NukeWorker Forum
Career Path => Radiation Safety => Topic started by: Carolina Jethro on Jul 22, 2013, 09:27
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Are sealed sources required to be inventoried on a periodic basis if they are stored in the RCA?
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http://www.nrc.gov/reading-rm/doc-collections/cfr/part035/part035-0067.html
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I had already seen that but that covers the medical field and I was looking for something for nuclear power plants. Thanks!
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Have you searched your license/FSAR
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Required vs best practice. I'd choose best practice.
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We do it as a best practice and I am not trying to get out of it just wanting to see if our procedure is correct in saying sealed exempt and non exempt sources inside the RCA do not have to be inventoried. Thanks for the help!
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We do it as a best practice and I am not trying to get out of it just wanting to see if our procedure is correct in saying sealed exempt and non exempt sources inside the RCA do not have to be inventoried. Thanks for the help!
If you don't inventory them.... how do you know they are there??
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We do it as a best practice and I am not trying to get out of it just wanting to see if our procedure is correct in saying sealed exempt and non exempt sources inside the RCA do not have to be inventoried. Thanks for the help!
It's been a long time, but I remember inventory and leak tests of all of our sources over exempt quantities sealed, plated, and gaseous.
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verbatim compliance with license conditions
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Short answer is yes.
If your facility has standardized Tech specs then the requirements for leak test and inventory should have been moved to your SLC's (selected licensee commitments manual).
I have never heard of an exemption for source's within the RCA but depends on what your SLC's say. There is a standard (somewhat) exemption for < 100 uci beta gamma emitters or < 10 uci alpha emitters.
sf
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Under what regulatory authority do you possess and use the sources? I would start there.
If the regulations are silent on the issue the NRC may have added License Conditions to your license requiring a periodic inventory (and maybe even a leak test).
NUREG 1556 Volume 20 Appendix E has a list of standardized verbage that may be used by NRC licensing personnel to add license conditions to a materials license.
For example:
For Inventories: "The licensee shall conduct a physical inventory every 6 months, or at other intervals
approved by the U.S. Nuclear Regulatory Commission, to account for all sources and/or devices received and possessed under the license. Records of inventories shall be maintained for 5 years from the date of each inventory and shall include the radionuclides, quantities, manufacturer's name and model numbers, and the date of the inventory."
The exception for Leak Tests: "Sealed sources need not be tested if they contain only hydrogen-3; or they contain only a
radioactive gas; or the half-life of the isotope is 30 days or less; or they contain not more than 100 microcuries of beta- and/or gamma-emitting material or not more than 10 microcuries of alpha-emitting material."
It is possible that the licensee may have committed to a periodic inventory in its License Application and the NRC found that acceptable and it is included as a tie down thereby making it a requirement.
Again, it comes down to the question, "What's in your license (and tech specs and application and other tie downs)?"
I thought of another relevant standard license condition (it applies regardless of area classification, i.e., restricted, controlled, or unrestricted):
"Sealed sources need not be tested if they are in storage and are not being used; however,
when they are removed from storage for use or transferred to another person and have not been tested within the required leak test interval, they shall be tested before use or transfer. No sealed source shall be stored for a period of more than 10 years without being tested for leakage and/or contamination."
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Are you licensed under 10 CFR 20 or 10 CFR 835, or some other CFR? What kind of facility are you dealing with? A plant has tech specs to consider. Some places have a technical basis for their controlling document. There is no one right answer because we are controlled by different requirements depending on where we are working.
So tell us what sources worry you and what kind of facility you work in and what your controlling documents are. But I'll be by the time you've answered those questions you will have an answer to the original question you've posed.