ML20035C918

From kanterella
Jump to navigation Jump to search
Application for Amend to License SNM-778 Incorporating Minor Changes & Improvements That Will Allow More Efficient Operation
ML20035C918
Person / Time
Site: 07000824
Issue date: 03/31/1993
From: Christopher Boyd
BABCOCK & WILCOX CO.
To: Adensam E
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9304090245
Download: ML20035C918 (77)


Text

_-

B&W Nuclear Environmental Services, Inc.

l

\\

a McDermott company P.O. Box 11165 s

Lynchburg. VA 24506-1165 (804) 522-5414 i

FAX (804) 522-6860 e

March 31,1993 i

U.S. Nuclear Regulatory Commission Attn: Elinor G. Adensam, Chief Fuel Cycle Safety Branch Division of Industrial & Medical Nuclear Safety Washington D.C. 20555 i

Gentlemen:

The B&W Nuclear Environmental Services, Inc., Lynchburg Technology Center is requesting an amendment to our license, SNM-778, to incorporate minor changes and improvements which will allow us to operate in a more efficient manner.

At this time for convenience, we are also making a few minor editoria! changes. A description of all of the changes is provided in Attachment 1 along with the actual proposed page changes to the specification and demonstration sections of our license. Changes are marked on the text pages by a vertical line in the right hand margin. A list of the revised pages is also being provided as Attachment 2. B&W NESI believes that these changes have no negative impact on our current operations and are administrative in nature.

This request does not significantly affect nor modify any operations which are currently approved and in progress. We believe that this request should not require an environmental i

review since it meets the categorical exclusion criterion outlined in 10 CFR.51.22 (c) (11).

l t

If you should have any further questions, please contact me at (804) 522-5753.

Since ely, harlie. Boy, Jr.

l i

Licensing & Compliance Officer Attachments cc:

U.S. Nuclear Regulatory Commission i

Attn: Stewan Ebneter, Regional Administrator 101 Marietta ST., N.W.

Atlanta GA 30323 1

f-P. R. Rosenthal

/o/

3/

M I lI 9304090245 930331 PDR ADOCK 07000824 C

PDR I

T m.

y-r.,-c

, - ~

,.r c

~ -.

t REVISIONS BY PAGE AND PARAGRAPH The following is a list of the major changes which are occurring in this submittal followed by a description of the changes by page and paragraph number.

1.

An option has been provided for the type of dosimetry used at the site based on the type of work performed and the areas frequented by the worker.

2.

The requirement for weekly radiological surveys in areas of the site which are not authorized for possession or use of licensed materials has been deleted. This does not have any negative impact on the radiological protection program in place for r

the restricted area.

3.

As we committed to doing in response to an NRC inspection Unresolved item

+

(URI-91-02-02), the minimum detectable limit for in-vivo counting has been more accurately defined. The Minimum Detectable Limit (MDL) is now defined as,

  • the limit which is provided by the vendor performing the in-vivo analysis for each individual taking into account the individual's chest wall thickness" On average, this value will range from 30 to 60 g U-235.

4.

The earlier discussions concerning the site's stack monitor have been modified to allow for the use of newer, upgraded equipment to replace the very old system which is currently operating.

5.

Weekly load testing was removed from the description of testing for the various back-up power systems discussed in Section 10. While the systems will be load tested periodically, we do not feel it necessary to do this on a weekly basis due i

to the wear and damage it causes on the equipment. The back-up power systems will still be tested weekly.

6.

Minor administrative errors have been corrected in Sections 2,11, and 13.

7.

The following pages were submitted in this package due to repagination only:

Pages 3-10 to 3-13 Page 5-4 Pages 12-7 to 12-10 Page 12-12 Pages 12-15 to 12-40 l

Page1

[

4 i

Attachment I Page 2-8 Paragraph 2.6.8 The previous reference to section 2.5.9 (which was incorrect) was changed to 2.5.8.

j Pace 2-9 Paragraph 2.7.2.1 The previous reference to section 2.5.9 (which was incorrect) was changed to 2.5.8.

i Pace 3-9 Paragraph 3.2.4.3.1 In sections d. and e. on in-vivo counting, the minimum detectable limit has been more accurately defined by replacing the previous value with the term "MDL" and the addition of the footnote.

Pace 3-14 Paragraph 3.2.4.6.3 In the first sentence, the words, "and in the cafeteria" have been deleted.

The second sentence, concerning weekly surveys in unrestricted areas of the site, has been deleted.

Pace 3-15 Paragraph 3.2.4.8.1 i

This has been reworded to more accurately identify the Radiological Contingency Plan.

