Publication Date: 1/1/75
    Pages: 7
    Date Entered: 2/23/84
    Title: DESIGN CONSIDERATIONS FOR MINIMIZING RESIDUAL HOLDUP OF SPECIAL NUCLEAR MATERIAL IN EQUIPMENT FOR DRY PROCESS OPERATIONS
    January 1975
    U.S. ATOMIC ENERGY COMMISSION
    REGULATORY GUIDE
    DIRECTORATE OF REGULATORY STANDARDS
    REGULATORY GUIDE 5.42
    DESIGN CONSIDERATIONS FOR MINIMIZING
    RESIDUAL HOLDUP OF SPECIAL NUCLEAR MATERIAL
    IN EQUIPMENT FOR DRY PROCESS OPERATIONS
A. INTRODUCTION
    Paragraph (b) of Section 70.22, "Contents of Applications," of 10
    CFR Part 70, "Special Nuclear Material," requires, among other things,
    that each application for a license to possess at any one time more than
    one effective kilogram of special nuclear material (SNM) contain a full
    description of the applicant's program for control of and accounting for
    SNM that will be in his possession under license, including procedures
    for controlling SNM during its processing or use in the facility and
    procedures by which process losses are determined. Section 70.51,
    "Material Balance, Inventory, and Records Requirements," indicates that
    certain licensees must conduct their nuclear material physical
    inventories in compliance with specific requirements.
    The control of and accounting for SNM can be made more effective
    by reducing residual holdup in process equipment following draindown and
    cleanout. Such a reduction would lessen the severity of the problems
    associated with determining the residual holdup component of a physical
    inventory and would reduce the uncertainty component contributed by
    residual holdup.
    The purpose of this guide is to call the attention of individuals
    who participate in equipment design and layout and in measurement
    control to the utility and significance of reducing residual holdup.
    This guide, therefore, is intended for plant managers, designers,
    operators, material control personnel, and others at the decision-making
    level who include safeguards as an integral part of their professional
    activities.
    This guide describes design features acceptable to the Regulatory
    staff for minimizing the residual holdup of SNM after draindown or
    cleanout of equipment used in dry process operations.(1) The design
    features noted will facilitate physical inventory measurements and
    reduce material balance uncertainties. They are not expected to
    interfere excessively with process operations. In particular, this
    guide is applicable to (1) gas handling, (2) glovebox operations, (3)
    calcining, (4) dry solids transfer, (5) dry blending and classification,
    (6) packed bed conversions, and (7) comminution.
B. DISCUSSION
1. Background
    Past experience and current observation of process operations used
    in various systems indicate that the publication of general guidelines
    for equipment design could assist in achieving the degree of material
    control and accounting needed for satisfactory protection of SNM.
    Sizable amounts of SNM accumulate as deposits during material processing
    or draindown. For certain process steps, modes of operation, and types
    of material, the quantity of the accumulated deposit may reach a steady
    state that fluctuates around some characteristic amount. In other
    instances, a deposit may continue to accumulate as the process continues
    to operate and may not become apparent until draindown or cleanout. In
    either case, the quantity of SNM in residual holdup following draindown
    often is difficult to determine with sufficient precision and accuracy
    to meet material unaccounted for (MUF) and limits of error of MUF
    (LEMUF) requirements. Appropriate design could increase the
    effectiveness of draindown and assist in reducing residual holdup and
    the consequent need for determining the retained SNM. Good design also
    should improve the capability for any needed cleanout following
    draindown.
    ----------
    (1) Regulatory Guide 5.8 addresses drying and fluidized-bed
    operations for purposes of minimizing residual holdup of SNM. Regulatory
    Guide 5.25 addresses residual holdup problems unique to equipment used
    for wet process operations.
