ML20011B126

West Valley Demonstration Project Environ Safety & Health Program Plan

ML20011B126
Person / Time
Site:	West Valley Demonstration Project
Issue date:	10/31/1981
From:	Mairson R, Marchetti S ENERGY, DEPT. OF
To:
Shared Package
ML20011B125	List: ML20011B124 ML20011B126
References
19930, WVDP-001, WVDP-1, NUDOCS 8112040068
Download: ML20011B126 (43)

Text

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WDP-001 i

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I ENVIRONMENTAL SAFETY AND HEALTH PROGRAM PLAN West Villey Demonstration Project October 1981 1

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Approved:

R. C. Nairson, Project Manager

[e.g./e Y S. Marchetti, Manager Environmental and Occupational Safety 3

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TABLE OF CONTENTS Section Title Page

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1 A.

PROGRAM MANAGEMENT PLAN 2

A.1 Management Policies 4

A.2 Organizational Structures and Duties 4

1 A.2.1 Environmental and Occupational Safety 8

A.2.2 Facility Operations 9

A.2.3 Engineering and Quality Assurance 9

A.2.4 Safety Committees 9

A.3 Procedures

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10 A.4 ALARA Proc. am 10 A.5 Internal Rev'ew of ES&H Programs

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11 A.6 Accident /Ir.cioent Investigation and Repo.rting 12 A.7 Training and Certification of Employees ENVIRONMENTAL, SAFETY AND HE'ALTH PROGRAM ACTIVITIES 15 B.

15 B.1 ES&H Program Documentation 15 B.l.1 Radiation Protection B.l.2 Industrial Hygiene and Safety 17 17 B.1.3 Environmental Protection 18 B.1.4 Radioactive Materials Shipping 18 B.1.5 Criticality Safety 18 B.l.6 Emergency Planning 19 B.I.7 Nuclear Waste Management 19 B.2 Radiation Protection Program 19 B.2.1 Radiation Surveillance 19 B.2.2 Radiation Dosimetry B.2.2.1 External Dosimetry Program T

20 20 B.2.2.2 Internal Dosimetry Program 21 B.2.3 Radiological Control Instrumentation.

21 B.2.4 Sealed Source and Radioisotop.e. Control.

c 22 B.2.5 Radiation Producing Machines

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22 B.2.6 Facility-Related Controls 23 B.2.7 Personal Protective Equipment and Clothing 24 B.3 Industrial Hygiene and Safety B.3.1 Hazardous / Toxic Material Control

-M 24 25 B.3.2 doutine Safety Survey Prog

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26 B.3.3 Health Hazard Controls 26 B.3.4 Sampling and Analysis 27 B.3.5 Personal Pr.otective Equipment B.3.6 Crane and lifting Safety 29 30 B.3.7 Fire Protection Program 31 B.3.8 Medical Services

TABLE OF CONTENTS Section Title Page B.4 Environmental Protection 32 32 B.4.1 Management Support B.4.2 Airborne Radioactive Effluent Control 32 B.4.3 Liquid Radioactive Effluent Control 33 B.4.4 Effluent Sample Analysis 33 B.4.5 Environmental Monitoring and Reporting 34 B.5 Radioactive Materials Shipping and Criticality Safety 34 B.5.1 Radioactive Materials Shipping 34 B.5.1.1 Receiving Radioactive Material Shipments 34 B.5.1.2 Shipping Radioactive Material 34

.B.5.1.2.1 Packaging Radioactive Material 34 8.5.1.2.2 Onsite Shipment of Radioactive Materials 35 B.5.1.2.3 Off-site Shipment of Radioactive Materials 35 B.5.1.2.4 Radioactive Materials Shipping Support 35 B.S.2 Criticality Safety 35 B.S.2.1 Management Support 35 B.5.2.2 Criticality Safety Control 36 s

B.5.2.3 Criticality Safety Training 36 B.S.2.4 Criticality Alarms and Dosimeters 36 B.5.2.5 Abnormal Conditions 36 B.6 Emergency Planning Program 37 l

B.6.1 Emergency Planning 37 l

B.6.2

. Classification of Emergencies 37 Emergengy Organization 37 i

B. 6.3 '

8.6.4 Emergency Support 38 B.6.5 Emergency Equipment 38 38 B.6.6

- Emergency Warning and Communications y

B.6.7 Emergency Procedures 38 B.7 Nuclear Waste Management 39 B.7.1 Airborne and Liquid Effluents 39 B.7.2 Solid Low-Level Wastes 39 l

B.7.2.1 General Requirements 39 8.7.2.2 Transurance Wastes 40 B.7.3 Liquid Radioactive Wastes 40 B.7.4 Sludges 40 B.7.5 Reactive Wastes Forms 40 l

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ENVIRONMENTAL, SAFETY AND HEALTH PROGRAM PLAN The Environmental, Safety and Health (ES&H) Program Plan presented in the fol-lowing paragraphs describes the safety program which the West Valley Nuclear Services Company (WVNSCo) intends to implement at the West Valley Demonstration Project (WVDP). The plan describes a program which meets or exceeds the requirements of applicable Department of Energy (D0E) regulatory requirements and forms the basis for:

e-Detailed documentation of the ES&H program elements;

,o Identification of areas requiring policy stdtements; and,

. is ' Development of checklists for pefforming internal reviews and program appraisals.

The plan is organized into seven basic sections which include:

o Program management; o

Radiation protection; e

Industrial hygiene and safety including fire protection and occupa-tional medical services; e

Environmental protection and pollution control; e

Nuclear and transportation safety; e

Nuclear waste management; and,

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o Emergency planning.

Each section presents a general overview of how the system of assurance for that particular area is implemented, establishes responsibilities of line and staff functions, describes lines of communication, indicates the approval authority for programs and facility changes, and discusses periodic reporting to management.

A.

PROGRAM MANAGEMENT PLAN Program management includes. aspects of the ES&H program which are generic to each of the specialized safety programs. These aspects include areas

.such as nanagement policy, organizational structure, management committees and?.in.ternal review program, line organizational responsibilities, etc.

The.following paragraphs present a discussion of ES&H program management aspects and how they will be implemented by WVNSCo.

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A.1 Management Policies

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WVNSCo policies and authority are derived from those.of the Westinghouse Advanced Energy Systems Division which in turn are directly traceable to the policies of the Westinghouse Electric Corporation.

In carrying out the WVDP, it is WVNSCo's intent to:

e Operate the facility in a cost effective manner which meets or exceeds applicable regulations and Federal requirements governing the opera-tion of DOE facilities.

e Develop and implement programs to assure the protection of the envi-ronment, and the health and safety of the general public.

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Take all practicable steps'io' eliminate, or reduce, potential exposure e

of employees to accidental injury or to conditions adversely affecting their health while on the job.

It will also be WVNSCo policy to inform employees concerning off-the-job hazards and to instruct them in what can be done to minimize those hazards.

To implement this operating philosophy, formal policy statements dealing with specific ES&H programs will be promulgated.

The formal policy state-ments are based on the requirements of the ERDA Manual Chapters, DOE Orders and the chapters which supplement DOE Order 5480.1. Eurthermore, the pol-icy areas are related directly to the WVNSCo organization responsible for their implementation. Statements of management policy are reviewed by the Project Manager's Staff, they are approved and issued by the Project Man-ager as project Policies and Procedures.

Table A-1 contains the policy statements which will be issued for the WVNSCo ES&H program. The policies will be contained in the WVDP Policies and Procedures Manual which assigns implementation of the policy to the proper organization or organizations and describes the responsibility of line organizations in its implementation. The procedures are reviewed by the Project Manager's Staff and are approved and issued by the Project Man-ager through the Project Control organization.

Project Control is respon-sible to assure that proper distribution of the Policies and Procedures Manual is made to all members of management, that control of the manuals and subsequent revisions is maintained, and that procedures are periodi-cally reviewed to assure continued applicability.

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TABLE A-1 STATEMENTS.'0F;WVNSCo POLICY ON ES&H MATTERS Policy Area Statement of Policy Industrial Hygiene and WVN'SCo will assure that:

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Workers are protected against toxic Safety 7,

e rnaterials and health hazards in the 2^

workplace; e

Risks from fire are maintained at the lowest praticable level; and e

Construction activities are con-ducted in a manner which protects the general public and employees from injury, and Government property from damage.

Environmental and

' Operations at WVDP will be conducted in a Pollution Control ~

manner which assures strict control of environmental pollution sources and com-pliance with Federal Environmental Pro-tection Laws and Executive Order'12088.

Radiation and Criticality Radioactive wastes and other radioactive Safety materials (including those in transit) will be controlled in a way as to reduce radiation exposures to workers and the general public to the lowest levels practicable. Fissile materials will be processed, stored, transported and han-died in a manner which presents an acceptably low risk of accidental criti-(

cality.

l Emergency Planning and It will be WVNSCo policy to assure that Occurrence Reporting an emergency plan and organization is in place to deal effectively with emergen-cies and for notification, investigation i

and reporting _of occurrences.

Safety Review, Human It will be WVNSCO policy to asure that Factors Assurance and safety-related program or facility modi-Reliability fications presenting unreviewed safety.

questions (introduction of a condition either not previously analyzed for.

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safety impact or outside the envelope of the existing safety analysis) are reviewed for ES&H concerns. Human fac-

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tors engineering and reliability will be=

considered.

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It will be WVNSCO policy to assure that Training all employees are trained in ES&H pro-tection matters to the extent necessary for safe performance of their job func-tion.

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A.-2 Organizational Structures and Dutig Implementation of the ES&H program is an operating line management respon-sibility. Development of the ES&H program is the responsibility of the Manager of Environmental and Occupational Safety.

In the emergency plan-ning and training areas, he supports the Facility Operations Manager; in the areas of human factors engineering and reliability assurance, he is supported by the Managers of Engineering and Quality Assurance respectively.

j The Manager of Environmental and Occupational Safety is also responsible for the development of policies and procedures relative to the independent safety review program. This program requires the formation of ad hoc com-

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mittees to conduct objective reviews o' significant modifications to pro-f grams or facilities. The organizational structure and duties of the WVNSCo staff which provide ES&H program management are described in the following i

i paragraphs.