8 Paragraphs 3.2.4.9.1, 3.2.4.9.2, 3.2.4.9.3, 3.2.4.9.4, and 3.2.4.9.5 These paragraphs have been combined into two paragraphs which provide an option for the type of dosimetry used at the site.

l t

Page 2

-_,,,,r,

~

l Paragraph 3.2.4.9.6 j

This paragraph dealing with film badges has been deleted.

Page 5-i The page numbers have shifted due to the changes on Page 5-2.

Page 5-2 Paragraph 5.1.4 The discharge rate of the stack has been revised from approximately 20,000 ft'/ min to 30,000 ft'/ min and the discharge volume from 1.1 E10 ft' to approximately 1.7E10 ft'.

Paragraph 5.1.4.2 The counting system for the stack particulate has been changed to "a low background alpha-beta" system.

Paragraph 5.1.4.4 This paragraph discussing the stack monitoring system has been modified to allow for the -

upgrading of the system with new equipment.

Page 5-3 Paragraph 5.2.2, item No.10 In the second sentence, the word " leak" was changed to " source" Paragraph 5.2.3 The word "results" was added after the word sampling.

Eage 10-2 Paragraphs 10.2.5.1,10.2.5.2, and 10.2.5.3 The word " load" was removed form the last sentences on testing in these paragraphs.

Page 3 j

~

.+.

' Attachment 1 Paragraph 10.3.1 The references to Building A were removed.

Paragraph 10.3.2.1 This paragraph was deleted.

Pages 10-3 and 10-4 The paragraph numbers on these pages have changed due to the revisions on Page 10-2.

Page 11-9 Paragraph 11.2.2 "NNFD-RL" has been changed to " site".

Pages 11-10 and 11-11 Paragraph 11.2.4 "NNFD-RL" has been changed to " site" Pages 12-i to 12-iv The page numbers have shifted due to the changes within Section 12.

Page 12-3 Paragraph 12.3.2 "All site and non-site worker will.." has been changed to read, "All site workers and non-site workers will be issued a film badge or a TLD. SRD's shall be issued to those workers expected to receive greater than 10% of the applicable limits set fonh in 10 CFR 20." Also, the last sentence of the first paragraph has been changed to read, "... place their dosimetry in a location

." vice on a rack.

Page 4

4 Paragraph 12.3.3 f

i The words, "to the receptionist" have been deleted.

Paragraph 12.3.4

" Film badge" has been changes to "TL.D or film badge".

.j The last three sentences of the first paragraph have been deleted.

4 In the second paragraph, the words, " film badge and/or monthly TLD badge" have been changed to " film or TLD badge ".

Pace 12-4 i

Paragraph 12.3.4 l

The last sentence has been reworded slightly to include the removal of " lens of the eyes" from items which comprise the whole body.

Paragraph 12.3.4.1

" Pocket Dosimeters" and " Indirect dosimeters" have been changed to "Self-Reading Dosimeters l

(SRD's)"

[

t In the second to last sentence in the first paragraph, the requirement to re-zero the dosimeters daily has been deleted.

l t

The second paragraph of this section has been deleted.

Old paragraph 12.3.4.2 has been deleted.

i New paragraph 12.3.4.2 (formerly 12.3.4.3) has been modified by deleting the second and third sentences.

Eage 12-5 Paragraph 12.6.1 Manager, Safety & Licensing has been changed to Manager, ES&H.

j Page 5 a

,}

l l

4 i

Page 12-6 Table 12-2 The window thickness and range for the stack particulate and gas monitor has been revised to l

reflect equipment upgrades.

i Page 12-11 Paragraph 12.8.1.2 i

in sections d. and e. on in-vivo counting, the minimum detectable limit has been more accurately defined by replacing the previous value with the term "MDL" and the addition of the footnote.

Eage 12-13

[

r 1

Paragraph 12.8.2 The words, " film badges, dosimeters" have been replaced with, "TLD badges" and the last i

sentence of the first paragraph deleted since this is a regulatory requirement already addressed

.j in 10 CFR.

l I'

Page 12-14 Paragraph 12.8.3.2 i

The sentence starting, "The second monitor..." has been modified to reflect an upgrade in the

- t stack monitoring system. Also the 2 cfm flow rate has been deleted since the flow rate is adjustable.

Page 13-i Figure 13-2 is now titled in the Table Of Contents as, " Vegetation & Water Sample Locations" j

vice " Environmental Monitoring Locations.'

i Figure 13-3, which was inadvertently omitted from our May 1992 license amendment, was added l

to the table of contents.

Page 6 i

J

+

Pace 13-2 i

Paragraph 13.2 The second paragraph has been modified in the same manner as paragraph 12.8.3.2.

i Pace 13-9

~

\\

This page was inadvertently omitted from the pages sent with our May 1992 license amendment and is being provided at this time. There have been no changes to this page.

i

?