    ----------
    Minimizing the quantity of material retained in equipment after
    draindown generally enhances the effectiveness of a material protection
    program in the following ways:
    a. Quality of Physical Inventories
    Reducing the quantity of residual holdup that is not
    amenable to measurement improves the quality of a physical inventory.(2)
    The extent to which the measurement of the residual holdup contributes
    to the quality of a physical inventory depends on the amount of holdup
    and the uncertainty of the measurement method.
    b. Susceptibility and Accessibility of SNM
    If the quantity of residual holdup remaining after draindown
    and/or cleanout of equipment is reduced, less SNM is accessible and
    susceptible to theft or diversion during the sampling, identification,
    and evaluation necessary to complete a physical inventory. Lessening
    the effort necessary to remove and/or evaluate residual holdup reduces
    the amount of time SNM is accessible, the number of people who need
    access to it, and the opportunity for unauthorized individuals to gain
    access to SNM during a physical inventory.
2. Unit Operations
    This guide deals with the reduction of residual SNM holdup during
    a physical inventory in seven process operations common to dry chemical
    processing. These operations are described in the following paragraphs.
    a. Gas Handling
    Gas-handling operations considered here include handling of (1)
    process gases and (2) carrier gases that may contain suspended SNM
    particles. The transfer of UF(6) from shipping containers to process
    vessels is the most common example of the handling of gaseous SNM in a
    fuel conversion facility. Offgases from activities such as drying,
    calcination, pneumatic solids transfer, and fluidized-bed reactions
    contain SNM in particulate form; the use of filters, cyclones, and
    scrubbers to remove these particulates from the gas streams should be
    considered.
    ----------
    (2) Regulatory Guide 5.13 addresses the subject of conducting
    physical inventories of nuclear material.
    ----------
    b. Glovebox Operations
    Gloveboxes are used principally for handling materials
    containing uranium-233 or plutonium.
    c. Calcining
    Calcining is applied to dried solids that have been produced
    in a precipitation step. For example, plutonium oxalate is calcined to
    plutonium oxide. The oxide product from the calciner may be subjected
    to comminution and/or blending before it becomes feed for the
    fabrication of fuel. Some equipment can be used to perform both drying
    and calcining simultaneously. Certain types of scrap or waste may be
    calcined as part of the recyling or recovery of its contained SNM.
    d. Dry Solids Transfer
    Dry solids are transferred in a number of fuel conversion or
    fabrication steps. For example, dry ammonium diuranate (ADU) powder
    formed during the drying of the filter cake from an ADU precipitation
    process is transferred to a calcining furnace for conversion to uranium
    dioxide. Similarly, dried mixed plutonium-uranium oxides formed by
    coprecipitation are transferred to the next process step. SNM oxide
    powders are transferred to blenders and to fuel pelletizing equipment.
    e. Dry Blending and Particle Classification
    Blending and classifying are commonly utilized in various
    chemical conversion and fuel fabrication processes. Examples include
    the ammonium diuranate or fluid-bed processes for uranium conversion;
    the conversion of mixed uranium-plutonium nitrates to mixed
    uranium-plutonium oxides; and the fabrication of spherical particles by
    spheroidizing and particle coating.
    Dry particulate materials may be blended to produce a
    uniform mixture of two or more materials having different chemical
    compositions, particle sizes, shapes, surface areas, or other
    properties.
    Classification can be used to produce a controlled particle
    size distribution or shape for materials to be blended or for materials
    that have been blended just prior to fabrication.
    Blending and classifying may be performed as separate or
    combined operations.
    f. Packed Bed Chemical Conversions
    Packed bed conversions can be used for converting a solid
    uranium compound to a metal or to another solid compound by a controlled
    exothermic batch reduction process. For example, this type of operation
    is used for the reduction of uranium tetrafluoride to uranium metal with
    magnesium or calcium metal. Compounds of other metals may be added to
    effect a coreduction that yields an alloy product. Packed bed
    operations may also be used for the reaction of uranium dioxide with
    carbon or graphite to produce uranium carbides.
    g. Comminution
    Comminution is applied to dried or calcined oxides in order
    to obtain a powder suitable for fabrication into desired fuel shapes.