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A.2.1 Environmental and Occupational Safety i

j WVNSCo management will provide a staff of safety professionals to implement those ES&H policies which are related to specific organizational duties.

In general terms, the responsibilities of the ES&H organization will be as follows:

Establish, interpret and implement the ES&H program and policy require-i o

I ments; Adopt and interpret applicable codes, standards and guides; e

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Provide ES&H services for employees;

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Provide training support and support an emergency response capability; e

Support line organizations with regard to ES&H matters; e

e Determine the need for operational ES&H research; Collect, evaluate and disseminate ES&H related information; l

e Support hazard and risk assessment and systems safety programs; and, e

Provide safety review procedures and practices and an internal surveil-e lance function.

In addition to those staff members directly committed by WVNSCo, support is available if necessary from ES&H organizations within the Westinghouse Nuclear i

Energy Systems and operating Divisions of the Westinghouse Electric Corporation.

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l Figure A-1 depicts the ES&H management organization at WVDP for the period o time starting with the initial decontamination and decommissioning operations The ES&H through solidification and final decontamination and decommissioning.

organization will provide functional support during the early period of project activity with a smaller staff. The functions and responsibilities of these organizations are discussed in the following paragraphs.

Manager, Environmental and Occupational Saftey The Manager, Environmental and Occupational Safety, will be responsible for a activities concerning industrial safety and radiation protection of employees, He will be responsible for developing the general public, and the environment.

training programs for workers to instruct them in performing t safely.

authority to cease operations in the event that operating conditions.are not in compliance with operational safety controls or approved operating procedures.

This authority will also be delegated to both his management and their staff.

Manager, Radiological and Nuclear Safety The Manager, Radiological and Nuclear Safety, through the lead Radiological Control Engineer, will be responsible for maintaining radiological safety of the plant by regularly evaluating and assessing surface contamination, radia-tion levels, and airborne radioactivity concentrations in work areas with A major responsibility of this organization is to- -

respect to approved limits. assist operating management in developing progra tion exposures as low as reasonably achievable. Cost effectiveness of these He will be responsible programs will be a consideration in their development.

for ensuring that a personnel dosimetry program is in place to determine radia-tion exposures of employees and visitors who are authorized to receive occupa-tional radiation exposure and that records of such exposures are properly main-tained and reported. He will also be responsible for ensuring proper calibra-tion and maintenance of the radiological control instrumentaton used in normal He will have the authority to remove from the list of or emergency operations.

employees authorized to receive occupational radiation exposure, those who have either exceeded the established administrative radiation exposure limits or who have not demonstrated their continuing understanding of, or the need for com-pliance with the Project's radiological safety-related operating procedures.

He will be responsible for review of facility and process design, and design and process changes and to provide engineering support to operational groups He will maintain the Radiological Controls which prepare those procedures.

Manual which implements the policies contained in the Policies and Procedures.

The Manager, Radiological and Nuclear Safety, through the lead Nuclear Safety Engineer, will also be responsible for reviewing facility operations which involve fissile material storage, processing, handling and shipping, and for developing and implementing a control and monitoring program to prevent accumu-lating unsafe quantities of nulcar materials.

He will be responsible for' ensuring that criticality monitoring instrumentaton, nuclear accident dosime-ters and an effective and well documented analysis program and review system are in place.

In compliance with WVNSCo policy, these systems will meet or x

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exceed the DOE requirements for nuclear criticality safety of non-reactor nuclear facilities described in 00E Order 5480.1, Chapter IV.

He will be responsible for maintaining an effective thermoluminescent dosimetry laboratory, dosimetry processing equipment, and an effective record system which is used in processing both environmental and personnel dosimeters. He will also be responsible for establishing programs which ensure the safety of fissile and radioactive material shipping. The Manager, Radiological and Nuclear Safety will report to the Manager, Environmental and Occupational Safety.

Reporting to the Manager, Radiological and Nuclear Safety will be four Radio-logical Control Shift Supervisors, based on the potential need for.three oper-ating shifts. The Radiological Control Technicians who will provide routine monitoring and surveillance functions report to these supervisors.

Safety pro-fessionals and management within the Environmental and Occupational Safety Department will be on call to provide shift technical support if needed. The Radiological Control Shift Supervisors are field representatives of the E&OS Department. They are responsible for ensuring that the facility radiation and contamination surveys are completed as scheduled and that they are properly documented. Additionally, they are responsible to assure proper surveillance of work being conducted on radioactive systems and posting. controlled areas.

Manager, Industrial Hygiene and Safety The Manager, Industrial Hygiene and Safety, will be responsible for providing the services to control personnel exposures to toxic chemicals and harmful physical agents and to control mechanical and electrical hazards. He will also be responsible for ensuring that programs are in place for properly storing and disposing of toxic chemicals including their shipment off-site.

He will assure that surveillance of the occupational environment is. maintained to identify, evaluate, and control conditions pertinent to health and safety, and to assure compliance with the requirements of the DOE Orders, 29CFR and 40CFR, where applicable. He will asure that industrial hygiene and safety matters are prop-erly documented.

In addition to industrial hygiene and safety services, he will also be respon-sible for providing occupational medicine and fire protection services. At a minimum, the occupational mccicine program will meet the requirements of DOE Manual 0528 and will ten;ider the requirements of the Westinghouse Electric Corporation.

The Manager, Industrial Hygiene and Safety, through the Fire Marshall, will also be responsible for providing fire protection services which meet the requirements of 00E Order 5480.1. These services include:

Fire protection 'e'n incering; e

e Economic justification level for loss prevention; Training and certification of personnel; and, e

Surveillance of facilities for deficiencies with respect to NFPA regu-s lations.

Reporting to the Manager, Industrial Hygiene and Safety will be the safety sur-veillance engineer whose sole. function will be to perform continuous safety surveillance over areas where operations are performed which present a level of ES&H risk. He will be responsible for identifying and ensuring the correction of deficiencies in both ES&H program implementation and implementation of safety policy and procedures by the operating organizations. He will have both the authority and responsibility to cease operations in the event that they are not proceeding in accordance with established operating procedures and safety controls or involve an unreviewed operation which presents a safety risk.

, Manager, Environmental Surveillance The Manager, Environmental Surveillance, will be responsible for activities concerning pollution abatement and control, monitoring for chemical releases and for providing an effective and appropriate environmental monitoring program to ensure that releases of radioactive material to the environs are within the limits of DOE Order 5480.1 and as low as reasonably achievable (ALARA).

In addition, he is responsible to ensure that these programs are developed and implemented in a cost effective manner. He will also be responsible for iden-tifying and ensuring the correction of non-compliance areas. He will supervise the analysis of environmental samples and perform periodic assessments of the plant environmental monitoring system and instrumentation to ensure that it is functioning properly and in accordance with applicable standards. He will report to the Manger, Environmental and Occupational Safety.

A.2.2 Facility Operations The E&0S organization provides support to Facility Operations in the area of training and emergency planning. E&OS will develop training programs, qualifi-cation standards and questionnaires in the area of fire protection, radiation worker training, use of containment devices, fissile material handler training, radiation orientation for non-occupationally exposed workers and training in the use of respiratory protective devices. These programs will be presented by either E&OS or the Training Department; in both cases, the training records will be maintained in a central file by the Training Department.

Specific training policies and requirements are discussed under Section A.7.

The Plant Operations Manager is responsible for maintaining the Emergency Plan and implementing the requirements of the applicable DOE Orders. E&0S will sup-port Plant Operations in the safety area and in providing a radiological emer-gency response capability.

A.2.3 Engineering and Quality Assurance The Manager of Engineering is responsible for assuring that human factors con-siderations are given to facility designs and modifications. Additionally, designs and modifications will also consider system reliability. Quality -

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Assurance will participate in design reviews and reviews of proposed modifica-tions to assure that quality-related requirements haw been considered.

A.2.4 Safety Comittees The Manager E&OS is responsible for preparing policy and procedures for an This program requires the formation of ad independent safety review program.

hoc-committees whose function will be to provide an independent review of sig-nificant modifications to programs and facilities (see also Section A.5) to '

assure that:

ES&H protection matters are comprehensively addressed; e

Risks have been identified and that they are acceptably low; and, e

Management authorization of operations is documented.

e The safety committees are staffed by personnel who are essentially of the organization being reviewed.

to the Project Manager.

A.3 Procedures Hazardous work or operations which are potentially hazardous will be per-Policy state-formed using approved operating or maintenance procedures.

ments and implementing procedures for preparation, updating or changing of procedures will be contained in the WVDP Policies and Procedures Manual Procedures which will be provided to all members of WVNSCo management.

will also be included to permit controlled field changes to operating pro-These procedures will be approved by the cedures should the need arise.

Project Manager and distributed by the document control organization.

Operating and maintenance procedures are prepared and issued for review by the Facility Operations organization, normal reviews and approval will include E&OS and Quality Assurance. Procedures will contain a date and a

, revision number, systems will be developed to assure that only the approved procedure in effect is available at the job site. Facility Operations will assure that maintenance and operations personnel are trained in the proce-Procedures are generally written for operations and maintenance dures.

guidance; in special cases, when unique functions are being performed or the work presents a special safety hazard, specific training and practice with mockups may be used to assure that personnel understand the procedure and can perform the work as planned. Additional details on procedures are presented in specific discussions on individual safety programs.

The issuance, approval, implementation and maintenance of procedures will be periodically audited by Quality Assurance. During facility reviews con-ducted by the safety committees sample reviews of procedures will be con-ducted to check implementation of procedures and the related administrative controls for operating procedures.

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A.4 ALARA Program e.1 A formally documented program directed toward maintaining personnel radia-tion exposure and environmental releases "as low as reasonably achievable" (ALARA) will be implemented. FThis program is required by management oolicy and is coordinated by the Manager E&OS and implemented by line management.

