Group maintains extensive documentation on deployment and maintenance of equipment, pre-fire planning, facility characteristics, training of
)
personnel, results of actual occurrences, etc. Portablefire extinguishers are deployed according to NFPA 10; these are commonly dry chemical and CO, types. In addition, portable extinguishers are commonly located in each laboratory and building hallways.
Portablefire extinguisher agency is determined by thefire load in the area of work.
Building entrances and stairwells have standpipe connections; fire hydrants are located at various positions on the exterior of buildings. The loading dock of Building 245 has a sprinkler system.
Laboratories are monitored with automaticfire alarm devices activated by heat or smoke, or both. Thefire alarm device type is determined by thefire hazard within the work area covered. Manualfire alarm boxes (pull stations) are located according to the NFPA code. Upon activation of any alarm, the signal is received at two locations: in the Fire Station in Bldg. 303 and in the Security Office in Bldg.101.
I j
j 05/20/97 11-9 -4 I
radiation safety program.
"10.1.4 Division Chiefs Each Division Chief managing radiation work is responsible for the following:
Ensuring that staff members comply with radiation safety rules in implementing the a.
NIST radiation safety policy; j
- b. Ensuring that staff members are aware of radiation safety procedures and receive training as required:
Reporting potential items of substantial safety hazard as defined in 10CFR21.3(k) e c.
to the Chief. Health Physics, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence or discovery, except 4
for items relating to the Reactor license which are to be handled according to that I
license; and I
- d. Reporting significant radiation safety matters to his or her supervisor.
10.1.5 Staff NIST employees and other individuals working on the NIST site are responsible for the following:
- a. Observing approved radiation safety rules;
- b. Consulting with Health Physics early in the planning of operations that might involve radiation sources;
- c. Obtaining authorization from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiation safety, or for disposition of radiation sources;
- d. Notifying Health Physics of any occupational radiation exposure from work at facilities other than NIST; e.
Immediately informing Health Physics upon discovery ofloss or theft of any radioactive materials; f.
Immediately informing their supervisors and Health Physics of accidents involving radiation or radiation sources; and
- g. Informing their supervisors of defects that could create a substantial safety hazard.
a 10.2 Organi=:ica R: Enizing Radia:ic: S;ferj Cc==in===h=' =d :M:=::=' n== and p:::=n:
==== =: '.!;::d b:k B: &: =i =.ng=i:k; ! 6: Cc==l::= = =bj=: := ch ng:. :
$ disre:ic; fi: Depurj Dir=:=.
(Chi) Dr Ch-i; E. Kuya::, E=:::w: Di=:ct, "i;ning Cc==in=, PhD, Phys:=,1960, Pkh=h-Uni.., =pri:=: in :!=::cn. ph::=, nd p ni& phy;ic.
(Vi= Chi) Dr Harj L. Rcck, Deparj Di=:=, ?t:=i6 Si=: nd Engi=aang L:irc:crj, PhD. uim A=ly:i=! Chemi;: y,1969, T== A & " Uni'., =pe-i== :n n=!= ch=i;;rj.
m
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Dr H=$= Ch= 'kyn, Phy;iit, A=!y:i=1 Ch:=irrj Di iin, PhD (Physic) 1989, CL"G'; =u::en phy;ic.