    It also may be applied to dried cake or to solid scrap (which is being
    prepared for recycling) from a fabrication process.
    The product of comminution is a fine, free-flowing powder
    with a fairly uniform particle size distribution. The comminution
    equipment is selected so as to control particle size and surface area of
    the powder and to obtain the desired pelletizing and sintering
    properties.
    Ball mills or rod mills may be used to combine blending with
    a comminution step.
3. Holdup in Gas Handling
    The holdup problems in equipment for handling gases fall into the
    following two general categories:
    a. Those problems related to the storage and transfer of UF(6),
    including the prevention of condensation of UF(6) in transfer lines by
    heating, the removal of as much gas as possible from the containers by
    heating and purging, and the accurate measurement of the residual "heel"
    in the container.
    b. Those problems related to SNM particulates entrained in
    gaseous waste streams, including the deposition and accumulation of
    particulates in ducts, filters, cyclones, and scrubbers.
4. Holdup in Gloveboxes
    Holdup problems in gloveboxes are related to the type of
    operations and to the degree of leak-tightness of the process equipment
    installed within the glovebox. Equipment that is totally and reliably
    enclosed and is essentially automatic in normal operation contributes
    negligible holdup to gloveboxes. Problems of holdup arise during
    maintenance or other nonroutine operating periods when process
    containments are breached.
    Some operations, such as those in which dry solids are loaded into
    and discharged from equipment units, may inherently permit the escape of
    SNM to the glovebox environment. Examples of this type of operation are
    comminution, blending, and agglomeration where quantities of fine powder
    can escape and accumulate on glovebox internal surfaces and all
    equipment surfaces.
5. Holdup in Calcining
    Holdup occurs in calcining when powder sticks to rough surfaces or
    is trapped in crevices. The powder may become entrained in gas streams
    and be deposited in ductwork and filters. Material can also be
    inadvertently spilled into inaccessible locations within the calciner
    during operation. The fact that the calcined powder usually has a high
    bulk density helps to reduce dusting in handling.
    Direct heating in calciners using a heated gas stream can cause
    dust particles to become entrained in the gas stream. Indirect heating
    and direct radiant heating, on the other hand, do not normally
    contribute to holdup.
    Cylindrical rotating-retort calciners are particularly desirable
    for high-throughput, low-holdup operation. These calciners, which may be
    operated continuously, have the advantages of minimum physical handling
    of product and great potential for automation. However, the presence of
    lifting bars or flight carriages in these calciners makes them more
    difficult to drain down or clean out for a physical inventory of SNM.
    A batch or semicontinuous operation with trays of material
    traveling through an indirectly heated muffle-type calciner has
    comparatively little holdup, unless the trays are accidentally tipped
    and the contents spilled into the calciner as a result of mechanical
    malfunction of the tray conveyer systems. This problem can be greatly
    reduced by the use of covered trays.
6. Holdup in Dry Solids Transfer
    Dry powders usually are moved from one process step to another by
    manual, mechanical, or pneumatic means. The manual method involves
    loading a container at the discharge point of equipment for one unit
    process and moving it by hand to the charging position of the equipment
    of the next unit process. This technique is generally employed when
    relatively small quantities of material are involved. When properly
    designed, the containers used to manually transfer dry solids can be
    cleanly emptied except for the small amount of material that clings to
    the inner surface. This residual material can easily be removed by
    brushing, vacuuming, or dissolution.
    Mechanical conveyors have broad application in the chemical
    industry, but are not generally used for transfer of material containing
    SNM. Screw and belt conveyors have been used in some operations for
    moving large quantities of ADU powders. Holdup problems with mechanical
    conveyors generally arise as a result of material adhering to the
    surfaces of screws, idlers, bearings, and belts. Because the screw
    cannot sweep the interior of the transfer tube completely, significant
    residual material may remain held up in a screw conveyor. In all
    mechanical conveyors, dusting can be a problem.
    Pneumatic conveyors constitute a relatively simple way to move
    large quantities of dry solids. In this operation, solid particles
    suspended in air are transferred by the bulk movement of the air.