In essence, the program establishes annual radiation exposure reduction goals and management commitments.to facility modification, changes in oper-ating practice etc., which will assist in meeting the goals. Progress toward meeting the goals will be reported to management monthly and an annual summary report will be prepared which presents the accomplishments for the previous year and establishes goals and corresponding activities for the following year. The formal ALARA program and its implementation is the subject of annual safety committee review.

A.5 Internal Review of ES&H Programs WVNSCo policy at WVDP establishes a formal requirement for independent reviews of the ES&H program. The formal policy statement is implemented by the WV0P Policies and Procedures which establish schedules and methods for performing the reviews. The plan for WVNSCo review of the ES&H program at WVDP consists of interrelated audits, functional appraisals and management reviews.

Surveillance and audits are conducted by internal organizations which include the safety surveillance engineer and the Quality Assurance organi-zation. Safety surveillance is a continuing function of the Industrial Hygiene and Safety organization. The surveillance engineer conducts facil-ity surveillance on a routine basis against checklists developed from requirements contained in the ES&H standards manuals (see B.1). Procedur-ally, each operating area of the facility presenting a level of ES&H risk which represents a distinct management unit or function is a subject of surveillance. ES&H related records such as training records, fire protec-tion equipment, safety signs and equipment, procedures, dosimetry records, instrument calibrations, and radiation / contamination survey records are reviewed for completeness and proper followup where corrective action was required. A fire protection surveillance is also ccnducted by the Indus-trial Hygiene and Safety organization. Results of the surveillance are submitted to the area supervisor for corrective action and copies are transmitted to the area manager and the manager of E&OS. A followup file of surveillance results is maintained and reviewed during the next sched-uled surveillance to ensure that corrective actions have been implemented.

Quality Assurance also conducts periodic audits of each organization to ensure that policy, implementing procedures and operating procedures are in place and being complied with. The results of these audits are transmitted to the responsible manager of the organization being reviewed and his man-ager. Audit findings require a formal response on specific corrective action to correct deficiencies and preclude recurrence. Followup and closGcJt of corrective actions are required by Quality Assurance.

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In addition to the audits, functional appraisals are conducted. While audits and surveillance are concerned with whether ES&H programs are being implemented, functional appraisals are intended to determine the effective-ness and operability of ES&H programs. These functional appraisals are conducted by a WVNSCo safety committee which reviews industrial hygiene, nuclear safety, and radiation and environmental protecton. The functional appraisals are required by policy and implemented by WVDP Policies and Pro-cedures. The safety committee reports to the Project Manager and the results of appraisals receive top management ettention. The areas reviewed by the safety committee include:

-sj Adequacy of ES&H policy; Adequacy of procedures implementing ES&H policy;

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.c Adequacy of training procedures and programs;

e*. Completion of audits and surveill.ance as scheduled; or, Accuracy and completeness of record systems; o

Normal operating and emergency procedures; o

Adherence to operating limits and controls; Physical condition of facilities; and, e

e Other areas indicative of ES&H program functions.

Safety committee functional appraisals of the ES&H prngram are conducted at a frequency specified in the WVDP Policies and Procedures. The safety com-mittee is staffed by personnel who are both independent of the function being reviewed and interdisciplinary.

At least every three years, a management review of the ES&H program is con-ducted. Like the functional appraisal, the management review examines the effectiveness of the ES&H program and determines whether there is a need for programmatic changes within the system. Part of the management review responsibility is to review functional appraisals conducted during the pwiod since the last review. The management review is conducted by the Advanced Energy System Division Radiation and Safety Committee which i

l reports its findings to the General Manager of the parent Division. The WVDP Project Manager is reponsible for assuring corrective action.

A.6 Accident / Incident Investigation and Reporting i

As discussed in Section A.1, Westinghouse has a policy of reporting all, incidents and accidents. This policy is implemented by the WVDP Policies and Procedures Manual. The reporting requirements and the procedures for reporting are contained in the applicable ES&H program documents discussed in Section B.l.

Systems provide for reporting and documenting all incidents either internally or.to the Department of Energy. The reporting guidelines are those described in DOE Order 5484.1.

I The plan is to report occurrences to the DOE both orally and in writing.

The oral report is made to the responsible DOE representative or his dele-gate within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the occurrence is determined to be reportable.

Westinghouse will not provide notification of an occurrence to any outside organization unless previously authorized to do so by 00E. Those incidents which are not required to be reported to DOE will be reported internally using a system defined by procedures contained in the Technical Procedures Manual. An internal notification system is established in the appropriate ES&H operating manuals (see 8.1) for incidents which are not DOE reportable.

For botE,00E reportable and internally reported incidents, a formal notifi-cation system will be maintained. The notification system meets the requirements of DOE 5484.1.

It is WVNSCo policy to begin an investigation as soon as possible following an incident and that every incident be inves -

tigated at a level commensurate with severity.

.A t ough severity is a major consideration, other considerations which dic-lh "s.

tate the required level of investigation may include impact on the progress of the mission, public sensitivity, public involvement, novelty, or persis-tent recurrence of similar events.

Westinghcuse as the WVDP operating contractor intends to utilize the Man-agement Oversight and Risk Tree (MORT) method for incident / accident inves-tigation. This will be a requirement specified in the Policies and Proce-dures Manual. As such, WVNSCo will have on its staff at least one member who is trained and qualified in the MORT methodology. Trained and auali-fled Accident Investigators are available from the Westinghouse Electric Corporation. WVNSCo may either utilize this resource when necessary or have on its staff, members trained and qualified to perform the investiga-tion function.

The general approach to be applied in all investigations is one of looking beyond personnel failure to determine what system fai. lure occurred to allow the event to take place. The method requires an analytical approach to the investigation to determine "what happened" and, "what should have happened to prevent the occurrence." Human factors engineering and reliability assurance are factors included in the investigation of every incident.

Remedial actions are developed as a result of the investigation to prevent recurrence and are directed toward implementing changes or reinforcing areas of the safety system which failed and led to the incident to prevent recurrence.

A.7 Training and Certification of Employees The Westinghouse Electric Corporation, as a matter of its operating policy, requires that each activity provide a formally organized and continuing-program of employee training. The importance of training at WVDP is empha-sized by formation of a training organization under the Facility Operations Manager. As a general statrent of policy, WVNSCo will provide a level of training consistent with an individual's work assignment and responsibili-ties.

In addition to completion of training programs, employees will be required to demonstrate their proficiency by performing to a minimum stan-dard in qualification examinations. The training standards for ES&H pro-grams are documented in the appropriate ES&H manual (e.g., Radiological Control Technician and Radiological Control Supervisor qualification stan-dards are contained in the Radiological Controls Manual). Personnel who are not capable of demonstrating acceptable performance to a documented standard for a given operation are not permitted to perform that operation except under the direct continuous control of a qualified employee.

Employees who have qualified but by their actions on the job indicate a lack of knowledge in ES&H performance, will be immediately disqualified and retrained. The general process of ES&H training is discussed in the fol-lowing paragraphs. The training programs meet the intent of ERDA Manual 4204, " Employee Training and Nuclear Manpower Resources."

All new employees are required to attend a general orientation program.

Additionally, all employees not involved in radioactive work are required to receive basic radiological training, which is repeated annually. This training ensures that personnel understand the posting of radiologically controlled areas and the identification of radioactive. materials.

The instruction also explains the impact of WVDP on the radiation environment of personnel employed outside radiation areas and outside the WVDP facil-ity. Additional instruction is provided on the recognition of emergency l

signals and the response of employees who have no formally designated responsibility during an emergency. For employees who are responsible for fissile material handling, emergency procedure training and examination is required at least annually.

Before being authorized to work with radioactive materials (or to enter any i

radiologically controlled area unescorted) a worker is required to complete a formal course in radiation worker training.

In addition to being taught technical safety and practical factors, selected incident / accident reports will also be discussed to familiarize the worker with how things can go wrong while on the job. Qualification as a Radiation Worker requires suc-cessful completion of a written examination and successful demonstration of practical factors such as frisking their person for contamination and don-ning and removing protective clothing. Radiation workers are required to be retrained and demonstrate their proficiency every two years.

j Those employees who, in addition to working in radiologically controlled areas, are responsible for fissile material handling or control will receive additional training in nuclear safety and the mass control system where implemented as a means of criticality control. The course satisfies the requirements of.00E Order 5480.1 Chapter 4.

Qualification as a fissile 4

material handler is by written examination. Under no circumstances will personnel be permitted to handle or control fissile material without com--

pleting the formal qualification program.

In addition to the ES&H training programs discussed, employes will also receive training, retraining and examination in the following areas:

e Standard and emergency operating procedures; s

Safety and emergency systems; e

Instrumentation and' control; Facility operating characteristics; e

Principles ~of nuclear facility operation; e

Materials handling f acilities and procedures; o

On-the-job training to assure that they are familiar with their assign-e ment; and, The importance of change control and the proper procedure for making e

changes in the facility's operation.

Supervisors in facilities where radioactive and fissile materials are han-died receive training similar to that described above except that the level of training and understanding required by supervisors.is of much greater depth than for facility operators.

r In general, qualified workers will meet the following crite:ia:

Bioassay and/or whole body count baseline completed; o

e inclusion on periodic bioassay roster; Medical baseline examination, including respirator physical; e

Inclusion on periodic medical examination roster; e

Completion of radiation worker training course; o

Completion of respirator training course;

}

e Successfully fitted with an approved respiratory protective device; i

e Completion of facility indoctrination; e

Completion of required special training; e

No precluding physical limitations or radiological restrictions; e

~

NRC Form 4 or eqiivalent on file with Radiological and Nuclear Safety; e

and, e

Personnel dosimetry badge assignment.

s 1

A personnel dosimetry badge will be permanently assigned to only qualified radiation workers. A permanent badge will not be assigned without complet-ing the training and qualification requirements.

Emergency response teams receive specialized training in carrying out their assignments. Emergency first aid training is also required of certain employees with responsibility for responding in an emergency.

Individual employees are encouraged to acquire requisite job skills by tak-ing advantage of occupational and technical training opportunities provided by existing local educational facilities. WVNSCo will also undertake, as required, conventional industrial trainin.g activities such as apprentice-ship programs and specific on-the-job training.

