Bioenvironmental Engineering Memorandum Association Assignment
Order ID 53563633773 Type Essay Writer Level Masters Style APA Sources/References 4 Perfect Number of Pages to Order 5-10 Pages Description/Paper Instructions
5 May 2021
MEMORANDUM FOR XXXXXFROM: 30 OMRS/SGXB
SUBJECT: Declaration of Licensing Exemption – X Ray Fluorescence (XRF) Machine Rigaku Supermini200, Aerospace Fuels Lab, Bldg.#6670
References: (a) AFMAN 48-148, 20 July 2020, Ionizing Radiation Protection
(b) 10 Code of Federal Regulation (CFR) Part 20, 2021, Standards for Protection Against
Radiation
(c) Rigaku, 2021, X-ray Fluorescence Spectrometer Supermini200
Instruction Manual
(d) 21 CFR 1020.40, 19 September 2007, Center of Disease for Radiological Health (CDRC),
Compliance Guide for Cabinet X-Ray Systems
(e) Rigaku, 2021, Radiation Safety Training
1. Summary: Bioenvironmental Engineering (BE) received a request from the Aerospace Fuels Lab to assess the radiation safety and compliance for their Rigaku Supermini200 X ray fluorescence machine. As per reference (c), x-ray fluorescence spectrometer Supermini200 is a system to analyze the types and quantities of elements in a sample. A high voltage (50kV) is applied to the X-ray tube and primary X-rays are generated from the target causing scatter radiation. The primary X-rays irradiate a sample and fluorescent X-rays specific to each element are generated from the sample. A spectroscopic analysis is made using a goniometer to measure the intensity of each spectrum.
2. Assessment: The unit is sealed and contains no radioactive materials (RAM), reference (c). Furthermore, reference (d) confirms the radiation performance standard for the cabinet X-ray systems.
a. The XRF system as per reference (e) produces a beam in the X-ray tube housing which is sealed. The X-ray beam then travels through the shutter, optics, secondary collimators, primary collimaters, the sample, and the detector. The x-ray beam is all sealed through their traveling paths. The x-ray apparatus is completely enclosed and interlocked x-ray diffractometer and spectrometer. If a panel is opened while the x-ray unit is being used, the interlock will either shutoff the x-ray or close the shutter, preventing accidental exposure to personnel. The x-ray apparatus has lead collimators to provide shielding against radiation.
b. In addition to the performance standard reference (b) in reference (d), manufacturers of cabinet x-ray systems sold in the U.S. must comply with 21 CFR Parts 1000, 1002, 1003, 1004, 1005, and 1010. Rigaku manufacturers are required to certify in accordance with (IAW) 21 CFR 1010.2 that their products sold in the U.S. comply with the radiation safety performance standard for cabinet x-ray systems as indicated by reference (d). The emission limit as per reference (d),(c)(1)(i), radiation emitted from the cabinet x-ray system shall not exceed an exposure of 0.5 milliRoentgen or 0.4385 millirem in one hour at any point five centimeters outside the external surface.
c. A BE 2016 scatter survey on the Rigaku Supermini200 X ray machine shows that exposure is minimal and well below the annual dose limits for both the public and radiation workers in reference (b) and reference (d).3. Conclusions/Recommendations: The Rigaku, Supermini200 for Declaration of Licensing is exempt under reference (b).
a. The Rigaku, Supermini200 is not required to be a radioactive material (RAM) permit licensed device since there is no RAM in the device. On 3 May 2021, BE confirmed this information with Rigaku Corporation.
b. BE radiation survey performed in 2016 was useful in making measurements to identify the location of the largest amount of radiation emission on a cabinet x-ray systems external surface and were below reference (a), (b), and (d) dose limits. BE plans to re-accomplish this survey to update our data and review of the device.
c. This correspondence serves to inform Aerospace Fuels Laboratory that Rigaku, Supermini200, serial #BE65000145-01 under reference (b) is exempt as a RAM source as per U.S. Nuclear Regulatory Commission License requirements.
4. If there are any questions or concerns, please feel free to contact name xxxxxx at commercial#: xxxxxx or myself at commercial#: xxxxxxxxx, or by email at xxxxxxxx.NAME, CHIEF
TitleAttachment:
2016 Supermini Scatter Survey
RUBRIC
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