ML20031F501
| ML20031F501 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/1981 |
| From: | Eadie G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-41 NUDOCS 8110200013 | |
| Download: ML20031F501 (5) | |
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WMUR w/F WMUR r/f WM r/f NMSS r/f SEP 22 1981 PDR GEadie HPettengill WMUR:GGE JLinehan WM-41 DMartin RScarano
!!EMORANDUM FOR:
William M Shaffer III r
New Facilities Section BFisher > Q
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Uranium Recovery Licensing Branch fy 3
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FROM:
Gregary G. Eadie OCT 6 1981 Operating FacilitiesSection II
,e u.s..w m,,,, / g Uranium Recovery Licensing Branch m~ma PRELIMINARYREVIEW0FDOE'S"RADIOLOGICALC0thROL _
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PLAN FOR UllTRAP AT SALT LAKE OFF
SUBJECT:
I have reviewed the June 1981 DOE report prepared by Ford, Bacon, and Davis, Utah, Inc. titled "UMTRAP--Salt Lake Off-Site Properties, Radiological Control Plan", and have the following comments:
1.0 Contamination Control This section discusses the operational procedures to be used to control contamination levels both cn and off-site. The discussions of site access, truck loading and unloading, routing, and accidental spillage are adequate. The final decontamination of all equipment will be as detailed in NRC's " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear liaterial".
Conclusion The proposed contamination control program appears to be adequate; therefore, no further action is required.
2.0 Radiological Control Staffing This section discusses the responsibilities of the radiological control staff. The Health Physics Supervisor is responsible for the radiological control program. Radiation monitors will perform the actual surveying of personnel and equipment. Radiation technicians will perform the laboratory analyses, and instrument maintenance and calibration programs.
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DF MJ Conclusion The proposed radiological control staff appears to be adequate. However, it should be required that there will be full time Health Physics coverage i
of all operations at both the re.nedial action site and at the Vitro aisposal site.
3.1 Environmental Monitoring Two high-volume airborne particulate samplers will be operated during site excavation, and filters will be analyzed for gross alpha concentrations.
An action level of 50% of the NRC's values in 10 CFP. 20 Appendix'B will be used to determine the need for additional dust control measures at the sito.
Working Level grab sampling will be conducted inside structures during remedial action, and analyses will be completed using the approved Bureau of Mines method. Additional Working Level monitoring will be completed using other analysis systems such as the Harshaw Radon Daughter Analyzer, track etch, and the RPISU. Working Level exposures will be kept to less than 2 Working Level Months (WLM) in any consecutive three month period.
Radon grab samples will also be collected to provide supplemental infomation. Radon samples may also be.taken using Wrenn chambers and track etch.
Conclusion 1.
On-site airborne particulate sampling should be conducted continuously during the actual excavation operations at tne remedial action site and also during operations at the Vitro disposal area in order to i
evaluate the workers exposures.
2.
Also, continuous airborne particulate sampling should be conducted at a downwind boundary location in order to evaluate potential exposure to the " general population" surrounding the Vitro disposal area. This boundary monitor need only be operated if the results of the on-site sampling, as required in #1 above, indicates airborne particulate levels in excess of 10% of 10 CFR 20, Appendix B, Table II values.
i 3.
Rather than the proposed 2 Working Level Months (WLM) exposure criteria which may result in allowing exposures up to 8 WLM in a year, the Working Level exposures should be compared to the NRC's 10 CFR 20 Appendix B. Table I or Table II values (i.e., 0.33 or 0.033WLrespectively).
4.
To date, the NRC has not received any calibration data for the track etch devfce for measuring Working Levels and therefore, the NRC has not approved this device for Working Level monitoring
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Therefore, until adequate calibration data has been purposes.
received by the NRC. the use of Track Etch devices for Working Level deteminations for remedial action designation or for confimation of cleanup shall not be acceptable.
5.
The RPISU is not a passive detector since it has an active air pump which requires 110 volt AC electrical power. Also, the TLD chips fmm the RPISU should be calibrated in known Working Level atmospheres and real samples should be " read out" on the same instruments as i
used for the original calibrations.
In the past, the EPA Las Vegas Facility has supplied RPISU units, and the EPA has completed the l
calibration, read out, and data reporting for Working Level measurements.