WVNSCo as the operating contractor is the administrator of these training programs and is responsible for compliance with training standards affect-ing both permanent and contractor personnel. As the operating contractor, WVNSCo intends to maintain current and accurate records showing the train-ing of each employee. The training status of individuals employed by WVNSCo and its contractors will be the subject of internal audits conducted by the Quality Assurance organization.

B.

ENVIRONMENTAL, SAFETY AND' HIALTH PbGRAM ACTIVITIES The following section presents the plan for implementation of specific activities within the ES&H program. The major activity areas represent functions which will be covered by specific policies and procedures. Table B-1 contains a listing of specific policy areas and major program elements which will be addressed in the appropriate procedures.

B.1 ES&H Program Documentation 2

As discussed in Section A.1 of the program plan, WVNSCO policies and imple-menting procedures relative to the ES&H program will be contained in the WVDP Policies and Procedures Manual. The procedures in essence represent the authority to implement specific ES&H programs and to develop and imple-ment appropriate ES&M program documentation. The program documentation will take the. form of procedures manuals or program requirement documents which contain the specific program elements in detail. The following para-graphs briefly describe the program documents required in each of the ES&H functional areas.

B.l.1 Radiation Protection The radiation protection.. program standards and detailed procedures which describe how the radiation protection program will be implemented in the facil-ity are contained in the Radiological Controls Manual.

This manual addresses 4

each of the major program elements including:

e General sampling and analysis programs; e

Conta:nination control; TABLE B-1 ES&H POLICY AREAS AND PROGRAM ELEMENTS l

1 Regulatory Requirements Implementing Procedures Policy Aree implemented WVDP will provide through its Industrial Hygiene and Safety industrial Hygiene ERD AM CS 28. " Contractor Occupational organization' and Safety Medical Program" e Documented programs to protect employees against DOE 54801. Chapter Vll." Fire Protection" health hazards in the work place.

DOE 5480 t. Chapter IX. " Cons truc tion e Programs and personnelto protect the public. employees.

Safety and Health Program" property.and programs trom fire.

29CRF1910." Occupational Safety and e Monitoring of construction activities to protect the public.

Health Standards" employees. property.and programs and 29CRF t 926/1910." Safety and Health

• Eauspment and personnet to monitor and control tonc ma-Regulations for Construction" terials in the work environment.

WVDP will provide programs for WVDP which witt.

Environtrental and DOE 5480.1. Chapter Xil." Prevention.

e Ensure compliance with Federallaws on environmentat Pollution Control Controt and Abatement of Environmental protection and Executive Order 12088.

Pollution" e Monitor re' ease points and the environ :ient to assure con-ERD AM OS 13. "E f fluent and Environmen-trolof pottution sources and compliance with environmen-tal Monitormg and Reporting" talstandards:

e Maintain environmentallevets of radioactivity as low as Radiation a' d Crit-ERD AM 0511.-Radiation Waste Man-reasonably achievable and cost eff ective: and n

Cahty Safety agement" ERDAM OS24." Standards for Radiation p

Protect'on

--

• Assure that radioactive wastes are stored. processed and e s as to reduce radiation exposve to man and me an Packa go ssi and Ot r Rad oac-tive aRnals e Maintain radiation exposures to mdividuals and popula-DOE 54801. Chapter IV.,' Nuclear Critical-sty SaMy e Control snipping of radioactive ano tissile materialto pro-ERDAM 0525." Occupational Rad.ation tect public health and safety; and Exposure Information" e Control unsafe accumulation of fissile materialduring prc-ERD AM 054 5." Nuclear Accident Dosime.

duction. storage transport and hand!ing to reduce the risk try Program" of criticality accidents.

~ e Provide personnel.environmentaland nuctearaccident -

dosimetry programs.

Ernergency Plan-ERD AM 0502. *Wotification. Inve stigation WVDP will ensure public and employee safety during emergen-ning and Occur-and Reportmg of Occurrences" cies by:

rence Reporting DOE Order 5500." Emergency Prepared-

• Developing and implementing emergency plans. conduct-ing emergency pian trainmg and drills, and maintainmg a ness" functional staff. and e Ensuring that procedures are in place for notification.

investigation and reportmg occurrences Safety Review.

DOE Order 54801. Chacter V." Safety of WVDP will provide a safety review program which Human Fatters Non-Reactor Nuclear Facilities"

• Provides for independent review of significant mod:tica-and Rehab*lity (Reference " Human Factors in Design."

tions; e is staffed by personnelindependent of the operation bemg ERDA 76 45-2. July 1976)

Assurance

reviewed, o Ensures that human factors and retiabihty assurance are considered m revien s: and e Ensures that hazardous operations are conducted with written procedures Training ERD A Manual 4 204.* Employee Trainmg EE tH trammg programs at WVDP will and Nuclear Maripower Resources" e Instruct and ouality employees in radiation protection Other DOE Orders and ERD A Manual theory and practice, e Provide mstruction and cuahty employees in usingiespira-chapter 5 as appbcJDie tory protect.ve deuces.

e instruct and enamme employees m nuclear criticahty safe ty.

e Teach employect euc mterialhandhno p'ocedures amt

• Provide other ES&H trammg as necessary.

e Personnel dosimetry and bioassay schedules; e

Training and qualification requirements; and, e

Controlled area posting.

A second manual, Radiological Control Procedures, will be the operating manual which provides detailed instructions to the Radiological Control Technicians.

The review and approval requirements applied to the procedures manual are dis-cussed in Section A.3.

B.1.2 Industrial Hygiene and Safety i

The WVNSCO industrial hygiene and safety program consists of four essential elements, these are:

e Industrial hygiene; e

Industrial safety; e

Crane and lifting safety; and, e

Fire protection.

The industrial hygiene and safety program is described in detail in the Indus-trial Hygiene and Safety Manual. This manual, which is similar in scope to the Radiological Controls Manual, contains the details of how the program is to be implemented.

B.1.3 Environmental Protection The WVNSCo environmental monitoring and protection program is documented in the Radiological Controls Manual. Control of disposal, handling and shipping of non-radioactive pollutants is addressed in the Industrial Hygiene and Safety

. Manual. These manuals identify the regulatory standards to be implemented, delegate authority, specify internal review and audit requirements, describe management interfaces and reporting requirements. The program elements in the environmental protection include:

e Effluent release controls; t

e Environmental monitoring and sampling requirements; and, e

Procedures.

Specific environmental monitoring and related analytical procedures which pro-vide detailed technical instructions are contained in the Environmental Proce-dures Manual. The review and approval requirements for this manual are the same as those discussed in Section A.3 for operating procedures.

B.l.4 Radioactive Materials Shipping Requirements governing the shipment of radioactive materials are contained in the Radiological Controls Manual and meet the requirements of ERDA Manual Procedures for preparing the necessary shipping papers, packaging mate-3 0529.

rial, preparing shipping containers for transport, surveying containers and vehicles and transporting or receiving shipments are contained in standard The standard operating procedures which are approved as operating procedures.

discussed in Section A.3 implement the requirements of the Radiological Con-trols Manual.

4 8.1.5 Criticality Safety In the initial stages of the project, a review will be conducted to determine the extent of the potential criticality safety program. As such,;the program

, described in Section B.S.2 is intentionally brief, the need for expansion of the program will be assessed later as a function of scope of work. The program which will be developed will meet the requirements of 00E Order 5480.1, Chapter 4.

B.l.6 Emergency Planning The plan for dealing with the various emergencies which may occur during the operation of the WVDP is documented in the WVDP emergency plan. The emergency plan addresses the major program elements which include the following:

Emergency classifications s

e Emergency organization 6

On-site and off-site emergency support 4

e Emergency actions Emergency warning and communications e

e Emergency facilities s

Emergency preparedness The detailed procedures implementing the emergency plan are included in the Emergency Procedures Manual.

The Emergency Procedures Manual includes specific procedures for dealing with personnel, plant work area, sit and general emergencies.

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B.l.7 Nuclear Waste Managemesu 4

The WVNSCo nuclear waste management program described in the ES&H documentation addresses those areas of the program which present an impact on worker and environmental protection. As such, controls are applied to collection, The processing, transportation, storage, and disposal of radioactive wastes.

intent of these controls are to:

Minimize external exposure to personnel; e

Reduce the volume of radioactive waste generated; and, 1,.

e Reduce the total radioactivity discharged from the facility.

e Specific requirements on collection, processing, transportation, storage and disposal of radioactive wastes are contained in the Radiological Controls Man-Operating procedures for radioactive waste processing will be developed ual.

by Facility Operations based on the guidelines contained in the Radiological Controls Manual.

B.2 Radiation Protection Program B.2.1 Radiation Surveillance The radiation surveillance program encompasses the assessment of surface con-tamination, direct radiation, room air concentration, radiation producing The prescribed standard of per-equipment, and safe work practice monitoring.

formance in each of these areas is contained in the Radiological Controls Man-ual, instructions in performing the measurements, recording data, retaining data and required followup actions are in the Radiological Control Procedures Manual.

B.2.2 Radiation 00simetry The radiation dosimetry program meets the requirements of ERDA Manual Chapter 0525 and will be described in the Radiological Controls Manual. The program as described will contain the following elements:

Exposure limits, controls and administrative guides;-

e Requirements for external dosimeters; e

Requirements for internal dosimetry; a

Guidelines for special internal and external dosimetry; and, e

e Records maintenance and control.

Details on the scope and requirements of the programs will be described in the Additionally, employees will receive instruc-Radiological Controls (1anual.

tions regarding the dosimetry program during Radiation Worker training and Dosimeter process-i written instructions at the time of dosimeter assignment.

ing, assignment, and records maintenance procedures will be contained in the Dosimetry data and related calibration Radiological Control Procedures manual.

controls will be reviewed by the Manager of Radiological and Nuclear Safety or the lead Radcon Engineer for accuracy before placement in the permanent rec-ord. Dosimetry data will be made available to the employees supervisor for !

