ML20214G357
ML20214G357 | |
Person / Time | |
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Site: | 07000157 |
Issue date: | 05/19/1987 |
From: | Bidinger G, Provencher R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
To: | |
Shared Package | |
ML20214G345 | List: |
References | |
NUDOCS 8705270036 | |
Download: ML20214G357 (11) | |
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MAY 191987 FCUF:R8P DOCKET N0: 70-157 LICENSEE: The University of Texas at Austin Austin, Texas
SUBJECT:
SAFETY EVALUATION REPORT, LICENSE APPLICATION DATED JANUARY 16, 1986, RE LICENSE RENEWAL I. INTRODUCTION A. General The Nuclear Engineering Teaching Laboratory of the University of Texas at Austin uses special nuclear materials (SNM) to supplement the training and instruction programs in the field of nuclear engineering. Figure 1 shows the University of Texas located in Austin, Texas.
The SNM authorized under the license includes plutonium-beryllium (Pu-Be) neutron sources and a U-235 subcritical assembly. These materials are generally stored in the same room as the University's reactor which is located in the Nuclear Engineering Teaching Laboratory. The reactor is operated under Reactor License R-92, independent of the SNM license. Since these activities are under the direction and control of one organization, the safety of the activities under the SNM license is enhanced by the more stringent controls needed to ensure the safety of the reactor operation.
B. License History Materials License No. SNM-180 for the University of Texas was first issued in 1958 to authorize possession and use of 1 gram of contained U-235 in fission counter tubes and 32 grams of plutonium in two Pu-Be sources. The license was amended in 1960 to authorize use of U-235 in a subcritical assembly containing 470 grams U-235 as 20 percent enriched uranium dioxide (U0,) impregnated in high-density polyethylene. The license was renewed in 1963, 1966, 1969, 1974, and 1981.
The current license has an expiration date of February 28, 1986; however, since that date, the license has remained in effect in accordance with the timely renewal provisions of Subsection 70.33(b) of 10 CFR 70. By letter dated January 16, 1986, the licensee made timely application for the license renewal.
Additional information on the renewal application was provided through telephone discussions with a licensee representative on April 27, and May 11, 1987.
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THE UNIVERSITY OF TEXAS AT AUSTIN e 'r_0 ::
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University of Texas SER 3 II. AUTHORIZED ACTIVITIES Licensee activities and programs being assessed by this safety evaluation are related to the possession and use of uranium enriched in the U-235 isotope and plutonium. These activities include radiation safety, nuclear criticality safety, organization and administration, and regulatory compliance.
III. POSSESSION LIMITS The University of Texas has requested and the staff recommends that the following forms and quantities be added as a condition of the license:
Material Form Quantity A. Uranium enriched A. Uranium dioxide A. 470 grams U-235 in the U-235 isotope in polyethylene enriched to 20% in the U-235 isotope B. Plutonium B. Sealed plutonium- B. 128 grams of beryllium neutron plutonium '
sources IV. LICENSE APPLICATION A. Review History The safety review of the University of Texas' renewal application included an evaluation of the application transmitted by letter dated January 16, 1986.
Staff obtained supplementary information on the renewal application through telephone discussions with a licensee representative on April 27, and May 11, and with NRC Region IV staff on April 29, 1987.
B. Current Application In the license renewal application, the licensee has committed to and will be held accountable for minimum requirements of its license (SNM-180). Accordingly, the staff recommends that the license renewal application be incorporated as a condition of the license, as follows:
Authorized use: For use in accordance with the statements, representations, and conditions specified in the licensee's l application transmitted by letter dated January 16, 1986. l V. FACILITIES The licensed materials are stored and used in experiments in the Nuclear Engineering Laboratory located in Taylor Hall at the University's main campus.
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University of Texas SER 4 Laboratory facilities associated with the nuclear engineering program include a research reactor and a charged particle accelerator with appropriate NRC license, NRC R-92, and Texas Health Department Radioactive Material License Authorization TDH 6-485 No. 48, respectively.
Primary location for storage and operation of the subcritical assembly and storage of the Pu-Be neutron sources will be Taylor Hall, Room 131. By letter dated January 16,19E6, the University of Texas informed NRC that a change had been made to the renewal application since the previous submittal in 1981. The change removes Building 10 of the Balcones Research Center for use and storage of the licensed materials. The licensee reported that Building 10 has been dismantled.
In the renewal application cover letter and through telephone discussions with staff on April 27, 1987, the licensee requested that the renewed license authorize temporary use of the Pu-Be neutron sources in Room 32N of the Engineering Science Building, also located on the main campus. The licensee stated that Room 32N, controlled as a restricted area, contains stationary neutron measurement equipment that requires calibration using the Pu-Be neutron sources. The staff, therefore, recommends the following license condition:
Authorized Place of Use: The existing Nuclear Engineering Laboratory located in Taylor Hall and Room 32N of the Engineering Science Building.
VI. PERFORMANCE HISTORY A. Regulatory Compliance Since the license was renewed in 1981, one health and safety inspection was conducted by NRC Region IV personnel. The inspection report dated February 27, 1984, noted one violation. This was classified as a Severity Level IV, which is considered one of the least significant types of violations. The violation involved failure of the licensee to calibrate radiation detection instruments every 6 months, as required by the license.
B. Personnel Exposures During the inspection of the University on February 27, 1984, Region IV staff found the 1983 average annual external dose received by students, staff, and faculty to be negligible. The inspector did report an anomolously high individual external dose of 260 mrem / year, nevertheless, this is approximately 5 percent of the occupational exposure limit given in 10 CFR 20.
VII. ORGANIZATICN AND ADMINISTRATION The University's renewal application demonstrates that there is an adequate technical staff with the qualifications to administer an effective radiological safety program. The following sections contain a description of the licensee's relevant organization and radiological safety program, along with additional conditions developed by FCSB staff.
University of Texas SER S A. Organization
- 1. Supervision and Responsibility The President of the University of Texas has established a Radiation Safety Committee (RSC) whose purpose is to define policies and practices regarding the safe use of radioisotopes and sources of radiation on the University campus.
The Radiation Safety Officer is delegated authority by the RSC for establishing and auditing the radiation safety program.
The members of the R-3diation Safety Committee are three faculty and/or staff members from the Science or Engineering Departments.
There is also a Reactor Committee, responsible to the Dean of the College of Engineering, with at least three members knowledgeable in nuclear safety. The Reactor Committee reviews, evaluates, and approves standards associated with the operation of the laboratory, including all nuclear operations. The Radiation Safety Officer is an ex-officio member of the Reactor Committee.
The Radiation Safety Officer reports to the University Safety Engineer although he receives guidance from the Radiation Safety Committee. The responsibilities of the Radiation Safety Officer include the following:
- a. Controlling personnel exposure to radiation.
- b. Conducting periodic surveys and leak testing sealed sources.
- c. Calibrating radiation detection devices.
- d. Disposing of radioactive wastes.
- e. Maintaining records of exposures.
- f. Training staff.
- g. Aiding in the preparation of procedures.
The laboratory operation is under the direct control of the Laboratory Supervisor or a licensed Senior Operator designated by the Laboratory Supervisor. The responsibilities of the Laboratory Supervisor include direction of the daily activities of the laboratory, which involves use of the reactor licensed by NRR as well as the subcritical assembly which is covered by Materials License No.
SNM-180. The responsibilities of the Laboratory Supervisor also include maintenace of equipment records, review of experiments and procedures, and supervising the use of radioactive materials and sources.
- 2. Minimum Qualifications The resumes for individuals in safety positions show that their experience more than satisfies the requirements for the positions as defined in the renewal application. The applicant has established minimum qualifications for the following positions:
Radiation Safety Officer: Bachelor's degree in engineering, physics, or related field with 3 years work experience in radiatica safety and/or radiological health plus a thorough working knowledge of Texas regulations for control of radiation and the NRC regulations.
Laboratory Supervisor: Bachelor's degree in engineering or science with 3 years experience in a related field. Qualifications for a USNRC Senior Operator's license.
During a telephone discussion on May 11, 1987, Dr. T.L. Bauer informed the s'aff c that the Radiation Safety Officer, H. W. Bryant, received a bachelor's degree in environmental health and safety in 1982. The licensee indicated that an updated resume for Mr. Bryant will be fowarded to the NRC.
B. Administrative Practices
- 1. As Low As Reasonably Achievable (ALARA)
In general, the radiation doses incurred in the use of the neutron sources and the subtritical assembly are negligible (refer to Section IV, 8). The ALARA goal is supported by the procedures of the concerned University organizations.
Both occasional and periodic reviews of radiation doses to staff, students, and visitors are conducted by laboratory staff and by the Radiation Safety Officer.
- 2. Procedures In the renewal application, the licensee described a system of procedures regarding personnel monitoring, laboratory operations, and instrument calibration.
The licensee included written procedures in the renewal application that adequately classify emergency conditions and describe emergency actions. The licensee should develop detailed written safety procedures regarding personnel monitoring, laboratory operations, health physics surveys, and calibration activities. As indicated in the renewal application, the Laboratory Supervisor drafts and approves changes to procedures, and the Reactor Committee reviews substantive changes to the procedures. Accordingly, the staff recommends the following condition:
The licensee shall establish, maintain, and follow written health and safety procedures for health physics surveys, personnel monitoring, laboratory operations, and calibration activities. The procedures shall be reviewed and approved in writing by the Reactor Committee. This condition is effective for all activities conducted 90 days from the date of this license renewal.
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- 3. Records The records of surveys and personnel exposures are retained in accordance with NRC regulations.
C. Training Program Since the subcritical assembly is used to teach basic concepts to undergraduate and graduate students, a portion of each student's education before performing experiments with radioactive materials will include radiation hazards, dose measurements, and laboratory procedures. Experiments are performed under the supervision of laboratory staff. Staff personnel are trained to handle materials through a combination of formal classroom education and laboratory training.
The licensee indicated that experiments are performed under the supervision of trained personnel. However, the licensee also indicated that the SNM may be handled and transferred at times other than during experiments. The staff believes it is important to safety that whenever licensed SNM is handled by the licensee, it should be either under the supervision of or by an individual who has successfully completed training to handle the licensed SNM through a combination of formal classroom education and laboratory training. Accordingly, the staff recommends the following condition be added:
Prior to working with or handling licensed special nuclear material, all personnel shall receive training or shall be under the supervision of persons who have received training in the formal radiation safety program.
VIII. RADIATION PROTECTION A. Personnel Exposure Control Each licensee must comply with the provisions of 1G CFR Part 20, which provides limits for both external and internal occupational exposures. The licensee has demonstrated that these values are observed and exposures are maintained well below the limits in keeping with the ALARA philosophy.
Personnel monitoring devices are required for all persons working with radiation sources. Personnel external exposure is controlled and evaluated on the basis of the data from personnel dosimeters. The film badges are read every 2 weeks, however, the licensee omitted this commitment in the renewal application.
Accordingly, the staff recommends that the following condition be added to the license:
The licensee shall read and evaluate the personnel film badges at intervals not to exceed 1 month.
University of Texas SER 8 B. Airborne Activity Because of the nature of the radioactive material being handled under this license, airborne activity should not be of concern. Nevertheless, the licensee has indicated in the renewal application that a continuous air monitor is present in the reactor room (Room 131, Taylor Hall).
C. Contamination Control The eight, 10-inch diameter disks comprising the subcritical assembly core are enclosed in a polyethylene jacket. Since 1960, swipe tests have shown no measurable leakage of activity. Thus, the core is handled by hand when changing reflectors. Axial and radial holes in the subcritical assembly may be filled with 35 smaller fuel disks of about 1-inch diameter. The smaller disks are also enclosed in polyethylene, but gloves are used in handling the smaller disks to protect against possible contamination. Radiation signs are used to define radiation areas during subcritical assembly operations, use of the Pu-Be neutron sources in Taylor Hall, and during calibration operations using neutron sources in the Engineering Science Building. The reactor room is continuously monitored by area radiation monitors with preset alarms (5 mR/hr).
In the renewal application, the licensee has committed to the standard, 6-month frequency leak tests of the sealed plutonium-beryllium neutron sources. However, the licensee did not commit to a specific method or frequency for leak testing the polyethylene-encapsulated-uranium fuel. The NRC has developed a standard condition regarding leak testing of sealed uranium sources which is applicable to the uranium fuel. Accordingly, staff recommends that the NRC standard condition be incorporated as an annex to the license as follows:
The licensee shall leak test the polyethylene-encapsulated-uranium fuel in accordance with the enclosed Annex A, " License Condition for Leak Testing Sealed Uranium Sources," May 1987.
D. Instrument Calibration In the University of Texas license as renewed in 1981, the NRC imposed a conditian requiring the licensee to calibrate radiation detection instrumentation at intervals not to exceed 6 months. By letter dated January 16, 1986, tne licensee requested that the calibration frequency be extended to a period not exceeding 8 months. The licensee indicated that this extended calibration period would conform with calibration requirements imposed by the Reactor License (R-92).
Since the change in calibration frequency would allow the licensee's program to be more consistent with requirements of similar licenses and does not affect the safety of the licensee's activities and personnel, the staff recommends the following condition:
The licensee shall calibrate the radiation detection instruments at intervals not to exceed 8 months.
E. Radioactive Waste Disposal Sources of radioactive waste from operation of the subcritical assembly are slightly contaminated gloves from the small polyethylene impregnated fuel pellets and activation products exposed in the assembly. Provisions exist for temporary l storage in Room 131, Taylor _ Hall, and disposal of low-level radioactive waste materials such as gloves and rags by the Radiation Safety Office. In general, foils or materials . irradiated in the assembly are short half-life and thus reusable.
j IX. NUCLEAR CRITICALITY SAFETY Experiments have been conducted with the assembly and neutron sources which show a multiplication factor of less than 7.5 for all reflector and fue1~1oad conditions.
- The fuel is thus insufficient to achieve accidental criticality, and the licensee should continue to be exempted from the requirements of Section 70.24 of 10 CFR Part 70. Accordingly, the staff recommends the folowing condition
I The licensee'is exempted from the requirements of 10 CFR 70.24 insofar
- as this section applies to the materials covered by this license.
i X .- DECOMISSIONING
! In the renewal application, the licensee has not committed to a plan for
- decontaminating premises or equipment prior to-abandonment or release for
- unrestricted use. The NRC has developed guidelines for the decontamination and survey of surfaces or premises and equipment prior to abandonment or release for unrestricted use. The staff, therefore, recommends that the NRC guidelines be incorporated as an annex to the license as follows
The licensee shall decontaminate facilities, surfaces, and equipment in accordance with the enclosed Annex B, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
- Materials," May 1985.
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XI. CONCLUSION AND REC 0m ENDATIONS Upon completion of the safety review of the licensee's application and compliance
- history, the staff has concluded that the University of Texas has-the necessary i' organization and technical staff to administer an effective radiological safety program. Positions of importance have been filled with personnel meeting the
- minimum qualifications for their level of responsibility.- -Staff has recommended
- ' that the licensee conduct activities related to the use of licensed SNM in accordance with written procedures approved by the Reactor Committee. Also, staff has recommended that the licensee provide training or supervision by a trained 1 individual to all personnel handling SNM. Conformance by the University of Texas
, to the commitments made in the license renewal application dated January 16, 1986,
) as well as to the conditions developed by FCSB, should ensure a safe operation and l the quick detection of unfavorable trends with prompt corrective action.
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University of Texas SER 10 gy yg ygf Since the proposed action is to renew the special nuclear material license of an educational institution, neither an Environmental Assessment nor an Environmental Impact Statement is required in accordance with 10 CFR 51.22(c)(14)(v).
Based on the facts summarized in the foregoing paragraphs, it is recommended that Materials License No. SNM-180 be renewed for a 5 year term in accordance with the license renewal application dated January 16, 1986, and subject to the conditions listed in the renewed license.
Original Signed BY(
Richard B. Provencher Uranium Fuel Section Fuel Cycle Safety Branch Division of Fuel Cycle, Medical, Original Signed RYY Academic, and Commercial Use Safety Approved by:
George H. B1dinger Uranium Fuel Section i n
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ANNEX A LICENSE CONDITION FOR LEAK TESTING SEALED URANIUM SOURCES MAY 1987 A. Each uranium source shall be tested for leakage at intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that a test has been made within 6 months prior to the transfer, the sealed source shall not be put into use until tested.
B. The test shall be capable of detecting the presence of 0.005 microcurie of alpha contamination on the test sample. The test sample shall be taken from the source or from appropriate accessible surfaces of the device in which the sealed source is permanently or semipermanently mounted or stored.
Records of leak test results shall be kept in units of microcuries and maintained for inspection by the Commission.
C. If the test reveals the presence of 0.005 microcurie or more of removable alpha contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such. repairs or to be disposed of in accordance with the Commission's regulations. Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of Fuel Cycle, Medical, Academic, and Commercial Use Safety, U.S. Nuclear Regulatory Comission, Washington, DC 20555, describing the source, the test results, the extent of contamination, the apparent or suspected cause of source failure, and the corrective action taken. A copy of the report shall be sent to the Administrator of the nearest NRC Regional Office listed in Appendix D of Title 10, Code of Federal Regulations, Part 20.
D. The periodic leak test required by this condition does not apply to sealed sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to another I person unless they have been leak tested within 6 months prior to the date of use or transfer.
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ANNEX B GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR NATERIAL U.S. Nuclear Regulatory Comission Division of Fuel Cycle, Medical, Academic, and Comercial Use Safety Washington, DC 20555 May 1987 kl5 f i
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- e, The instructions in this cuide, in conjunction with Table 1,.specify the ~
- radionuclides and radiation exposure rate limits which should be-used in _
' decontamination and survey of surfaces or premises and equipment prior to' ,
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abandonment or release for unrestricted use. The limits in Table 1 do not
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apply to premises, equipment, or scrap containing induced radioactivity for which the radiological considerations pertinent to their use may be different. The release of such facilities or items- from regulatory control is 1, censidered on a case-by-case. l 1
j 1. The licensee shall make a reasonable effort to eliminate residual i contamination.
- 2. Radioactivity on equipment or surfaces shall not be covered by paint, i plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in 1 Table 1 prior to the application of the covering. A reasonable effortr must be made to minimize the contamination prior to use of any covering.
! 3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be detemined by making measurements at all traps, and
{ other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the limits.
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- 4. Upon request, the Comission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having surfaces contaminated with materials in excess of the limits specified. This may i ~
L include, but would not be limited to, special circumstances such as razing of buildings, transfer to premises to another organization continuing work '
with radioactive materials, or conversation of facilities to a long-term I storage or standby status. Such requests must:
1 a. Provide detailed, specific infomation describing the premises,
, equipment or scrap, radioactive contaminants, and the nature, extent, j and degree of residual surface contamination.
- b. Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment.
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or scrap, are unlikely to result in an unreasonable risk to the j health and safety of the public.
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- 5. Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contamination is within the limits specified in Table 1. A copy of the survey report shsll be filed with the Division of Fuel Cycle, Medical, Academic, and Commercial Use Safety, U. S. Nuclear Regulatory Commission, Washington, DC 20555, and also the Administrator of the NRC Regional Office having jurisdiction. The report should be filed at least 30 days prior to the planned date of. abandonment.
The survey report shall:
- a. Identify the premises.
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- b. Show that reasonable effort has been made to eliminate residual contamination.
- c. Describe the scope of the survey and general procedures followed.
- d. State the findings of the survey in units specified in the -
instruction.
! Following review of the report, the NRC will consider visiting the facilities to confirm the survey.
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TABLE 1 ACCEPTABLE SURFACE CONTAMINATION LEVELS 6
AVERAGEbcf MAXIMUMbdf REMOVABLEbef NUCL10ESa U-nat, U-235, U-238, and 1,000 dpm a/100 cm2 associated decay products 5,000 dpm a/100 cm2 15,000 dpm a/100 cm2 ,
Transuranics. Ra-226 Ra-228. 300 dpm/100 cm 2 20 dpm/100 cm2 Th-230. Th-228, Pa-231, 100 dpm/100 cm2 Ac-227. 1-125, 1-129 ,
Th-nat, Th-232, Sr-90, 200 dpm/100 cm 2 Ra-223, Ra-224 U-232, 1-126, 1000.dpm/100 cm2 3000 dpm/100 cm2 '
1-131, 1-133 Deta-gama emitters (nuclides with decay modes other than alpha emission or spontaneous 5000 dpm sy/100 cm2 15,000 dpm 87/100 cm 2 1000 dpm sy/100 cm2 fission) except Sr-90 and . -
others noted above.
aWhere surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nuclides should apply independently.
bA s used in this table, dpm (disintegrations per minute) means tre rate of emission by radioactive material as detemined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factort associated with the instrumentation.
cMeasurements of average contaminant should not be averaged over more than I square meter. For objects of 'less surface area, the average should be derived for each such object. .
d The maximum contamination level applies to an area of not more than 100 cm2 8 The amount of removable radioactive material per 100 cm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.
f The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 trad/hr at I cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber. . .
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