ML23151A565

PRM-040-026 - 62FR65039 - Chromalloy Tallahassee; Receipt of Petition for Rulemaking

ML23151A565
Person / Time
Issue date:	12/10/1997
From:	Miraglia F NRC/EDO
To:
References
62FR65039, PRM-040-026
Download: ML23151A565 (1)

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DOCUMENT DATE:

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ADAMS Template: SECY-067 12/10/1997 PRM-040-026 - 62FR65039 - CHROMALLOY TALLAHASSEE;

'RECEIPT OF PETITION FOR RULEMAKING PRM-040-026 62FR65039 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

DOCKET NO. PRM-040-026 (62FR65039)

\\ In the Matter of CHROMALLOY TALLAHASSEE; RECEIPT OF PETITION FOR RULEMAKING DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 11/11/97 12/08/97 08/04/99 07/17/97 12/03/97 07/16/99 LTR FM TONY EVANS, CHROMALLOY TALLAHASSEE SUBMITTING PRM RE EXEMPTION IN LICENSING 1 REQUIREMENTS TO INCLUDE AIRCRAFT ENGINE.PART I

FEDERAL REGISTER NOTICE - RECEIPT OF PETITION FOR RULEMAKING FEDERAL REGISTER NOTICE - DENIAL OF PETITION FOR RULEMAKING l,

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OOCVE UM RUL p M L/o-:U~

FTITION 7 ~:lfRio603'1)

NUCLEAR REGULATORY COMMISSION 10 CFR Part 40

[Docket No. PRM-40-26]

• 99 AUG -4 P 4 :22 Chromalloy Tallahassee, a Division of Chromalloy Gas Turbine Corporation; Denial of Petition for Rulemaking AGENCY:

Nuclear Regulatory Commission.

ACTION:

Denial of petition for rulemaking.

SUMMARY

The Nuclear Regulatory Commission (NRC) is denying a petition for rulemaking (PRM-40-26) submitted by Chromalloy Tallahassee, a division of Chromalloy Gas Turbine Corporation. The petitioner requested that the NRC amend its regulations regarding the exemption from licensing of source material found in 10 CFR 40.13(c)(8), so that the exemption would include finished parts containing nickel-thoria alloy from both aircraft engines and battle tank engines.

However, after performing a regulatory analysis, no benefits of granting this petition could be identified. Also, it has not been persuasively shown that denying the petition would have a negative impact on Chromalloy since, as a Florida general licensee, Chromalloy currently could repair battle tank engines containing nickel-thoria alloy parts provided two possession limits are observed. Further, Chromalloy now indicates it has no definite plans to begin such repairs in the foreseeable future. But, to grant this petition the NRC would incur the cost of conducting a rulemaking. Moreover, before this action could have an effect on Chromalloy, the cost of an additional rulemaking to change the Florida Administrative Code would need to be incurred by the State of Florida. Thus, when viewed in terms of regulatory effectiveness and efficiency, the NRC can not justify the expenditure of resources to grant this petition.

P~. (ir, 7/~tt/C/'I J ~I/FR4t>1B'/

ADDRESSES: Copies of the petition for rulemaking and the NRC's letter to the petitioner are a~lable for public inspection or copying in the Nuclear Regulatory Commission's Public Document Room, 2120 L Street NW. {Lower Level), Washington DC. No public comments on this petition for rulemaking were received.

FOR FURTHER INFORMATION CONTACT: Mr. John L. Telford, Office of Nuclear Material Safety an~ Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, telephone (301) 415-6229, e-mail JL T@nrc.gov.

SUPPLEMENTARY INFORMATION:

The Petition The petition was submitted by Chromalloy Tallahassee (Chromalloy), a Federal Aviation Administration approved Overhaul and Repair facility located in Florida, a NRC Agreement

. State.1 Chromalloy overhauls and repairs jet aircraft engine combustors (e.g., for the JT9D jet engine). These combustors are made of nickel-thoria. This use of thorium source material falls under the exemption from licensing found in 10 CFR 40.13(c)(8), and in the Florida Administrative Code in Paragraph 64E-5.202(3)(i).

Chromalloy stated that it was interested in overhauling and repairing the engine of the M1A1 ABRAMS Main Battle Tank. This tank's engine is the AGT 1500 gas turbine engine. The combustor of the AGT 1500 contains 15 splash rings and 15 fuel nozzles made of nickel-thoria 1An Agreement State is one which has entered into an Agreement with NRC to assume regulatory authority over byproduct, source, arid small quantities qf.special nuclear material.

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alloy. The thorium content of this nickel-thoria ~lloy is less than 2% by weight. Moreover, the thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria {i.e., thorium dioxide). Chromalloy stated that these splash rings and fuel nozzles meet all the technical requirements of the current licensing exemption, except that the exemption is limited to finished

• aircraft engine parts. Chromalloy requested that the NRC establish an exemption from licensing to include the AGT 1500 tank gas turbine engine.

In support of its petition, Chromalloy referenced a petition for rulemaking submitted to the.

Commission byE I. du Pont de Nemours & Company (PRM-40-6) dated February 13, 1963.

That petition requested that the Commission amend its regulations to establish an exemption

. from licensing for persons re*ceiving, possessing, using, transferring, or importing any finished products containing nickel-thorium alloys with up to 4 percent thorium by weight. Chromalloy

.pointed out that the Commission's response had been:

"the Commission has found that the possession and use in the United States of thorium contained in thorium metal alloys in which the thorium does not exceed 4 percent _by weight is not of *significance to the common defense and security, and that such activities can be conducted without unreasonable hazard to life or property.*

The proposed exemption was for "any finished product or part;" nowhere in PRM-40-6 do the words "aircraft engine parts" appear.

Chromalloy stated that the final exemption was not published-until November 18, 1967 (32 FR 15872) and that the expression "jet aircraft engines" is mentioned for the first time in that notice.

After consulting with the NRC staff, Chromalloy believes that the material used for the experimental tests for the final exemption must have been from jet aircraft engines. At tha~ time, the only use of nickel-thoria components was in aircraft engines. Chromalloy stated that this is 3

possibly the reason the exemption specifies only finished aircraft engine parts. The production ofJb.!3 M1A1 Abrams Main Battle Tank was begun in 1985. This tank's engine, the AGT 1500, contains the same nickel-thoria alloy as is used in the JT9D jet aircraft engine. Therefore, Chromalloy stated that the alloy material in the AGT 1500 gas turbine engine would produce the same results, if put to the same experimental tests the Commission conducted in 1963-1967.

Chromalloy observed that in a Federal Register notice published by the Atomic Energy Commission on November 18, 1967 (32 FR 15872), the Commission considered that jet aircraft:

engine parts are not intended for public use.

"The Commission considers that finished aircraft engine parts containing nickel-thoria alloy are not products intended for use by the general public within the purview of§ 1-50.15(a)(6) of 10 CFR Part 150,... "

Finally, Chromalloy a~erted that if the Commission does not view the presence of nickel-thoria in aircraft engine parts to be unsafe to the public, then the presence of nickel-thoria

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in tank engine parts should be viewed in the same light. Moreover, the public's exposure to tank engine parts is far less than the public's exposure to jet aircraft engine parts. Therefore, Ch~malloy stated that the exemption in §40.13(c)(8) should be applicable to both the* JT9D aircraft gas turbine engine and the AGT 1500 tank gas turbine engine.

Public Comments on the Petition

• The Notice of Receipt of the Petition was published in the Federal Register on December 10, 1997 (62 FR 65039). The comment period closed on February 23, 1998. No comments were received.

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Reasons for Denial In order to determine whether th]s petition should be granted or denied, the NRC performed a regulatory analysis. The details of the analysis are provided below.

Benefit The NRC was. unable to identify any benefits of granting this petition. Granting the petition would not improve the level of protection of public health and safety. If the petition were granted, r~diation exposure of workers would be expected to either remain the same or increase modestly. Moreover, granting the petition would neither address a generi<? issue nor improve regulatory effectiveness and efficiency for either the NRC or the State of Florida. The NRC has a mechanism in§ 40.14 to address a non-generic issue by providing a specific exemption, upon review of a request to possess additional source-m.aterial. If Chromalloy desired to make such a*

request, the same mechanism exists in the Florida Administrative Code in Subsection 64E-5.102(1 ). In addition, granting the petition would not provide any practical benefits-to

. Chromalloy since, it c~rrenUy may overhaul and repair the AGT 1500 tank gas turbine engine as a general licensee under the Florida Administrative Code Subsection 64E-5.205(1 ), provided I

two possession limits are observed. Chromalloy may use and transfer up to 15 pounds of source material at any given time, and may receive up to 150 pounds of source material in any one calendar year. Since the 15 splash rings and 15 fuel nozzles in the AGT 1500 tank engine are 2 percent thorium by weight, Chromalloy could possess up to 750 pounds of such nickel-thoria alloy parts at any given time, and up to 7,500 pounds of such parts in any calendar year.

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Impact Denying the petition would have no negative impact on Chromalloy. As a Florida general licensee, Chromalloy could repair AGT 1500 tank gas turbine engines. However, contrary to its stated desires in the petition, Chromalloy now indicates it has no definite plans to begin such repairs in the foreseeable future. But, to grant this petition the NRC would incur the cost of conducting a rulemaking. Moreover, before this action could have an effect on Chromalloy, the cost of an additional rulemaking to change the Florida Administrative Code would need to be incurred by the State of Florida. Whether Florida would decide to change its Administrative Code is uncertain.

In summary, this petition is being denied because no benefits of granting the petition could be identified and the cost of granting the petition would include two rulemakings. Thus, when viewed in terms of regulatory effectiveness and efficiency, the NRC1can not justify the expenditure of resources to grant this petition. For the reasons cited in this document, the NRC denies the petition.

Dated at Rockville, Maryland, this 16th day of _Ju_l..... Y ____, 1999.

For the Nuclear Regulatory Commission.

Frank J. Miragli,

Acting Executiv Director for Operations.

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DOCKET NUMBER PETITION RULE PAM LI o -:l IP

( ~, f:/< ~503'1)

NUCLEAR REGULATORY COMMISSION 10 CFR Part 40

[Docket No. PRM-40-26)

DOCKETED USNRC (7590-01-P]

"97 CIC -8 P 4 :01 Chromalloy Tallahassee; Receipt of Petition for Rulemaking AGENCY: Nuclear Regulatory Commission.

ACTION: Petition for rulemaking; Notice of receipt.

SUMMARY

The Nuclear Regulatory Commission (NRC) is publishing for public comment a notice of receipt of a petition for rulemaking, dated July 17, 1997, which was filed with the Commission by Chromalloy Tallahassee. The petition was docketed by the NRC on September 11, 1997, and has been assigned Docket No. PRM-40-26. The petitioner requests that the NRC amend its licensing exemptions to establish an exemption from licensing requirements to include the M1A1 Battle Tank Engine AGT 1500 which contains nickel-thorium.

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o2-3, 199~

DATE: Submit comments by (76 day1 after p1.1blioatian i" the Feaeral Regiete~. Comments received after this date will be considered if it is practical to do so, but the Commission is able to assure consideration only for comments received on or before this date.

ADDRESSES: Submit written comments to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attention: Rulemakings and 1

Adjudications Staff. Hand deliver comments to: 11555 Rockville Pike, Rockville, Maryland, betwE5en. ~:45 a.m. and.4:15 p.m. Federal workdays.

For a copy of the petition, write the Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

The petition and copies of comments received may be inspected and copied for a fee at the NRC Public Document Room, 2120 L Street, NW. (Lower Level}, Washington, DC.

FOR FURTHER INFORMATION CONTACT: David L. Meyer, Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Telephone: 301-415-7162 or Toll Free:

800-368-5642.

SUPPLEMENTARY INFORMATION:

The Petitioner The petitioner, Chromalloy Tallahassee (Chromalloy) is a Federal Aviation Administration approved Overhaul & Repair facility located in Florida, which is an NRC Agreement State. Chromalloy overhauls and repairs jet engine combustors, one of which has a componen~, specffically the JT9D,jet engine, that falls under the exemption from licensing found in 10 CFR 40.13(c)(8), as adopted by the State of Florida at Subsection 100-91.302(3) of the Florida Administrative Code.