• I review, it is the supervisor's responsibility to assure that each of his Data will also be employees receives the results of dosime.try evaluations.

summarized by budget code monthly both numerically and graphically as part of the ALARA program (see A.4). Records of external and internal exposure will be retained in a permanent file by Radiological and Nuclear Safety, a copy of the

. record will be placed in the employe medical records.

B.2.2.1 External Dosimetry Program External dosimetry services will be provided by the WNSCO either on site or as In either case, the dosimeters of record will meet at a purchased service.

least the minimum performance requirements for personnel dosimeters specified by the Nuclear Regulatory Commission.

Issuance of record dosimeters will be made by Radiological and Nuclear Safety after certain qualification standards and criteria are met (see A.7).

A signed checklist will serve as evidence of Follow-

, completion and will be retained with the employee's dosimetry record.

ing initial dosimeter assignment, record dosimetry badges will be issued and stored at the main guard house. All employees entering radiologically con-trolled areas will be required to wear a record dosimeter. Dosimeters will be processed either monthly or quarterly depending on the employees potential exposure; guidelines on processing periodicity will be published in the Radio-logical Controls Manual. Dosimetry badges will be exchanged at the guard house for processing, a quality assurance program will be in place to assure proper dosimeter performance and readout.

In addition to the record dosimeter, supplementary dosimeters will be issued to certain employees to assist them in controlling their own exposure. The type of dosimeter issued will depend on the potential for exposure, guidelines for their use will be contained in the Radiological Controls manual. These dosime-ters will be read by the Radiological Control Technicians, the dose recorded and returned to the employee; a record of the exposure will be retained in a log book. When it is desired to retain ~a record of personnel exposure by job, a record of exposure will also be retained with the applicable Radiation Work Permit. Unexpected or off-scale readings on the supplementary dosimeters will be cause for special processing of the record dosimeters.

B.2.2.2 Internal Dosimetry Program The internal dosimetry program will consist of a combination of in-vivo count-ing and bioassay. Prior to instituting an internal dosimetry program, an eval-uation of options will be conducted to determine the percentage of dose missed for each option considering the biological half life of nuclides sampled and the potential sampling / counting schedule. Analytical sensitivity will at least meet the minimum requirements of the Nuclear Regulatory Comnission. The employees will be divided-into risk groups for evaluation. All new employees or contract employees who will work in an area where uncontained radioactive materials are stored or handled will be subjected to internal dosimetry analy-ses prior to entering the site and at the time of termination.

^

In addition to the normal schedule, the option to do special in-vivo counting or bioassay evaluations will exist for use in followup,of accidental exposures or incidents of potential internal exposure.

These evaluations may include analysis of other media including hair, blood, saliva, nose wipes', and excised tissue or wound counting as necessary.

Internal dosimetry records will be retained in a manner similar to the external dosimetry records. Additionally, a quality assurance program will be in place to assure the accuracy of the measurements, the records system and overall effectiveness of the program.

l B.2.3 Radiological Control Instrumentation 1

WVNSCo will provide a full suite of radiological control instrumentation for West Valley operations. The instruments will be. inventoried and a roster of instruments will be maintained.

Instruments will be purchased using only approved procurement specifications and upon receipt, will be subjected to per-formance tests and inspected to assure that the specified performance criteria have been met.

A maintenance and calibration program will be established for the instruments, the program will have the following essential elements:

Instruments will be assigned to a maintenance and. calibration schedule; s

Records will be maintained to provide a calibration / maintenance history e

l for each instrument; t

Calibrations will be performed using written procedures and NBS trace-o able standards.

In addition to the calibration records, calibration stickers will be affixed to the instruments which indicate the date of calibration and when the next calibration is due; Instrument calibration will-be subjected"to internal surveillance and e

audit; and l

e Instruments will be source checked daily prior to use to ensure oper-ability. A source check card will be attached to each instrument as a record of daily source checks.

Fixed counting instruments will be located in facilities appropriate to the use of the instruments. For example, instruments used for analysis of environmen-tal media will be located in an as low as background area as possible.

It is WVNSCo's intent to utilize state-of-the art instrumentation.

B.2.4 Sealed Source and Radioisotope Control The sealed source control-program is described in the Radiological Controls manual. As a general rule, no sealed sources may be purchased without the approval of Radiological and Nuclear Safety and an approved purchase specifica-tion. Although the purchase of radioisotopes is not anticipated, the control program will be essentially the same as that for sealed sources in the event that they are required.

~

4 Uponreceipt,sealedsourceswillbelekktestedandplacedonthesealed source inventory list. Leaking sources will not be accepted and arrangements will be made for their safe return to the manufacturer.

In. addition to the receipt leak test, sealed sources will be leak tested annually. Source dis-posal will be controlled as to disposition and will require removal from the source inventory list. The souce inventory list will also indicate' transfer of sources between organizations._ Sealed sources will be inventoried quarterly.

~

For irradiation sources such as high-range calibration facilities or radio-graphy equipment, the design of the facility or system shall meet ANSI N543-1974, as-built engineering drawings of the facility will be maintained current, user training and certification will be required and an operational 4

survey program will be developed for the' system or facility.

Initial startup and any modifications to the safety interlock system will require safety com-mittee review and approval. Records of facility operations, maintenance and calibration will be retained in an auditable manner.

The sealed source program will meet the requirements of 10 CFR Part 34.

B.2.5 Radiation Producing Machines The purchase of radiation producing machines.is not_ anticipated; if such equip-ment is needed on either a permanent or contractual basis, the controls to be applied will be similar to those discussed in section B.2.4.

Radiography, whether performed by WVNSCo or subcontract personnel will be required to meet 10 CFR 34. The specific controls will be described in detail in the Radiologi-cal Controls Manual.

B.2.6 Facility-Related Controls Facility-related controls include the following:

c Building rules; e

Glove box and hood controls;

/

e Breathing air system control; e

Ventilation and ventilation system control; and e

Area posting and contamination control General facility rules and regulations on conduct in radiologically controlled areas and contamination control will be contained in the Radiological Controls manual. Employees performing work in these areas will be required to be quali-ficd as radiation workers,-facility rules and regulations and contamination control are presented in~ detail during the Radiation Worker Training program.

When other than routine operations or maintenance are required, the radiologi-cal controls to be applied to the work are specified in a Radiation Work Permit (RWP). RWP's are issued by the Radiological Control Technician for a specific operation and lists the survey requirements, special dosimetry requirements and protective clothing or devices required to perform the work. RWP's are issued on a 24-hour basis and must be reissued if the work extends beyond that time l

.l l

For exposure control, the total dose received by all personnel during I

period.

the job will be recorded on the RWP.

Glove boxes and hoods will be controlled to AIGH ventilation standards.

Per-sonnel assigned to work in glove boxes and hoods will receive special training in contamination control and bag-in/ bag-out techniques as part of Radiation Worker Training.

Breathing air needed for work in contaminated areas shall meet the specifica-tions for Grade E air and will not be supplied from a potentially contaminated source.

Ventilation systems and ventilation balance will be maintained by Facility Operations personnel such that contaminated areas of the facility are main-tained at a pressure lower than atmospheric. Temporary portable ventilation j

When such

• systems may be used for ventilating walk-in containment devices.

systems are used, they will discharge air either to a filtered ventilation sys-tem or through two stages of HEPA filters.if discharged to the room air or environment directly.

Controlled area postings will meet or exceed the requirements of 10 CFR 20 with respect to direct radiation exposure.

In addition to direct radiation expo-sure, contaminated areas will also be identified. Areas to which entry is not permitted for any safety-related reason are identified as " restricted access Entry to these areas is permitted only under special controls and areas."

As a general rule, yellow and magenta will be detailed work procedures.

reserved colors to indicate the presence of contamination or radiation, these colors will not be permitted for other applications.

Controlled area standards and posting requirements will be contained in the Radiological Controls manual.

B.2.7 Personal Protective Equipment and Clothing Personal protective equipment and clothing suited to the hazard present will be supplied on an as-needed basis or permanently assigned depending on the nature of the equipment used. Protective equipment to be provided includes:

e Anti-contamination clothing; Respiratory protective devices; e

Prescription eyeglasses for use in respjratysp6.W.

o Body cooling suits or supplied air suits as appropriate; and e

Disposable. prof.ective clothing.

e Protective apparel will be stored at the change room or control point in the Protective clothing will be process building for normal facility entry.

removed when personnel exit a controlled surface contamination area, clothing designated for use in contaminated areas will not be permitted to be worn else-where in the facility. Used protective clothing will be stored in closed metal receptacles at the change point. When special protective apparel is required -

~

l in addition to the normal anti-contamination clothing (such as air-supplied suits in a walk-in containment) the apparel will be removed and stored at the L

exit of the containment area.

l Sanitized and tested respiratory protective devices will be stored at the work location or change room / control point in sealed plastic bags. Respirators will not be reworn without decontamination, sanitizing, refurbishing if necessary, and testing. Used respirators will be collected for processing at the exit of l

the contaminated area.

Protective clothing and respiratory protective equipment will be laundered and sanitized by a licensed off-site vendor. Laundering and sanitizing will be perforihed against a'n approved specification. Materials returned from the laun-dry will be inspected upon receipt to ensure that the clothing has been prop-erly decontaminated prior to reuse.

Items not meeting the specified limits will be returned to the vendor for reprocessing. Respirator refurbishing will

,be performed by the contractor, performance testing will be done by WVNSCo per-sonnel.

B.3 Industrial Hygiene and Safety B.3.1 Hazardous / Toxic Materials Control

'AtWVNSC[$Aterialcontrolbeginswiththereviewofpurchaserequisitionsto

~

identify potentially hazardous / toxic materials.

Industrial hygiene and safety will review all prchase requisitions with safety significance to assure that unique hazards 5aphInot being introduced into the facility and to assure that proper controls are being applied to receipt inspection, storage and disposal.

The Westinghouse Electric Corporation provides hazardous material data sheets to its industrial hygiene organizations to identify hazardous materials and recommend appropriate controls and safe work practices for these materials and their disposal. This information will be available for conducting reviews of purchase orders. Hazardous material disposal will be controlled to assure that disposal meets the intent of EPA criteria.

