ML21057A037

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Public_DTRA-NRC License Application_Final 02262021
ML21057A037
Person / Time
Site: 07007029
Issue date: 02/26/2021
From: Mannis D
US Dept of Defense, Defense Threat Reduction Agency
To: Ty Naquin
NRC/NMSS/DFM/FFLB
Naquin T
References
Download: ML21057A037 (94)
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Text

Defense Threat Reduction Agency NRC Category III Special Nuclear Material License Application Controlled by: DTRA Controlled by: ESOH Distribution Statement: B POC: Daniel Mannis, 571-616-6208 DISTRIBUTION A: Approved for public release; distribution is unlimited.

U.S. Department of Transportation IAEA CERTIFICATE OF COMPETENT AUTHORITY SPECIAL FORM RADIOACTIVE MATERIALS East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE USA/0826/S-96, REVISION 0 This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency1 and the United States of America2 for the transport of radioactive material.

1. Source Identification - ORNL U ZipCan.
2. Source Description An equilateral triangle shaped single encapsulation made of a titanium inner container and a stainless steel outer encapsulation that is tungsten inert gas seal welded.

Approximate exterior dimensions are 57 mm (2.24 in.) on each edge and 11 mm (0.43 in.) thick. Construction shall be in accordance with attached ORNL Drawing No. N3E020995A576, Revision A.

3. Radioactive Contents - No more than 2.66E-1 TBq (7.17 Ci) of Uranium-232, 1.15E-3 TBq (3.11E-2 Ci) of Uranium-233, 7.36E-5 TBq (1.99E-3 Ci) of Uranium-234, 2.56E-7 TBq (6.91E-6 Ci) of Uranium-235, 7.68E-7 TBq (2.07E-5 Ci)of Uranium-236, and 3.84E-8 TBq (1.04E-6 Ci)of Uranium-238. The radioactive content is uranium oxide embedded in zirconium felt. The sum of the mass fractions must be no more than 3.2 grams (U element weight).
4. Management System Activities - Records of Management System activities required by Paragraph 306 of the IAEA regulations shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the requirements of Subpart H of 10 CFR 71.

1 "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, No. SSR-6" published by the International Atomic Energy Agency (IAEA),

Vienna, Austria.

2 Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

Appendix A.1 Attachment 1

(- 2 -)

CERTIFICATE USA/0826/S-96, REVISION 0

5. Expiration Date - This certificate expires on May 31, 2024.

This certificate is issued in accordance with paragraph(s) 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the April 23, 2019 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

June 10, 2019 William Schoonover Associate Administrator for Hazardous Materials Safety (DATE)

Revision 0 - Original issue.

Appendix A.1 Attachment 1

1 U.S. Department of Transportation East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0826/S-96 ORIGINAL REGISTRANT(S):

Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC, 20585 USA Appendix A.1 Attachment 1

babcock & wilcox y-12, llc., a Babcock & Wilcox company 1 of 2 Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RR6A December 13, 2011

1. Source Identification:

Model Number NMLDS-001 Serial Number 9A37-E4-RR6A

2. Distributor:

United States Department of Energy National Nuclear Security Administration Y-12 National Security Complex

3. Lot Identification No:

4.Sample Lot Identification No:

5. Lab Sample Identification No:

3C326HRH17 3C326HRN00 3C32KYRH17 3C32KYRN00 Y110250053 Y110250050

6. Assay Date:

October 11, 2010

7. Analytical Results:
8. Uranium Mass:
9. U-235 Isotope Mass:
10. Uranium Activity:
11. Date of Manufacture October 2010
12. Source Description - The sealed source has a 4.90 inch diameter. It consists of a depleted uranium (DU) core, aluminum spacers, The device is encapsulated by two welded Ti shells with a thickness of.090. The following engineering drawings document design and construction of the assembly and are attached:

Isotope Mass % -

RH17 Mass % -

RN00 U-234 U-235 U-236 U-238 Appendix A.2 Attachment 1

Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RR6A August 3, 2011 2 of 2

13. Quality Assurance -Design, manufacture, and certification testing of assemblies was performed in compliance with DOE O 414.1D, 10 CFR 830.120, and ANSI/HPS N43.6-2007. The three phases of the project were conducted by Oak Ridge National Laboratory (ORNL), Y-12 National Security Complex, and ORNL Transportation Technologies Group (TTG), respectively.
14. Leak Testing and Freedom From Contamination - Under direction of ORNL, two prototype RSTDs were subjected to tests to demonstrate compliance with 49 CFR 173.469 Tests for Special Form Class 7 (Radioactive) Materials. Leak Tests, Heat Tests, and Percussion Tests were performed on the two units. In both cases, the units met the requirements for Special Form Certification.
15. Planned Use - The sealed source will be used as a passive interrogation source for spectroscopy portals that detect special nuclear material.