3.2 Soil Contamination and Excavation Control The EPA clean-up standard has been interpreted to mean 5 pCi of radium-226 per gram of soil above background levels. Micro-R-Meters will be
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. used to perfom game radiation surveys. Bore Hole logging will be dcne
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using a Nal crystal in order to determine the extent of buried residual
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radioactivity.
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i Conclusions 1.
The details of the detemination of the radium-226 concentration of background soils for the Salt Lake City area should be provided l
since it has been proposed to " clean-up" areas to 5 pC1/g of radium-226 above background levels.
2.
The u ; of direct gama radiation surveys should be utilized to detemine the extent of contamination by residual radioactivity rather than relying on " elevated Working Levels measurements to dictate that gama measurements" will be perfomed inside a structure.
A reliable gamma survey can be completed and documented as a floor diagram of the structure / property rather easily and often faster than obtaining the results of Working Level sampling.
3.3 Measurements for Confirmation of Clean-up Soil samples will be collected and analyzed in the laboratory to confim the level of clean-up success prior to backfilling. Also, a gama radiation survey will be completed to demonstrate that the levels are less than 20 pR/hr above background (i.e., the EPA Standard 40 CFR 192).
Working level grab samples will also be collected; but, after restoration of the property, track etch Working Level monitors will be used for three months to confirm successful remedial action.
Conclusions l
1.
In order to c.onfim successful clean-up of residual radioactivity at a property, it should be adequate to show that the gama radiation
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levels anywhere on the surface of the >roperty is less than 20 pR/hr above the backgmund level, and that tie radium-226 in soil is less than 5 pC1/g. Such surveys obviously indicate the presence of
- elevated levels of radioactive materials and therefore negate.the need to conduct grab, or three mt,ath sampling, or annual average Working Level measurements.
4.0 Calibration Procedures ano ality Assurance Calibration procedures were provided for the Micro-R-Meter, Geiger counters, alpha survey meter, radon Lucas cell, and the other gama spectrum analysis systems. Details of the QA Program were not provided; however, the QA Program has been reviewed and approved by Sandia National Laboratories - Albuquerque.
Conclusions 1.
The claibration of the Micro-R-Meters utilizing the procedures provided in Appendix 1
" University of Utah Laboratory Information" should be reevaluated.
a.
The proposed procedure uses Cs-137 to calibrate the instruments; -
howeve the gama spectrian of interest is from radium-226 and its dahe sters (i.e., Bi-214).
b.
The radiation field produced from the Cs-137 source " ranges from 0.0 uR/hr up to 100 R/hr, depending on the distance fmm the source." However, the lower msponse range on the Micro-R-Meter, and the act;ual radiation level of interest, is much less than this 500 pR/hr lower limit for this Cs-137 source.
Instruments should be c441brated at radiatton levels in the range of 20 to 100 pR/hr.
Other Considerations 1.
Adiscussionofthepersonneldosimetry(e.g..filmbadge.TLD,or pocket dosimeter) requirements for the workers at the remedial site or at the Vitro disposal site should be provided.
2.
Although the Appendix contained a letter describing analysis of urine samples for uranium, no discussion was provided of the bioassay program. The details of a bioassay program which includes: the individuals who are mquired to participate, frequency of sample collection, baseline data collection, and analysis for uranium, and radium-226 concentrations should be provided.
1 3.
The details of the "pmtective clothing" requirements (e.g., work gloves, coveralls, boots, etc.) for the workers at the remedial action site and at the Vitro disposal site, and for the truck drivers should be provided.
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The details of a " personnel skin contamination" surveys program (e.g., the use of hand-held 51pha contamination probes, and/or hand and foot monitors) should be provided.
S.
The details of a program to minimize the ingestion of radioactive materials (e.g., areas of no smoking, no drinking and no eating) should be provided.
6 The details of the emergency medical treatment prograr; for workers who are injured while working in the contaminated areas should be providwi.
Resolution On September 15, 1901, G. Eadie contacted D. Ball (DOE-Albuquerque Office) to discuss several of these matters and was infomed that the health and safety requirements for the on-site workers were discut. sed in DOE's " Health Physics and Safety Plan".
It is recommended that a copy of this memorandum be transmitted to the DOE for their consideration for pertinent revisions to the subject document.
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Gregory G. Eadie Operating FacilitiesSection II Uranium Recovery Licensing Branch Division of Waste Management Approved By:
9 Harry J. Pettengill Section Leader Operating FacilitiesSection II Uranium Recovery Licensing Branch Division of Waste Hanagement Case Closed: 33000055M01E i
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