A listing of the types of purchased material requiring review will be contained in the Industrial Hygiene and Safety Manaul. These will include among others:

o Power tools; l

e Safety equipment; e

Compressed gases; e

Fire protection equipment; Nonionizing radiation producing equipment; and, e

o Ladders and scaffolds.

B.3.2 Routine Safety Survey Program The routine safety survey program consists of the following elements.

4 f

=

Supervisor's Area Safety Inspection e

The, area safety inspection is a supervisor's tool for inspecting his work area (s) for potential safety hazards. The inspection will be per-formed every other month by supervisors who are responsible for labora-tory, shop and manufacturing areas. Each cognizant supervisor is required to sign and date an Area Safety Inspection Report when the inspection is completed. Completed forms shall be retained by super-visors for at least two years.

Supervisor's 07fice Safety Inspection

~

i e

The supervisor's office safety inspection will be performed annually by supervisors responsible for office areas or at the written request of t-Industrial Hygiene and Safety.

The Supervisor's Office Safety Inspec-tion Report is issued to area management to guide them in performing their inspections. Completed office safety inspection forms shall be returned to Industrial Hygiene and Safety for review.

e Emergency Equipment Inspections To insure emergency equipment provided throughout WVDP is available and The in good working order, it will be inspected on a regular basis.

l inspection responsibilities and frequency for each type of equipment j

and the inspection guidelines are contained in the Industrial Hygiene and Safety Manual. Those supervisors identified as having " ownership 1

responsibility" have the overall responsibility to ensure the equipment is both available and functional, Industrial Hygiene and Safety Inspections o

The safety surveillance engineer will perform periodic safety inspec-tions of site areas to identify deviations from established safe prac-tices and regulations. He will be accompanied by the area supervisor during the inspection and unsafe practices or conditions will be reported to the supervisor.

A report documenting observations and rec-ommendations requiring corrective actions will be sent to the area supervisor with a copy to the next higher level of management. During these inspections, the safety surveillance engineer will check the per-formance of the area Supervisor's bi-monthly inspections.

B.3.3 Health Hazard Controls Prior to the implementation.of any activity or operation and prior to changing any established operation, Industrial Hygiene and Safety will review and approve facility design plans including layout drawings and operating proce-For operations with safety significance, i.e., potential safety haz-dures.

The plan ards, the operating group manager will prepare a written safety plan.

will identify safety controls and procedures necessary for the safe performance Because this of operations in compliance with applicable safety standards.

safety plan will supplement operating proce ures, only crucial safety.

requirements will be incorporate into the plan. The plan will be reviewed and approved by Industrial Hygiene and Safety.

Inthedesigneffort,WVbCowillconsiderengineeringcontrolsinfavorof people-oriented or adminisf.cative controls.

The principal considerations in design will be the substitution of less hazardous materials or processes where Isolation o,f the process in a hood or glove box will be consid-practicable.

cred as an alternate with ippropriate consideration of cost in term of initial capital investment, maintenance, space, worker productivity, decontamination and disposal in addition t0' safety-related concerns such as noise, vibration, heat, etc. Area ventilation will also be considered in system design in both a local and general sense. The followin$ considerations will be given to the ventilation design to assure that toxic material concentration will be main-tained below the threshold limit value (TLV):

7.y, e

Potential for generating contaminants; l

General ventihtion will meet AIHA and/or AIGH recommendatiod; e

local exhaust will meet kIHA and/or AIGH reconrnendations; e

Ventilation systems will be inspected annually for:

e a.

unsafe chemical accumulation, b.

containment effectiveness, c.

performance of scheduled-. maintenance l

d.

air balance, e.

contt'inant loading, f.

functioning of special equipment.

l B.3.4 Sampling and Analysis i

Because of WVMSCo's intent to supply engineering controls for operations involving hazardous / toxic materials, a routine industrial hygiene sampling and analysis program is not anticipated to be necessary.

However, the capability will be prov Hed to sample a variety of media including; e

Air; e

Sound levels; e

Water; Biological (bioassay); and, e

4 e

Electromagnetic radiation and light.

Sampling will be done either with equipment purchased specifically for'the project, by contract industrial hygiene services, or by the Westinghouse Elec-tric Corporation industrial hygiene services organization.

As discussed above, the strategy in industrial hygiene sampling will be princi-pally to verify the proper functioning of engineered controls such as 5

~

ventilation systems, fume hoods and other isolation devices. A minimal level of nonroutine sampling for hazardous / toxic materials may be performed in addi; tion to specific tests of engineered controls to supplement the legal record.

.When it is not practicable to provide engineered controls for short-term condi-tions, people-oriented controls and work area sampling will be substituted.

Sampling will be done to assure that exposure limits are not being exceeded-and to provide a legal record of the exposure which will be retained in the employee's medical record.

In the event that the anticipated exposure period is lengthy, bioassay baseline sampling may be required. The Westinghouse Elec-l tric Corporation " Medical Surveillance Manual" will be used to direct the type When an industrial toxin and radioactive materials exist of bioassay required.

as co-contaminants, the level of control applied will be suited to the more hazardous substance. For example, son'e decontamination agents used at WVDP-may contain hazardous / toxic materials; when these agents are used in a radioac-

• tively contaminated environment, the employee protective' apparel and equipment will be designed to preclude exposure to both agents. As such, personnel expo-sure monitoring and work area samples may not be required for the chemical-agent.

B.3.5 Personal Protective Equipment Personal protective equipment will be made available, used and maintained in a sanitary and reliable condition. The area supervisor will ensure that employes and visitors within their drea wear appropriate protective equipment whenever it is necessary by reason of hazards encountered.

All personal protective equipment made available will be of safe design and construction for the work to be performed. Protective equipment will meet or exceed appropriate governmental require.nents such as American National Stan-dards Institute (ANSI) and National Institute of Occupational Safety and Health (NIOSH) requirements. The type of protective equipment which will be made available will include items for:

e Eye and face protection; s

Foot protection; e

Head protection; e

Hand and arm protection; e

Respiratory protection; Body and leg protection; and, e

e Protection against falls.

The respiratory protective devices used at WVNSCo will meet NIOSH/MSHA stan-dards. The respiratory protection program will provide at least the following elements: -

Written operating procedures for respirator selection and use will~be a.

developed, Respirator selection will be based on the hazards to which the worker b.

is exposed.

The user will be instructed and trained to use the respirator properly c.

and to recognize its limitations.

The respirator will be assigned to an individual for his exclusive use d.

when possible.

Respirators will be cleaned, disinfected, refurbished and retested I

e.

after usa.

Respirators will be stored in a convenient, clean, and sanitary place.

f.

Emergency respirators will be inspected at least monthly and after each g.

use.

Surveillance of work area conditions and th'e degree of employe exposure

~

h.

~

or stress will be monitored.

The continuing effectiveness of the respirator program will be regu-i.

larly evaluated.

. Jy Only those persons who are physically able to perform the work and use The local j.

the equipment will be assigned tasks requiring respirators.

physician will determine the pertinent health and physical conditions.

The respirator user's medical status will be reviewed periodically.

The respirator Only approved or accepted respirators will be used.

k.

must give adequate protection against the particular hazards, in accor-dance with the standards of NIOSH/MSHA.

The following types of respirators will be provided in conjunction with the program:

Particulate Removing Respirators a.

Particulate removing respirators protect personnel against inhalation of nonvolatile airborne particles in the form of dust, spray, and They usally consist of one or two particulate removing car-mist.

Half tridges connected to a half-mask facepiece or a full facepiece.

mask face pieces.will not be permitted for radioactive work, t

b.

Chemical Cartridge Respirators bhemicalcartridgerespiratorsusuallyconsis'tofoneortwocartridges containing granular adsorbants or catalysts) attached to a half-mask facepiece or a full facepiece.

These respirators protect against low

.Q concentrations of vapors or gases such as acid gases, ammonia, and sol-vent vapors.

'A c.

Airline Respirators A source of compressed air (compressor or pressurized tank)' supplies-

~

respirable air through a hose to the wearer of an airline respirator.

The airline respirator is used for a wide variety of airborne contami-nants, both particulate and gaseous, and for higher concentrations of gases and vapors.

d.

Self-Contained Breathing Apparatus A self-contained breathing apparatus is a respirator that employs a supply of air carried by the wearer to provide him with a respirable atmosphere.

Self-contained breathing apparatus offers respiratory pro-tection against toxic vapors, gases, particulates and combinations thereof in any concentration; and against any degree of oxygen defi-ciency.

B.3.6 Crane and lifting Safety Overhead cranes, jib cranes, pendant cranes, and hoists will be inspected by both Facility Operations and at least annually by a professional representative of a crane manufacturing company including non-destructive examination of hooks. The specific inspection requirements to be applied to cranes, the inspection records and related documentation to be utilized in the crane inspection program will be presented in detail in the Industrial Hygiene and Safety manual.

In addition to periodic inspections, cranes will be load tested in accordance with specific procedures. Both static and dynamic tests will be performed; all cranes and hoists will be subjected to static tests, trolley and bridge cranes will be subjected to dynamic +asts.

Cranes and hoists will be tested prior to use, after installation and annually thereafter and prior to use after a cable change or major repairs. Specific load test criteria will be contained in the Industrial Hygiene and Safety manual. Cranes and hoists will be operated only by personnel qualified and certified to operate the specific piece of equip-mer.t. Operators will be issued a WVNSCo Operator's Permit, the qualification standard for crane operators is contained in the Industrial Hygiene and Safety manual. The number of qualified crane / hoist operators will be minimized to the maximum extent practicable to sustain operations.

Similar qualifications are required of fork-lift operators.

In addition to standards.. dealing with cranes, specific requirements will be delineated in the Industrial Hygiene and Safety manual for slings.

The elements of this program include requirements in the following areas:

e Identification; e

e Storage;

, l w

e Inspection; e

Safe operation.

B.3.7 Fire Protection Program Fire protection services will be provided within the Industrial Hygiene and Safety organization to assure compliance with ERDA Manual 0552.