[

r s

i i

5 Page 7 i

i t

t w

,-n--.,

~,,--

~

e s-s

-n-

-,e

~+~

I

8 1

1 f

LIST OF REVISED PAGE REMOVE ADD Eage Dale Eage Dalc 2-8 5/92 2-8 2/93 i

2-9 5/92 2-9 2/93 3-9 7/90 3-9 2/93 3-10 7/90 3-10 2/93 3-11 7/90 3-11 2/93 3-12 7/90 3-12 2/93 3-13 7/90 3-13 2/93 3-14 7/90 3-14 2/93 3-15 7/90 3-15 2/93 5-i 10/85 5-i 2/93 5-2 7/90 5-2 2/93 5-3 4/87 5-3 2/93 5-4 3/89 5-4 2/93 10-2 7/90 10-2 2/93 10-3 10/85 10-3 2/93 10-4 6/88 10-4 2/93 11-9 5/92 11-9 2/93 11-10 5/92 11-10 2/93 11-11 5/92 11-11 2/93 12-i 5/92 12-i 2/93 12-ii 5/92 12-ii 2/93.

12-iii 5/92 12-iii 2/93 12-iv 5/92 12-iv 2/93 12-3 5/92 12-3 2/93 12-4 5/92 12-4 2/93 12-5 5/92 12-5 2/93 12-6 5/92 12-6 2/93 12-7 5/92 12-7 2/93 12-8 5/92 12-8 2/93 12-9 5/92 12-9 2/93 i

Page1 i

i I

+s sn.

j

-i

.j i

REMOVE ADD em a to um.

l 12-10 5/92 12-10 -2/93 12-11 5/92.

12-11 2/93-12-12 5/92' 12-12 2/93 12-13 5/92 12-13 2/93 12-14 5/92 12-14 2/93 12-15.5/92 12-15 2/93 12-16 5/92 12-16 2/93

.l 12-17 5/92 12-17 2/93 12-18 5/92 12-18 2/93 l

12-19 5/92 12-19 2/93 12-20 5/92 12-20 2/93

-l 12-21 5/92 12-21 2/93-12-22 5/92.

12-22 2/93 j

12-23 5/92 12-23 2/93 l

12-24 5/92 12-24 2/93 j

12-25 5/92 12-25 2/93 12-26 5/92 12-26 2/93-12-27 5/92 12-27 2/93 12-28 5/92 12-28 2/93 j

12-29 5/92 12-29 2/93 12-30 5/92 12-30 2/93 l

12-31 5/92 12-31 2/93 12-32 5/92 12-32 2/93 12-33 5/92 12-33 2/93 12-34 5/92 12-34 2/93' 12-35 5/92 12-35 2/93 12-36 5/92 12-36 2/93 i

12-37 5/92 12-37 2/93 12-38 5/92 12-38 2/93 i

12-39 5/92 12-39 2/93 l

12-40 5/92 12-40 2/93 12-41 5/92 None 13-i 5/9 13-i 2/93 13 5/9 13-2 2/93 None 13-9 2/93 Page 2

1 l

2.6.4 Retraining - Persons who are designated as Authorized Users shall be retrained annually. Satisfactory completion of the retraining shall be determined by passing a written examination.

2.6.5 Respiratory Protection Training - Training in respiratory protection techniques and equipment shall be required of all workers before the use of such equipment will be permitted.

Satisfactory completion of this training shall be determined by passing a written examination.

2.6.6 Respiratory Protection Retraining - Retraining in respiratory pro-tection shall be performed at two year intervals.

Satisfactory completion of this retraining shall be determined by passing a written examination.

2.6.7 The training specified in Section 2.6 shall be administered by the Supervisor, Health Physics, or his designated and qualified alternate.

2.6.8 Nuclear Criticality Safety Training - Nuclear Criticality Safety training provided as a part of the programs specified in Sections 2.6.2, 2.6.3 and 2.6.4, shall be performed by the Nuclear Criticality Safety Specialist or his designated alternate. The designated alternate must meet the same minimum qualifications as those specified for the Nuclear i

Criticality Safety Specialist (2.5.8).

l 2.7 OPERATING PROCEDUPES 2.7.1 Area Operating Procedures 2.7.1.1 All operations with licensed material shall be conducted in accordance vith Area Operating Procedures or Radiation Work Permits (see 3.1.1).

2.7.1.2 Area Operating Procedures (AOP) - Area Operating Procedures shall be established for all routine operations in which SNM, source and byproduct materials are stored or handled. AOP's shall include those nuclear criticality and radiation safety controls and limits that apply to the operation.