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Background===

The petitioner is interested in developing a repair for the M1A1 ABRAMS Main Battle Tank. The M1A1 ABRAMS Main Battle Tank is driven by the AGT 1500 Gas Turbine Engine.

The hot section or combustor of the AGT 1500 is made up of 15 splash rings and 15 fuel nozzJes all of which are nickel-thoria alloy. The thorium content of the nickel-thoria alloy in the splash rings and fuel nozzJes contain less than 2% by weight and the thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria (thorium dioxide). The petitioner stated that the splash rings and the fuel nozzles meet all the technical requirements of the current exemption, except that the exemption is limited to finished aircraft engine parts.

The NRC's current regulations state:

§ 40.13 Unimportant quantities of source material.

(c} Any person is exempt from the regulation in this part and from the requirements for a license set forth in section 62 of the Act to the extent that such person receives, possesses,

~uses, or transfers:

e (8) Thorium contained in any finished aircraft engine part containing nickel-thoria alloy.

Provided, That:

(i) The thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria (thorium dioxide); and (ii). The thorium content in the nickel-thoria alloy does not exceed 4 percent by weight 3

The Petition The petitioner requests that the NRC amend its regulations In § 40.13(c)(8) to establish an exemption from licensing requirements to include the M1A1 Battle Tank Engine AGT 1500 which contains nickel-thorium.

Because the petitioner is located in an NRC Agreement State, it requested that the Florida Department of Health grant an interpretation of the current exemption to include the M1A1 ABRAMS Main Battle Tank Engine. The petitioner stated that the Florida Department of Health would not grant its request and advised the petitioner that Florida Department of Health was under the impression that the NRC was reevaluating the NRC's position on the nickel-thorium exemption.

In support of its 'petition, Chromalloy has referenced a petition for rulemaking submitted to the NRC by E. I. du Pont de Nemours & Company (PRM-40-6) dated February 13, 1963, that requested the Commission's regulations be amended to establish an exemption from licensing requirements for persons receMng, possessing, using, transferring or importing into the United States any finished products or part fabricated of, or containing nickel-thorium alloys containing up to 4 percent thorium by weight. The petitioner pointed out that the NRC's response had been:

"the Commission has found that the possession and use in the United States of thorium contained in thorium metal alloys in which the thorium does not exceed 4 percent by weight is not of significance to the common defense and security, and that such activities can be conducted without unreasonable hazard to life or property."

The proposed exemption was for "any finished product or part;* nowhere in PRM-40-6 do the words *aircraft engine parts* appear.

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The petitioner stated that the final exemption was not published until November 18, 1967 (32 FR 15872) and that the expression *jet aircraft engines* is mentioned for the first time In that notice.

After consulting with the NRC, the petitioner believes that the material used for the experimental test for the final exemption must have been from jet aircraft engines, which at this stage in the development and use of nickel-thoria components in engines was the only application. This is possibly the reason that the exemption specifies only jet aircraft engines.

The M1A1 Battle Tank Engine AGT 1500 was not developed until after 1967. The M1A1

• Battle Tank Engine AGT 1500 contains the same nickel-thoria alloy as Is contained in the JT9D jet engine. The petitioner also has pointed out that the material in the M1A1 Battle Tank Engine AGT 1500 would produce the same_ results if put to the same experimental tests the Commission conducted in 1963-1967.

In support it its petition, Chromalloy asserts that the NRC considers that jet aircraft engine products are not intended for public use, and cites a Federal Register notice published by the Atomic Energy Commission on November 18, 1967 (32 FR 15872) as a basis for this assertion:

"The Commission considers that finished aircraft engine parts containing nickel-thoria alloy are not products intended for use by the general public within the purview of§ 150.15{a)(6) of 10 CFR Part 150, 'ExemptiQns and Continued Regulatory Authority in Agreement States Under Section 274.' Accordingly, the transfer of possession or control of such finished aircraft engine parts in Agreement States by the manufacturer, processor, or producer would not be regulated by the Commission."

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Finally, the petitioner asserts that if the Commission does not view the presence of nickel-thoria in jet aircraft engines to be unsafe to the public, then the presence of nlckel-thoria in tank engines should be reviewed in the same light because the public's exposure to battle tank engines is far less than the public's exposure to aircraft engines. Therefore, the petitioner believes that the exemption must apply to both the JT9D aircraft and the M1A1 AGT 1500 battle tank gas turbine engine.

Dated at Rockville, Maryland, this j ~

day of December, 1997.

For the Nuclear Regulatory Commission.

' e Commission.

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CHROMALLOY TALLAHASSEE

• division of Chromalloy Gas Turbi11t1 Corporation 2929 HARTSFIELD ROAD TALLAHASSEE, FLORIDA 32303 PhoM: (904} 575-7575 FAX: (904} 575--8497 DOCKET NU BER PETITION RULE PAM 'IO-:l_ h (C#P.FR<PS03'1) 1997 JUL 2Ll AM II: 38

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i\\,\\V July 17, 1997 Director, Division of Freedom of Information and Publications Services Office Administration DOCl<ETEO SEP 1 1 1997 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Chief, Rules Review and Directives Branch

Dear Sir:

RUl.fMAKINGSANO

~STAFF SDec We have been advised by the Florida Department of Health to submit this request to you asking for an interpretation or an amendment of an existing licensing exemption under 10 CFR. The relevant section (i.e., 10 CFR 40.13(c)(8)) allows an exemption for:

Thorium contained in any finished aircraft engine part containing nickel-thoria alloy, Provided, That:

(i) The thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria (thorium dioxide); and (ii) The thorium content in the nickel-thoria alloy does not exceed 4 percent by weight.

This exemption has been adopted verbatim by Florida at Subsection l0D-91.302(3) of the Florida Administrative Code.

BACKGROUND Chromalloy Tallahassee is an F.A.A. approved Overhaul & Repair facility. We overhaul and repair jet engine combustors, one of which has a component that falls under 40.13(c)(8) (i.e., the JT9D jet engine). With the future comes change and opportunity. That opportunity for us is a chance to develop a repair for the M 1 A 1 ABRAMS Main Battle Tank.

The MlAl is driven by the AGT 1500 Gas Turbine Engine. The hot sectj.pn or combustor of the AGT 1500 ~ made up of 15 splash rings and 15 fuel nozzles all of which are nickel-thoria alloy. The spl~ h rings and fuel nozzles contain less than 2 % by weight and the thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria (thorium dioxide).

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U.S. NUCLEAR REGULATORY COM ISSION RULEMAKINGS & ADJUDICATIONS STAFF OFFICEOFTHESECRETARY OF THE COMMISSION Docwnent Statistics Postmark Date ____

7 ____

Coples Received _____, ____

Add'I Copies Reproduced _ 3 ___

Special Dlstnbution f1 t ye r, PP&, 1<1 D5

Since the splash rings and the fuel nqzzles meet all the te.chnical requirements of the exemption, we went to the State of Florida Department of Health asking the State to grant us an interpretation of the exemption to include the MlAl ABRAMS Main Battle Tank AGT 1500 Gas Turbine Engine. After several attempts the State turned down our request on the ground that an NRC health. physicist advised them that the Nuclear Regulatory Commission was reevaluating its position on the nickel-thorium exemption: *Despite the fact that the components in question would meet the exemption if not for their use, the NRC representative could not recommend that the exemption be extended to include tank components when his agency is reconsidering the appropriateness of the current exemption" (See Appendix A).. I subse.quently contacted a representative at the NRC Department of State Agencies and he told me that he did not believe the previous statement to be true. He had no knowledge that the NRC was thinking about repealing the thorium exemption.

• Our further.research led us to the original petition proposing this exemption.in the Federal Register dated Wednesday, August 7, 1963. A clip of that Federal Register is typed below for your conveni~ce and highlighted on a copy of the original Federal Register under Appendix*B:

"By letter ~f February 13, 1963, E.I. du Pont de Nemours & Company, Inc., Wilmington, Delaware, filed a petition for, rule making (PRM-40-6) requesting that the_ Commission'.s regulation, "Licensing of Source Material"*, 10 CPR Part 40, be amended to establish an *exemption from licensing requirements for persons receiving, possessing, using, transferring or importing into the United States any finished products or part fabricated of, or containing nickel-thorium alloys containing up to 4 percent thorium by weight.

The Commission has given careful consideration to this ~ti.on. Based.

on data furnished by the petitioner, and on other data available to the Commission, the Commission has found that th~ possession and use in the

• United States of thorium contained in thorium metal alloys in which the thorium

. does not ex~ 4 percent by weight is not of signifi,cance to the common..

defense and security, and that such activities can be conduc~ without unreasonable hazard to life or property."

Note that nowhere in this petition do the words "aircraft engine parts" appear. Rather, the proposed exemption is for "any finished product or part."

However, the exemption was not published until November 18, 1967 (See Appendix C). Between 1963 and 1967, it appears that the Commission was assessing whether the

• thorium could be a detrimental contaminant in discarded parts melted for their nickel content "Subsequent to publication of the proposed exemption for comment, the Commission considered whetlier this exemption could ultimately result in 2

contamination by thorium of materials used in construction of nuclear reactors, as a result of discarded nickel-thoria parts being incorporated as scrap in the melting of alloys containing nickel. If significant thorium impurities were to be present in materials used in constructing nuclear reactor plants, such impurities could result in additional radioactive fission products in the reactor coolant and potentially in the atmosphere surrounding the reactor plant and in discharged wastes."

The Commission was satisfied as a result of the testing done to show that the material once melted will leave the thorium in slag and melt the nickel so there will be no contamination:

"Among the information considered was the experimental evidence provided by the petitioner on the removal of thoria in slag during metal processing. The petitioner has reported the results of a laboratory experiment that followed commercial melt practices for scrap and fluxing agent additions.

These results have shown that essentially all of the thoria introduced into stainless steel and Income! melting furnaces is separated with the slag. The petitioner also has reported the results of a full-scale melt of Hastelloy alloy X to which a large quantity of nickel-thoria scrap was added. These results also have shown that more than 99 percent of thoria was removed in the slag and the thorium content in the finished Hastelloy alloy X was substantially below the,

limits of concern with respect to reactor construction material contamination."

In the paragraph that follows, the expression "jet aircraft engines* is mentioned for the first time. After consulting with Ms. Susan Greene at the NRC, we believe that the material used for the experimental test must have been from jet aircraft engines which is possibly the reason that the exemption specifies only jet aircraft engines:

"On the basi~ of currently available data, the Commission has-concluded that the thoria (thorium dioxide) covered by this exemption would normally be removed with slag in melting steel and nickel base alloys. Therefore, the Commission considers it unlikely that carryover of thorium during melting of metal scrap, generated in the use of nickel-thoria alloys, in jet aircraft engine parts, will contaminate nuclear reactor construction materials to a level which would increase reactor plant radio-activity levels. It is noted, however, that the data on removal of thorium in the metal processing are directly applicable only to thorium dispersed in nickel-thoria alloys in the form of finely divided thoria (thorium dioxide) and the exemption has been limited accordingly."

What isn't shown by this history is that at this stage in the development and use of nickel-thoria components in engines, the only application was jet aircraft engines. The AGT 1500 Battle Tank Turbine Engine was not developed until after 1967 (See Appendix D):

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"The incentive to use DS Nickel in this application [i.e., in the AGT 1500] was generated in the late 1960's during the early development phase of the engine. n Thus, the MlAl AOT 1500 engine contains the same nickel-thoria alloy as is contained in the JT9D jet engine. Furthermore, the material in the AGT 1500 engine would produce the same results if put to the same experimental test the Commission conducted in 1963-67.

Finally, the Commission considers jet aircraft engines products not intended for public use (see the Blue Highlighted Section in Appendix C):

"The Commission considers that finished aircraft engine parts containing nickel-thoria alloy are not products intended for use by the general public within the purview of§ 150.15 (a)(6) of 10 CFR Part 150, 11Exemptions and Continued Regulatory Authority in Agreement States Under Section 274*. Accordingly, the transfer of possession or control of such finished aircraft engine parts in agreement States by the manufacturer, processor, or producer would not be regulated by the Commission.*

But certainly, public exposure to battle tank engines is far less than public exposure to aircraft engines. If the presence of nickel-thoria in jet aircraft engines is not unsafe to the public, then the presence of nickel-thoria in tank engines cannot be unsafe to the public..