    Holdup problems are fewer than with mechanical conveyors since the
    transfer lines can be kept smooth and free of obstructions. Even though
    dusting constitutes a problem with pneumatic conveyors, the quantity of
    material remaining after draindown is normally small and cleanout can be
    achieved by sending brushes through the lines or by flushing with
    cleaning solutions.
7. Holdup in Dry Blending and Classifying
    Several factors contribute to holdup in blending and classifying
    equipment. One problem arises when dry particulate material of
    irregular shape and size collects and becomes packed in lines and in
    internal recesses of equipment. This is most likely to occur if fine
    particles are present. Irregularly shaped particles may become trapped
    in screens. Spherical particles generally flow freely and drain readily
    from equipment. Ultrafine powder must be handled carefully to reduce
    dusting.
    Mechanical batch-type blenders with internal agitators contribute
    to significant material holdup since any material that collects around
    the mechanical agitator and drive mechanism is difficult to remove.
    Unless sealed covers are provided, material can be dispersed as airborne
    fines.
    Holdup problems are minimal in batch-type blenders with smooth
    internal surfaces, no internal moving parts and designs that permit
    charging and discharging by gravity. The simple V-cone blender with a
    full-diameter cover is an example of this type of blender; it is most
    difficult to prevent holdup in the gasket area. Dust accumulations on
    the surfaces of a V-cone blender can easily be removed with a brush or
    wipe.
    Pneumatic batch-type blenders are equipped with feed and
    recirculation piping that extends the surface area to which material can
    adhere. This piping system makes pneumatic blenders particularly
    difficult to clean. Although these blenders may be designed to discharge
    by gravity, a holdup problem can result if a line becomes plugged or
    packed with material that is not detected upon draindown.
    Some operations combine comminution with blending to reduce the
    size of particles while performing a mixing operation. Ball or rod
    mills may be used for this, but the large surface areas of such mills
    may result in significant material holdup after emptying. The design of
    this equipment makes it especially difficult to clean.
    Blending may also be done by splitting and recombining of
    controlled quantities of material. This gravity-flow operation may
    include mechanical agitation of the flowing stream with an impeller or
    gas jet. The principal source of material holdup in splitters is the
    accumulation or caking of material on ledges and in recesses in the
    equipment. Plugging is a problem in the extensive piping or tubing used
    with multiple splitters. For this reason, mechanical vibrators are used
    to keep material flowing in lines.
    The sieves, screens, and air classifiers used to classify dry
    particles contribute to some holdup of SNM. Particles that are trapped
    and held up in screen openings are difficult to remove and may require
    some mechanical cleaning. Material is held up in the piping used with
    air classifiers. Unless screens or sieves and air classifiers are
    completely enclosed and sealed, dusting can result in a significant
    holdup of material.
    Mechanical vibrators that are used to classify spherical particles
    are easily cleaned and usually have no significant holdup problems.
8. Holdup in Packed Bed Conversion Operations
    The holdup problem that normally occurs with packed bed conversion
    operations is caused by the SNM that is unreacted or occluded and
    remains in the slag. This holdup material may be accounted for by
    nondestructive analysis (NDA) or by being recovered in normal recycle or
    scrap-recovery operations.
    Occasionally, the refractory lining between the packed bed and the
    steel containment shell for uranium metal reduction is porous or thin,
    permitting molten uranium to contact the shell. This results in a
    "blowout" and the release of uranium metal outside the containment
    shell. Spills of this sort can result in significant holdup of SNM in
    auxiliary equipment.
    Some ceramic particles from the carbide conversion process adhere
    to or react with the walls of the graphite crucible. This holdup
    material, which cannot be recovered by a simple draindown or cleanout
    operation, contributes to MUF until the crucible is evaluated or
    processed for recovery of SNM, but its contribution is normally small.