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05/20S 7 11 10-2
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- 10.2 Organization i
Siembers and alternates of the Ioni:ing Radiation Safety Committee are named by the i
Deputy Director of NIST. The current list, with organi:ational titles, is:
l l
(Chair) Dr. Chris E. Kuyatt, Director's Office; Executive Director, Visiting Committee j
(Vice Chair) Dr. Bert Af. Coursey, Director, Ionizing Radiation Division (IRD), Physics Laboratory (PL) i OW2W97 11103 i
Dr. James M. Adams,.Research Physicist, Neutron Interactions and Dosimetry Group, IRD,PL Mr. Jeffrey T. Cessna, Research Chemist, Radioactivity Group, IRD, PL Dr. Heather H. Chen-Mayer, Research Chemist, Nuclear Methods Group, Analytical Chemistry Division (ACD), Chemical Science and Technology Laboratory (CSTL)
Mr. Keith H. Eggert, Safety Engineer, Environmental Compliance Group, Occupational Health & Safety Division (OHSD), Office of the Director of Administration (Admin)
Mr. Douglas M. Eagleson, Supervisory Health Physicist, Health Physics Group, OHSD, Admin Mr. Thomas G. Hobbs, Chief,' Health Physics Group, OHSD, Admin Dr. Richard M. Lindstrom, Research Chemist, Nuclear Methods Group, ACD, CSTL Dr. Santos Mayo, Physicist, Semiconductor Electronics Division, Electronics and Electrical Engineering Laboratory (EEEL)
Mr. J. Franklin Mayo-Wells, StaffAssistantfor Technical Coordination / Operations, EEEL Mr. Lyman E. Pevey, Chief, OHSD, Admin Dr. Henry J. Prask, Physicist, Neutron Scattering Group, NIST Centerfor Neutron Research (NCNR), Materials Science and Engineering Laboratory (MSEL)
Dr. J. Michael Rowe, Director, NCNR, MSEL Dr. Frands J. Schima, Research Physicist, Radioactivity Group, IRD, PL Dr. Christopher G. Soares, Research Physicist, Radiation Interactions and Dosimetry Group, IRD, PL Dr. David S. Simons, Leader, Analytical Microscopy Group, Surface and Microanalysis Science Division (SMSD), CSTL Mr. Lester A. Slaback, Jr., Supervisory Health Physicist, Health PI'~ics Group, OHSD, Admin Ms. Cynthia J. Zeissler, Physical Scientist, Analytical Microscopy Group, SMSD, CSTL l
l 05/2W97 11-1 0-4
11.6 Surface Contamination
' Table 11.11-1, Controls and Action levels, and Table 11.11-2, Administrative Action Levels and Actions, list controlling levels for surface contammation. Measurements for surface contamination checking and protective measures are described in sections II-l1.1, II-l1.4, and 11-11.7 of this manual.
Hand and shoe monitoring may be performed -with conveniently placed equipment; resuspension factors for transforming surface contamination levels to airborne activity concentrations are applied as described in section H43-4 II-11,5 of this manual.
I1.7 Shipping and Receiving
. All radioactive materials received at NIST and all radioactive materials shipped from NIST are controlled by Health Physics. Usually, incoming packages are brought to the Health Physics receiving area in Building 245, unless alternate provisions are made with the ultimate recipient.
In either case, surveys for compliance with transport regulations are made within time limits specified by the regulations. Health Physics and the recipient then survey the package and contents and determine if the shipment is acceptable fd incorporation into the project for which the source is intended. Usually, outgoing packages are held in the NIST shipping area in Building 301 until Health Physics or a designated representative checks the package for compliance with transpon regulations.
Type B shipments are made in accord with the provisions of the quality assurance program as detailed in a separately submitted document.
If an incoming shipment shows contamination at any level of packaging, the package is held j
in the Health Physics or other designated storage area until a decision is made, jointly between Health Physics and the recipient, on retuming the source, decontaminating the source, disposing of the materials, or establishing proper controls for safe use of the source.
I1.8 Posting and Labeling Table 11.11-1 shows control mechanisms and action levels under which radioactivity operations are permitted. The contamination limits shown represent a depanure from customary practice in that specific nuclide limits are provided for beta-emitting nuclides when the identity of the nuclide is known. As an ALARA precaution, Health Physics requests decontamination of area:, in which any detectable contamination above normal background levels are found. Health Physics review may result in a detemunation that actions other than described in this table should be implemented. Such alternate actions are documented by Health Physics.
- 11.9 Surveys Health Physics performs weekly routine surveys of a laboratory in which unsealed radioactive material is utilized when the initial proposal or subsequent evaluation of the work environment demonstrates that levels could exceed the levels at which posting is required, as shown in Table II.ll-1. A: specified by Health Physics, the surveys could include smear tests of surfaces, radiation level tests. radiation quality tests, air activity contamination tests, or combinations of these, and other ~ radiation safety assurance procedures. For special situations, such as maintenance, similar surveys, time and motion studies, or practice sessions on mock 05/2 &95 !!.113
contamination might be expected to accumulate. Sources will be immediately withdrawn from use'and action taken to repair or dispose of the source, and appropriate actions taken to notify the NRC, if the following limits are exceeded for removable contamination:
a any indication of leakage from the irradiator sealed source in the water shielding pool.
e 0.05 mi:=:=ie: ===: f== a ::!:$:=py ejp: :=1;d==::.
e 0.005 microcuries or more from any other sealed source.
