ML20202H840
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| ML20202H840 | |
| Person / Time | |
|---|---|
| Site: | 03011717 |
| Issue date: | 01/21/1998 |
| From: | Prange B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| References | |
| 50-16832-01, 50-16832-1, 572587, NUDOCS 9802230032 | |
| Download: ML20202H840 (32) | |
See also: IR 05000168/2032001
Text
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NRC FORM 374
U.S. NUCLEAQ REGULMoRY COMutssioN *
" .\l ATERIAI,S 1,1 CENSE .
I
Pursuant to its Atomic Energy Act of 1954. as amended. the Energy Reorganitation Act of 1974 (Public Law v1438), and Title 10. Code of Q
l Federal Regulation., Chapter i. Parts 30,31,3133, 4. 35. 36,39,40, and 70, and in reliance on statements and representations heretofore made Q
l by the licenwe e license n hereby iwued au:horia..g the incensee to recene, acquire, poweu, and trarnfer byproduct source, and special nuclear Q
:s ma.crial designated below; to t se such material for the purpose (o sad at the place (s) designated below; to deliser or transfer such material to i)
, persom authortied ta receis e it in acc "rdance with the regulations of the applicable Parttu. This license shall be deemed to contain the conditions @l
g specified in Section 181 of the Atomic Energy Act of 1954, as amended, and is hubject to all applic
9 Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.
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In accordance with letter dated l
October 31, 1997 3I
J Union Oil Company of California 3. Licenw Number
50-16832-01 is amended in $!
:1 dba Unocal Agricultural Products Division its entirety to read as follows: 3l
:I Kenai Plant :l
:i 2- P.O. Box 575 3l
:i Kenai, Alaska 99611 A Expiradon Date
June 30. 2002 }l
3 5. Docket or 2l
;j Reference No. 030-11717 sj
al 6. Il> product, Source, and/or 7. Chemical and/or Physical 8. Maximum Amount that Licenwe
Special Nuclear Material kl
al Form May Possess at Any One Time gl
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Under This License
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i' A. Cesium-137 A. Sealed sources A. No single source
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1 gauging devices that have been registered either with NRC under 10 CFR 32.210 2!
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J or Agreement State specific license authorizing distribution to persons 2l
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R 11. A. Licensed material shall only be used by, or under the supervision of, Alan E l
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5 Thye, Steven Mills, or Cynthia L. Rogers. E
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W' B. The Radiation Safety Officer for this license is Alan Thye. E
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W 12. A. Sealed sources shall be tested for leakage and/or contamination at intervals E
N not to exceed the intervals specified in the certificate of registration issued E
$ by NRC under 10 CFR 32.210 or by an Agreement State. E
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i W B. In the absence of a certificate from a transferor indicating that a leak test E
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( has been made within the intervals specified in the cortificate of registration E
g' issued by the NRC under 10 CFR 32.210, or by an Agreement State prior to the g
g transfer, a sealeri source received from another person.shall not be put into g
g use until tested, g
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y C. Sealed sources need not be leak tested if they are in storage, and are not g
i being used. However, when they are removed from storage for use or g
g transferred to another person, and have not been tested within the g
g required leak test interval, they shall be tested before use or transfer. No g
g_ sealed source or detector cell shall be stored for a period of more than 10 g
y years without being tested for leakage and/or contamination. g
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g D. The leak test shF be capable of detecting the presence of 0.005 microcurie of g
y radioactive material on the test sample. If the test reveals the presence of g
y 0.005 microcurie or more of removable contamination, a report shall be fileo g
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with the U.S. Nuclear Regulatory Commission in accordance with y
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10 CFR 30.50(b)(2), and the source shall be removed immediately from service
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and decontaminated, repaired, or disposed of in accordance with Commission !8
regulations. The report shall be filed within 5 days of the date the leak test
5 result is known with the U.S. Nuclear Regulatory Commission, Region IV, 611 E
5 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, ATTN: Director, Division E
E of Nuclear Materials safety. The report shall specify the source involved, the E
test results, and corrective action taken.
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5 E. Tests for leakage and/or contamination shall be performed by persons E
5 specifically licensed by the Commission or an Agreement Sttte to perform such E
3 services. The licensee is authorized to collect leak test samples but not E
5 perform the analysis; analysis of leak test samples must be performed by E
5 persons specifically 1; censed by the Commission or an Agreement State to E
% perform such services. E
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k 13. Sealed sources containing licensed material shall not be opened or sources removed E
N from source holders by the licensee, except as specifically authorized. E
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% 14. The licensee shall conduct a physical inventory every 6 months to account for all E
Mj sources and/or devices received and possessed under the license. E
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15. Each gauge shall be tested for the proper o)eration of th,t on-off mechanism and E
I indicator, if any, at no longer than 6-monti intervals or at such longer intervals I
I as specified by the manufacturer and approved by U.S. Nuclear Regulatory Commission. I
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N 6. Installation, initial radiation surveys, relocction, removal from service. I
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maintenance, and repair of devices containing sealed sources shall be performed by E
N Alta Thye, Steven Mills, Cynthia Rogers or by persons specifically licensed by the i
f Commission or an Agreement State to perform such sere'ces. Installation, t
i replacement, and disposal of /,ealed sources shall be performed only by persons I
g specifically licensed by the Commission or an Agreement State to perform such I
, services. '
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N 17. The licensee may initially mount a gauge if permitted by-the certificate of t
registration issued by the NRC or an Agreement State and under the following t
conditions: l
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l ( A. The gauge must be mounted in accordance with the written instructions provided i
by the manufacturer; i
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;*, R. The gauge must be mounted in a location compatible with the ' Conditions of
/ Normal Use" and " Limitations and/or Other Considerations of Use" in the
Certificate of registrati;n issued by the NRC or an Agreement Stats;
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C. the on-off mechanism (shutter) must be locked in the off position, if f
applicable, or the source must be otherwise fully shielded; g
D. the gauge must be receive.1 in good condition (package not damaged); and
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q E. the gauge must not require any modification to fit in the proposed location. g
f Mounting does not include electrical connection, activation or operation of the I
gauge. The source must remain fully shielded and the gauge m.ay not be used until it I
i is installed and made operational by a person s)ecifically licensed by the L
g commission or an Agreement State to perform suc1 operations.