9. Holdup in Comminution Equipment
    Nearly all flow of material through comminution equipment is by
    gravity. Equipment is normally capable of being drained down with a
    minimum of holdup. Holdup of SNM in comminution is most likely to occur
    in the form of airborne particles that leak from equipment or that
    escape during transfer and handling and collect in ventilation ducts,
    filters, or on the surfaces of equipment and gloveboxes.
    If gyratory or jaw crushers are used in the comminution operation,
    some holdup may occur on the corrugated surfaces of the jaw faces.
    When SNM consists of hard friable ceramic sinter cake or fused
    particles, equipment such as rotary hammer mills may be used for
    comminution. The irregular surfaces of breaker plates, rotating
    mechanical discs and hammers, and screen bars in this equipment
    contribute to holdup and make draindown and cleanout difficult.
C. REGULATORY POSITION
    To facilitate the measurement and/or recovery of residual special
    nuclear material held up in process equipment and to improve the
    accuracy and reliability of a physical inventory, the amount of residual
    SNM held up in equipment should be minimized. The design of equipment
    used to carry out physical or chemical changes on special nuclear
    material by dry process operations, including gas handling, glovebox
    activities, calcining, dry solids transfer, dry blending and
    classifying, packed bed conversion, and comminution, should incorporate
    features that minimize residual holdup.
    Some appropriate equipment design features and characteristics
    whose use is acceptable to the Regulatory staff for this purpose are
    described in the following paragraphs. These features should be
    implemented to the extent practicable. Implementation also should be
    consistent with other quality assurance, health, and nuclear safety
    codes and standards that may be applicable.
1. General Design
    a. Inside surfaces of equipment and gloveboxes should be free
    of crevices, protrusions, and other irregularities that could entrap
    material.
    b. Inside surfaces of equipment and gloveboxes that contact SNM
    should be selected, coated, polished, or machined to prevent or resist
    the adherence of powders or other dry particles.
    c. Where possible, the lower portions of vessels such as
    blenders and storage bins should be of conical shape and fitted with
    bottom outlets to facilitate material draindown and cleanout.
    d. Overlapping metal surfaces in contact with process material
    should be avoided except where sealed by welding; internal welds should
    be ground flush with inner surfaces. Possible exceptions are gasketed
    openings such as inspection and cleanout doors or ports.
    e. The internal angles, corners, and recesses of gloveboxes and
    equipment should be designed and constructed to permit complete
    draindown or cleanout.
    f. Seams that promote corrosion should be avoided.
    g. Materials of construction that contact SNM in any form
    should be selected so that surfaces do not corrode, dissolve, or erode
    during operation or during contact with rinse solutions used for
    cleaning. Materials for construction of jaw faces, wear bars, or
    breaker plates of comminution equipment should provide maximum
    resistance to pitting or erosion.
    h. Structural integrity should be adequate to resist the
    formation of leaks, cracks, and crevices due to thermal, vibratory, or
    other stresses. Transfer and instrument lines should be designed and
    installed so as to minimize mechanical stresses on interconnected
    equipment.
    i. Operating variables such as material flow rate, moisture
    content, particle size, and vessel geometry should be evaluated and
    selected to reduce undesirable formation of holdup (e.g., caking or
    sticking).
    j. Process units should be closely coupled and sized with
    minimal intervening holdup bins and containers, consistent with good
    engineering design.
2. Internal Design
    a. Equipment should have a minimum of internal components upon
    which process material can collect.
    b. Sensing devices such as thermocouples or other detectors
    should be installed in a manner that minimizes the amount of solid
    material that can be retained on their surfaces.
    c. Permanently mounted process equipment internals that cannot
    be removed for cleaning should be designed and installed in a manner
    that minimizes holdup in the equipment during draindown and permits
    cleanout if necessary.
    d. The inner surfaces of ducts in which deposition of
    particulates can occur should be smooth and free of recesses or other
    irregularities. Vessels and transfer lines in which condensation of
    vapors can occur should be heated and/or insulated.