Users of the sealed source will be authorized by the United States (U.S.) Defense Threat Reduction Agency (DTRA). These users of the sealed source will use it in accordance with the safety, quality, security and other requirements of the users regulatory authorization basis (i.e. U.S. Nuclear Regulatory Commission (NRC) license or state authorization for special nuclear materials). Some tests (use) may be conducted at U. S. Department of Energy (DOE) facilities, and will be performed in accordance with the authorization basis of the DOE facilities.

16. Conditions of Use -The SNM is totally encapsulated and sealed within the titanium casing of the item and since the radiation from the encapsulated radiological material does not pose a significant exposure threat to users, the sealed source can be contact handled using normal care not to expose the disk to forces which could compromise the casing.

During loading and handling:

a.

The device shall not be subjected to conditions or an environment which exceeds its ANSI N43.6-2007 classification testing requirements b.

The device shall not be exposed to an extremely corrosive (acidic or caustic) environment which could degrade or compromise the titanium casing.

Appendix A.2 Attachment 1

babcock & wilcox y-12, llc., a Babcock & Wilcox company 1 of 2 Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RF2M December 13, 2011

1. Source Identification:

Model Number NMLDS-001 Serial Number 9A37-E4-RF2M

2. Distributor:

United States Department of Energy National Nuclear Security Administration Y-12 National Security Complex

3. Lot Identification No:

4.Sample Lot Identification No:

5. Lab Sample Identification No:

3C326HRD95 3C326HRDFL 3C32KYRD95 3C32KYRDFL Y102790054 Y102790055

6. Assay Date:

October 11, 2010

7. Analytical Results:
8. Uranium Mass:
9. U-235 Isotope Mass:
10. Uranium Activity:
11. Date of Manufacture October 2010
12. Source Description - The sealed source has a 4.90 inch diameter. It consists of a depleted uranium (DU) core, aluminum spacers, The device is encapsulated by two welded Ti shells with a thickness of.090. The following engineering drawings document design and construction of the assembly and are attached:

Isotope Mass % -

RD95 Mass % -

RDFL U-234 U-235 U-236 U-238 Appendix A.2 Attachment 2

Data Sheet for Radiological Signature Training Device (RSTD)

Model NMLDS-001, Serial Number 9A37-E4-RF2M December 13, 2011 2 of 2

13. Quality Assurance -Design, manufacture, and certification testing of assemblies was performed in compliance with DOE O 414.1D, 10 CFR 830.120, and ANSI/HPS N43.6-2007. The three phases of the project were conducted by Oak Ridge National Laboratory (ORNL), Y-12 National Security Complex, and ORNL Transportation Technologies Group (TTG), respectively.
14. Leak Testing and Freedom From Contamination - Under direction of ORNL, two prototype RSTDs were subjected to tests to demonstrate compliance with 49 CFR 173.469 Tests for Special Form Class 7 (Radioactive) Materials. Leak Tests, Heat Tests, and Percussion Tests were performed on the two units. In both cases, the units met the requirements for Special Form Certification.
15. Planned Use - The sealed source will be used as a passive interrogation source for spectroscopy portals that detect special nuclear material.

Users of the sealed source will be authorized by the United States (U.S.) Defense Threat Reduction Agency (DTRA). These users of the sealed source will use it in accordance with the safety, quality, security and other requirements of the users regulatory authorization basis (i.e. U.S. Nuclear Regulatory Commission (NRC) license or state authorization for special nuclear materials). Some tests (use) may be conducted at U. S. Department of Energy (DOE) facilities, and will be performed in accordance with the authorization basis of the DOE facilities.

16. Conditions of Use -The SNM is totally encapsulated and sealed within the titanium casing of the item and since the radiation from the encapsulated radiological material does not pose a significant exposure threat to users, the sealed source can be contact handled using normal care not to expose the disk to forces which could compromise the casing.

During loading and handling:

a.

The device shall not be subjected to conditions or an environment which exceeds its ANSI N43.6-2007 classification testing requirements b.