This pcogr.am will contain the following essential elements:

Provideandmaintainanimprovedriskleveloffireprotectionad5quate o

to meet the objectives of ERDA manual 0552 for physical property and material; Provide a higher standard of fire protection than that required to meet e

improved risk requirements when justified; Provide statements of policy, conduct audits and surveys and training c

as necessary to minimize losses from fire and related incidents; Maintain an active in-house program to include the. elements of an e

improved risk program identified in ERDA Manual 0552 Part II; Establish a program to assure that DOE fire protection standards and e

guides are incorporated into plans and specifications for all new facilities; Conduct loss potential analyses for facilities on a regular and formal e

basis and at a frequency related to the potential loss (but at least annually);

Submit an annual summary of the fire protection program and loss expe-o rience from the previous year.

/

In addition to these programmatic items, the following areas will be addressed relative to existing and planned facilities.

Plans, procedures, equipment and crained personnel adequate to permit centrolling any credible fire emergency that may arise will be provided.

In addition to onsite capability port arrangements will be made with the local fire protection agenc,ies. mutual sup-When practical, physical means such as geographic isolation, firewalls, and fire doors will be used to limit the maximum size of areas that could be dam-aged in the event of a fire.

Good construction practices will be utilized such as fire resistive or noncombustible buildings and materials with isolation or segregation of hazardous operations.

Enclosures for stairways, elevators, ducts or other openings which present a potential for horizontal and vertical fire spread will use fire resistant construction materials and devices such as fire dampers to limit spread.

Protection of special hazard areas will be provided by fire control systems and systems such as filters, relief valves, blast walls etc. to minimize damages associated with fires.

Adequate and reliable fire protection water supplies i

4 and distribution systems such as hydrants, standpipes, etc. will be provided for fire fighting. Automatic and manual means for detecting and reporting incipient fires will be provided as.necessary. A watchman service will be pro-vided in accordance with the "AEC Fire Protection Guide, Watchman Service."

For short term special hazards such as welding, cutting and burning, permits are required. The permits specify special controls such as fireproof screens l

and clothing, a firewatch and fire fighting equipment which must be on hand at the work site for the duration of the job.

B.3.8 Medical Services The WVNSCo medical services program will meet the requirements of ERDA Manual I

0528 and assures the health and safety of employees in the work environment through the application _of occupational medicine. The program will be used to:

s I

Assure mental and physical fitness of employees to perform their jobs e

without undue risk; Provide early dete'ction and t'reatment of employee illness or injury by-e means of scheduled periodic health evaluations and unscheduled visits to the physician; e

Provide health counseling; immunization and alcohol / drug abuse counsel-ing; and to il Conduct special examinations for respirator wearers, crane and vehicle e

operators, and to determine employees who are sensitive to the effects of other occupational stresses.

i In addition to records of physical condition and medical health, occupational exposure information such as radiation and toxic material exposure histories will be maintained in the employees record. WVNSCo will arrange for'outside emergency medical services with a local facility which with WVNSCo support, will be capable of providing medical treatment of contaminated patients. A nurse will be availai'le at the West Valley facility on a specified schedule during the normal shift and will bis available off shift for emergency support, an occupational medicine specialist will be retained on contract to Povide part-time on-site medical services.

In addition to the DOE criteria, consider-ation will be given to the requirements of the Westinghouse Electric Corpora-tion medical services policy.

B.4 Environmental Protection B.4.1 Management Support -

4 The initial program staff will consist of an environmetal protection engineer and one technician. Additional personnel will be added as program needs expand, which will updgrade the environmental protection group to full depart-ment status as identified in Section A.2.1.

The program will implement the reporting requirements of DOE 5484.1 Chapter 4.

B.4.2 Airborne Radioactive Effluent Control During the initial phase of WVNSCo operation the environmental protection per-sonnel will evaluate existing sources of airborne radioactive effluent and their monitoring systems. The evaluation will be targeted to determine:

6 The potential for elimination of release points; e

The potential for consolidation of release points; e

Mechanisms for decreasing or eliminating discharge; and e

Adequacy of the existing monitoring systems.

Once necessary changes are identified, the changes will be addressed on the basis of a prioritized schedule.

In addition, trends observed in airborne mon-

,itoring data will be used as a means of assessing the effectiveness of opera-tional control of radioactive material at the site.

Following the initial operating phase, the act.ivities described above will become part of the normal l

ALARA program at the site.

Some areas of potential concern in the present facility are:

e Adequacy and testing of airborne filtration systems (ERDA 76-21 and ANSI N510-1975);

e Adequacy of existing airborne effluent monitors and their associated alarm systems; and, s

NBS traceable calibration of the equipment in the airborne monitoring system including detection efficiencies, and air flow rates.

The airborne effluent monitoring system will be upgraded, if necessary, to: 1) meet existing DOE regulatory requirements, 2) comply with ANSI N13.1, 3) assure that off-line analysis of samples and monitoring of effluent stream are accu-rate, and 4) meet existing industry standards and practices for the sampling of respirable airborne radioactive particulates. The results of the analysis of airborne effluent releases will be summarized and retained as a lifetime rec-ord. No gaseous airborne radioactive monitoring is planned for the site since there is no credible mechanism for releasing significant amounts of radioactive material in gaseous form.

The airborne effluent monitors will have at least one alarm level and may have a second low-level alarm. The alarm level will be based on:

e The potential for' exceeding the offsite dose limits using conservative meteorological assumptions; e

The most limiting isotope which would be detected by the system; e

The efficiency of the monitoring system; t

Assuring that off-site doses are ALARA; and,

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6 The potential for exceeding existing effluent release limits (as speci-fied in 10 CFR 20 and measured at the release point.)

The low-level alarm will be set at a factor of 4 to 10 lower than the high-level alarm on certain systems to allow operator action. to prevent a potential release.

The actions to be taken in the event of an alarm will be specified in operating and emergency procedures.

B.4.3 Liquid Radioactive Effluent Controls A program similar to that described in B.4.2 will be implemented for evaluation and control of radioactive liquid effluents.

,B.4.4 Effluent Sample Analysis Environmental samples will be evaluated by either an on-site or contract envi-ronmental laboratory using specific Environmental Procedures (see B.l.3) or approved specifications. The laboratory procedures will utilize techniques such as:

o Gross counting; 6

Spectroscopic analysis; and, o

Chemical separation techniques to isolate specific isotopes of interest.

In analyzing environmental media, all analytical techniques and equipment used will be calibrated in a manner traceable to NBS standards. The analysis will consider the effects of background activity, sample contamination, minimum detectable activity of the analytical method.

To ensure valid analytical results, a documented program to assure calibration of instrumentation, verify the reproducibility of the analytical method and daily accuracy checks to assure the validity of the calibration of the equip-ment or analytical techniques will be used. The quality program will include the use and documentation of blind and spiked samples. These requirements will be implemented t'ircugh the Environmental Procedures. Results of the analytical techniques will be documented in a readily retrievable form.

In addition to maintenance of analytical data, some key environmental samples may be archived indefinitely after counting for future reference.

B.4.5 Environmental Monitoring and Reporting 111 environmental monitoring and sampling programs will be designed to assure

-Sat the sample taken is " representative" and that the analytical techniqyes suitable to the material analyzed. The program will chose sampling point sities which will be based on the probability of detecting a significant act on the environment.

The specific implementation of the program will be tred in the Environmental Procedures (see section A.3 for development and oproval requirements)..

i B.5 Radioactive Materials, Shipping and Criticality Safety B.5.1 Radioactive Materials Shipping B.S.l.1 Receiving Radioactive Material Shipments All incoming shipments of radioactive material will be surveyed for contamina-tion and direct radiation, evaluated for compliance with the shipping regula-tions, and their receipt documented. The receiving procedures will be speci-fied in the standard operating procedures.

Upon completion of the receiving procedures, the radioactive material will be stored in an approved secure area in a manner which minimizes exposure of personnel in.the area.

B.S.I.2 Shipping Radioactive Materal All material shipped either on-site or off-site at WVNSCO Will be shipped in a a

manner which complies with 00E, 00T, and NRC regulations.

B.5.1.2.1 Packaging of Radioactive Shipments The shipper will package the radioactive material in an approved shipping con-tainer. Selection of a package for shipment of radioactive material will con-sider:

e Activity; o

Isotope (s);

o Physical form; 4

e Chemical form; e

Associated hazardous material (co-contaminants);

e Volume of material; e

Mass of material; Projectedcontainerdoserates(ALARA);

e e

Transport vehicle design; and, The limitations specified in the Certificate of Compliance (C0C) or

)

e license for the package.

Package selection will'be described in a standard operating procedure.

The shipper will follow the specific standard operating procedures for the, shipping container to be used.

In addition, the shipper will possess a c6py of the applicable C0C or license and the applicable standard operating _ procedure and verify that the packaging is in compliance with both documents.

B.5.1.2.2 On-Site Shipment of Radioactive Materials The shipper will have in his possession and follow the applicable standard In addition, the shipper operating procedure for the package he is shipping.1) provide th will:

The transfer documents, and 2) any special transport or loading instructions.

shipper will also notify the receiver upon shipment, who will in turn notify All aspects of the shipment will be covered by spe-the shipper upon receipt.

cific standard operating procedures.

B.5.1.2.3 Off-Site Shipment of Radioactive Material l

The Radiological Control Technicians will provide radiological support to In addi-Facility Operations as specified in standard operating proce

,all applicable federal laws for shipment of hazardous materials.

5 B.5.1.2.4 Radioactive Materials Shipping Support All personnel with responsibility for 1)' procedural evaluation, 2) shipment evaluation, 3) surveys of radioactive shipments, or 4) other shipping support activities will have specific training appropriate to their level of responsi-bility(seesectionA.7).

B.S.2 Criticality Safety During the initial phase of WVNSCO operation, the potential for accidental criticality will be evaluated and the program here-in described will be modi-fied as necessary to assure compliance with DOE requirements and " cost effec-tive operation" of the facility.

l B.5.2.1 Management Support The E&0S criticality safety program is implemented by the Lead Nuclear Safety Engineer, under the authority of the Manager of Radiological and Nuclear The staffing in the department will be increased as necessary to pro-Safety.

vide support appropriate to the program needs.