    e. Provision should be made for heating and purging UF(6)
    cylinders and transfer lines to permit maximum removal of the gas.
    f. Pneumatic conveyors should be fabricated without internal
    obstructions to the flow of air and suspended solids. Charging and
    emptying ports should be designed to minimize dusting and holdup of
    material at these points.
    g. Trays that are used to transport material through batch or
    semicontinuous muffle-type calciners should be designed so that they
    cannot be tipped over or their contents spilled during handling or
    normal operation. When a tray is fully loaded, the distance of the
    center of gravity from any side should be at least four times its
    distance from the bottom of the tray. Racks, carriages, conveyors,
    guides, or drive mechanisms that are used to assist or direct the
    transport of trays should be designed so that individual trays cannot be
    tipped or caused to ride over one another.
    h. The use of blenders with internal mechanical agitators
    should be avoided. If agitators are used, they should be designed to
    permit areas to drain freely and to present minimum surface for the
    collection of solid particles.
    i. Containment retorts or crucibles for packed-bed conversion
    should be designed without recesses, internal flanges, or other uneven
    surfaces that would interfere with the normal discharge of the bed
    material after conversion.
3. External Design
    a. Visual access should be provided to surfaces or spaces where
    material is likely to accumulate. Alternatively, clearance should be
    provided so that either external use of nondestructive assay instruments
    or internal probes can be used to detect the presence of SNM or to
    identify the location of residual material not visually accessible.(3)b. Dusting should be controlled and contained at the charging and
    discharging ends of mechanical or pneumatic conveyors. Pneumatic
    systems should be leaktight, and appropriate cyclones and filters should
    be used at the discharge end to separate solids from the carrier gas. In
    mechanical systems, the conveyor bodies should be enclosed to reduce the
    dispersement of airborne SNM material.
    c. Equipment should be arranged so that the routes of solids
    conveyors are as short as practical and have the smallest number of
    bends and interconnections.
    d. Exhaust ducts should be provided on all equipment in which
    waste gases are generated (e.g., hoods, gloveboxes, and pneumatic
    transfer equipment). The pressure inside exhaust ducts carrying SNM
    particulate should be sufficiently negative to prevent the loss of
    material by leakage to surrounding areas.
    e. When large quantities of SNM particulates are carried by
    exhaust gas streams, suitable devices (such as cyclones) should be
    employed to separate the bulk of such solids from the gas streams.
    Prefilters at the exit point in gloveboxes or enclosed equipment and
    final filters prior to release should be used to remove particulates
    from exhaust gases. If measurable quantities of SNM in fine
    particulates or vapors pass through a final filter, a suitable wet
    scrubber should be installed in the exhaust system to remove them. When
    wet scrubbers are used, consideration should be given to installing
    suitable reheaters to prevent the corrosion of gas exhausters due to
    condensation.
    f. Devices for measuring differential pressure should be
    installed around filters to indicate the accumulation of material
    containing SNM.
    g. Drive motors and gear boxes for any solids conveyor should
    be mounted external to the conveyor, and the drive shaft should extend
    through a suitable leak-tight seal. Bearings for drives and idlers
    should be protected against the entrance of solids.
    h. Conveyor enclosures should be equipped with vibrating
    devices to reduce the quantity of solids adhering after a normal
    draindown.
    i. External surfaces of equipment installed inside gloveboxes
    should be smooth and free of crevices, cavities, and openings. Drives
    and power trains for process equipment should be located outside
    gloveboxes, with appropriate seals for drive shaft penetrations through
    glovebox walls.
    ----------
    (3) Regulatory Guide 5.23, "In Situ Assay of Plutonium Residual
    Holdup," provides additional methods and procedures.
    ----------
    j. Provision should be made for charging and discharging of dry
    particulate material in the calcining operation by use of enclosed
    charge and discharge lines.
    Continuous calciners should be equipped with externally mounted
    vibrating mechanisms to ensure uniform flow of material throughout the
    calciner and to prevent the formulation of areas in which the material
    accumulates.
    k. Completely enclosed charge and discharge lines, ventilated
    hoods, or gloveboxes should be provided for all charging, discharging,
    or handling of SNM for blending, classifying, and comminution equipment.