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f18. The licensee may maintain, repair, or replace device components not relued to the
radiologicc1 safety of the gauge (i.e., tM ,ealed source, the source holder, source
drive mechanism, on-off mechanism (shuh), shutter control, shielding); and that
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do not result in th* potential for any portion of the body to come into contact with
the primary beam a in increased radiation levels in accessible areas. ([
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I 19. Prior to initial use and after installation, relocation, dismantling, alignment, or I
I any other activity involving the source or removal of the shielding, the licensee i
l- shall assure that a radiological survey is performed to determine radiation levels I
d in accessible areas around, above, and below the gauge with the shutter open. This 1
I survey shall be performed only by persons authorized to perform such service by the i
Il Commission or an Agreement State, t
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I 20. The licensee shall operate each device containing licensed materials within the i
I manufacturer's specified temperature and/or environmental limits such that the i
I shieldingandshuttermechanismofthesourceholder;arenotcompromised, ..
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g 21. The licensee shall assure that the shutter mechanism of each device is locked in the i
e closed position during periods when a portion of an individual's body may be subject t
I to the direct radiation beam. The licensee shall review and podify as appropriate i
its "leck-out" procedures whenever a new gauge is obtainea to incorporate the device i
manufacturer's recommendations, i
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22. Except for maintaining labeling as requirad by 10 CFR part 20 or 71, the licensee g
shall obtain authorizetion from NRC before raking any changes in the sealed source, g
device, nr source-device combination that would alter the description or g
specifications as indicated in the respective Certificates of Registration issued g
either by the Commission pursuant to 10 CFR 32.210 or by an Agreement State, t
23. The licensee is authorized to transport licensed material only in accordance with [
the provisions of 10 CFR Part 71, " Packaging and Transportation of Radioactive g
Material". g
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24. In addition to the possession limits in item 8, the licensee shall further restrict I
che possession of licensed mate tal to quantities below the minimum limit specified
in 10 CFR 30.35(d) for e n ablishing decommissioning financial assurance, g
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MATERIALS LICENSE Tan or nerereate Nua" r
SUPPLEMENTARY SHEET 30-11717 ,
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Amendment No. 8
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L 25. Except as specifically provided otherwise in this license, the licensee shall I
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conduct its program in accordance with the statements, representations, and li
I procedures contained in the documents, includin any enclosures, listed below. The N
I Nuclear Regulatory Commission's regulations sha 1 govern unless the statements, 8
N representations, and procedures in the licensee's application and correspondence are N
1- more restrictive than the regulations. I
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I A. Application dated April 1, 1992 -
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N B. Letter dated June 23, 1992 N
N C. Letter dated Febraary 10, 1995 g
N D. Letter dated October 23, 1995 N
N E. Letter dated January 17,1996 N
N F. Letter dated October 31,1997 N
N G. Letter dated December 11, 1997 N
I H. Letter dated January 14, 1998 N
1 1. Facsimile dated January 20, 1998 E
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FOR THE V.S. NUCLEAR REGULATORY COMMISSION
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Date 2 1 1995 By 2, r&syac7_ '
ater 'als Branchf f I
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Wa$ nut Creek, California 94596 E
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UNITED STATES
**# %\ NUCLEAR REOULATORY COMMISSION
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% Walnut Crook Field Omco
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%+,,,,,*/ 1450 Maria Lane. Suite 300
Walnut Creek CalNomia 94596-5,.68
9
JAN I1 1100
Union Oil Company of California
dba Unocal Agricultural Products Division, Kenal Plant
ATTN: Alan Thye
Radiation Safety ufficer
P.O. Box 575 '
Kenal, Alaske 99611
SUBJECT: LICENSE AMENDMENT .
Please find enclosed License No. 50 16832 01. You should review this license ct.refully
and be sure that you understand all conditions. If you have any questions, you may
contact Kent M. Prendergast at (510) 975 0255.
NRC expects licensees to conduct their programs with meticulous attention to detail and a
high standard of compliance. Because of the serious consequences to employees end the
public which can result from failure to comply with NRC requirements, you must conduct
your program involving radioactive materials in accordance with the conditions of your NRC
license, represent 3 tic.ns made in your license application, and NRC regulations, in
particular, note that you must:
1. Operate in accordance with NRC regulations 10 CFR Part 19, " Notices, Instructions
and Reports to Workers: Inspection and Investigations," 10 CFR Part 20,
* Standards for Protection Against Radiation," and other applicable regulations.
2. fossess radioactive material only in the quantity and form indicated in your license.
3. Use radioactive material only for the purpose (s) indicated hi your license.
4. Notify NRC in writing of any change in mailing address (no fee required if the
location of radioactive material remains the same).
5. Request and obtain written NRC consent before transferring your license or any
right thereunder, either voluntarily or involuntarily, directly or indirectly, through
transfer of control of your license to any person or entity. A transfer of control of
'
your license includes not only a total change of ownership, but also a change in the
controlling interest in your company whether it is a corporation, partnership, or
other entity. In addition, appropriate license amendments must be requested and
obtained for any other planned changes in your facility or program that are contrary
to your license or contrary to representations made in your license application, as
well as supplemental correspondence thereto, which are incorporated into your
license. A license fee may be charged for the amendments if you are not in a fee-
exempt category.
_ _
. . _ . _ _ _ . . . _ . . _ . _ . _ _ _ _ . - _ _ _ . _ _ _ _ . . _ _ _ _ . _
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Union Oil Company of California 2-
6. Maintain in a single document decommissioning records that have been certilled for
i completeness and accuracy listing all tha following items applicable to the license:
* Onsite areas designated or formerly designated as restricted areas as defined '
,
, in 10 CFR 20.3(a)(14) or 20.1003.
,
* Onsite areas, other than restricted areas, where radioactive materlats in
,
quantitles greater than amounts listed in Appendix C to 10 CFR
20.1001 20.2401 have been used, possessed, or stored.
* Onsite areas, other than restricted areas, where spills or other unusual
occurrences involving the spread of contamination in and around the facility,
equipment, or site have occurred that required reporting pursuant to 10 CFR
30.50(b)(1) or (b)(4), including areas where subsequent cleanup procedures
. have removed the contamination.
* Specific locations and radionuclide contents of previous and current burial
areas within the site, excluding radioactive material with half lives of 10 days
or less, depleted uranium used only for shielding or sa penetrators in unused
munitions, or sealed sources authorized for use at temporary job sites.
* Location and description of all contaminated equipment involved in licensed
operations that is to remain onsite after license termination, <
7. Submit a complete renewal application with proper fee, or termination request at
,
least 30 days before the expiration date on your license. You will receive a
' reminder notice approximately 90 days before the expiration date. Possession of
radioactive material after your licen:;e expires is a violation of NRC regulations.
8. Request termination of your license if you plan to permanently discontinue activities
involving radioactive material.
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i Union Oil Company of California 3-
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You will be periodically inspected by NRC. Failure to conduct your program in accordanto
with NRC regulations, license condi' ions, and representations made in your license
,
application and supplemental correspondence with NRC will result in enforcement action
against you. This could include issuance of a notice of violation; imposition of a civil
penalty; or an order suspending, modifying, or revoking your license as specified in the
" General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement
Policy), 60 FR 34381, June 30,1995.
Thank you for your cooperation.
Sincerely,
, ,
h(f. f
Beth A. Prange
Sr. Health Physicist (Licensing)
- Materials Branch
Docket: 030 11717
License: 50-16832 01
Control: 572587
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Enclosures: As stated
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January 23,1998
RSO File
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Kent Frender,tast
Nuclear Regu;atory Commission
Fat 510 975 0381
Subject: Name Change
Mr. Prendergast:
,
This is to notify you that there has been a name change invoMag the Unocal Kens' Plant. 'lhe ,
new name is Unocal Agricultural Products Division, Kenal Plant. His O a division name
chtage only and does not involve any changes in ownership, stock, or Unwal management.
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Sincerely,
,
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Nan R. Thye
Safety Supeniror
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January 20,1998
RSO File
Kent Prendergast
! Nuclear Regulatory Commission ,
Fax: 510 975-0381
1
-
Subject: Name Change
Mr. Prendergast:
This is to notify you that there has been a name change invohing the Unocal Kenal Plant. 'lhe
new name is Unocal Agricultural Products Division, Kenal Plant. This is a division name
chany only and does not involve any changes in ownership, stock, or Unocal manapment.
'
Sincerely,
. A [
Alan R. Th>i
befety Supenisor
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Inspection File
Docket file
State of Alaska
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DOCUMENT NAME: G:\uNOCAL.mic
To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV:MB lh C:MB l Al l l l
KPrendergast e BPrange 7J79
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, OFFICIAL RECORD COPY
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* Unocal Corperstlen
, Agricultural Products
P.O. Dos 676
Kenat, Alaska 09611
Telephone (907) 776-8121
.
UNOCAL@
January 14,1998
SAF 017 9R
RSO file
Kent Prendergast
Nuclear Reguistory Commission
1450 Maria Lane, Suite 210
'
Walnut Creek, CA 94596
Subject: Cynthia Rogers Training
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Mr. Prendergast:
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.
As we discussed, this is to outline training provided to Cynthia Rogers in addition to on site
, fixed gauge training proyided by George Brown of pinnatz., Unocal has requested Ms. Rogers l be added to the Kenal Plant license as a Radiatio,n Safe,typfgerg , , . n . ,,
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Ms, Rogers' training was provided by Steve Mills and myself.. .Wetedare as lis.i
authorized
users on the license. The training was site-specific to the Kenal Plant Radiation Safety
Program. Tgtal training time was in excess of 16 hours and included the following:
' '
Review of the Kenal Plant Radiation Safety Proham,'includirig tchoideeping' requirements.
'
Personnel sa(ety when world'1g around gauges, incitiding the perscanel monitoring program,
A physical conditions inspection of thq gauges, with instryction on performing.a visual
inspection and inventoq,,, ,
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Ilow and why wipe' tests are performed. -
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Methods and'manufachtier's pr'ccedures f$r gauge retaov$1 d lock'otit of ths gauge.
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Additionally,< George Drown of Ohmart was able to show Ms. Rogers the procedure to locb
out and remove a Fauge when he perfomied this task on-site. ' Personnel safety during this
portion of the training,was a major topic. - '
Emergency procedures were also discussed. . .
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Kent Pandergast 2- Janaury 14,1998
Regulatory Comruission SAF-017 98
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I trust this protPen the information you needed to complete the revisions to the Kanal Plant
fixed gauge lic4. n. IfI can be of further assistance, don't hesitate to call.
_-
, Sincerely,
.
Alan R.Thye
Safety Supenisor
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January 8,1998
Unocal Chemical
Atta: Stese Mills
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P O. Ilox $75
Mile 2! Spus liighway
Kenal, Alaska 99611
4 ,~ U.S. Nuclear Regulatory Commission
Attn: Kent Pendergast
1450 Maiia 1.ane
Walnut Grove CA 945 % 5368 '
Re: Unocal Renal, Alaska
The purpose of this letter is to clarify questions that have been asked related to the trah ag
of Cynthia Rogers and the exact model numbers of some of the source hohless at the Unocal
plant.
Dming my visit of Septernber 17,18 and 19,19971 conducted an intense traininF elass
with Cynthia following our standard radiation safety tuanual. Since Cynthia is a well
trained Industilan liygienist with training in and experience in NORM, we u ere ubic to
cover a lot ofinfor: nation in , short period of time, Topics covered at dillerent tienes over
the thme days were:
* hadiation Theory
* Measusing and monitoring practices
.
Salety Calculation and the ALARA principle including Time, Distance, &
Shiciding
* Ilealth effects and TEDE calculations
e ILnergency procedures
* US NRC Regulations
*
General procedures- Installation, handling and removal of devices.
I ob>cived her performing various radiation safety [ meedun:s such as wipe tests, shutter
tests, and surveys, in addition I administered a verbal test of various topies. Cynthia
demonstrated good knowledge t onderstanding of radiation principles. I feel that this
training and her past experience with NORM qualifies her to be a user of material as
defined in Unocal's license.
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Jcri DD 00 Olio 2p Fiold Sctvico 513-272-4301 p.2 l
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lanuaryit.199R l
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The Ohmart model SHLM source holder is defined in Registration Nib 522 D-815-5.
Some of she source hohlers at Unocal piedale this seghtration cTl thereforr the tags do not
define the current models. A brief discription of this modelis as follows:
.
Model SilLM refers to any source holder that the r,ource capsule in mounted in n
(anier that enn be inserted into the dry well of a vessel.
*
The designation 11 or C refers to text or cable operated respectively. All of the
original <!esigns v c rod operated.
*
The 1.2 or 3 vo s according to the outside dinmeter. The larger the diarneter
the higher act, sty source can be uwd due to the a<lded shielding.
*
Some models are made with an added external gate or shutter mechviistn. These
have the R designation.
I inspected all of the sources at Unocal dunng my trips in 1995 and 1997. They are what
we would currently label as SHRM l II. I have included some original manufactunng
docuenentation that verifies this. It is my opinion that the tags should remain as they are
and a copy of this letter filed for future clarification if required
i
I would like to apoloF re for the delays in my response but my schedule and the holidays
delayed some of any research and I felt necuracy was importuit.
Sincerely
The Ohman Corporation
y Wl,2 eevy7
Ocorge W. Ilrown
Radiation Safety Ollicer
Training Manager
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Attached:
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UNITED STATES
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'" NUCLEAR REGULATORY COMMISSION
REGION IV
****# WALNUT CREEK FIELD OFFICE
1450 MARIA LANE. SUITE 210
WALNUT CREEK, CALIFORNIA 94596
I
FACSIMILE TRANSMITTAL
REQUEST
CATE: January 7. 1998
FROM: Kent M. Prenderaast. Radiation SDecialist
~
~
Teleolone iumber 510/975 0255
Facsimile 4 umber 510/975 0381
T0: Alan Thye .__
NUMBER OF PAGES (INCLUDING COVER): 5
FAX NUMBER: 907/776 3213
VERIFICATION NUMBER (IF KNOWN): 907/776 8121
SPECIAL INSTRUCTIONS: Please deliver to Alan Thye
SUBJECT: LICENSE AMENDMENT
Alan, I am unable to add Ms. Rogers to your license at this time. Please
review the information on training from NUREG 1556 and submit additional
training documentation, Please call me if you have any questions.
Sincerely,
Kent M. Prendergast
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, CONTENTS OF AN APPLICATION
Radiation Safety OITicer' in draft NUREO.1556, Vol. 4, ' Consolidated Guidance about
Materials Licenses: Program. Specific Guidance about Fixed Gauges Licenses,' dated
October 1997. Within 30 days of naming a new RSO, we will submit the new R$0's ,
name to NRC to include in our license."
)
OR
*
Attemative information demonstrating that the proposed RSO and any future RSO are
qualified by training and experience.
l
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Note:
*
It is important to notify NRC, as soon as possible, ofchanges in the designation of the
RSO; such notifications will be handled as administrative amendments not requiring
fees as long as the application contains the commitment listed in the third bullet under
" Response from Applicant."
*
Altemative responses will be evaluated using the criteria listed above.
8,9 ITEM 8: TRAINING FOR AUTHORIZED USERS AND INDIVIDUALS
WHO IN THE COURSE OF EMPLOYMENT ARE LIKELY
TO RECEIVE OCCUPATIONAL DOSES OF RADIATION IN i
EXCESS OF 1 mSv (100 mrem)IN A YEAR L
Regulations: 10 CFR 19.11,10 CFR 19.12,10 CFR 30.7,10 CFR 30.9,10 CFR 30.10,10
CFR 30.33.
Criteria: Authorized users must have adequate training and exper ence. Successful completion
of one of the following is evidence of adequate training and experience:
*
Fixed gauge manufacturer's course for users !
'
*
Equivalent course that meets Appendix G criteria
Individuals who in the course of employment are likely to receive occupational doses of
radiation in excess of 1 mSv (100 mrem) in a year must receive training according to
10 CFR 19.12.
Applicants requesting to perform noa-routine operations such as installt.tian, initial radiation
survey, repair, and maintenance of components related to the radiological safety of the gauge,
gauge relocation, replacement and disposal of sealed sources, alignment, or removal of a gauge
from service, must provide additional training. See the section in this draft report entitled
" Radiation Safety Program - Maintenance" and Appendix N.
Discusion: The individuals using the gauges are usually referred to as authonzed users.
Authorized users have the responsibility to ensure the proper use, security, and routine
maintenance of fixed gauges containing licensed material. Authorized t,sers must attend the
Draft NUREO 1556. Vol 4 8 10
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CONTENTS OF AN APPLICATION
training and instruction given at the time ofinstallation or receive equivalent training and
instruction. ,
1
Licensee personnel who work in the vkinity of a fixed gauge but do not use gauges are not I
4 required to have radiation safety training as long as they are not likely to receive 1 mSv (100
mrem)in a yem, liowwer, to minimize potential radiation exposure,it is prudent for these !
individuals to work under the supervision and in the physical presence of an authorized user or
to be provided some basic radiation safety training. Such licensee personnel should be info:med
of the nature of the gauge and the meaning of the radiation symbol, and should be instructed not
to touch the gauge and to keep away from it as much as their work permits.
Response from Appileant: Provide either of the following:
* The statement: "Before using licensed materials, authorized users will have successfully ~'""
completed one of the training courses described in Criteria in the section entitled
'Tiaining for Authorized Users and Individuals Who in the Course of Employment are
Likely to Receive Occupational Doses of Radiation in Excess of 1 mSv (100 mrem)in a
Year' in draft NUREO 1556, Vol. 4,' Consolidated Guidance about Materials Licenses:
Program Specific Guidance about Fixed Onuge Licenses,' dated October 1997."
OR
. A description of the training and experience for proposed authori7ed users.
Note: Altemative responses will be evaluated using the criteria listed above.
8.10 ITEM 9: FACILITIES AND EQUIPMENT
Regulations: 10 CFR 30.33(a)(2),10 CFR 32.210
Criteria: Facilities and equipm:nt must be adequate to protect health and to minimize danger
to life or property. This may be demonstrated by the following:
+ The location of the gauge is compatible with the " Conditions of Normal Use" and
'
" Limitations and/or Other Considerations of Use" on the SSD Registration Certificate
* The fixed gauge is secured to prevent unauthorized removal or access (e.g., located in a
locked room, permanently mounted, or chained and locked to a storage rack).
Discussion: Fixed gauges incorporate many engineering features to protect the user from
unnecessary radiation exposure in a wide variety of environments. Fixed gauges may be located
in harsh environments involving variables such as pressure, vibration, mounting height / method,
temperature, humidity, air quality, corrosive atmospheres, corrosive chemicals including
process materials and cleaning agents, possible impact or puncture conditions, and fire,
explosion, and flooding potentials. Applicants need to consult the sections on the SSD
Registration Certificate entitled, " Conditions of Normal Use" and " Limitations and/or Other
- Considerations of Use" to determine the appropriate gauge for a location. In those instances
3 11
Draft NUREO .1$$6, Vol. 4
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APPENDIX 0
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Criteria for Acceptable, Training Courses for Authorized Users
COURSE CONTENT
f
Classroom training may be in the form oflecture, videotape, or self study emphasizing practical
subjects important to safe use of the gauge:
Radiation Safety:
Radiation vs. contamination
-Intemal vs. extemal exposure
- Biological effects of radiation
Types and relative hazards of radioactive material possessed
ALARA concept
- Use of time, distance, and shktding to minimize exposure
- Location of scaled source within the gauge
Regulatory Requirements:
- Applicable regulations
License conditions, amendments, renewals
Locations of use and storage of radioactive materials
- Material control and accountability
- Annual audit of radiation safety program
Transfer and disposal
- Recordkeeping
g
- Prior events involving fixed gauges
-llandling incidents
- Recognizing and c.asuring that radiation waming signs are visible and legible
- Ucensing and inspection by regulatory agency
- Need for complete and accurate information
- Employee protection
- Deliberate misconduct
M
Practical Explanation of the Theory and Operation for Each Gauge Possessed by the Licensee:
Operating and emergency procedures
- Routine vs. nori-Routine maintenance
- Lock-out procedures
01 Draft NUREG 1556, Vol. 4
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APPENDlX 0
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On the job training must be done under the supervision of an authorized user:
* Supervised liands-on Experience Performing:
Operating procedures
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. Test runs of emergency procedures
- Routine maintenance l
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- Lock out procedures
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TRAINING ASSESSMENT 1
:
Management will ensure that potential RSOs and authorized users are qualified to work l
independently with each type of gauge possessed. This may be demonstrated by written or
oral examination or by observation.
COURSE INSTRUCTOR QUALIFICATIONS
Instructor should have either:
. Ilachelor's degree in a physical or life science or engineering
* Successful completion of a fixed gauge manufacturer's course for users (or equivalent)
* Successful completion of an 8 hour radiation safety course AND
+ llours hands on experience with fhed gauges
OR
+ Successful completion of a fixed gauge manufacturer's course frr users (or equivalent)
* Successful coinpletion of 40 hour radiation safety course; AND
+ 30 hours of hands-on experience with fixed gauges.
Note: Additional training is required for those applicants intending to perform non routine
operations such as installation, initial radiation survcy, sepair, and maintemmce of components
l related to the radiological safety of the gauge, gauge relocation, replacemmt, and disposal of
- w- sealed sources, alignment, or removal of a gauge from service. See Apper ixN "Non Routine
Operations."
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Draft NUREG 1556, Vol. 4 G2
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tinocal Corporation
AgriouMural Preducts
P.O. Box 675
Konal. Alsoka 99611
Telephone (DOT) 776 8121
UNOCAL@
December 11,1997
Ken Fendergas
Nuclear Regulatory Conunission)
Fax 510-975 0255
Ken:
In resTxmse to your question of more defhwion of the Ohmart gauges used in the Unocal Kenal
Plant, I am happy to ptovide the following information.- -
Because of safety and operational considerations, it is requested that shutter check requirement
be changes from 6-month intervals. The tests require a shutdown of the plant process widch is
wry costly or bypassing the signal from the sensor which is a safety and environmental
concern,
i
Pour of the gauges are Model ES 2, which are density gauges that do not have shutters. The
rest of the gaugas are designed with the source on the end of a rod or cable that is inserted into
a large vessel. They are located in out of the way places such as on the top of large vessels, so
'
are not liable to be contacted by personnel or equipment that could do damage.
As outlined in previous correspondence, Ohmart has approved a visual examination of the
gauge at least annually instead of h 6-tnonth shutter check. The plant is typleally scheduled for
-
a maintenance shutdown every two to four years when a shutter check can be done. Acudental
plant shutdowns of short duration sometime occur annually.
Inspections of the gauge will be done annually by a Radhtlon Safety Officer during years that
shutter checks cannot be done. The inspection will include a visual examination to all exposed
parts of the gauge and the operational rod or cable. The examination will check for corrosion,
bent rods. kinked cables, and any damage to the gauge. Any problems found wm S addressed
appropriately. Radiation Safety Officers will also examine the gauges during leak , ats.
.
Since '), _f
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Alau Thye
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MC. 82. 8997 in 3341 t.f rXit iEE LCPT 6 DAl PLft(T fC.490 P.1/2
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UNOCAL
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Agriculturtil Products--Kenai Plant
Safety & Environmental Department
P.O. Box 575
MI. 21.5 Spur Hwy.
Kanal, Alaska 99611
Phone: (907) 776 8121
Fax: (907)776 3213
TO: Irn en d er A 4- A
COMPANY: O u rire I2 oculsbry bm m.'s a ion
FAX NUMBER: [6 /o ) - 975 - 03 P/
CC: L. -..
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PAGES:
(including coverpg.)
FROM: ,4 l tH T -(t' .
DATE: l?-li t147 TIME: ll:57 4_
Comments:
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Transmmal Problems?T Pieese repoi them to taa Eny:ronmental Se.retary at (907) Tl6 3155.
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UNOCAL@
October 31,1997
SAF-299-97
Radiation Safety Officer File
lleth A. Prange
Region IV, WCFO
U. S. Nuclear Regulatory Commission
1450 Maria Lane
Walnut Creek, CA 94596-5368
Subject: License Revision
Dear Ms. Frange:
This is to request a revision of the materials license for Unocal's Kenai Plant facility in Kenai,
Alaska. The request for revision includes:
1. Removal of L. O. Woods from the liense, who has retired from Unocal.
2. Addition of Cynthia L. Rogers to the license as authorized to use or supervise use of
licensed material. Ms. Rogers is the Industrial liygienist at the facility, holds a Masters
Degree in Industrial llygiene, and has received a three day Radiation Safety Officer
training class by Ohmart Training Manager George W.13rown. The training was done on-
site so specific information about the sources at the facility could be included.
3. The license now requires six month leak test frequency. Unocal requests a change to a
three year leak test frequency, based on manufacturer's recommendation in attached letter.
6726T?
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' lieth A. Frange 2- October 31,1997
US Nuclear Reg. Commission liNV-299 97
4. Change of required six month shutter test interval, based on manufacturer's
recommendation, llecause of safety concerns with bypassing the sensor or bringing the
plant down and restarting Ohmart recommends performing shutter checks during non-
scheduled plant shutdowns, which typically occur once a year, with a thorough visual
inspection performed if a shutdown does not occur in a year. Scheduled plant shutdowns
occur every three to four years, and a shutter check will be performed at lea.ct at that
frequency.
Also please be advised that two gauges were recently shipped back to Ohmart, as they were no
longer needed. Copies of the leak tests taken before shipment are attached, as well as gauge
information.
Sincerely,
[U
Alan R. Thye
Safety Supervisor
linclosures:
Ohmart Corporation recommendation for shutter test frequency
Ohmart Corporation recommendation for leak test frequency
Ohmart Corporation training provided for Cynthia Rogers
Gauge Leak Test October 18,1997
Gauge Description prior and after October 19, 1997.
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! Ohmart Corporation (800) FOR LEVIL tositru
i 4241 Allendorf Drive (513) 272.0131 teiephone
- Cincinnati Ohio 45209 9961 (513) 272. 0133 tax
" http://ohmartvega.com uRL i
USA
Infotohmartvega.com t.md ;
} 1 4 [ October 27,1997 .
,
j Unocal
*
P.O. Box 575 -
Kenal, Alaska 99611
i ] Attn: Alan Thye ! ( , ,
Mr. Thye:
'
This letter verifies that Ohmart source holders that use Cesium-137 or Cobalt-60 contained
in the model A 2102, A 2100, or A-5771 capsules have been approved for a leak test
i
frequency of three years by the NRC and or the State of Kentucky.
For source holders manufactured prior to 1992 the NRC registered the source capsule. The
- registration numbers are NR 522-S-178-S (A 2102), NR 522-S-204-S (A-2100), and
NR 522 S 206-S (A-5771). All Ohmart source holders used one of these three capsules, i
Source holders manufactured after 1991 are registered with the State of Kentucky. Those !
registries are numbered: ='
]
- KY S12 D -101-B 1) SH F1,(SH 1),SH-F2,(SH 2) ;
-102-S 2) (SHLG-1), SHLG-2, SHLC *
-103-S 3) SHLM-B-1,2,3 and SHLM s '3.
i
-104-S 4) SHLM-BR-1,2,3,4 and SHLM s-, _,2,3,4
,
- -105 S 5)SHRM BW,SHRM-B,(SHRM PA) j
l -106-S 6) MDTS
-107-S- 7) Moistart-5000 with SHN AND SHWA
1
-108-S 8) SHRD
-109 S 9)(SHD)
i
-110-B 10) SR-A, (SR-1 A)
- -111-B 11) SR-2, (SR-1) ,
j. Sincerely, 3
,
THE OHMART CORPORATION
f fe$1 H Qe
George W. Brown
Radiation Safety Officer
Training Manager
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4241 Allondorf Drivo
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Cincinnati, Ohio 45209
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E 5'3 272.o13,
Fax 513 272-0133
Field Smice Report No. AK92-120-2288
Unocal Chemical, Mile 21. Kenai AK 99611
September 17 to 191997
Arrived at plant 917 97 met with Alan Thye, Safety Supervisor, Steve hiills Safety
inspector and Cynthia Rogers Industrial liygienist. Purpose of the trip is to packag and
label two sources for shipment for return to Ohmart, inspect and repair a model SilLM B
that the rod is difGcult to open and close, to spend as much time as possible training
Cynthia and Steve and conduct an audit of UNOCAL radiation safety program. In order
to accomplish this I decided that I would train the individuals on each task demonstrate
the task then observe them as they performed the various operations.
The Drst task we did was the inspection of the SilLhi holder, Steve had discovered that
the lock nut on the packing was not loosened and that was probably why it had been
difHeult to operate, inspection of the holder showed it to be rusted and the label while
readable was in need of replacement. It was decide that the device would be removed so
it could be wire brushed, painted and the label replaced. The packing nut will also be
rechecked and replaced as necessary. During this time the following operations were
taught as described above. Proper meter use, Survey for stray Deld radiation and
occupancy evaluation, Wipe testing for contamination with gross contamination checks,
Shutter lock out and verincation of shutter closure. Also reviewed procedures for
removal and reinstallation of source holder. Label and replacement collar were ordered.
We next inspected the two model SilF 2 sources that are to be returned. Source were in a
locked warehouse and found in good condition with the shutters closed and locked. I
discussed shipping requirements and he need to have a skid constructed.
While waiting for the skid I started an intense training class with Cynthia following our
standard radiation safety manual which they had on site. Since Cynthia is a well trained
Industrial 11ygienist with training in and experience in NORh1 we could cover a lot of
ground in a short period of time. Topics covered at different times over the three days
were:
* Radiation Theory
. hicasuring and monitoring practices
e Safety Calculation and the ALARA principle including Time, Distance, &
Sinelding
e llealth effects and TEDE calculations
* Emergency procedures
e US NRC Regulations
. General procedure. Installation and removable of devices and handling of
devices
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,1 _l
, 4241 Allendorf Driva
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Cincinnati, Ohlo 45209
,
E , $13 272 0131
Fax 513 272 0133
Field Service Report No. AK92-120-2288
Unocal Chemical, Mile 21, Kenai AK 99611
, On Thursday afternoon the parts arrived and Alan Thye Steve Mills, Cynthia Rogers and
I reviewed the repair of the SilLM source holder this included painting and replacement
of the packing gland and label. A general discussion of the different types of source )
holder and the installation requirements of some of the different styles specifically the !
model SliF series
I conducted a review of the radiation safety program that is required by
10 CFR 201101(c). In general I found the program to be complete and comprehensive.
Some of the references to the Code of Federal Regulations need to be updated and some
wording needed to be changed to agree with the current rules. A ma*ked up copy was left
with Alan Thye. In discuscion with Alan, Steve and Cynthia the subjects ofleak test and
shutter check frequencies was discussed. Currently leak test and shutter test are done
every six months. This creates some operational problems for Unocal. Unocal's license
allows for three year leak test of approved des ',es, the Ohmart sources that they have
been approved for three year wipe test. I will send Alan a letter confirming this. Their
license also allows for longer shutter test if approved by the manufacture and NRC.
Since operating the insertion type device causes plant upsets which are a serious health
and safety issue I will review the installations and types of devices and make
recommendations in a separate document. This will require approval by the NRC to
become effective,
in conclusion it is my opinion that Unocal's program is adequate, well managed and
meets the guide lines of the U.S. Nuclear Regulatory Commission.
The Ohmart Corporation
George Brown
h /d?
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Radiation Safety Officer
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4241 Allendorf Drive
5MM ,
Cincinnati, Ohlo 45209
513 272-0131
Fax 513 272-0133
September 19,1997
To:Unocal Chemical
Kenai, Alaska
Attn: Alan Thye
Re: Shutter Test
Dear Alan:
During my visit to your plant you asked what was Ohmart's re:ommendation for the frequency of
shutter test. Item 14 of your license specifies that this test be performed "...at no longer than 6-
month intervals or at such longer intervals as specified by the manufacturer and approved by the
U.S. Nuclear Regulatory Commission." I have reviewed the types of devices and the installation
and environment of these devices in your plant. Your concerns are that doing these test requires a
shutdmvn of the process which is very costly or bypassing the signal from the measuring sensor
which is a health and safety concern.
My investigation shows that you have seven devices in your facility that were all manufactured by
Ohmart. Four of these are Model ES 2, these density gauges do not have shutters and therefore are
not a problem. The rest of the devices are of the S11LM design all of these have the source on the
end of a rod or cable that is inserted into the vessel. This design protects the operating mechanism
because it is not open to the atmosphere. So:ne of these have been in your plant for twenty years
with no failures. This is consistent with our experience with this style of device. Because of the
design of the holders and my review of the installation and environment I would have no objection
to the following on-off mechanism test procedures.
Source holders will be checked for proper operations of the On/Off mechanism during periodic
non-scheduled shutdowns. These generally occur at least once a year. If no shutdown has
occurred a visual examination to the exposed parts of the operation rod or cable will be
performed to look for corrosion bent rods or kinked cables this inspection will occur at least
annually. Shutters will be checked during every plant scheduled turnaround.
The major concern of shutter operability is to insure that no one can enter a vessel with the source in
the vessel or on position. Since this can only occur during shutdowns or turnarounds these modified
procedures will not have any increase risk for exposure.
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l 4241 Allendorf Drive
- Cincinnati, Ohio 45209
- E 513 272 0131
Fax 513 272 0133
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i If you choose to modify your shutter check procedure you must submit this recommendation along l with Unocal's request for an amenOnent to get the U.S. NRC's approval prior to implementing this j change. i l If you or the NRC have any questions please contact me at 1800 543 8668. !
- Sincerely,
The Ohmart Corporation
l
&Afh
George W. Brown
a o,.9
c /{ '
Radiation Safety Manager
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b'o Plant Equipment Type of Source S. O. Source isotope S/N mci Ship
Description Gauge Equip. Holder Date
Souct is Number
; located in
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1 . Ilydrolizer Level 2LX- 6029022 SilLM CS-137 2636 25 3/77 l
l 5 tripper 302A l
G Overhead ' Y l Condenser
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p 2 !5 I IIP Stripper Level 5LX-701 49085-2 tiu-00 CS-137 2442 10 12/75 l 3,4' 5 Reactor Level 5LX-700 D732003 SHLM- CS-137 3012 2X 3/87 {- 053 C2 & 2000
3356
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5 5 A Density 5 DX- 49133-1 ES-2 CS-137 64960 1500 4/76
Granulator 981A I
6 5 B Density 5DX- 49133-2 ES-2 CS-137 64961 1500 4/76
Granulator 981B
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7 5 C Density 5DX- 49133-3 ES-2 CS-137 64962 O F ,/76
Granulator 981-C i
'8 5 D Density SDX- 49133-4 ES-2 CS-137 64965 1500 4/76
Granulator 981-D I
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y Gauges present in the Kenai Plant, September 21,1997,
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No. I l'lant Equipinent Type of
j l Description Source Gauge isSource
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Equip.
S. O. Source Isotope S/N Ship
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Iloider l uCi
Number : Date
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Ilydroliver-Stripper Level
2LX-302A l 6029022 ' SilLM CS-137
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Overhead Condenser '
2636 25 3/77
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2 2 1st Absorbe.- Level 2LX-212B
2nd Deck AK920200633 Sil F2-45 CS-137
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68586 600 7/92
3 2 1st Absorber Density 2DX-212
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llottorns Purnps AK920200633 Sli F2-0 CS-137 73143 3 75 7/92
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l Level SLX-70) '49085-2
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5 Reicto- Level ' EL3-00 ~ l CS-137 '2442 ' 10 12/75
SLX-700 D732003053 g h A
SIILM-C2 ' CS-137 3012T.
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~1 5 "A" Gianufator Density SUX-98 t A 49133-1 ' ES-2
3356
2X
2000
3/87
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CS-137 64960 1500 4n6 h ih
a 5 "H" Granulator q
Density SDX-981B 49133-2 G A
.- E5-2
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9 5 C" oranulator Densit y
CS-137 64961 1500 4n6 g W hph
5DX-981C 49:33-3 ES-2 xt &
, CS-137 64962 l'c0 4/76
io 5 D oranuiaior Density
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5Dx-98 D 49:33-4
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ES-2 CS-i37 64965 iS00 - 4/76 h9
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The Ohmart porporation
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42j1 Allendorf Drive e Cincinnati, Ohio 45209 * i
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Phone (513) 272 0131 e FAX: (513) 272-C.D g gy ,
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/d/USC#/ -MNAN Th')E Nuclear Services
/7)de f./ ia: No. Dai. 2-
SptM N WY *
/0 /V4I b U 7 6 // Customer P.O. No.
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Leak Test Kit
Caution: This kit is to Oe used only for the source holder desenbod below. The information below appears on the metallic label on the actual
OHMART source holder. Supply smiar information if holder not OHMART. j
Shop or Customer Order No. (S O/C O ) Isotope Sonal No, mCA Source Ho6 der
AK99 - @e#61? W/s7 64186 600 SHP,t
Date Ship ied User identification Other
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Date of Test Tested By (Tester's Sqnature)
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l&7M $<96fVr
This kit is to be used only by those whose lice em to perform leak tests. (P 0 Part 20)
OHMART ANALYSIS
The following are analy$s result
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Source is O K (Actwity less than 0 905pCi)
-] Rew'pe Required
] Defectwo
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W Wid I /o-W-P7l
Tested ByrAuthortzed Signature Date
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The Ohmart Corporation-
4241 Allendorf Drive e Cincinnati, Ohio 4S209
Phone l$13)2724131 FAX:(513)272 0133
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G d a ,4 / j%gfj/g Nuc! car Services
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AK qq ,
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Leak Test Kit
Caution: Thas kit is to be used only for tha source holder desenbeu below. The information below appears on the metallic label on the actual
OHMART source holder. Supply simi!ar information if holder not OHM ART.
Shop or Customer Order No. (S OJCA) Isotope SenalNo. mCA Source Holder
AK12- Opo ~ oG31 &t37 O/93 .T 7S~ fHF2
Dste Shipped User identificatio.1 Other
Date of Test Tested By (Tester's S>gnature)
jlf " Y s2 l'
This lut is to be used only by those whose hcense permit them to cerform leak tests (Per CFR 10 Part 20)
OMMART ANALYSIS
The tcilowng are a- , sis res '
Sc.urcs is O K (Actw:ty less than 0.005pCi) Rew'pe Required Detectwo
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