B.S.2.2 Criticality Safety The Radiological and Nuclear Safety organization will implement controls to assure that there is no criticality following any two unlikely and independent All factors affecting the poten-credible events involving fissile materials.

tial for nuclear criticality will be considered in criticality safety analyses, these include for example:,

Mass of fissile material; o

e Source geometry; 4

b-e Moderation; and, i

j e

Reflection.

4 Requirements for criticality analyses, verification and internal review proce-dures, and documentation of analyses are presented in detail in the criticality safety procedures.

I In any area where criticality is credible, Radiological and Nuclear Safety will insure in~lusion of criticality safety requirements in all procedures, design c

documents, etc.

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B.5.2.3 Nuclear Safety Training i

Personnel will receive nuclear safety training commensurate with their respon-j sibilities. The training program is briefly described in Section A.7.

4 l

h.5.2.4 Criticality Alarms and Dosimeters i

j Criticality alarms and criticality dosimet'ers will be placed as required in 00E Order 5480.1 Chapter 4.

Where feasible the criticality alarms shall use neu-l tron rather than gamma detectors.

B.S.2.5 Abnormal, Conditions l

In the event of an abnormal condition (one which may violate a mass or geometry i

control), no action will be taken except at the direction of the manager of l

E&0S or his delegated representative. Following resolution of an abnormal con-i dition, corrective action taken and the preventative action to preclude recur-rence of the event event will be documented as specified in the Radiological Controls Manual.

B.6 Emergency Planning Program l

B.6.1 Emergency Planning The emergency planning program encompasses preparations for dealing with any emergency which may occur during the course of the WVDP.

j The emergency planning program includes planning'and preparations for personnel i

emergencies, plant emergencies, site emergencies, emergency alerts, and general emergencies impacting the public. The program includes plans for controlling 4

and mitigating the effects of natural phenomena, fire, nuclear incidents /

accidents, radiological incidents, environmental releases, and personnel injuries.

i The emergency planning p ogram also' includes the organization established for dealing with emergencies, emergency communication and warnings, emergency equipment and facilities, emergency support organizations available to assist a

i the WVDP in specific emergencies,-and emergency preparedness and' training.

3 36 -

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Planning for dealing with emergencies is documented in the WVDP Emergency Plan. The WVDP Emergency Plan will meet the requirements of DOE Order 5500.

Specific procedures for dealing with emergencies will be documented in the WVDP.

Emergency Procedures Manual.

Responsibility for the WVDP Emergency Plan and the WVDP Emergency Procedures Manual resides with the Plant Operations Manager.

B.6.2 Classification of Emergencies

~

The WVDP Emergency Plan will include provisions for dealing with various kinds of emergencies recognizing that the type, severity, and potential consequences of emergencies vary widely depending on their nature. Classifications of emer-gencies include personnel emergencies, emergency alerts, plant work area emer-gencies, site emergencies, and general emergencies. The Emergency Plan will recognize the various types of emergencies which may exist and plans for con-

. trolling and mitigating their effects.

B.6.3 Emergency Organization The WVDP Emergency Plan will include the WVDP emergency organization. An ini-tial emergency organization composed of personnel availatile on-site on all shifts and a final emergency organization composed of senior personnel which is mobilized to take charge of the emergency situation are described. The WVDP emergency organization defines the roles and responsibilities of personnel in both the initial and final emergency organizhtions.

The initial emergency organization is headed by the Operations Shift Supervisor and includes E&OS, Operations, and Security personnel on-site during all shifts; the final etter-gency organization is headed by the Deputy Project Manager or his designated alternate and includes senior E&0S, operations, and technical management to be mobilized at the site to take charge of emergencies as indicated in the Emer-gency Plan.

B.6.4 Emergency Support Emergency support is available to WVNS personnel from various local, state, and federal agencies. Local support is available from the West Valley Volunteer Fire Company (ambulance service and fire control), the Cattaragus Co. Sheriff, medical and health support from the Bertrand Chaffee Hospital in Springville, Concord Medical Group, and the Cattaragus and Eric County Health Departments, and support from the Cattaragus Co Natural Disaster Coordinator.

State agency support is available from the New York State ERDA, New York State Police, and State Warning Point at Albany.

Federal support is available through the Department of Energy Idaho Operations Office Warning Communications Center, DOE Region 1 Radiological Assistance Team, and Region 1 Directorate of Inspection and Enforcement of tha USNRC: The WVDP Emergency Plan and Procedures will include plans and procedures for noti-fying and requesting assistance from local, state, and federal agencies as required.

B.6.5 Emergency Equipment Emergency equipment is maintained at various locations at the WVDP and at Bertrand Chaffee Hospital in Springville.

Emergency supplies at the WVDP include Monitoring Kits, Emergency Rescue Paks, Self-Contained Breathing Apparatus, Medical Supplies and Surgical Equipment, Fire Fighting Equipment (extinguishers and hose stations / hydrants). The Bertrand Chaffee Hospital is equipped with a room for decontamination, evalua-tion, and medical treatment at the Reception Ward. The room is equipped with supplies and equipment for decontamination and emergency treatment of personnel as described in the emergency procedures.~

B.6.6 Emergency Warning and Communications Emergency warning at the WVDP site is provided by the site public address sys-

. tem and the evacuation siren if evacuation of the site becomes necessary.

Com-munications during emergencies are provided by the site public address system, CB radio units, security radio, the Cattaragus Co. Sheriff's radio, and the site telephone system. Notification of off-site personnel and agencies will nominally be via telephone with radio communications as a backup.

Communications to federal agencies (DOE, NRC, etc.) and New York State agencies will be coordinated with the 00E-ID0 site representative.

B.6.7 Emergency Procedures Emergency preparedness at the WVDP will be maintained by personnel training and drills which will be conducted in accordance with the WVDP Emergency Plan.

Drills will be conducted at specified frequencies in accordance with the DOE criteria and will include realistic drill scenarios and appropriate levels of contact and involvement of outside support agencies.

B.7 Nuclear Waste Management

.s As discussed in Section A.1, it is WVNSCo's policy to control radioactive waste collection, processing, transportation, storage, and disposal in a manner which reduces the radiation exposure of workers and the general pub-lic to the lowest levels practicable. This policy is implemented by the requirements, documents and the operating procedures discussed in Section B.l.7.

The following paragraphs briefly describe key features of the nuclear wast: management program dealing with facility-generated low-level wastes. High-level waste processing and hi-level waste form criteria are beyond the scope of the ES&H program clan.

B.7.1 Airborne and Liquid ~ Effluents The airborne and liquid radioactive effluent control programs are presented in Sections B.4.2 and B.4.3 respectively.

Bases for action levels (cor.centrations where protective or corrective actions are required) and alarm points (concen-trations where effluent releases are shutdown or diverted)'are contained in the Radiological Controls Manual.

1 B.7.2 Solid Low-Level Wastes Solid low-level radioactive wastes include materials such as smear papers, HEPA filters, contaminated gloves, disposable protective clothing, and decontamina-tion materials etc. For the purpose of this program plan, low-level solid waste includes both low-dose-rate transuranic and non-transuranic wastes.

B.7.2.1 General Requirements Every effort will be made to reduce both the volume and radioactive content of site-generated solid radioactive wastes.

Volume reducton methods will include waste segregation, compaction and potentially waste incineration if stabiliza-tion becomes necessary. The radioactive content of solid wastes will be reduced by controlling waste-producing systems either by administrative means or by design changes to eliminate the source or control the release of radioac-tive materials.

i Solid wastes will be collected in lined fireproof containers such as metal drums and will be segregated into compressible and non-compressible wastes at the point of generation. For ease of handling, used HEPA filters will be con-tained in plastic, placed in either wooden or cardboard boxes and removed from the facility.

If it becomes necessary to temporarily store used HEPA filters at the generation point, they will be placed in metal or fireproof containers.

Waste collection containers will be color-coded and labeled for compressible or non-compressible waste use. The waste containers will be sealable and meet the packaging requirements for on-site shipment of solid radioactive materials.

i Waste materials placed in the containers will be contained in plastic to permit later segregation if required and compaction without speading contamination.

Solid wastes will be collected on a prearranged schedule and at designated locations in the facility. Weather and fire protection will be provided for the facility waste collection / storage area. Waste containers will be trans-ported to a waste processing area for compaction into drums or with a compactor capable of compressing several drums of waste into a large wooden box for on-site storage, on-site disposal, or transportation off-site. A system will be in place to specially process or compact contaminated HEPA filters.

i B.7.2.2 Transuranic Wastes Transuranic (TRU) wastes are defined as "those contaminated with certain alpha-emitting radionuclides of long half-life and high specific radiotoxicity to greater than 10 nanocuries/ gram." The radionuclides included are 233-0 and its daughters, plutonium, and transplutonium nuclides except 238-Pu and 241-Pu (unless co-contaminated with 239-Pu). Throughout the solid waste collection and processing program,.TRU wastes will be segregated for special treatment, packaging, storage and disposition. The waste material will be subject to cri-teria which makes the waste suitable for ultimate disposal in a repository (if such criteria are identified by the 00E). TRU waste packaging will be compati-ble with the packaging criteria for 20-year retrievable storage..

Determination of TRU content of containers will be based on either direct assay measurements or estimates based on the radiosotopic content of the materials being placed in the containers.

B.7.3 Liquid Radioactive Wastes Transport of wastes on site in the liquid form will not be permitted except for small volumes of waste for the purpose of analysis. Liquid wastes will either be processed to remove or reduce their radioactive contents prior to release or solidified in concrete or another suitable agent.

B.7.4 Sludges Non-reactive sludges will be solidified prior to disposal by mixing with cement or other suitable agents.

W.7.5 Reactive Wastes Reactive waste forms such as acid wastes, contaminated resins which are poten-tially capable of producing gases, hydrocarbon wastes containing high concen-trations of alpha emitting nuclides, etc., will be stabilized prior to packag-ing and transport for disposal.

Stabilization and disposal will be planned in advance of producing reactive waste forms to preclude long-term on-site storage in the reactive form.

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