With all the information given above and all the documentation attached, I hope you can grant us an interpretation of the exemption to include the Ml Al Battle Tank Engine AGT 1500. As we have shown, the NRC regulations have not kept up with modem technology.

The exemption talks about "aircraft engine" parts because those were the only parts that contained the nickel-thona alloy at the time. The thorium dispersed nickel in the AGT 1500 battle tank gas turbine engine is IDENITCAL to the thorium dispersed nickel in the JT9D aircraft gas turbine engine. The exemption must apply to both.

• If there is any more information that you may need please let me know. You may contact me at (904) 575-7575 or at the address.above. Thank you for your time and consideration.

Tony Evans Safety & Environmental Tech.

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Control No. 970411-433 Lawton Chiles Governor James T. Howell, M.D., M.P.H.

Tony Evans Safety & Environmental Tech.

Chromalloy Tallahassee 2929 Hartsfield Road Tallahassee, FL 32303

Dear Mr. Evans:

Secretary April 21, 1997 RE:

Exemption Request We acknowledge receipt of your letter dated April 9, 1997, concerning your company's activities involving engine parts containing 2 percent thorium. As previously discussed,,when the engine parts are used in aircraft, they qualify as exempt source material per subsection 100-91.302(3), Florida Administrative Code (F.A.C.). However, the exemption only applies to aircraft engine parts, so use of the same parts in tank engines disqualifies them for the exemption. Possession of the tank parts makes your company a general licensee under subsection 100-91.305(1), F.A.C.

As discussed with you by phone, our staff contacted the U.S. Nuclear Regulatory Commission (NRC) to investigate this issue further. An NRC health physicist informed us that his agency was investigating the appropriateness of the current exemption and suspected that it would be repealed in the future. He could not recommend extending the exemption to include additional parts when his agency was considering eliminating it altogether. Therefore, we are unable to grant your request to expand the exemption described in subsection 100-91.305(1), F.A.C.

If you have any questions or if we may be of further assistance, please call us at (904) 487-2437.

WLC Phone(904)487-2437 (SC) Z77-2437 Sincerely, 4/,,a-J-.tf-----

Walter L. Cofer Senior Health Physicist Bureau of Radiation Control

• Radioactive Materials Section 1317 Wmewood Boulevard* Tallahassee, FL 32399-0700 Fax (904) 921-6364 (SC) 291-6364

Lawton Chiles Governor James T. Howell, M.D., MP.H Secretary Tony Evans Safety & Environmental Tech.

Chromalloy Tallahassee 2929 Hartsfield Road Tallahassee, FL 32303

Dear Mr. Evans:

January 17, 1997 RE:

Regulations Applicable to Thorium Alloys On December 11, 1996, we received your letter requesting information on the*

regulatory implications of your company performing maintenance and repair work on gas turbine engines that include components containing thorium in the.form of a nickel-thoria alloy.

Your letter is a follow-up to our earlier telephone conversations and correspondence on the subject of radiation control regulations as they apply to aircraft parts containing thorium alloys. As we stated in our 4/9/96 letter, we concluded that your company's possession and work with thorium at'loy aircr~ft engine parts is exempt from our regulations per subsection 10D-91.302(3), Florida Administrative Code (F.AC.)

Your latest letter asks if the exemption could also apply to similar engine components that meet the established criteria (finely dispersed nickel-thoria alloy with thoriu.m content less than 4 percent by weight) but that are parts from a tank engine, not an aircraft engine.

Because the exemption in question was originally promulgated by the U.S. Nuclear Regulatory Commission (NRC), we contacted the NRC's Radioactive Sealed Source and Device Registry section to investigate your inquiry. We found that the Commission is reevaluating their position on the nickel-thorium exemption and may remove it in the future. Despite the fact that the components in gul?stion would meet the exemption if

_ _nqt _f~~ _their use, the NRC representative could not recommend that the exemption b§.

extended to include tank components when his agency is reconsidering_t!1~

§Qpropriateness of the current exemp_!ion. Therefore, without further justification, we are unable to grant an exemption to your company for your proposed activities involving nickel-thoria alloy components from tanks.

Phone (904) 487~2437 (SC) 277-2437 Bureau of Radiation Control* Radioactive Materials Section 1317 Winewood Boulevard* Tallahassee, FL 32399-0700 Fax(904)921-6364 (SC) 291-6364

Tony Evans January 17, 1997 Page2 In lieu of an exemption, your company may seek a general license (GL) for possession of so.urce material under the provisions of subsection 100-91.305( 1 ), F.AC., which states:

"A general license *is hereby issued authorizing commercial and industrial firms... to use and transfer not more than 15 pounds Of source material at any given time for research, development, educational, commercial or operational purpo$es. A person authorized to use or transfer source materjal, pursuant to this general license, may not receive more than a total of 150 pounds of source material in any one calendar year."

The 15 pound limit is not as restrictive as it appears. The limit applies to the weight of the thorium only, so your company may not be too hampered by this requirement if you can calculate what the total weight of thorium is in your engine parts in order to demonstrate compliance with the weight limit. There is no fee associated with this license, and persons possessing this GL are exempt from Part IV and X provisions (as long as compliance with the possession limits is maintained).

As we stated in our previous correspondence, your workers may face a degree of risk from inhalation/ingestion of airborne thorium particles, so use of best management practices in the form of particulate respiratory protection is recommended.

If the weight 1imitations of the GL would present a restriction on your operations, an additional option is to apply for a specific license (SL) authorizing possession of source material in quantities above the 15 pounds at any time/150 pounds per year limit. This option presents greater financial, administrative and operational costs, however. There is a $435 nonrefundable application fee and annual fees totaling $200.55. A complete radiation protection program demonstrating adequate facilities, equipment, personnel and procedures must be developed and submitted for departmental review and approval, and a wide range of regulatory requirements will go into effect.*

Thank you for your inquiry. If you have any questions or we may be of further assistance, please call us at (904) 487-2437.

Sincerely,

~,,&;/_,tr--

Walter L. Cofer Senior Health Physicist WLC

2929 HARTSFIELD ROAD TALLAHASSEE, FLORIDA 32303 Phone: (904} 575-7575 FAX: (904) 575-8497 State of Florida Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, Fl 32399-0700 attn: Mr. Micheal Stephens re* Regulations Applicable to Thurium Alloys Dear Mr. Stephens

[i]

As you will remember from our earlier conversation and correspondence, here at Chromalloy Tallahassee we overhual and repair gas turbine engines. All of the parts we repair are from the combustion or "hot" section of the engine, parts such as cumbustion chambers, heat &heilds, deflectors and vanes. The alloy that performs the best in extreme temperature's is a dispersion strengthened nickel alloy, dispersed with thorium.

By letter dated April 9, 1996, The Department of Health confiimed to us that our receiving and handling(i.e., repairing) thorium-containing heat sheilds from the JT9D jet turbine engine is exempt from the licensing requirements of Section lOD-91.301 of the Florida Administrative Code because the thorium is dispersed in the nickel-thorium alloy and the thorium content in the allloy does not exceed 4 percent by weight. Section 1 0D-91.302(3 )(i) Copies of the correspondence exchanged between our company and The Department are enclosed for your convenience.

In the near future our company hopes to be repairing the AGT1500 gas turbine engine, which contain splash rings and deflectors containing thorium dispersed nickel. That engine is the "powerplant" for the Ml battle tank used by the U.S. Army just as the JT9D gas turbine is the "powerplant" for the Boeing 747 aircraft. I Have attached an abstract entitled "D1spers10n Strengthened Nickel for Gas Turbine Appbcat,ons" which demonstrates the similarities in the thorium dispersed nickel alloy used in the combuster of both the JT9D and the AGT1500 gas turbine engines. We will be receiving, storing and handleing the splash ring and deflectors from the AGTl 500 in exactly the same way we receive, store and handle the heat sheilds from the JT9D

Although the AGTl 500 splash ring is not an aircraft engine part, we believe it otherwise meets the technical "spirit" of the exemption in the regulation. We have check with Jim Kennedy from [Avco Lycoming(Allied Signal)] the maker of the AGT1500, to confirm that in the thorium dispersed nickel the thorium content does not exceed 4 percent by weight, in order to satisfy-those criteria in the Section 10D-91.302(3)(i) exemption.

Therefore, please confrim that we do not need to be licensed to work, store or handle thorium dispersed nickel splash rings and Deflectors from the AGT1500 gas turbine engines.

Tony Evans Safety & Environmental Tech

Tony Evans Safety & Environmental Tech.

Chromalloy Tallahassee 2929 Hartsfield Road Tallahassee, FL 32303

Dear Mr. Evans:

RE:

Regulations Applicable to Thorium Alloys On March 21, 1996, we received your letter requesting information on the regulation of heat shields containing thorium in the form of a nickel-thoria alloy that are components of jet engine combusters. Your letter is a follow-up to our earlier telephone conversations on this subject. Your letter states that your company overhauls and repairs the combusters; and in our conversations, you added that your company's primary work involving the heat shields is to pop out old rivets and replace them with new ones. If a rivet cannot be removed in this manner, it must be ground out, created the potential for airborne thorium if a grinding wheel strikes the heat shield in the process of cutting out the rivet. You expressed concern that your workers were at risk from ingestion of airborne thorium particles.

The applicable regulation is found in Part Ill rucensing of Radioactive Materials") of Chapter 100-91, Florida Administrative Code (F.AC.), Florida's regulations for the control of radioactive materials.

Subsection 100-91.302(3), F.A.C. [equivalent to 10 CFR 40.13(c)(8)], states that "Any person is exempt from this part to the extent that such person receives, possesses, uses, or transfers:

(i)

Thorium contained in any finished aircraft engine part containing nickel-thoria alloy, provided that:

1.

The thorium is dispersed in the nickel-thoria alloy in the form of finely divided thoria or thorium dioxide; and

2.

The thorium content in the nickel-thoria alloy does not exceed 4 percent by __ weight.

• 1317 WlNEWOOD BOULEVARD* TALl....AHASSEE, FLORIDA 32399-0700 L-\\WTON a-rn.E.<; G()\\"ER.,OR

Tony Evans April 9, 1996 Page2 In our telephone conversations, you stated that the heat shields are manufactured and distributed by United Technologies/Pratt & Whitney (UT/P&W). On March 19, I contacted Steve Jvers (860/565-7526) at UT/P&Ws Hartford, CT, facility to discuss their company's authorization to distribute the heat shields. Mr. Jvers stated that the heat shield (Part No. 747-106) alloy is approximately 2 percent thorium, verifying your letter's statement that the parts contain less than 4 percent thorium by weight. He also verified that the thorium is dispersed in the nickel-thoria alloy. Thus, the heat shields meet both criteria for exempt source material as specified in subsection 1 0D-91.302(3),

F.AC.

While the heat shields are exempt from all regulatory requirements, ingestion of airborne thorium as a result of grinding remains a potential health hazard, so use of best management practices (i.e., particulate respiratory protection) by your workers is recommended.

Thank you for your inquiry, which reflects your company's concern for the health and safety of your workers. If you have any questions or we may be of further assistance, please call our office at (904) 487-2437.