    An exception may be material of a particle size or flow characteristic
    such that no fines are released during handling. All openings, covers,
    or mechanical drive penetrations for blending, classifying, and
    comminution equipment should be sealed during operation to prevent the
    spillage or release of SNM.
1. Piping or tubing that is external to blending or screening
    equipment and that may become plugged internally with particulate
    material should be equipped with externally mounted vibrating mechanisms
    to ensure a uniform flow of material and should be removable for
    inspection and cleaning.
    m. Retorts or containment shells used for packed bed operations
    such as uranium metal reduction should be adequately sealed to prevent
    the loss of SNM as vapor during the reduction process. The materials
    used for the construction of the containment shells for uranium metal
    reduction should be compatible with the external furnace preheat
    atmosphere and with the insulating material (refractory lining) used to
    separate the packed bed from the retort so that the shells will not
    corrode or warp during operation.
4. Design for Accommodating Cleanout
    a. Equipment such as calciners and gloveboxes should be
    provided with access ports, removable covers, or removable sides to
    allow visual inspection of the internal surfaces.
    b. Access ports or removable panels should be provided to
    facilitate cleaning of internal surfaces by appropriate methods such as
    brushing, vacuuming, washing, scraping, or rinsing to remove, dislodge,
    or dissolve SNM particles.
    c. Equipment should be provided with fittings as connections
    for washdown and rinsing of internal surfaces of vessels and pipes.
    Air, steam, water, or appropriate chemical solutions may be used to
    dislodge, dissolve, or otherwise remove particulate process material,
    residues, and condensed vapors remaining on internal surfaces of the
    equipment.
    d. Provision should be made for flushing and draining and for
    removing and collecting any of the various rinses in which SNM may be
    entrained or dissolved. Removal of material from blenders, calciners,
    comminution equipment, or other equipment should be facilitated by
    designs that permit disassembly. Also, flush distribution devices
    should be connected at high points in the transfer lines or upper zones
    of equipment and should be designed and arranged to allow flushing media
    to contact the interior surfaces and cavities of the process equipment
    and of auxiliary devices inside the equipment. Valves should be
    installed at appropriate locations in the system for complete draining.
    e. Supplementary mechanical equipment not permanently mounted
    should be capable of being disassembled and removed for cleaning and
    inspection.
    f. Provisions should be made to permit verification that all
    material has been removed from enclosed transfer lines or from other
    equipment such as blenders enclosed in gloveboxes.
    g. Filter media should be removable or capable of being
    backpurged while in position. Removable filter media should be treated
    by leaching or by combustion and leaching for the recovery and
    determination of SNM. The design of cyclones should permit cleanout of
    residual solids and powders.
    h. Ducts should be fabricated so as to be easily disassembled.
    For example, taped joints may be used to facilitate disassembly.
    i. The normal contents and all rinse solutions from rotary
    retort-type calciners that contain lifting bars or flight carriages
    should drain freely by gravity from the bottom of the calciner.
    j. Containment shells or crucibles should be designed with
    openings or access for thorough mechanical cleaning such as brushing or
    scraping to remove or dislodge all solid particles of SNM that may
    remain on internal surfaces after the equipment has been emptied.
    k. Mechanical equipment, jaw faces, and breaker plates should
    be capable of being disassembled and removed from crushers,
    disintegrators, or pulverizers for cleaning and inspection.
D. IMPLEMENTATION
    The purpose of this section is to provide information to
    applicants and licensees regarding the Regulatory staff's plans for
    utilizing this regulatory guide.
    This guide reflects current regulatory practice. Therefore,
    except in those cases in which the applicant proposes an acceptable
    alternative method for complying with specified portions of the
    Commission's regulations, the method described herein will be used by
    the Regulatory staff in evaluating all license applications docketed
    after publication of this guide.
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