Technical Assistance Request Regarding Issues in Several U.S. Air Force Submittals Dated February 15, 1990, March 26, 1990, and October 23, 1990
HPPOS-283 PDR-9306160232
Title: Technical Assistance Request Regarding Issues in
Several U.S. Air Force Submittals Dated February 15, 1990,
March 26, 1990, and October 23, 1990
See the memorandum from J. E. Glenn to L. J. Callan dated
January 4, 1993. This memo responds to a technical
assistance request from Region IV, dated October 2, 1992
(Enclosure 1), regarding issues in several U.S. Air Force
submittals dated February 15, 1990, March 26, 1990, and
October 23, 1990 (Attachments to Enclosure 1).
The following are the issues summarized in the TAR by
Region and the NMSS comments on these issues:
1. USAF letter dated February 15, 1990, requests an
exemption from 10 CFR Part 71 requirements when using the
Department of Transportation (DOT) exemptions, Department
of Defense (DOD) Exemption DOT-E 2136, March 31, 1988, and
DOD Exemption DOT-E7573, July 7, 1988, issued to DOD
(Attachments to Enclosure 1).
One example cited by the USAF is the transportation of
munitions containing explosives and licensed depleted
uranium components by rail or in troop-carrying aircraft
under sensitive circumstances involving national security
or national defense. 10 CFR 71.7 states that on
application of any interested person or on its own
initiative, the Commission may grant any exemption from the
requirements of the regulations in this part that it
determines is authorized by law and will not endanger life
or property or the common defense or security.
An exemption to 10 CFR 71 is appropriate based on the
exemptions granted by DOT. However, it appears from a
review of these exemptions that they have both expired and
are no longer valid. Therefore, the region may only grant
the exemptions from 10 CFR Part 71 contingent upon the DOT
exemptions being current.
2. USAF letter dated March 26, 1990, requests exemption
from leak testing carbon-14 (C-14) reference light sources
used in hermetically sealed Astroinertial Navigational
(AIN) units installed on aircraft.
This exemption appeared to be justified because (1) of the
small size of the sources and the radionuclide involved and
(2) the sources are hermetically sealed units that USAF
dose not repair to maintain. The sources range to a
maximum activity of 500 microcurie (500 micro-Ci), which is
only five times the value specified for exempt C-14 in 10
CFR 30.71, Schedule B.
The request was referred by NMSS to the Source Containment
and Devices Branch in a memorandum, dated November 13, 1992
(Enclosure 2), and based on their response (Enclosure 3),
the revision to the leak test condition may be granted to
the USAF.
3. USAF letter dated October 23, 1990, requests approval
for alternate disposal under 10 CFR 20.302 [or, at present,
10 CFR 20.2002] to release 2.6 millicuries (mCi) of
krypton-85 (Kr-85) to unrestricted areas by slowly venting
the gas into a fume hood which exhausts directly to the
effluent.
Alternative disposal was requested because burial sites
will not accept Kr-85 at pressures above 22.044 pounds per
square inch. The proposed alternate disposal is by venting
the gas to unrestricted areas as discussed above. USAF's
calculations show that annual limits of 10 CFR 20.106 [or,
at present, 10 CFR 20.1302] for Kr-85 will not be exceeded
by the venting request. Additionally, Wright-Patterson AFB
(Ohio) has received concurrence from the Ohio Radiological
Health Program and the Regional Air Pollution Agency for
the action contingent upon NRC approval and compliance with
National Emission Standards.
The requested method of disposal and consideration appears
to be similar to the method discussed in the memorandum to
W. Fisher, Region IV, dated January 30, 1992 (Enclosure 4),
regarding an earlier Air Force request to dispose of the
Kr-85 sources. This method should be approved provided
that the limits of 10 CFR 20.106 (a) [or 10 CFR 20.1302
(b)] are not exceeded and actual exposures are maintained
ALARA.
Regulatory references: 10 CFR 20.302, 10 CFR 20.2002, 10
CFR 30, 10 CFR 71
Subject codes: 7.8, 9.0, 9.1, 11.1, 12.17
Applicability: Byproduct and Special Nuclear Material