WLC/wlc Sincerely,

~~~f~

Senior Health Physicist Radioactive Materials Section Office of Radiation Control

CHROMALLOY TALLAHASSEE a division of O,romolloy Gos Tvrbintt Corporation 2929 HARTSFIELD ROAD TALLAHASSEE, FLORIDA 32303 Phone: (904) 575-7575 FAX: (904) 575-8497 April 9th, 1997 State of Florida Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee Fl, 32399-0700 attn.: Walter Cofer re: Regulation Exemptions Applicable to Thorium Alloys

Dear Mr. Cofer:

As you will remember from our earlier conversations and correspondence, Chromalloy Tallahassee requested confirmation ihat we do not need {o be licensed to work, store or handle thorium dispersed nickel splash nngs and deflectors from the AGT 1500 gas turbine engines. We believe that the exemption IOD-91.302(3)(i) even though it reads " Thorium contained in any finished aircraft engine part containing nickel thoria alloy", should apply to the AGT 1500 because it is also a gas turbine engine, similar to those used in aircraft, including the JT9D Mod 6, for which we currently hold this exemption.

On January 17, 1997 you wrote that without further justification you are unable to grant an exemption. Please accept the following as further justification; The AGT1500 is a Lycoming manufactured gas turbine engine that is similar: in configuration to aircraft gas turbine engines. This particular model is used for ground-based vehicles. The AGT1500 combustion chamber is manufactured from the same materials used for aircraft engine combustors. The Thorium Dispersed Nickel used for details of the AGT1500 is exactly the same as that used in heatshields in the JT9D Mod 6 combustor. The same percentage (two percent) of thorium is contained in both components. Please use the above mentioned information as justification and grant the exemption to the AGT 1500. If there is any further information required please contact me at (904) 575-7575.

• w take. captm-e, or i:lll tnigrator:Y birds be noted that the proposed exemption 1S not perm.Itted. an that area of land

• would not 1nc1ude such 1lnished-prodncts and water in Stewart County, Tennessee, or part.a as are designed for lngest1on or descrfbed as follow8:

1nha.lat1on by, or appllcatl.on to, a bu-

.All the area of the bed of the Cmnber-man be1n&" for 8.DY purpose, including,

• .

• land River, bank to bank, submerged or but not limited to, d1agnostlc, tberapeu-axposed, lncludfng the waters thereof, tlo, or research purposes, or are designed between river mile 90.0, approximately for use in any deV1ce, Instrument, appa-n,e-quarter mne downstream from ratus or apparel, which 1s intended to be

~ver Island, and river mile 102.25, ap-placed on or in a human body. Exam-roxlmatelY one-half mile downstream ple!! o! products which may be intended from the confluence o! Wellll Creek with for use on or in a human body are spec-the CWnberland Rlver. The area ls Im-tacle frames and false teeth.

edlately contlgu0Ul5 to and* abutting Pursuant to the Atomic Energy Act of

1-pcn lands o! the United s~tes (Cross 1954, as amended, and the Admlnlstrn.-

ereeks Na.t1onal Wlldllfe Refuge) ac-tive Procedure Act o! 1946, notice 1s quired by the Corps of Eng1neeni as part hereby given that adoption o! the follow-

! the Barkley Dam and Lake Barkley Ing amendment of 10 CFR Part 40 Is o

cont.emplated.

All interested persons Project.

STEWART L. UDALL, who desire to submit written comments

.Secreta.nJ of the Interior.

or sugestlons in connection with the pro-posed amendment should i;end them to the Secretary, United States Atomic Energy Commission, We.shlngton 25, D.C., within 30 days after publication of this notice in the FEDERAL REaxsTEB..

Comments received after thll.t period will be considered if it 1.5 practlcable to do w, but assurance of consideration cannot be given except as to comments ffl.ed within the period specified.

AUGUST 1, 1963.

[P.R. Doc. 63-8363; Plled, Aug. 6, 1963; 8:tll a.m.J ATOMIC ENERGY COMMISSION

[ 10 CFR Part 40 l LICENSING OF SOURCE MATERIAL Proposed Exemption of Products Con-taining Certain Thorium-M e t a I Alloys By letter of February 13, 1963, E. L du Pont de Nemours & Company, Inc.,

Wflmlngton. Delaware, filed a petition for rule making CPRM--40-6) requestlng that the Commission's regulation, "Li-censmg,of Source Materlal, 10 CPR Part 40, be amended to* establlsh an exemp-tion from Uoenslng requirements for pen;ans: receiving, possemdng,

using, transferring or Importing into the United States any. :finished products or part fhbr1cated. ** of;---<<. contaln1ng nlckel-tbortu.m alloys contalning up to 4 percent thorium by weiglit.

The Comm1ssion has given careful COlll!ideration to this petition. Based on data furnished by the petitioner, and on other data available to the Comnµssion, the Commlssion has found that the pos-session and use in the Unit.ed States of thorium contained in thorium-metal alloY8 in which the thorium, does not exceed 4 percent by weight Is not of significance to the common defense and security, and that such activities can be conducted without unreasonable hazard to ll!e or property.

The proposed amendment to 10 CFR Part 40 set forth below would amend

§ 40.13(cl (4) to exempt from the licens-ing requirements of Part 40 the receipt, J)OSSeSSion, use, transfer, and import into the United States o! thorium in. finished Products or parts fabricated of, or con-ta.1nlng any thorium-metal alloy in which the thorium is uniformly dls-P81'6ed in the alloy and its content in the alloy does not exceed 4 percent by Weight. The proposed exemption would not authorize the chemical, pbyslcal or metallurgical treatment or processing of any such product or part. Also, it should

1. Subparagraph <4l o! § 40.13(c) is amended to read as follows:

§ 40.13 Unimportant M>trn:C materiaL quantities of (c) Any person Is 03:empt from* the regulation in this part and from the re-quirements for a license set forth in sec-tion 62 of the Act to the extent that such person receives, possesses, uses, trans-fers, or imports into the United States:

(4) Thorlum contained in any fln1sbed product or part fabricated of, or. con-ta1ning thorium-metal alloys, provided that the thorium 1s uniformly dispersed throughout the alloy and its content in the alloy does not exceed 4 percent by weight; and provided t.hat the exemp-tion contained in this subparagraph shall not be deemed to authorize either:

ill the chemical, physical or metallur-gical treatment or processing of any such product or part; or (ii) the receipt, possession, use, transfer, or import into the United States of any such product or part which Is designed for ingestion or inhalation by, or application to, a human being for any purpose, including, but not llmlted to, diagnostic, therapeutic, and research purposes, or which Is de-signed for use in any device, instrument, apparatus, or apparel, which ls intended to be placed on or in a human. body.

(Sec. 161, 68 Stat. 948; 42 U.S.O. 2!201)

Dated at Washington, D.C., this 29th day of July 1963.

1'9* the Atom.le Energy Commlsslon.

WOODFORD B. McCOOL, Secretary.

. [P.R. Doc. 63---8347; P11ed. Aug. 6, 1963; 8:46 a..m.]

FEDERAL AVIATION AGENCY *0

[ 14 CFR Part 71 [New] l

[Ampace DoCket No. 63-WE-16)

CONTROL ZONE, CONTROL AREA EX-TENSION AND TRANSmON AREA Proposed Alteration, Revocation, and De!ignation In CODJ;onance with ICAO Interna-tl.onal Standards and Recommended Practices, notice ls hereby given that the Federal Aviation Agency ta considering amendments to Part 71 CNewl ci! the Fed-eral Aviation Regulations. This pro-posal relates to the deslgna.tlon of navi-gable airspace out.side the United States.

.Applicablllty of International Stand-ards and Recommended Practices by the Air Trame Service_ PAA. in areas out-side domestic airspace of the U.S. is governed by.Art1cle 12 and Annex 11 to the Convention on International Civil AvlatJ.on CTCAOl, whlch pertains to the establishment of air navigation facllltles and services necessary to promoting safe, orderly and expeditious fl.ow of civil air traffic. Its purpose Is to lnsUre that civil flying on International air routes ls carried out under uniform conditions designed to improve the safety and efficiency o! air operations.

The International Standards and Recommended Practices In Annex 11 ap-ply in those parts of the airspace under the Jurlsdlctlon o! a contracting state, derived from ICAO, wherein air traffic services are provided and also whenever a contracting state accepts the responsi-bility of providing air traffic services over high seas or in a.Jrspa.ce of undetermine,d.

sovereignty. A contracting state accept-ing such respon.siblllty may apply the International Standards and,Recom-mended Practices to clvtl aircraft in a manner consistent with that adopted for airspace under Its domestic Jurisdiction.

In accordance with Article 3 of the Convention on International Civil Avia-*

tion, Chicago, 1944, state aircraft are exempt from the provislon.s of Anne."( 11 and its Standards and Recommended Practices. As a contracting state the U.S. agreed by Article 3(d) that Its state aircraft will be operated In interna-tional airspace with due regard for the safety o! civll aircraft.

Since this action Involves the designa-tion of navigable. airspace outside the United States, the Admln1.strator has consulted with the Secretary of State and the Secretary of Defense In accord-ance with the provisions of Executive Order 10854.

The following controlled airspace 1s presently designated in the Crescent City, call!., terminal area:

1. The Crescent City control zone is designated within a 5-mile radius of Jack McNamara Fleld, Crescent *City, Calif.

2. The Crescent City control area ex-

-tension 18 designated within 5 miles

• either side of the Crescent City VOR 330" and 235° True radials, extending from the VOR to 25 miles northwest and 20 miles southwest of the VOR.

PART 40

• STATEMENTS OF CONSIDERA--

th1U* l.ndicat~ a need tor a anoner llcen.et period.

All lDtcre&t.ed person& were invited to submit written co=ent& a.nd succes-Uona tor conslderaUon In connccUon

.-tt.b t.he proposed amendment within 30 dan &!tcr publlcaUon or the noUce or propo&ed rule ina.k!ni In the J"xoo.U:

R11:cisrn. Alter co!lllderatlon ot the comment& received and other !actors ln-YOIW<i. the Commi&&1on hu adopted the propo$C'd amendment. The text or the amendment &et forth below I.I ldenUcal with the text of the propoeed amend-ment publl.\\hed on December 22, 1~6.

Since the am.tndment I.I lnunded to provide rel!~ from.. rather th&n to lm-poce. re&tncUoru under rel"UlaUoru cur-rently lD effect. It,rtll become e!rectlve without the cwtoma.r, 30-da7 noUce.

Accordlnrl1, purru.a.nt to the Atomic Eneru Act of 1954. u amended. and the AdmlnlstraUve Procedure Act of JH6. u amended, the followlnc amend-ment or 10 CFR Put 40 I.I published u a document subject to codJ.1kaUon to be C'!rccUve upon publlcaUon In the P'Da:u.1.

R.xCDTU.

. 11?..r.i~~

ijgµ~

• ""f4~~-~~ *****.,i~

• i,;,*;11 * ~

h

"!'.unoimcf~

-,. ** *' -~~:, l'<,;;.,-;;-c- -..~~41.icharred

</@.§** *Amotia..!Ui7"~rin&uon* coiuid-ereii*'w~ the expertmental evidence pro-Tided b1 the peUUoncr on lbe rcmonl of thorta In ~

dur1nc metal proceulnJ.

The peUUoncr bu reported the reaulta of a laboratoT7 expertment that followed commercl&l melt pracUoca for acr&p and ftuxlnJ acent add!Uoru. Tbeec raultl have ahown that cucnt.1All1 all of the U>ori& Introduced Into al&lnlca It.eel and Incom.cl m.eltlnc fume.ca la ~ted Yith the~.~ peUUoncr al.lo bu~

ported the reaulta of a full-JC&le melt of Hut.cllo1 allo1 X to which a t&rce quan-t1t1 of nlcl:cl-thoria JCr&P WU added.

These result& ai.o have wo'"ll that more than -89 percent of the thorta,ru rt*

moved In the alq and the thorium con-tent 1n the fmt&hcd R~!t~UO!..Uor X wu irubst&n ti.&lly below the limlt& o!

concern..-1th ~t to re&ctor con-struction lll&tcri&l ront&minaUon.

On the b&.s1a of currenU.1 avLllable d.&t&. th" Comml.&slon bu concluded Uat the lbort& <thorium d1ox1del covered b7 th1I enmpUori would nonnall)' be re-moved "1th al&c' 1n mclt.tni *steel a.nd nickel bue &llo,-J. Therefore, the Com-miaion con.ddcn lt unlikcl1 that c:art7-over of thorium durlnc mclt.tni of met&!

8Cr&P. renerated. ln. Ule

• UN of nickcl-U>ora allo11 ln Jct &1rcra.!t enitne ptJU, W1ll oontamlnate nuclear ruct.Qr coo~

ltructlon materiala.eo** -a -level which would. 1ncreue reactor -::plant n.dlo-actlnty levw. lt l.i 'noted; bonvcr; that the *mt.a on.removal of *thorium ln the mcial ~c a:,:* d1reetl1 applie&ble onl7 to thor1l.lll1.:.~eed _1n_.ru4e!*

Ulori&-.Uo11 ln Ole form o! anc17 d1T1ded

.Ulori& :(thorium d1ox1de> and.the ezemp-tion bu been UmJt.ed acoord1nal7.

In order to continue verldcauon that cont&min&Uon ot nactor oonat.rucuon materi.&4 b7 thorium or other s1mUu tmpw1Ues doea not occur or bu1ld \\IP over an cxtalded period or Ume, the Comm.lagjon wUl &rr&n&e pcrio<11callr to ample rea.ctor construction inatcrta.h; tor thorium and other cont&min&nt&. It thu periodJc u.mpt.lnc' &how& a.n In~

tnc thorium level In such matcra1s. the recul&Uon act forth below mar be &mend-ed from time to Um~ to effect~

control& to prevent the thorium eon-C&incd In c1acardcd nlcltct-tborta a1n:rart en,-1ne parts from oont&mina~ matc-r1.&la u.cd for oon.stracUoo ot nuclear Jle&cton.

The Ccmmiulon 'll'1D a1ao a;,ply, U determined neoesu.ry, specl11cation lim-it.a on the amount o! thorium a.nd other GmJ1&r 1n&terl.&l, allowed u tn.cc oon-taminanta 1n matert&l& U8ed for cxm-structJon of nucle&r rcacton. 1b-lim-lw would dilfer for d11fercnt cont&mi-nanta and for Y~ rcaclor uaes.

The amendment publl&hed below dl!-

fen from the proposed rule publi.shed 1n the hou.u. ~ClSTn (28 F.R. a-O{JJ 1n the tollo11.1nc rc;P(!Cu :

1. The ucmptJon ha., been restrtc~

to thorium cont.&incd In a.n11l.nWlcd &1r-cnrt enctne part cont.a.1nJ.nr nlckel-thoria alley: f'TOf]ided. That : (al The t.borlum 1s d.ispe~ In t.he nJckcl-thorta t.lloy In the form ot tlnely divided lhorta

<thorlurn d1oxidel; and <bl the t.hor1um content In the n1cl:el-thor1& alloy d0e3 not ex~ 4 percent by v.tle-ht.

2. The cxemptJon u In the form o! a new I 40.13<cl <8J n.t.bcr t.ha.o a.n amendment off 40.13Ccl <4l a.s propo,;ed No chan1e 1s bclnc made at thu Ume ir; the exemption for thorium In tune-,t.cn-thorlum &nd m...-nealum-thorium &llon presently provided In I 40.13<c><4l.

3. The cxemptJon adopted permJt,g the c:mduct o! acUvlUcs,ucb u rcpa.ir or t1nlshed alrcra.!t en1lne puu conu.1o1.n, nlcltel-thor1a alloy, and the h&ndllni' and proces.sln& of nickel-thorla scrap by &erap dealers and prote=rs. An analy.ds of the potcntl&l health h.&urcu &how, tha.t It 1a hirhly unllltely that the sm&ll number o!

workers e&rryln& out ruch operatlona ln-volvln&' n!ctel-thorl& at1011 1.lll be u-

~

to n.dlat1on or airborne conccntra-tJons o! n.dJoacUve rnatcrW 1D uce&.s o!

limit& rtcommend~d oy the !ntcrnaUona.J Commis&lon on Radloloe-ical Prot.ccuon tor lndlvldue.la 1n the sener&l public when averqcd OV(.T a period of J 1ear.

ENCLOSURE.1 j

PAftT 41

• STATEMENTS eF CCNSI.EftATleN

, l'reRnt subp&rqn.ph of I '°*1:1 (Cl *hU been ~l..ed subpan.cn.ph

6. Pruent puuraph <di off 40.23 hu be-en redulenated puauaph <ti and &

ne..,* puatn.ph (dl ha.a bttn added to I 40.23 to provide & 1enen.l lloe~ for the

.:xport to countrin or dcst!na.Uoru other th&.n thOR 1!.rted In f 40.PO. Southern Rhodula and Cuba. of thorium con-t&Jnt'd In ffnh.hed &ircnJ't ensme P&l'U conta.tntnr n1ctel-thort& a.Uoy, provided th&t: <al The thorium 11 ~rsed In the 1lfckel-thoria alloy In the form of flnel:,

dJvtded thork <thorium diox1del; and

<bl the thoriw:n conunt In t.ht meket-tbort& al!Ol' does not exceed 4 percent t,ywdiht.

'The toncomc ttY1'1otu rdSect turther

-commmton con.dderaUon of Ult pro-pose<!. amendment. inclodina' addJUonal mfonnatJon and data recetftd aftu the DC,Uce of PJ'OPOKd nm mu:Jnc wu pub--

Jished on Aunist ?, 1H3.

Tht Co1nrn1.uion ha.a found that the re-

<<fi,t, poueulon. use, transfer, and Im*

p""!t 1nt.o th1! Unfted St.I.tu o! thonum c*..nt.alned in an:, tmfshed tJi.crl.{t~c 1)1..rt cont.1.ln.lni nlcl:d*thort& &Doy. pur-A,;w.nt to the exempUon 1n I 40.l3<cHII!

W'J,ublbhcd bclo"', involve un.lmport.t.nt qU&nUUcs o! 11,0UTct ma\\.enll...-lt.hln the mu.nlnr o! tectlon 152 of t.he Atomic Encro Act of Hl5.(, '-' amended, which a.rt not o! dim!t\\cance to the common

<Ide= and 5C"CUl1ty, a.nd that auch a.c-t1Tities can be conducted 1"1thout un-nuona.ble ha.urd to file or J)l"O'PUtJ'.

Tht Commhslon hu I.ho found that the n:port o! thonum 1n flnfshed tJrcrut enritle p&rt.5, pursu.&nt to the aeneral U-

<<rae ill I 40.23<dl published bclov.*. will

not be ln.l.mlcaJ to the 1nterut.s of the t1n1tedSt.t.w.

The CommtMlnn conc1ders th&t fln-uhtd alrcn.ft enrioe J)llU conta!nlni:

~ nscteM.borf& alloy are not.Products.in*

"nded for use b7 the'.reneral public within the pUI"1'kT of I 150.i6<al Ull of 10 CFR P&J1. 15'0, "Exemptions and Con-tinued.Reru]&toTY Authority 1n Anff-ment States Under SecUon 274", Accord*

lnclY, the trt.lu!er ot s,o&aea:don or control o! IUCh fll:lhhtd &trcnft entine p&rt.s 1n t.fft,eJDcnt Sta tu ' by the m&ft\\l-f&etunr, proccs.sor, or producer would

.not be ftl'U]&ted by the Commtuion.

Punw.nt to the Atomic Encrc:, Act of 1iS4. &$ amended, 'and the Adm1nWn-t1ve Procedure Act of lP-(6, u amended.

U}e 1ollo...-tnr amendments of 10 CFR hrt ~o ue published u a dOC1.1ment 1ub--

Jfl;t to eodllica.Uon. to be dfectitt thlrty (30l d&yi after publlet.Uon 1n the l"z:D.

ltUl. RI.C:t!!ttl\\.

~ FR 1 007 Pubhthed 9/5/69 Effective 915/69 Uranium Contained In Counterwelghta On July 18, lH&, the Cornmlulon pub-liahed ln tbt hl:>lUL Rl,Qttn:l (J.( 7'.R.

1210'1 > prOP(')led t.tnendmenta to l ta rec-*

\\lla.Uon "Lleemlnc o1 Source Matai&l",

10 cm P&J1. 40, ptrta1nlnc to the exemp..

t1on from lloen.dnr NQuirement& ol.

'W'Ulium oont&ined 1n oount.u'wet('hta 1nl1alled 1n t.1rcn.!t. t'Ocl:ets, proJecWes, and m\\.uilcs, or stored OT handled tn eoanecUon 'With tnst.t.llation or removt.l of such count.envel.&ht.c, and the sen-e:ra1 lio,eriae for Che ~rt ot 'lUCh 3-4 FR 195-46 oounte::.nireW:i1.I.

Publl&hed 12/11/69

'T'be amendment.I wowd:

Effective 12/11/69

• Rn1.lc t 40.U<c> <6l io sub&ti--

tu~ fo:r the word.a "'C&u~ ~/14,uoui A ITUftd' mcna actlff Matert&l-tlranium.. In f.be exit(..

to. lea-end required to ~ ~

cm s.. P*rt 20 St*i.m.nu of Con&lc:k-nation.

-.eh uempt counurwcJ.aht ooota.in1l;!

,ira..nJum, the 'lf'OTda Deplet(-d l7ranium ;

1:1 Ddete the exi&Una p!'01'idon tn I,0.12 <c> <1> <111> that the coumerwd.cht pla.tma or other COT~ mu.rt 1:1,Qt be re-

mond or peoetn.ted:

c,,. Add

• Drlf 1,o.n<cl m <111, to re-cru1re e.eh exempt oountenrrllltt to be kbe1o4 -<< m,.rttd du:rabb' and k-cibb' with the Sdent.fflc:aUon of (ht mt.n\\Uit!'*

W'er a.nd the lla.kment: "'Ona.ut.boriu Alte~tiona Prob.1b1 ted";

d. Add a si,ew I 40.U<c><&HM ata.tin6 that UH esemptlo.n conta.!.ned b:l I f0.11 (C) (6) ~

not. be ~eel W IIUthoriu the cbemial, pti.ydc.tl, or metallursial tnt.tment or~

ot aempt coun-w,r;c,aht.t other &h&n rep&!r ar ruton.-

tion of &ll:1 pl&tiD&' 0!" o(.hcr C01'*~; and e Rn1.1,e I f0.23(C) (,o rd'.!ect the ~

kic'-e:nd requim:nenta 1n 1 '°.u <c> m.

AU in"'"'ted i,.nc>lll,ren b:IT1t.K1 to IIUbml t YI1 <<al (lOIIlI!letlil &lld IUf.

~ona for oonJ11dcra.Uoo In oo.n.nection

,rtt.h the pro~ a..mcndmcnt 111th.l.n t.b1:rtr <301 d.&.ys t.f~r publlea.Uoo o! the DOtice :t:n the F'ot:UL fuClSTU. No c,om:me:nlA IUfi'C!at.1.D.i clu.nrtt. wen re-ceived The text of the a.mcndlneDU t('t out belcnr 11 lde-nUet.1 1"1th the t.u:t o!

the proposed amendme:nu publ.l.t.ht.d

.7ul1 18, 1~9.

Tbe amendments a! 140.lSCc) m

-1imJn&te the provWon ln the aempUon for un.ntum 1n countenedihtl tht.t the pl&Una or othu covertnc not be remo-,ed or ~etnted Lnd, &lthourh prohiblt.!llr ibe chem1cll. ph.Jlk&l, or metalluri1w treatme:nt or proeewnc of exempt

.,;nUllterwei(ht.1, permlt tbt repe.ir or rut.onUon o! IJl1 pl1.Una or other COT*

erm.r of counte?'Tcaht& ~

PTNeDt lirnltt.Uon 1n t.ht exempUon to oounter-wel,ihu

• on which the J)l.aUnr or oov*

erinr bu not been remond or penc-t.n.t.ed is no Jonnr ~.

II.nu <1 >

~

1.o d.lt.e 'With t.houa&.ndl of oount.e-...-d,chta ln we OTC the iiut treTcnl 7e&n fndk&ta tha.tpl"llleO( m.t.n*

ut a..oturfnc' t.ch.DJQUoM pro,1(1c &deq U&.t.e prot<<Uon &et..1nrt ox.Ida tton o! W'Llli um.

and (2) aiet:IT1Uee which YOUJd fnvol'fe proee.c.s1.na' of ura.nlum a.re apr-eu.ly pro-hiblud, uoept tor prooe,,;.&ea which do not iDv<,lve erpocure lu.u:rd.1 &l.&'tilll-a..n.Uy cUfferent from thoac 1nTOlved ln handlln.r &n Wldunt..(ed oounur-wctch.t..

The Cot:n.m!K1on c:on.dden t.hat the pro-l'Woru 1n the am.endmenu t.dcqw..~zy control th1! low n.d!t.tJon txpo&W"Ol t.ha.t in..:r ruult from dacuded coun\\.er-

'Wdiht&.

81.noe the f0Uow!n1 amendment&

relieve

from, nt.hu th.&n 1tnJ:,oe,c rutnct.ton.s m:idcr rea,ilationi cur-rently 1n etrect, they w1ll become ctrec-tJ ve 'W:I thout the euatoma.r, SO-d.&.y nouoe.

Aecord.1nc1Y. punu1.nt to the Atomle Enern-Act of 1964, a.a uncoded, and IJOCtions 662 a.t1d 663 of Utle 6 ot t.he United State.

Code, the.Jollowinr amendment.I to Tltle 10, Chapter I.

Code ot hdera.l ~ona. Pa.rt '° are publ.l.t.hed u a document subject to codUk.aUon etreeUve \\IPOll-l1ublleat1on b:l the l"DD.41. R.Gm::ru..

35 FR 6313 P'ubUsntd <4/18170 Effectiv. 511ano On~

10, 1HG, Ult OornmlMIOn a,ubl.l&bed 1n the J"nnu. Rzmnn <M P.R. U&ll) ~

a.mend.menu to 1ta

~n ~

of 8ouroe w.at..-

Ji&J". 10 CPR"Pui fO, to a:~ trom 1ioelljJ10C1JAdn..,.1 requirement.I ~

oirJ:1:t!Jc oot1t&1n1o&' not more &h&n 2 per-can 1r.r w-ddlt..:,u:roe mat.crlal;_..,.-6 110 AD 1nte:reltod penom W1'f't.,..,,,_

aiubcntt,mttim oocp.menf.1 and IU.JIU-U6tlf m ooncckntion m ccamectSon

'With U,e propoae,d t.melldmf"lltl Y1t.h1n eat, (e<II dl.7* after publ.\\e&Uon o! the noti<< m the Pnn.il Rl.ann. A.11.i!r OOQdden.t.loo of the comment.. a.nd other ta.c1on mTOlm, the com.m.1u1ot) h.u ados>t.ed the pl"OP('.>>ed &mendme:ou. 'The

~

o! the a.mendmcnt.c 11tl CJlll1. below 11 idvlUc.al with UK w.xt of the~

Ul.ftldme.ota publlihed ~r

10, lteO.

'T'be Coau:n111dan b&.I found th&t re-ceipt, ~on, we, tn.. n.der. and Sm*

)11:)rt fnt.o the tlnlted 81.&f.61 o! pl.etoclee-tm cen.m.lc cont.&.lniot not more 1.b.l.n 2 pe.reen t b7 wel.iht 110u:roe ma terit.J in-

"°1 Tt Wl1mport&nt qua.nUtJe.& O!,ource mat.erlllll Tith.In the lflca.nfnt o1 MCtion e2 of the Atom.le z:nem Act* of Jt6', u amended, whicll are not o! ~canoe to the common deten.ae &lld a<<:Urtt:,, &nd Uat aucb acUvtUe& can be conducted

'Wit.bout &nJ' unre.uon&.ble bua.:rd to W'e or propert7.

t71:llkr the provl.lJom o! 11&0.1&<11> C8l ot 10 CYR Pa.rt uo. "J::xempUOtl.l and Continued Recu)at.on Aut.horltY 1ll AcT-ecment 8tat..es Under Section 214."

the t.r&Nfer-ot pou.e,u:ion or control by t.he ma.nuf a.et.w-u, prooeuor. or producer of ptes.odcctric oer,.mlc datrlbut.ed tor w,e under the aemptJoi: would be aub*

ject to the Comm!J&lon'1 11ce:na1nJ &nd recu)ator,- reQuirement.c tTe:n 1.f the prod.

uct 11 ma.nu! a.etuttd pu.nua.nt to an Acreemcnt Stat;: llcenu. B:y the kmu of the n:empUoo, th.. Comml111on would extrclae auch reru].l.t.orY authority b:,

uempti.na, under D('W UO.UCcH2HUJ, ILil7 pef'IOll <incl udinl a m,.out -.cturer, proec:uor, or pro,duoer 1n Lil ~t Sta~ o! plesoelectrfc oeriunic> to the atblt that auch pert?n trana1en ple-110electrfc oenmic oonta.1nl.n.,c DOt more than 2 percent by wmht IOW"Cf! tn&teriLl.

Punu&nt to the Atomk J:nera Act of 1H4, u &menCSed, and.<<ti0ti$ 652 &.nd m of Utle 6 o! the Unlted St.aw Code, the t ollo'll'iof uneodmen ts

• 1.o Tl tic "l 0.

Chai,ter I. Code o1 Peden.I ~tloa-1.

Part'° lltt publiyled u I do,cumenl,-ab,.

ject to codl11c.a tlon etr ect1Te th1r'IJ ( 3() l d&71 aft.er J)Uhl.lc&Uon 1n the !'DUAL RsollTD..

35"FR 12195 Publllhed 7/30/70 Effactlve 8/29nO

Dispersion Strengthened Nickel for Gas Turbine Applications DSTM Nickel is a wrought PM product of pure (99.9+) nickel containing a uniform dispersion of 10 to 30 nm thoria particles. Its most noteworthy characteristics compared with conventional nickel base superalloys are: higher melting point, higher thermal conductivity and better long term stability for its superior creep strength and stress-to-rupture properties at elevated temperature.

The unique design, fabrication and assembly procedures that were developed to utilize DS Nickel for combustor components in the JT9D-7 and AGT1500 gas turbine engines are reviewed in the following paper by R W Fraser (Sherritt Gordon Mines Ltd, Canada), S G Berkley (United Technologies, USA) and B Hessler (Lycoming Division, Avco Corporation, USA) and over ten years of engine experience is summarized.

Reprinted from MET AL POWDER REPORT Vo!. 40, No. 10, October 1985

.D

The successful development of oxide dispersion strengthened nickel during the 1960's orfered the designers o{ gas turbine engines a new candidate material (l,2J.

Unlike the conventional superalloys which rely on several elements in solid solution and the formation or precipitated phases for strength, dispersion strengthened nickel with its insoluble dispersed phase. retains its strength and creep resistance at temperatures much closer to its melting point The availability of this unique matemil triggered development work by the gas turbine engine manufacturers and a variety of parts were

£abncated and evaluated [3]. The results of Athese early application studies directed the W'component development work to parts m the combustion section such as nozzles, heat shields. deflectors. splash rings and transition ducts which see some of the hottest temperatures in a gas turbine engine. i.e. gas temperatures up to 1900C and metal temperatures over 11 OOC. These components are typically fabricated from sheet and formability and fabncabtlity are as important cntena m the selection of materials as arc the properties at high temperature. Iterative developments by both the sheet and the engme manufacturers were successfully completed so that by the early 1970*s component parts could be made and utilized in the comhuslor systems. This paper rev1,:,w~

the unique PM proce'is that is used to manufacture DS Nickel. lls properties and characteristics and how these charactenshc~

have been ullhzed m the dc~1gn. fabr1cat1on dnd performance of comhu~tor c<,111ponenh Im th<> I\\GTl 500,ind qf th<* IT'!0-7 'l

lllrh1111* <>ngmes DS " !lw n*q1,1.. 1,*d 1r,1d,*m,1rk <1! '>h<'trtll

< ;unl<1n Mme*, L11111l<*d

...,,-->a:,~.;:.. *..:>>1v**-....,._. c *~ L '-'**cu Nickel for Gas Turbine Applications DS' Nickel is a wrought PM product of pure {99.9+) nickel containing a uniform dispersion of 10 to 30 nm thoria particles. Its most noteworthy characteristics compared with conventional nickel base superalloys are: higher melting point, higher thermal conductivity and better long term stability for its superior creep strength and stress-to-rupture properties at elevated temperature.

The unique design, fabrication and assembly procedures that were developed to utilize DS Nickel for combustor components in the JT9D*

7 and AGT1500 gas turbine engines are reviewed in the following paper by R W Fraser (Sherritt Gordon Mines Ltd, Canada), S G Berkley (United Technologies, USA) and B Hessler (Ly.coming Division, Avco Corporation, USA) and over ten years of engine experience is summarized.

PRODUCTION AND PROPERTY CHARACTERISTICS OF OS NICKEL SHEET DS Nickel is a wrought PM product of pure (99.9+)

mckel containing a

uniform dispersion of t O to 30 nm thoria particles. Its nominal composll.ion Is 98Ni-2ThO2* The process flowsheet consists of three basic operations: preparation of a composite mckel-thoria powder, consolidation of the powder mto a 100*.:. dense wroughl form and controlled thermomechanical proce~smg of the wrought form into a high quohty sheet product.

The 98N1-2Th0~ composite powder is prepared by a proprietary mod 11lca lion to hydrometallurg1cal processes descnbed m the literature (4.51. Each and every one of the micron sized powder particles contains about 2-:<, of the 10 to 30 nm thona particles The small thona particles are located in the surface of the host nickel particle as i-hown m Fig 1.

. \\~ "h:

r~

• ~

. ~

~.

fl(j / El<*, Im/I p/i<Jl<l/lllf'ffl!/rn{)ll 0/ /1/( /,,*/

th,,,w pmvtl,*t

\\--:'"'\\,;.***~ -~=-->>:

~

• W' :-* *.

r.'f-::r**

• ~! /;~~-

FIG.2 Transmission electron photo-micrograph The mckel-lhona composite powder particles are consolidated into 70% dense rectangular sheet billets by isostatic compaction at 200 MPa. The billets are then sintered !or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 1 lOOC in hydrogen lo improve handling and to remove oxygen lrom the surface of the micron s17ed c-ompos1te powders The smterea billets are preheated lo I 200C 1n hydrogen and then directly hot rolled lo Cully dense plates The hot rolled plates are stress relieved cond,lloned. trimmed and then cold rolled 10 gauge. The resulting sheets are given o ~trc~s reh<'v1ng anneal at l 200C in

..fiydrogen and then flattened and trimmed During 1h1s produc11on process the 1denl!ly of the ongmal mckel-thona composite powder 1s lo'il and the -.mall thonil pdrllcles are un1lormly <l,~rwr'i<'d lhrouqhoul lh,:, pur<'

md-.,*1,1u,,,1 "',h<1wn in r10

~ Th<> '-It<'

d1~tntJ11t;un nf lht* lhttrld p.uh<~lt""' t.....,h,1\\'I. f\\ 1?1 r1~ i Tiu* 1t1t*~111 ~11u1 n1t~tfhtn,11< 1 *~ t\\ pH rill\\

20

,11u1 1*1 11111.

r;*-.p**<*t,v,*h*

Tlw,lw,*1 dc*vc*lup, tl

, h.Ud< t**thlt<

t 0~11...,<*

qrdUlPd ttlH u1,tr1-ec tiu,*

lh411

, un..,1..,h ul or1<*n1t*d

\\

~.

Alloy lncfpfent Heltfng P!1at. *c (Ref 8) i -~ ~

OS Nickel.

I Hastelloy X..

Haynes 188...

TABLE I Incipient melting temperatures 1..

XI-C\\oi:140109:110 f,jf'(IC.. en.-t_...* -

FIG.3 Cumulative thotia particle size distribution m DS Nickel FIG.4 Photomicrograph of DS Nickel sheet section

!amellae shown m Fig 4. The oruentation o!

the lame!lae is a (100) <200> *cube texture Several articles (1.6.7) have described the interdependence ol the uniform thona dispersion, the texture and the mlcrostructure that develops dunng the thermomechanical processing step but m the commercial product, these vanables were optimized m terms or properties and then hxed. The relalionsh1p between the d1sperso1d and the structure of DS Nickel sheet 1s constant, from sheet to sheet and from batch lo batch due m large part lo the powder metallurgical ongm of the manufacturing process Although the general properties o! DS Nickel sheet havC' been puhh'ihed [81, the propNt1M of interest ltJ combu~tor OC'i1un engineers <1re worth noting

/\\s m<*ntmnP.d prcvtously comhustor,omponenl'i mtVit withstand the>

h1gh<-:.t tcmpcr.iturc-; 111 <J<l" turh11w <!fltJ 1111*,

dnd f<11lurc* of tlw,omp,11w1H on*ur,. 11,11,1lly,

,,,;,1 r<*,1111 "' "'Vl'r<* llw1111,,I *1r,1d1<*11I-<. "'"' 111 I

1453 1250 1302 a

• £:

.-~ "

extreme cases by melting. The pure nickel I

I

~

.-C'-<<Ma\\~

~'""~

• • UC,41"-, I ac"'"t.io matrix ot'fers DS Nickel al least a 150C FIG.6Dynamicoxidalioncharacterlstics advantage over conventional sheet metal superalloys as shown in Table t. Combustor components can also I.ail by thermal fatigue as a result of a lluctuallng stress induced by changing temperatures. Since this stress ls directly dependent upon the modulus of elasticity and the coefficient of thermal expansion and inversely proportional to thermal conductivity. thermal stresses are much less in a DS Nickel component because o( its lower modulus and its markedly higher thermal conductivity (Table 2).

(The coefficient o! thermal expansion of DS Nickel and other sheet metal superalloys is similar).

It is appropnate lo note that the high modulus or the early versions of DS Nickel was lowered by changing the texture components m the structure to mirumize the stress due to thermal gradients 171-Combustor components must have stab1ltty.

oxidation resistance and high temperature strength. Al high temperatures(> I OOOC). the strength or DS Nickel is superior to that of sheet metal superalloys and it exhibits superior stability due to the Inert thoria particles that strengthen the matnx and stabilize the microstructure (9j. 'stress-to-rupture properties for OS Nickel are shown m Fig. 5 and are relatively insensitive to i

\\

\\~\\

>H"*'"" \\

\\~~,M

\\

,. u!-"--:----.. ---,.--~

.. ---'-~.,---',.

,_...... -u...- *-- (t1*11 111),~...,"14l.'"J..l FIG.5 Larson-M1/ler stress rupture time temperature parameters 260"C OS llickel Uncoated 56 Coated 48 Reference Hater1a1sl8l Hastelloy X 13 Haynes 188 16 tem~rature and lime due to the remarkable microstructural stability and the absence or solid solution and,or precipitation reactions durlng Jong term exposure to high lemperattlre stress.

This superior temperature stability is also illustrated when DS Nickel is heated to 1320C. the llquidus temperature for several nickel base superalloys. and held for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. After this extreme treatment the reduction in high temperature strength is only 10% or its original value.

The oxidation and corrosion resistance of the pure nickel matrix is inadequate !or most applications al elevated temperatures where the strength of DS Nickel 1s o[ interest for design. This 1s particularly true for the combustor components in the gas turbine engine. DS Nickel requires a protective coating. Diffusion bonded coatings of duplex chromium-alummiurn using the pack dl((usion processes described in the literature (lOJ must be applied to the finished DS Nickel parts. The ecte~ of the coating on oxidation resistance is shown in Fig. which compares the weight change of DS Nickel. coated DS Nickel and two sheet metal superalloys during 100 h of drnamlC ox1dat1on at l lO0C m an atmosphere simulating that or a gas turbine engine.

The cross-section ol the fm1shed part 1s increased by the protective coating by about 14%, which decreases the high temperature stress characteristics of the total section by about 14% as shown m Fig. 5. The thermal conductivity of DS Nick.el is also lowered by the coating because al the inward diffusion of chromium into the pure nickel matrix However. as shown m Table 2. the thermel conductivity of coated DS Nickel 1s sllll markedly superior to that of the convent10nal sheet metal superallm s The formability and fabncabthty of DS Nickel was demonstrated generally during the early component development studies For components requmng strength at high T_!l-ermal Conduct1vityl, W/m.. *c 540°c s1s*c 11oo*c 58 62 69 46 55 61 20 25 32 20 25 29 McasureQents..-ere m.aoe in the plane of the sheet..

r 1\\111.F. 2 T/,rrnwl condu,t 1v11,, **,

Sllc;nstCh prOlk'1'1K't; clrc'I ~ruc-1urc d<*1x-mk*111 and-Ch<'."'nrcturc mW'I he r<'l*in<'<l dumiu s.-c-tndory" labrica1lo11. OS Nkk<"I Is; ductile

• nd it can be shaped at*mblcnt temperatures by o..avctntional forming mclhods such as drawing. spinning. bending. machining and

~

die (orming. Explosive ftJrming can

0 be used. The work hardening rate during

'orming Is similar to that or pure nickel.

Deformation should be limited during forming to reductions of 30--40%. annealing al IOOOC in a non-oxidising atmosphere arter deformation results in stress-relief only. DS Nickel resists reoystallisation and retains Its strength properties in this type of deformation annealing treatment. Tensile strength at high temperature can be reduced as much as 25%

by partial recrystallisation U delo~tion reductions as large as 90% are used between stress relieving anneals.

Joining OS Nickel presents unique problems that must be taken lnto account during the design of the component. Conventional fusion welding processes are not suitable for DS Nickel because melting causes agglomeration or the lhoria particles and subsequent loss of microstructural stability a~h temperature strength ( 11 I-Riveting.

ru* brazing. manual TIG-braz.ing with Hastelloy wire, MIG brazing with low carbon N1Cr ware and d1ffus1on bonding should be used to make high strength, high temperature Joints. Altemat.Jvely. components have been designed with very low stress Joints permntrng low strength fusion welds 10 be used to assemble the part. This [abncauon approach is discussed later in the paper.

iANUFACTTJRE AND PERFOAA1ANCE OF DS NI COMBUSTOR COMPONENTS AGT1500Turolne Engine One production applicallon for DS N1ckel 1s m the combustor ol the AGT1500 engine This 21500 HP recuperauve gas turbine 1s a

lactured by Avco Lycoming. Stratlord.

lieut. USA and 1s the powerplanl lor w Ml battle tank used by the US Army Fig. 7 represents a cutaway view ol this engine'. including the recuperator. and shows the location of the combuslor (indicated by an arrow).

The mcent1ve lo use DS Nickel in this aJli)J.!Callon ~as g~nerciied in the late 19fl0 s

<Luring the.: early d~~~~nt phase olthe engine Early combustor designs ut1li7<'d Haste1l1Jv X for all components uf lh<*

assembly In many tests. some combustor components would exh1b1t considerable distress after short periods ol engine>

op!'rat1on The d1stre~~

was usuallv manifested by m1ss1ng metal wh,ch had melteo awav This melting. 1n turn. wa~

causeo -'hy variallons 1n the temperature profile within the combustor creating thermal d1stort1on of ~om<:> of the comporn*nt~

"i1ch detrimentally affen<'d cooling airflow Nickel po~~~~~t*s,ev,*ral ddvantc1ges,n 1<>rhan1,al,md phvs1<,ti 1irnn<'rt11'~ ov**r ia\\t<:ll*iv X will< h,,11,ld 1,.. 11,, d lo.ill,*v,.,1, lh**

1,h\\<*n-,.,1 cldl1< uil,..,

lh 111<'1111,cl condun1v11y" h1<1IH'r th,111 th.ii.. 11 i11,1<*1lov X AVCO

,'\\.NK AGT 1500 TURBINE ENGINE FIG. 7 MI Tank AGT 1500 Turbine Engine FIG 8 External view of AGTI 500 combustor "A and a* show two of the three OS Nickel component~ used,n th1sassemblv min1m1~c, tl1~tort1on And. last b111 not lca~t 11 offers a

> I 50C advantage

,n nwltang t<'mpc>raturC' over 1-!ast<'lloy X th** lwnclit ol wh1,h is ohvwu~

/\\,n,rcl1nc1h*

J dC',*<'lnpm<'nl proqr.immC' wa, 1n1t1dlC'd 111 l<'c1fn how lo f.ihn, ill<' f)<; "-J1< hPI < 1 1flll){IIH"n1,

.encl

'H 1111, 1, 1 11t*

1h1 !'I tl\\lCt

Iii,

• \\(,l l rl(l(I

'111111111-..1111 I 1q H...,how,.111, \\lc*1n,1I \\'H"W 11! Ifie*, u1r<*111 except lor the nozzles ("A"). deflectors ( B"J and splash nngs. all of which are made of DS Nickel The nozzles and deflectors are simple tubular and flat geometnc shapes which present no manufacturing difficulties. On the inside ol the combuslor are a senes of air deflectors. called *splash nngs*, one of which 1s 1llustraled in Fig. 9. Although not extremely complex geometrically, lh1s component was the subject of much development work m the early J 970"s.is discussed-below The AG Tl 500 combustor was the f1rsl aµplicauon of DS Nickel at Avco Lycoming.

ln1llally a~ nught be expected. there was minimal inlormal1on regarding mechanical properties. manufacturing processes. and 1lw1r an1errelat1on~h1p Twn approaches. each with,*ar1at1on~.

wc>re used to evaluate manufacturing proce<.;scs for the splash rings.

One appraoch involved hydroforming from a cucul,H piece ol sheet. while the other in vol\\ ed butt weld mg of slnp followed by lornung ol the required contour The malenal th1d.ness wa~ nominally I 3mm r~lmtJllu1, <<t :h~ splash ring [ram strip oflered mox,mum ullli7.al1on of raw material 111 th, le IIIIJf,llllt('

lt'-1Jllllf' 111

~, 111, h

111,

)11*111111 tu111 1,1111111111,

• • II,ii 1111

• 1111il,11-.,1,,r tq1111J11*,lqf opc*r,11.-,

(tc*

111"',IJ( I whHli

\\1',,1,,1111,

.11111* 111,

• 111,,cl,*111 ll.1.,,1**1111\\ '~

/l(,'ll)"*''"f"'/'l,1,l1r,11,1

l<.'<*ltl** ducttl1I)*

S1mut1..,*,.,,,1,ly 111 ht.1x1-tl :i-ltt~, lu*Jd ii mt10,h1<*,*<1 lh,*

l'..\\'1,j1111,.. n,*11l,,f 1,1111111~1 ch,* t*nd, ell lh<',tup

!-'** ~ra: 1<.11111119 1<*rh111,111~, w,*rc t:?valudled in~ludmg*

• (11 G,1>1unq,t,*n.11<"wdd111<1

• (21 C:lt*,lton b<.>.im w,*ld,nq (31 f'lasmJar...-,...,*ld,ng (41 Auh.,nhth<" n~*, 1nt"t,1I,u<" \\,*1th 1,\\.,!11 'h't.J11<J cold HJ)tdloy X,, 11<'

(5) EIC<'tron b<'am b1a11ng with H11stell,1y X filler All

• pure welding processes were unsuccessful. they produced poros11y to a val)'tng extent and agglomeration of the thorns particles Gas metal arc with a H11stelloy X filler produced sound but rel,rnvely wide and weak 1omts The strongest io1n1s were made by eleclron be11m brazing usmg II technique whcrem 110 5mm Hastelloy X shim was placed over the bulled ends ol the OS N1cl..el strip,rnd br11zed usmg the beam ene:gy. thona agglomer4110n was m,111m1zed

"',:~ this method This technique pro, ea,ob<'

qu,:e practical and was used lorse\\'erc.l \\ ei!*s A

1ec~111ques "ere us<:>d to form th,:, sp*<1sh Wcnntour rrn,,, t~e roll rormed aPc hrc,ed el,*: 1111\\\\'c r a" I<<

n1t ~u'a,~*d Jn<]

t,*\\ hn1qu..,*

rorm,ng th,* 011: $<?. In t!w c.i~e of 1l11s apohc., 0,1 he ou.,... G*ar1~ter o: the d 1e v-. as 0 hnc* ca*,.~ i.h 1h11 nne* a,11meh" hd,*ing the contour 01 :he sp "sh rings Th,, rol!ed sheet mN~* c, 1.-,;er s ::ilaceo within the die. and 1h11 ca*,1t.

b<' *., <:>,,n :tic sh<'<'! me1al ou1s10C' c ani: er ar,; t~,- <1,e inner a,ameter 1s cvacua ea -..,e ca. ;-.,n :he 1nne1 diameter of :he sheet m1:.al 1s

• il<:c "1th "etc<

form,ng <'ri:'S'

,s St.: -.'r<:a I*. llH d*~ct,arge of d i.clli!C *or J<*~,. :.en, s~,o, k,,, ~"' 11,'llonn, th<,h,

d!

ou., dr*J uf't11,t ccintac.s the die ci:,,,

--,1~

prr,:*.>~s., o*kPd suc,<'ss!ullv but 11, t, r:**,Pr in pn 1du1 l1<m l>ccau~e th<'< it.-

r,, 01 pc** \\,1.,s tnv !:tlov...

Alternd:l*,

• cO sp,.--..,ng o, er d,,fJodc!n mandrel w2s uec as a seconc method or forming the nn,:_;s T:11s teC",'llQUC 1/2dS moderd!el)

St.((('S, Ji alt!":ough some brc>akage dad occur.;:.*10 out I 101~: This 1cch1aue was used ror a..J'."oc or t,r-: v'" I replocc b, 11\\ droform1ng

\\\\

, f\\forn1*rq r $h**<-"l P\\t>ldl

~ fl 11\\ n*...lull\\... :1 p,,.;

I>,

I]\\(,..,1 (t)P *';,

'1<lJh.

,,;'HHlt tfp*

\\ *,,1011,il),

till'.f(J* '.!"1\\ b(*Cd,

'[")

1 1\\l.)lld I,

• • , \\ I\\ ! . '

I I~ I Ii ** ' t j

{ I l*l

• 11 r)f I }*!\\I,'

,._ ll!)t)IJ

\\.I 1,,,

• l

• I\\ I It r I I*, t 1 I"

\\ I I* H u,mg lung~h*n uu*II ~,,.....,ml t 1.,,1.. lluy X 1111,,,

wire TI1ls ch.in1c w.i, '""'"'"' ***I,llh*t c*ngm,* testing <11 th,* c*mnh1"l"1,huwt*tl th.ti

., full sece,on JOIOI di lh<' hull ('nds of !hf' splash ring w<1s not r<?quir<'<'f,>nd b<'<'dusc th" tcchn1quc n1.,,1ru,t'd

,.,w nt.:1:1<*11~1I ulll1l'dl1on f-19 10 1s a :.J..t*td1,*! Ille* < Hh, 'l'<"l1t*n of tlw cyhndr1cal por1Ion l,: llH',mnlm,1111 ""' m,1 the mt~thod or,\\~',(*r. 1 bltrUJ (h,* -p].i..,,h f,fHI\\ hl th<' H.aslclloy X sla*r ln dhhl ('\\'IJ I,*d J.11 m tlw mdnuf.i.clurmg scqu,*nn*" '" follows

{ I )F11bncate spl11sh wigs and shdl (2) Chrom1z.e splash :mg~

(JI Fasten nngs to shell by 1c~1slance spot weldmg (4) Bra:z.e joml between nngs and shell wllh AMS47 77 filler (51 Assemble rem4u-:mg components (6) Pack alumm1?.e enlllc com bus tor I

I r I L FIG 10 Method of.:*s,.mh/mq DS 'v*c!.I

splash *,ng 10 h"os:,.**, st1cl/ u<irq ~p,J we/d,nqandvocJuf"" * ;**n.;

11 should be notea t*,s h, hr<111nu,,p, r.il*c*:*

,, pcrlr*:mcd to P"'

• p m,i\\lrnur11 1'11',, *..

1 ondt1<: l\\'tl} bt"l,, <:c*r f' "i'ld"'h r 1nq*.,-1;0 t***

sh<'ll tu nun1nH.le hn, :::*,ot<-. lh<* bhl1** he-,,~u Str11~tu*<1I !unct1on

-he duple, d1flu~1011

• e~1stance [or chron-am <Hld aluminium *~

FIG 11 Oxidation of edge of DS Nickel splash nng /ollowirg breakdown of prolective cooling rec;u,:<'d to provide acequlllC o>.1aa:,,Jr re,;.s.?nee lor the DS N1d.el The oroces~.ns scc~rnce 1s a result of the 'act that chrom :>cc D'i '-*cl..e* can be spot '<erdcd ano ri*c~*G :-

1 t",'-:. '"-i\\ \\. \\,t.*ld1ng (JI -~...:n11n1z.1.:"c n t":

o,f.,.,1: ono bra;:1119 ol 1~<: ouplex coc!*:*c *,

r1..i

c.,.b 1i, bc:.-ctiu-..<, o*.he-f0:*Hc:,

,..,... ;... ¥'"'\\,

afte-r 1h~

c~scmo*.

c.w:1,n,J'ltS 1s complNco T,,,~6. s

-\\GT I 500 coml'ustor 1~

a

• . 6>

1r.>;,*,:,.,,p,e111 over the e~*Jy de, elcor...-*n*a cc~ -;-is The DS 011cl..el components,;,-, <*

th<-* ;:iurpose,.,ell 1~e**: 1s, irtuc*.

c1~*:i"*on or melting o:

the$<'

ia;*~

oe*e* vrdt.on does occur

1s causec t-, "

l"(c*..::vt.n of the pr,*'<-<,e Cr--~. <'f*c:

T*

,q

'J 111 0\\1<1ai c*, eno ff1t* t:-

cC,._

~*..

(1'1

.', 't1tt,lllt) (l\\('[lj,_:,l 1l(*f(',,,11,,1~

,n F' nn cing1n(' Jh~ * *1on.. :e c,.~

r,rc-.:

d :lit* conlpon,'rH, orl tl*sin,11*1~

JT9D*7 TURBOFAN ENGINE

~.

,.qi:........ JC'*--*

GJ I!; **

I FIG.13 Hot.sec1lon FJG.14 JT9-D Outer bum er lmer. viewed from t~etop FIG. IS JT9D-7 Falsehead detail

-JT9D-7 Turbofan Engine Dispersion strengthened nickel was introduced into revenue service on the 13-0emg 747 as falsehead malenal in the JT9D-7 MOD Ill burner in 1974. A cutaway view of the JT9D-7 turbofan engine 1s shown in Fig 12 and this !igure 1llust rates the locallon or the burner (md1cat<?d by the arrowJ The locallon of the burner lalsehead 1s shown m Fig 13 il sectional view of the hot section ol the JT9D-7 A photograph of the JT9D-7 out<'f burner liner. viewed from the top 1s shown in f'1g 14 and a photograph of a DS N,chcl f.ihehC'od Vi shown in Fig 15 Falsehead d1,;torl1<>n w,1, a milJ<>r probl<'m in the early JT90 hum<'r~ made of Hn,tC'llo\\ X

\\Vhen the (alsehead maten<'!I d,~torts 11 d1sturb5 th<* ga~ pain,oolmq ilnd hot str,*..il-s

.ire created whic-h,Jn,,,us<* !urth,*r dam.t<J<'

down<;tream in tlw, 11qm,*

l'rop,*nv d,dn 5ugge,t<:d tli,it dhJwr,io11

,11,*11ciih,*n**d nr< k<:1 w,11dd ftol d1,1nrl 1111d1*1 11i~ 111i.*1.il111q rqn<J1l1on, <,I the l,111 n<*t l11J..,, ht*,1d l1t t t1u...., 11-..

("'<*<*p,1r,*ncplt,d t<*rup<*l,tllllt'" qr1*.tlt*f th.so

'l'l(J(,. Wd, IH*IIPf tl1tio lh,d ol.in, uth, t.... 11,

• t ntt*l--JI '"!Uflf,1llov r1u-.. -..upu!u *lltl IH<IJH'II\\'

advantage led to its selection M the falsehead matenal. Expenmental testing showed that the high temperature creep strength of DS Nickel is re<zuired in the high thrust JT9D-7F/

7J engines but acceptable durability was demonstrated with Hastelloy X (alseheads In the lower thru.st.IT9D-3A 1-7/-7 A-20 engines.

Ten years of service experience has now proven that the material selection cnterion wasvaltd.

In the hostile high temperature environment of the JT9D burner DS Nickel has insufficient oxidation resistance and is dependent on an oXJdauon resistant coal.Ing for long h!e. All part machining and forming must be done pnor to the application of the coating and care is required dunng the handling and installation of the coated part to avoid coating damage that would leave base metal exposed and unprotected. When OS Nickel was first introduced the coated falseheads were machined al the 1gmtor locations to provide dearance for the mgnitor plug. The resulting oxidation of the unprotected metal was stgnillcant and 1n October 1975 falseheads with ignitor cutouts made pnor to coating were introduced and this ox1da11on problem w<'!s elimmated Bending the falsehead matenal to obtam the correct cooling air gap dunng burner.!lssembly can cause the oxidation resistant coating lo crack 13ase metal oxidation can occur under these coating cracks and this localized distress can progress through the thickness of the !alsehead malenal. This type of distress emph.!!sizes the need lorcarelul handling dunng assembly.

In the JT90 burner the DS Nickel falseheads are held in place by rivets because the preferred welding asscmhly procedures are dilftcult to achieve w11h oxide dispersion strengthen<>d materials The nveted design requires complete disassembly of the burner head secllon lor lalsehead replacenrent and re-assembly requ,res 4 70 llnear C<'nt1metre~

of welding The design of future DS N,ckel components should recognize thC' practic-al requirement; of reriair and rcpla,emenl and design around the lim1tat1ons ol D'1 Nid,el ~o that,ts CXC<'llent high IC'ntpN,llur0 ("r('('f)

~tr<'ogth and high thermal condu, t1Y1tv con bC' ul1l11.erJ,,If,*< ti\\<*lv

( ONCLL'OINC Rl.\\1/\\IH,">

I IH* d, v**lopn1, n1 11( < (Httllt(*1< J,d ()....., N1, h< I

~,ppl1c,tt1n11-..,

111 IIH q,1-..

hll h111t t'IHJll\\f'

,0111nrm 1,, t!u p11lh*tU prt*dt<t<-,11,, /\\ult.111d db,1)Cn;kiu *s1r.:?ngth<"ncd mdlC!"lalsJ Is to l~d 1o succcss!ul.isnd rewarding applk.aUon to hardware. It is obviously Imperative that tit<?

development be conducted where lhe product m.,y fill a need not readily met by an alternative material system or approach. This view emphasizes the opportunity - for use In the temperature range above lOOOC where alternate materials are not available*. This prediction was true in 1966 and it is true today. It is interesting to note that dispersion strengthened nickel was. lo the best of our knowledge. not only the first oxide dispersion strengthened material to be used in a gas turbine engine but it was also the first high performance PM product to be used in the gas turbine engine. The pioneer dppUait.io11S of OS Nickel led the way for the many other PM material applications in this Important segment of the aerospace industry.

ACKNOWLEDGEMENTS The authors acknowledge the contnbutions of their colleagues to the developments reported in this paper and they wish to thank the Management of Sherritt Gordon Mines Limited, Pratt and Whitney Aircraft Group of Umted Technologies and Lycoming D1v1s1on ol Avco Corporation for theu perm1sst0n to pubhsh REFERENCES (ll F J Anders Jr.* et al, Metal Ptogress, December 1962.

(2) R W

Fraser et al,

• 01spers1on Strengthened Nickel by Compaction and Rolhng of Powder Produced by Pressure Hydrometallurgy', Modern Developments m Powder Metallurgy. Plenum Press, New York, 1966. Vol 2.p87.

(31 G M Ault. H M Burte.

Technical Apphcal!ons for Oxide Dispersion Strengthened Matenals*. Oxide Dispersion Strengthening. Gordon and Breach, New York. 1968. p J.

(4) United States Patent 3.469,967 (SI United States Patent 3,526.498 (6) L F Norns et al. *cold Rolling of Dispersion Strengthened Nickel, Powder Metallurgy

!or High Performance Applications. Syr.!lcuse University Press.

Syracuse. New York. 1972. p 257 (7l M J H Ruscoe el al, "The Development of Thermome,;:han1cal Processes !or Advanced Dispersion S!rengthened

Alloys, The M1crostructure and Design of Alloys, Thtrd loternational Conlerence on the Strength of Metals and Alloys. Cambndge, England.

1973 (8) Metals Handbook.

Ninth Edition (American Sooety !or Metals Metals Park Ohio.1980) Vol 3.p 151 (91 R W f-raser.

D J

Evans The Strengthening Mechanism tn D1sper~1on Sir<'ngthcned N1,kel, Oxide Dispersion

'Strengthening. Gordon and Breach. Nl'w

,\\ori.. 196R p 56.l (101 L,\\ '-1nn,t1n P1otC'c1i,<* Coatings !nr D1~p,*r",tn

<.;rr<'no1l,,*11,*d

'--l<"hd (hid<'

1)1,p1 r,dull

'°i!f(*tl(Jiht'fl!IHJ.

(~ur<ion rltld

!lr,*,11 It "'-*" \\ nrk l'lhH p 'i!>J 1111 L (,,.,11"'\\',,1 -11 TD Ni,1-.<:I nt1d TD N,C t.11 T111ti,11,-

V,1111*

\\nplw,1tio11~.

Ox,d,*

I l1,p,*i~1n11 S1n*11<Jlh,*11111<J, Ct1rdon

,ind llt<*,t< It :-ww York l'!IIH p HH'i