The device shall not be exposed to an extremely corrosive (acidic or caustic) environment which could degrade or compromise the titanium casing.

Appendix A.2 Attachment 2

Appendix A.4 Attachment 2 Page 1 of 1

ORNLPuZipCanSpecialFormApplicationandTestSummaryDataReportRevision1 DOEDocket#16120000 Page6of6 Appendix A.4 Attachment 3 Page 3 of 4

U.S. Department of Transportation IAEA CERTIFICATE OF COMPETENT AUTHORITY SPECIAL FORM RADIOACTIVE MATERIALS East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE USA/0823/S-96, REVISION 1 This certifies that the source described has been demonstrated to meet the regulatory requirements for special form radioactive material as prescribed in the regulations of the International Atomic Energy Agency1 and the United States of America2 for the transport of radioactive material.

1. Source Identification - ORNL Pu Cylindrical Source.
2. Source Description - Cylindrical single encapsulation made of Type 304L stainless steel and tungsten inert gas seal welded. An inner cylindrical assembly made of Type 304L stainless steel with a press fit lid contains the radioactive contents. Approximate exterior dimensions are 22.4 mm (0.88 in.) in diameter and 58.4 mm (2.3 in.)

in length. Construction shall be in accordance with attached UT-Battelle Drawing No. N3E020995A537, Rev. A, Sheet 1 of 3.

3. Radioactive Contents - No more than 101 GBq (2.73 Ci) of Plutonium-238, 35.7 GBq (0.965 Ci) of Plutonium-239, 131 GBq (3.54 Ci) of Plutonium-240, 608 GBq (16.4 Ci) of Plutonium-241, 2.33 GBq (63 mCi) of Plutonium-242, and 10.4 MBq (0.281 mCi) of Plutonium-244. The source contents may be a mix of the plutonium isotopes, but shall not exceed 15.54 grams of total plutonium. The Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, and Pu-244 are in solid oxide form.
4. Management System Activities - Records of Management System activities required by Paragraph 306 of the IAEA regulations shall be maintained and made available to the authorized officials for at least three years after the last shipment authorized by this certificate. Consignors in the United States exporting shipments under this certificate shall satisfy the requirements of Subpart H of 10 CFR 71.

1 "Regulations for the Safe Transport of Radioactive Material, 2012 Edition, No. SSR-6" published by the International Atomic Energy Agency (IAEA),

Vienna, Austria.

2 Title 49, Code of Federal Regulations, Parts 100-199, United States of America.

Appendix A.4 Attachment 5 Page 1 of 4

(- 2 -)

CERTIFICATE USA/0823/S-96, REVISION 1

5. Expiration Date - This certificate expires on October 30, 2022.

USA/0823/S-96 Revision 0 may be used until December 31, 2017.

This certificate is issued in accordance with paragraph(s) 804 of the IAEA Regulations and Section 173.476 of Title 49 of the Code of Federal Regulations, in response to the October 24, 2017 petition by Department of Energy, Washington, DC, and in consideration of other information on file in this Office.

Certified By:

November 03, 2017 William Schoonover Associate Administrator for Hazardous Materials Safety (DATE)

Revision 1 - Issued to revise the authorized radioactive contents.

Appendix A.4 Attachment 5 Page 2 of 4

1 U.S. Department of Transportation East Building, PHH-23 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration CERTIFICATE NUMBER: USA/0823/S-96 ORIGINAL REGISTRANT(S):

Department of Energy U.S. Department of Energy 1000 Independence Ave, SW EM-60 Washington, DC, 20585 USA Appendix A.4 Attachment 5 Page 4 of 4

Gomez W. Wright PO Box 2008 Oak Ridge, TN 37831-6011 (865) 576-5843 l wrightgw@ornl.gov Page 2 of 3 and constructed of welded Titanium metal that is intended to prevent the leakage/ escaped of the contained Oxide/ Zirconium radioactive material.