Each AOP shall be approved by the Nuclear Criti-cality Safety Specialist or his designated alternate, the Supervisor, Health Physics or his designated alternate, the Licensing 6 Compliance Officer or his designated alternate, the Industrial Safety Officer or his designated alternate and the Safety Review Commfttee.

License No SNM-778 Docket No.

70824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 2-8 Babcock &Wilcox a McDermott company i

i

2.7.1.3 AOP's may be revised with the approval of the Supervisor, Health Physics or his designated alternate, the Industrial Safety Officer or his designated alternate, the Nuclear Criticality Safety Specialist or his designated alternate, and the Licensing & Compliance Officer or his designated alternate.

The revised procedure may be used with these approvals until the next scheduled regular meeting of the Safety Review Committee when the revision must be approved by the SRC.

2.7.1.4 AOP's shall be available in each operations area where they apply and shall be followed by site personnel.

2.7.1.5 Dit e.ribution of new and revised procedures shall be made in accordance with a document control system which assures that the procedure manuals contain only the most current revision of the procedures.

2.7.1.6 AOP manuals shall be reviewed annually by the Licensing & Compliance Officer to assure that the manuals contain the most current revision of the procedures.

2.7.2 Technical Procedures 2.7.2.1 Technical procedures shall be established, reviewed, approved, and followed for Health Physics or Nuclear Criticality Safety. They shall be reviewed and approved by a Health Physicist or the Nuclear Criti-cality Safety Specialist, respectively, or their designated alter-nates. The designated alternate for a Health Physicist must meet the minimum qualifications specified in Sections 2.5.7.

The designated alternate for the Nuclear Criticality Safety Specialist must meet the same minimum qualifications specified in Section 2.5.8.

Approval l

cignatures shall appear on the procedure.

2.8 INTERNAL AUDITS AND INSPECTIONS 2.8.1 Nuclear Criticality Safety 2.8.1.1 The Nuclear Criticality Safety Specialist or his designated alternate shall conduct internal audits for the purpose of evaluating the nuclear criticality safety aspects of operations. This audit shall be conducted in accordance with written audit guidance. This audit shall be conducted once each calendar quarter.

A report of his findings shall be made to the Manager, ES&H within two weeks of completing the License No SNM.778 Docket No.70-824 Date Feb., 1993 Amendment No.

12 Revision No.

15 Page 2-9 Babcock &Wilcox a McDermott company

4

2. Determine if area surveys support the analysis results.
3. If #2 is positive, investi-gate the cause and correct as needed.
4. If exposure is confirmed by
  1. 2, investigate to determine how exposure was incurred and correct it.

If the ex-posure exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposure until the Super-

visor, Health Physics authorizes the lifting of the restriction.

d.

In vivo

< MDL*

None l

U-235 e.

In vivo MDL-120 pg

1. Determine if area surveys l

U-235 support the analysis results.

2. If #1 is positive, investi-gate and correct as needed,
f. In vivo

> 120 pg

1. Resample the individual U-235 within 10 working days.
2. Determine if area surveys support the analysis results.
3. If #2 is positive, investi-gate the cause and correct as needed.
  • The Minimum Detectable Limit (MDL) is the limit which is provided by the vendor performing the in-vivo analysis for each individual taking into account the individual's chest wall j

thickness. On average, this value will range from 30 to 60 pg U-235.

i License No SNM-778 Docket No.70-824 Date Feb., 1993 i

Amendment No. 12 Revision No. 15 Page 3-9 Babcock &Wilcox a McDermott company

4. If exposure is confirmed by
  1. 1, investigate to determine how exposure was incurred and correct it.

If the exposure exceeds 120 pg, the worker shall be restricted from further exposure until the Supervisor, IIcalth Physics authorizes the lifting of this restriction.

3.2.4.3.2 Plutonium Bio. say Program 1.

All workers who routinely work in Plutonium handling areas shall be subject to the Plutonium bioassay program.

The minimum frequency for urine sampling shall be six months. The minimum frequency for in vivo counting shall be annual.

Ad-ditional bioassays shall be performed when, in the judgment of the Supervisor, llealth Physics conditions during a job and/or other data (air samples, floor smears or clothing contami-nation) indicate an internal exposure may have occurred.

2.

The following are the action criteria for the routine Plu-tonium bioassay program:

Action Analysis Level Action to be Taken

a. Urinalysis

< 0.2 dpm/L None

b. Urinalysis

> 0.2 dpm/L

1. Resample the individual within 5 working days.

j

2. The Supervisor, llcalth Physics shall consider the need for worker restriction to prevent further exposure until the diagnostic evalu-ation is complete.

Only the Supervisor, 11enith Physics may lif t any work restriction once it is imposed.

3. Determine if area surveys support the analysis results.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-10

)

Babcock & