a ~ Recto From jg/og Ce. K Faveeece SECTION 3 - SAFETY AND REGULATORY REQUIREMENTS R.Gaovrn ue TS. Cond U.S. Nuclear Regulatory Commission (NRC) of an Agreement Stale, Aa “Agreement State” is one which has ‘entered into an agreement with the NRC, in which regulatory auth ‘over the sion and use of certain radioactive materials within the tic boundaries of the state bas ferred to the respective State. ‘These agreements provide for ahi ‘of compatibility between the regulatory programs ofthe state and the NRC. Because of the similarities between these programs, statements made about one are generally rue ‘fall domestic regulatory programs. Regulatory requirements will be detailed in Paragraph 34 and following. possession. ‘The following paragraphs discuss the inherent safety features of Texas Nuclear Gauges, the magnitude of the radiation hazard, and the regulatory responsibility of the user. 32. SAFETY OF THE TEXAS NUCLEAR GAUGE ‘As with any device containing radioactive materials, there are two geocral areas of concern: 1) to insure that ‘under all conditions of use and generally all accideat conditions the radioactive material remains contained in the source housing. ‘This is primary function of the manufacturer and is accomplished by the engineering design dnd construction ef both the source and source housing. Both source and source housing are extremely rugged : in design, and can withstand severe shock, vibration, and elevated temperatures with little probability of release of radioactive materials. 2) The second area of concern is the prevention of unnecessary radiation exposure. siti time the device is not installed is tr ‘configuration, and b) insuring that the shutter Pete a ete des a inne poe opr al cane through the sbielding of the gauging device and through a shutter in the off position is not sufficient to be ‘generally considered a hazard. ‘The radioactive material used in these gauges emits very penetrating radiation. This characteristic requires the source shield to be relatively massive and allows the source encapsulation to be very rugged. The radioactive material is first bound in a ceramic ‘matrix and encapsulated in a stainless steel cylinder that is welded closed good, this capsule is placed inside another cylinder of stainless steel that is also welded closed, This “double encapsulation’ assures thatthe source material will remain contained even under extreme conditions of use, Sources used in the Texas Nuclear line have been subjected to and pasted tests demonstrating conformance with ANSI standards and the U. S. Department of Transportation ‘specifications for "Special Form* materials, ‘The source is positively retained in the source head and remain conlained under severe environmental conditions. “The radiation hazard of the gauge is minimized by its construction, The source housing is a rugged steel right circular cylinder filled with lead and designed to ‘radiation outside the housing to a relatively low level, The source is contained within ‘Significant amousts of radiation can only be emitted thrugh he ports in defined desons. Wasa the actuator moved 1 8 OP ition, beams of radiation are emitted which ean be a hazard, Personnel must be prevented from access to the beam area with the actuator (ON. This is primarily accomplished by: Insuring that the actuator is closed and locked in the closed positioa anytime the source housing is not in its proper operating position against or between the bins or vessels being mositored. . Insuring that the actuator is closed and locked in the closed position anytime work is to be done inside the bopper being monitored, or anytime work is being done in any area within the beam geometry between the source and detector. « jing that access to the beam area is ted during normal operating conditions, if such acezss & possible. s un‘The radiation outside of the gaugs beam geometry is not high enough to be considered a hazard, Beds the source bead ll oer elements ofthe inallation mut be consered in atscaing the ttl sty ‘These elements may include the method of gauge mounting, cteistics of the process Suede ke at vibration maintenance techniques, etc. In 33 ADDITIONAL SAFETY NOTES 2. In the event of an accident, fre or explosion that may have damaged the source encapsulation or shuter mechanism, soll the regulatory auoriies Usted in your Hcease and Teas Nuclear. Personnel should be kept away from the gauge until it bas determined by appropriate ‘measurements that the area is safe. b. If the source housing containing radioactive material is lost or stolen, notify the regulatory authorities listed in your license. a Under no circumstances should you remove the source holder from the source housing, nor allow anyone else todo so without first contacting Texas Nuclear or the appropriate regulatory authorities. 4." Should the use of the gauge be discontinued, contact Texas Nuclear. Disposal of radioactive material must be handled by someone specifically liceased to do so. €. Radiological Emergency assistance may always be obtained from the NRC offices or the appropriate Agreement State agency listed at the end of this section. 34 REGULATORY RESPONSIBILITY ‘The regulatory approach to the control of radioactive materials isto disallow all possession and use except as party albbtaed by Lesnar Individuals may possess and use devices containing radioactive material UGhrough either a *Specific’ or a “General” license. Devices distributed to generally icensed individuals bave regulatory requirements that are detailed on a label provided on the device and in supplementary information such as that furnished in the Appendix of this manual. Distribution under a specific license implies thatthe individual bas corresponded with a regulatory agency and ihe une of ¢ document wiih wil cousin pectic tokeranious. Tow tide wil bare detailed in his application the conditions under which he will use these devices. Devices, therefore, possessed ‘under the provisions of a specific License must be utilized in a manner within the limitations specified by that license, Unless specifically authorized, the user may not perform functions like installation startup of relocation, or service to the source head. ‘The major distinction between these two methods of distribution is that the specific license may be changed or amended according to the needs and capabilites ofthe licensee, whereas, the general icense cannot be expanded x amended without a regulatory change. ‘A more detailed discussion of the two types of license is included in following sections. No license is to possess, install, and service those portions of the system which do not contain radioactive Ge, electronic units, detectors, etc). 34.1 Specific Licenses This document will state what the user may do with the devices and all other actions involving the radioactive portion of these devices is probibited. It will name specific individuals as responsible users and a Radiation Protection Officer who may or may not be one of these users. The Radiation Protection Officer is responsible for maintaining all the records associated with the device and assuring that no unauthorized activity is performed. The following items comment briefly on areas which often preseat problems: a‘The user must maintain a file containing his license, license application, installation surveys, leak test results, a copy of the regulations, copies of any inspection reports, and records of any transfer or disposal of devices. ‘The user may uncrate the source housing for inspection and may mount the device inits designated location, or store the system in an area that provides normal security from unauthorized access. 4, The user may not remove shutter-inibiting shipping bolts and/or locks unless the user's license authorizes radiation commissioning (installation) in addition to possession. The user would have to have procedures and radiation survey instrumentation to be authorized to perform radiological installation. iv, For all Texas Nuclear gauges, leak testing is required once every three years. The license will state that leak testing will be done by the licensee according to a submitted procedure. If one does not have his own instrumentation, then leak testing is usually done utilizing Texas Nuclear ‘mailable kits of by someone else specifically licensed to perform this service. ¥. To move the source housing once it has been commissioned requires a specific license condition authorizing final installation by the licensee. Approved installation procedures must be followed. Relocation and/or removal is interpreted as an installation. vi The user must not tamper with or attempt to modify the source head. Service and repair of the source head must be performed by someone specifically licensed. This also includes any actions which may violate the integrity of the source containing unit or the installation. 3.42 General License Certain devices may be distributed for particular uses under the auspices of what is called a “general license’. ‘Although one docs not apply to a regulatory agency nor is any documentation received other than from the ‘manufacturer, a general license isa lcease ia the strictest sense of the word. Appendix 1, which Texas Nuclear ‘asa manufacturer is required to furnish all general licensees, details exactly the regulatory requirements of this type of distribution. The general license is given in the frst paragraph of the Appendix and labeled 41.22(4)(1), ‘All following paragraphs of the Appendix pertain to the issuance ofthat license and the regulatory responsibility of the user. For convenience, the tag referred to in these regulations is reproduced below. REMOVAL OF THIS LABEL IS PROHIBITED 1. ‘The receipt possession, use and transfer ofthis Gevce are rubject 10 3 general cease and the fepuations ‘of the U.S Nuclear Repulaiony (Commission (USNRO) or the repulations of State with which the USNRC has entered into an Tppecment forthe exerse of regulatory authority, P abandonment of disposals prokbites. Transfers inom be in accordance with USNRC oF Sule Fepuations, "Continued operation is prohibited i there i any indication of fare of the source containment oF ‘hilding and Texas Nuclear should be noted. ‘Only. persons pecially authorized by the ‘Us RC or kn Agreement Sate may repair the source ‘containment portion ofthis vie, So This device stall be tested for leakage of Tadioatve material atiterals not the exceed three year and records of tbe resulls mainained of. BP Xéditonal information athe repslatory ‘quirements and safe use of this device are contained in the opening manual and repulsory Information arsished by Texas Nuceat 33