I1.12 Respiratory Protection l
Health Physics may issue dust stop or simi'a particulate breathing masks for dusty work environments. At the conclusion of thejob, Health Physics retrieves the masks and prepares them for reuse.
11.13 Protective Clothing Health Physics maintains a nominal supply of various protective clothing items, including gloves, shoe covers, coveralls, head covers, etc. These are freely available as needed for issue to laboratory workers using dispensable radioactive materials. For situations requiring protective clothing beyond the normal issue quantities, the requesting work imit may be asked to replenish the supply.
I1.14 Reports and Records The Chief, Occupational Health and Safety Division, documents management and authority notifications resulting from reports from Health Physics on off-normal investigations. Health Physics maintains documentation on routine and special radiological surveys, persormel monitoring, licensing interactions with NRC, instrument calibrations, ALARA reviews and findings, employee training and familiarization. environmental monitoring, and source control.
The Chairperson of the Ionizing Radiation Safety Committee maintains records of meetings of the Committee. Committee audits, and special reviews and investigations by the Committee.
1 Normal retention time for these records and documents is two years unless otherwise specified by regulations.
i 11.15 Administrative Control Levels Table II.11-2 describes the administrative action levels and the actions taken at those levels to control radiation and radioactive materials in specific situations and under specific conditions.
)
I 05/2(k98 11-11 5
7_
i f
PAGES FOR INSERTION INTO MATERIALS LICENSE DOCUMENT t.
1
Among the types of activities that may be authorized, the following topical list illustrates typical projects that may exist. Also listed are those buildings that would most probably be involved in a particular type of activity, although special authorizations by Health Physics could alter the locations listed.
materials and equipment irradiations - Bldgs 235 and 245 a
source preparations - Bldgs 220-226,235, and 245 m
source calibrations - Bldgs 220-226,235, and 245 m
instrument calibrations - Bldgs 220-226,235, and 245 m
sample assays - Bldgs 220-226,235, and 245 m
source characterizations - Bldgs 220-226,235, and 245 m
instrument and device characterizations - Bldgs 220-226,235, and 245 e
reference or counting source uses - Bldgs 101,220-226,235, and 245 e
radiochemistry - Bldgs 220-226,235, and 245 m
general research and development - Bldgs 101,220-226,235, and 245 m
sources incorporated into devices or equipment - Eldgs 101,220-226,235, and 245 m
miscellaneous, e.g., static elimination - Bldgs 101,220-226,235, and 245 m
1.8 Special Authorizations
- a. We request that radioactive material use be authorized at off-site locations subject to the following provisions:
the proposal is reviewed and approved by Health Physics and, if required, by the Ionizing a
Radiation Safety Committee.
NIST is responsible for the safe use of the radioactive material, which is controlled by u
an authorized individual who possesses written operating instructions while engaged in the project.
the radioactive material is an integral part of a measurement instmment or a contained a
source, such as a check or reference source.
lead-in-paint detectors may not exceed 100 millicuries of cadmium-109 or americium-241 a
as sealed sources in each device, otherwise the total quantity of radioactive material for a single authorized use may not exceed ten times the activity INed in 10CFR20, Appendix C, or, for those radionuclides not listed in Appendix C, may not exceed one microcurie of activity.
- b. We request authority to release contaminated equipment to uncontrolled areas in accordance with the USNRC's April,1993 " Guidelines for decontamination of facilities and equipment prior to release for unrestricted use or termination oflicenses for byproduct, source, or special nuclear j
material."
i
- c. We request exemptiw. from 10 CFR Part 36 Sections 23(a),23(b),23(c),23(d),27(a),27(b),
31(a), 51(d),51(e),51(g), and 67(a). The age of the facility utilizing teletherapy-style source heads and the expense of modifying the facility, coupled with existing safety features such as stability of permanent operating staff, multiple redundant iraerlock and radiation monitor systems to close the source shutters when activated, and the addition of an audible and visible radiation field monitor that will wam of high levels upon entry should the shutter closing mechanism fail provide adequate assurance of personnel safety.
l 05/20.98 I-13 l
w__
l understanding is by performance observations, dosimetry reviews, personal interviews, prior work experience, or similar evaluation methods. Should safety-related changes be made irt operations, or should any employee be reassigned or return after extended absence, the Division Chief determines the need for retraining.
Health Physics technicians are trained in fundamentals of radiological safety commensurate with their levels of responsibilities. Topics for this training might include the following:
basic principles; particle and photon properties; dosimetry concepts and practices;
- shielding; biological effects of radiation; protection standards; instrumentation and equipment concepts and practices; and operations for which specific responsibilities are assigned, such as radioactive materials, and personnel or environmental dosimetry.
All individuals who work with radioactive materials and the Health Physics technicians are required to participate in biennial radiological safety training. The Chief of Health Physics assures that train'.ig programs are available as required.
l At intervals such as at the periodic safety awareness meetings for staff personnel, information on such topics as facility changes, operational changes, reports of incidents at similar facilities, and other pertinent matters will be disseminated to appropriate personnel.
2.7 Operating Procedures Written operating, maintenance, and test procedures for work widt licensed radioactive materials are developed and followed. Those generated by the prospective radioactive material user are reviewed by Health Physics. Following the review and upon agreement on the safety practices to be observed, a Supervisory Health Physicist or a person with the same qualifications approves the proposal, subject to review if necessary by the Ionizing Radiation Safety Committee.
l Similarly, proposals for radiological safety-related changes in existing procedures, equipment, or facilities also require Health Physics review and approval, subject to Ionizing Radiation Safety l:
Committee review if necessary. Health Physics review addresses compliance with regulatory requirements and limits. ALARA commitments, monitoring concerns, emergency planning, and l'
training needs. Any required Health Physics surveillance and observations of procedures, I
including frequencies, are specified. Health Physics surveillance of radiation and radioactive j
material control during operations indicates if there is a need for any procedural updating and j
review.
I Health Physics operating procedures and major changes proposed for those procedures are reviewed and approved by the Chief of Health Physics. Health Physics procedures will be observed and followed.
2.8 Audits and Reviews lonizing Radiation Safety Committee representatives other than Health Physics staff annually audit the performance quality of operations that provide radiological safety assurance, reporting l
to the Committee and indicating necessary actions and follow-up audits. At least annually, Health 05/20/98 12-3
_-__---__-_L
Phy, sics staff members review surveillance techniques and results to assure compliance with applicable protocols, documenting results and follow-up actions and results.
' Supervisory Health Physicists or persons with qualifications equivalent to those of a Supervisory Health Physicist conduct radiation workplace safety observation tours at least quarterly for those workplaces that pose significant potential for radiation exposures or releases of radioactive materials, following written plans. Results of the tours are documented and corrective action needs found during the tours are transmitted to workplace supervisors in a j
timely fashion.
l l
2.9 invutigations and Reporting of Off-Normal Occurrences l
Health Physics, based on reports from Division Chiefs or workers, or on results of monitoring l
or surveillance, investigates suspected off-normal occurrences. The Chief, Occupational Health and Safety Division, reports these conditions to authorities and to management, as required by l.
applicable regulations, procedures, and license conditions.
l 2.10 Records l
Health -Physics maintains documentation on the results of required monitoring and surveillance, the results of approved proposal reviews, off-normal occurrence investigations, and other radiological safety program information, sufficient to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee documents and retains l
information on audits and provides reports to. management as required. Retention times for L
documents are as required by regulations or for at least two years.
l 2.11 Fire Protection L
A Fire Protection group in the Facilities Services Division provides a trained fire and emergency response organization. Any proposed laboratory or facility construction or modification must be reviewed by and have the approval of such management interests as the hc td of the Safety Office, the Chief of the Fire Protection Services, and the Chief of the Plant Disision or his designated representative. Members of the staff of the Fire Protection Services L
' group are trained to the equivalent of Fire Fighter III level.- Maintenance of fire fighting j
equipment is conducted according to written procedures. Extensive pre-fire plans exist, with I
information on locations of radioactive materials, flammable materials, and other hazardous j
l materials, and includes fire fighting protocols for those areas. The plans include locations of ~
water. supplies, storage areas, and other appropriate information. Fire Protection Services L
maintains extensive documentation on maintenance and deployment of equipment, pre-fire L
planning, facility characteristics, training, results of actual occurrences, etc.
[
05/20/98 l-2-4 E
1 l
u r.
2.
The periodic leak test required by this section does not apply to scaled sources that are stored and not being used. i'rior to any use or transfer to another person, the source shall be leak tested within 6 months prior to the date of use or transfer.
B. The test shall be capable of detecting the presence of 0.005 microcuries of radioactive l'
material on the test sample. The sample shall be taken from the sealed source or appropriate L
accessible surfaces of the container or from the device where the sealed source is mounted or stored in which one might expect contamination to accumulate. Records ofleak test results shall l'
be kept in units of microcuries and maintained for inspection by the USNRC.
If the test reveals the following:
1.
The presence of 0.005 microcuries or more of removable contamination from the sealed sources other than described below, or 2.
An indication that the sealed source which is stored in the water pool for shielding l
purposes is leaking, then NIST shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed ofin accordance with USNRC regulations.
Within 5 days after determining that any source has leaked, NIST shall file a report with the Division of Fuel Cycle Safety and Safeguards, USNRC, Washington, D. C. 20555, describing the source, test results, extent of contamination, apparent or suspected cause of source failure, and corrective action taken. A copy of the report shall be sent to the Administrator of the NRC Regional Office for Region I.
I a
05/20/98 l-3-4 l
8.4, Maps," Buildings, and Site Information Attachment I contains a NIST site plan and a topographical representation, building locations on site, and floor plans for buildings. The site exhibits a gently rolling topography and contains both open and wooded areas. Buildings include a central complex of the main administration building and several general purpose buildings designed to contain laboratories that accommodate customary scientific research and development functions, buildings that house the support functions ranging from grounds management, heating and air conditioning, and the like, to
- procurement, and special purpose laboratory buildings that are dedicated to specific research and development functions. This last category includes the Reactor and the Radiation Physics Buildings, where the majority of the work involving radiation and radioactive materials is conducted.
8.5 License History Table II.8-2 shows a chronological ordering of licensing history at NIST for radioactive materials. This history tracks licenses to the most recent renewal. In some cases, e.g., for 08-00566-05, the byproduct material license, a full history would extend to more than thiny years with many amendments and renewals. In 1980 a Materials License Manager was named to bear responsibility for licensing other than for the NIST Reactor. In 1985, five major licenses were consolidated into the single SNM-362 license.
)
l 05/20SB 11 2
= - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
TABLE II.8-2 NIST MATERIALS LICENSING
SUMMARY
YEAR LICENSE ACTION (identifier) 1997 SNM-362 renewal 1990 -
SNM-362 amendments 1 - 4 1994 1985 -
SNM-362 amendments 1 - 4 1990 1985 08-00566-05, 08-00566-10, 08-consolidation, incorporation into 00566-12, SMB-405, SNM-362 License No. SNM-362 1983 08-00566-05 Class I irradiator request 1982 all Ionizing Radiation Safety Committee 08-00566-05 change in limits (byproducts) all personal dosimetry technique 1981 SNM-362 filter process (SNM)
SNM-362 change in limits 08-00566-10 renewal (teletherapy) 1980 SMB-405 license manager named (source) 1979 SNM-362 renewal 08-00566 05 change in limits 1978 SMB-405 renewal 08-00566-12 renewal (irradiator) 1977 08-00566-05 renewal 05/20.98 1183
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8.6 Changes in Procedures, Facilities, and Equipment l
NIST employees and other individuals working on the NIST site are responsible for L
c'1aining authorizations from Health Physics for radiation source acquisitions, for any l-modifications in radiation source use that might affect radiological safety, or for disposition of radiation sources. Division Chiefs are responsible for ensuring that staff members comply with radiological safety rules and that staff members are aware of radiological safety l
procedures. The Chief, Occupational Health and Safety Division, is charged with managing l
the radiological safety program and with representing the Nationa! Institute of Standards and Technology in all matters relating to materials licensing. The Chief, Health Physics, is charged with administering the radiation safety program at NIST, including maintaining documentation to demonstrate the adequacy of the radiological safety program. The Ionizing Radiation Safety Committee is responsible for reviewing major radiation facility proposals and significant proposals for use of radiation, including modifications to existing facilities, L
and for assuring the performance quality of operations that provide radiological safety assurance.
8.7 Examples of Operations That Might Be Conducted L
As an example of the miscellany of types of work done at NIST, consider NCRP Report No. 58, A handbook of radioactivity measurements procedures, second edition. Of the fifteen consultants listed in the preface to the first edition, ten were from one working group within NIST (then NBS), as.well as the chairman of the scientific committee. The preface to the second edition names twenty-four persons who made contributions to that edition. Of those, fificen were NIST (then NBS) personnel, including Health Physics staff members. The wide variety of operational activities and of radionuclides described in the publication, essentially the product of only one of the groups at NIST, illustrates the extremely broad scope of work done at NIST.
For the specific nuclides listed in Table I.1-1, the following examples of research, development, and other activities will suggest the variety of operations involving radioactive
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materials at NIST. Uranium at any enrichment, from depleted through 99.9% "U,2nU, any 2
nuclide of plutonium, and thorium, might be used in metallurgical research, for beam transmission studies, in neutron beam research, for check sources, or as beam filters. Scaled sources of 2nPu are used as thermal sources. PuBe, Puli, and other sealed Pu-X sources are used in neutron research and are calibrated for customers. Scaled sources of 6 Co, '"Cs,2iopo (sometimes as PoBe), *Am "2Cf. or "Sr might be used in research requiring photon, neutron, or beta radiations, for instrument calibrations, in neutron physics research, medical device (implant seeds. eye irradiation applicators, etc.) calibrations and research, or basic nuclear chemistry and physics research such as half-life studies. Miscellaneous byproduct
. materials, including materials and containers irradiated in the NIST Reactor and brought out L
' of the Reactor licensed area, might be used as check sources, in laboratory intercomparison tests and studies, for light sources, for basic radiochemistry and nuclear physics research, for sample preparations for authorized customers, or in research for medical or other specific laboratory types.
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i Wastes with short half-lives are treated by decay-in-storage. Disposal of decay-in-storage waste, as provided in 10CFR20.2001(a)(2), is in accord with conditions given in 10CFR35.92.
9.5 Chemical Systems Nonradioactive chemical operations are the responsibility of the Environmental Compliance Group of the Occupational Health and Safety Division. Any facility or operation
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involving toxic materials is reviewed to insure compliance with appropriate regulations.
9.6 Fire Protection The buildings and facilities at NIST were constmeted in accordance with applicable regulations for Federal facilities in effect at the time of construction and are maintained under g
the fire protection auspices of the Fire Protection Group of the Facilities Services Division.
L The coverage by this trained fire and emergency response group includes around-the-clock fire, emergency medical, and hazardous material response capabilities.
l The Fire Protection Group reviews facility plans, including locations of fire hydrants, spnnkler systems layouts, access pathways, and other layout information related to fire L
fighting. The plans are maintained in the offices and workspace of the Fire Protection Group j
work area. Training of fire fighters is according to the State of Maryland and local County having authorization, in conjunction with NFPA. Materials and e.luipment available to the.
Fire Protection Group include appropriate vehicular firefighting apparatus, water supply systems, automatic sprinkler systems, portable fire extinguishers, protective clothing, and tools used in fighting a variety of fires, e.g., structural, vehicular, etc. Maintenance and deployment of fire fighting equipment is in accordance with NFPA codes. Extensive pre-fire plans have L
been developed incorporating information on location of radioactive materials, fiammable l-substances, and hazardous materials storage areas. '11e plans include fire fighting protocols
- for those areas, with locations of water supplies. automatic fire fighting response mechanisms that might be employed, and other pertinent information. The Fire Protection Group maintains -
extensive documentation on deployment and maintenance of equipment, pre-fire planning, i
facility characteristics training of personnel, results of actual occurrences, etc. Portable fire extinguishers are deployed according to NFPA 10; these are commonly dry chemical and CO2 types. In addition, portable extinguishers are commonly located in each laboratory and building hallways. Portable fire extinguisher agency is detemuned by the fire load in the area of work. Building entrances.and stairwells have standpipe connections; fire hydrants are located at various positions on the exterior of buildings. The loading dock of Building 245 has a sprinkler system.
Laboratories are monitored with automati:: fire alarm devices activated by heat or smoke, L
or both. The fire alarm device type is detemuned by the fire hazard within the work area L
covered. Manual fire alarm boxes (pull stations) are located according to the NFPA code.
L Upon activation of any alarm, the signal is received at two locations: in the Fire Station in Bldg. 303 and in the Security Office in Bldg.101.
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rabiation safety program.
L 10.1.4 Division Chiefs Each Division Chief managing radiation work is responsible for the following:
Ensuring that staff members comply with radiation safety rules in implementing the a.
NIST radiation safety policy;
- b. Ensuring that staff members are aware of radiation safety procedures and receive training as required:
Reporting potential items of substantial safety hazard as defined in 10CFR21.3(k) e c.
to the Chief. Health Physics, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence or discovery, except for items relating to the Reactor license which are to be handled accarding to that license; and
- d. Reporting significant radiation safety matters to his or her supervisor.
10.1.5 Staff NIST employees and other individuals working on the NIST site are responsible for
- the following:
- a. Observing approved radiation safety rules; 1.
- b. Consulting with Health Physics early in the planning of operations that might involve radiation sources;
- c. Obtaining authorization from Health Physics for radiation source acquisitions, for any modifications in radiation source use that might affect radiation safety,'or for disposition of radiation sources;
- d. Notifying Health Physics of any occupational radiation exposure from work at facilities other than NIST;
- e. Immediately informing Health Physics upon discovery ofloss or theft of any radioactive materials;
- f. Immediately informing their supervisors and Health Physics of accidents involving radiation or radiation source's; and u
- g. Informing their supervisors of defects that could create a substantial safety hazard.
10.2 Organization Members and alternates of the Ionizing Radiation Safety Committee are named by the Deputy Director of NIST. The current list, with organizational titles, is:
(Chair) Dr. Chris E. Kuyatt, Director's Office: Executive Director, Visiting Committee (Vice Chair) Dr. Bert M. Coursey, Director, Ionizing Radiation Division (IRD), Physics Laboratory (PL)
Dr. James M. Adams.
Research Physicist, Neutron Interactions and Dosimetry Group, IRD, PL Mr. Jeffrey T. Cessna.
Research Chemist. Radioactivity Group, IRD, PL Dr. Heather H. Chen-Mayer, Research Chemist, Nuclear Methods Group, Analytical Chemistry Division (ACD), Chemical Science and Technology Laboratory (CSTL) i 1
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c o,e Mr. Keith'H. Eggert,' Safety Engineer, Environmental Compliance Group, Occupational L
Health & Safety Division (OHSD), Office of the Director of L
. Administration (Admin)
L Mr. Douglas M. Eagleson, Supervisory Health Physicist, Health Physics Group, OHSD, l~
Admin Mr. Thomas G. Hobbs, Chief, Health Physics Group, OHSD, Admin Dr. Richard M. Lindstrom, Research Chemist, Nuclear Methods Group, ACD, CSTL Dr. Santos Mayo, Physicist, Semiconductor Electronics Division, Electronics and Electrical Engineering Laboratory (EEEL)
Mr. J. Franklin Mayo-Wells, Staff Assistant for Technical Coordination / Operations, EEEL Mr. Lyman E. Pevey, Chief, OHSD, Admin Dr. Henry J. Prask, Physicist, Neutron Scattering Group, NIST Center for Neutron Research (NCNR), Materials Science and Engineering Laboratory (MSEL)
Dr. J. Michael Rowe, Director, NCNR, MSEL I
Dr. Francis J.- Schima, Research Physicist, Radioactivity Group, IRD, PL Dr. Christopher G. Soares, Research Physicist, Radiation Interactions and Dosimetry Group, IRD, PL
~ Dr. David S. Simons, Leader, Analytical Microscopy Group, Surface and Microanalysis Science Division (SMSD), CSTL Mr. Lester A. Slaback. Jr.,
Supervisory Health Physicist, Health Physics Group, OHSD, Admin Ms. Cynthia J. Zeissler, Physical Scientist, Analytical Microscopy Group, SMSD, CSTL l
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I1.6 Surface Contamination Table 11.11-1, Controls and Action levels, and Table 11.11-2, Admmistrative~ Action Levels and Actions, list controlling levels' for surface contamination. Measurements for surface l
contamination checking and protective measures are described in sections 11-11.1,11-11.4, and 11-11.7 of this manual.
Hand and shoe monitoring may be performed with conveniently placed equipment; resuspension factors for transforming surface contammation levels to airborne activity concentrations are applied as described in section 1I-11.5 of this manual.
I1.7 Shipping and Receiving All radioactive materials received at NIST and all radioactive materials shipped from NIST are controlled by Health Physics. Usually, incoming packages are brought to the Health Physics receiving area in Building 245, unless attemate provisions are made with the ultimate recipient.
In either case, surveys for compliance with transport regulations are made within time limits specified by the regulations. Health Physics and the recipient then survey the package and contents and determine if the shipment is acceptable for incorporation into the project for which
- the source is intended. Usually, outgoing packages are held in the NIST shipping area in Building 301 until Health Physics or a designated representative checks the package for compliance with l
transport regulations.
Type B shipments are made in accord with the provisions of the quality assurance program as detailed in a separately submitted document.
If an incoming shipment shows contammation at any level of packaging, the package is held in the Health Physics or other designated storage area until a decision is made, jointly between Health Physics and the recipient, on retuming the source, decontaminating the source, disposing of the materials, or establishing proper controls for safe use of the source.
- 11.8 Posting and Labeling Table 11.11-1 shows. control mechanisms and action levels under which radioactivity operations are permitted. The contamination limits shown represent a departure from customary practice in that specific nuclide limits are provided for beta-emitting nuclides when the identity 1
of the nuclide is known. As an ALARA precaution, Health Physics requests decontamination of areas in which any detectable contammation above normal background levels are found. Health j
Physics review may result in a determination that actions other than described in'this table should j
be implemented. Such alternate actions are documented by Health Physics.
j 11.9 Surveys
~ Health Physics performs weekly routine surveys of a laboratory in which unsealed radioactive L
material is utilized when the initial proposal or subsequent evaluation of the work environment L
demonstrates that levels could exceed the levels at which posting is required, as shown in Table 11.11-1.~ As specified by Health Physics, the surveys could include smear tests of surfaces, radiation level tests, radiation quality tests, air activity contamination tests, or combinations of these, and-other radiation safety assurance procedures. For special situations, such as l
L maintenance, similar surveys, time and motion studies, or practice sessions on mock 0$/20/98 11-11 3 i
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- contamination might be expected to accumulate. Sources will be immediately withdrawn from use and action taken to repair or dispose of the source, and appropriate actions taken to notify the NRC, if the following limits are exceeded for removable contammation:
e any indication of leakage from the irradiator scaled source in the water shielding pool.
e 0.005 microcuries or more from any other sealed source.
.I1.12 Respiratory Protection Health Physics may issue dust stop or similar particulate breathing masks for dusty work environments. At the conclusion of thejob, Health Physics retrieves the masks and prepares them for reuse.
11.13 Protective Clothing Health Physics maintains a nominal supply of various protective clothing items, including gloves, shoe covers, coveralls, head covers, etc. These are freely available as needed for issue to laboratory workers using dispensable radioactive materials. For situations requiring protective clothing beyond the normal issue quantities, the requesting work unit may be asked to replenish the supply.
. I1.14 Reports and Records The Chief, Occupational Health and Safety Division, documents management and authority notifications resulting from reports from Health Physics on off-normal investigations. Health Physics maintains documentation on routine and special radiological surveys, personnel monitoring, licensing interactions with NRC, instrument calibrations, ALARA reviews and
' findings, employee training and familiarization, environmental monitoring, and source control.
The Chairperson of the Ionizing Radiation Safety Committee maintains records of meetings of the Committee, Committee audits, and special reviews and investigations by the Committee.
Normal retention time for these records and documents is two years unless otherwise specified by regulations.
I1.15 Administrative Control Levels l
Table II.11-2 describes the administrative action levels and the actions taken at those levels to control radiation and radioactive materials in specific situations and under specific conditions.
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