The RSTD Tile welded Titanium containment vessel has been tested and proven to survive an International Standards Organization (ISO) 2919:1999(E) Class 4 Impact Test that was qualified to have passed by both Before and Post Helium Leak Test assessment. The Helium Leak Test assessment was implemented in accordance with American National Standards Institute (ANSI)

N14.5-2014 American National Standard for Radioactive Materials-Leakage Tests on Packages for Shipment, Table A.1, Test Description A.5.5, Evacuated Envelope (with Helium back pressurization) under applicable ORNL Quality Assurance Program Description (QAPD) requirements that demonstrated the leaktightness of 10-4 torr-1/s (3.1 x 10-4 atm-cm3/s) based on air at 25°C (77°F) and one atmosphere differential for solid radioactive content contained within a capsule resistant to corrosion by water per DOT 49 CFR 173.469(a)(4)(i) requirements. Additionally, a Dry Wipe Test is conducted by an ORNL trained and qualified Radiation Control Technician with NIST calibrated instrumentation demonstrated to detect <20 dpm (<9.0 pCi) removable alpha and < 200 dpm (<90 pCi) removable beta contamination.

The Before Helium Leak Test was implemented to demonstrated that the Ti-welded fabricated containment vessel was entirely intact without any detectable leaks via the Helium Leak Test employed. The Before Dry Wipe Test was employed to demonstrate that there was no evidence of removable radioactive contamination that would indicate that the RSTD Tile outer welded Titanium encapsulation could be leaking radioactive material past the limits of DOE 10 CFR 835.1202 0.005 µCi (5 nCi or 185 Bq or 11,000 dpm) that would necessitate putting the sealed radioactive source Out-of-Service until RSTD Tile detected removable contamination could be linked to a leaking source or cross-removable contamination event.

Both the Before and Post ISO 9978 Class 4 Impact Test - Helium Leak Test and Dry Wipe Test assessment demonstrated that the Ti-welded containment vessel encapsulation integrity of the RSTD Tile remained intact, which provides evidence that the radioactive material content inside the RSTD Tiles is entirely encompassed by a non-leaking Ti-welded encapsulation capable of withstanding/ surviving an ISO 9978 Class 4 Impact Test.

Thus, the RSTD Tile is indeed a sealed radioactive source by DOE 10 CFR 835 requirements.

However, because the RSTD Tile do contain Special Nuclear Material, RSTDs Tiles cannot be registered with the National Sealed Radioactive Source Device Registry.

1.

The NRC regulations that established the National Sealed Source Device Registry (NSSDR),

10 CFR §32.210, and the regulation 10 CFR §30.32, that requires Specific Licensees to use sealed sources that have SSDR certificates or at least the SSDR information contained within is Only applicable to sealed sources containing Byproduct Material that are available for commercial use.

2.

The regulatory requirement that establishes the National Sealed Source Device Registry, 10 CFR 32.210 is only applicable to Specific Licensees that manufacture Byproduct Material containing sealed sources for commercial distribution.

3.

RSTDs are not manufactured nor available for commercial distribution and meet the requirements of 10 CFR 32.210(g) as a Custom Source that does not have to be evaluated by and have an SSDR with the NRC to be used by a Specific Licensee.

Appendix A.5 Attachment 3 Page 2 of 3

Gomez W. Wright PO Box 2008 Oak Ridge, TN 37831-6011 (865) 576-5843 l wrightgw@ornl.gov Page 3 of 3 4.

RSTDs are custom sources built to the unique specifications of a particular U.S. Government recipient and contain no more than 7.4 GBq (200 mCi) of any other radionuclide (besides 20Ci of Tritium).

5.

RSTDs do not contain Byproduct Material.

RSTDs contain Special Nuclear Material (SNM).

6.

There are no applicable regulatory compliance responsibility requirements in NRC 10 CFR 40 Domestic Licensing of Source Material, and NRC 10 CFR 70 Domestic Licensing of Special Nuclear Material (SNM)

For the registration of sealed sources that contain either Source or SNM in the NSSDR or a complementary registry.

In conclusion, RSTDs are inapplicable to SSDR because of their SNM content; wherein, the NRC has not established a regulatory requirement for Source or SNM bearing sealed sources to have SSD certificate evaluated, approved, and registered within the NSSDR by the NRC or an Agreement State equivalent.

If there are any further concerns or additional information required in regard to the design and construction of RSTD Tiles as sealed radioactive source containing solid SNM encapsulated in a welded Titanium metal containment vessel, please do not hesitate to contact me at your earliest convenience and I will make every effort to respond to your request for further information in as timely a manner as is possible.

Very respectfully, Go Gomez W. Wright Radiation Detection & Imaging Isotope & Fuel Cycle Technology Division Oak Ridge National Laboratory Appendix A.5 Attachment 3 Page 3 of 3

Appendix C Attachment 1 Page 1 of 1

Appendix D Attachment 1 Page 3 of 4

Appendix D Attachment 1 Page 4 of 4

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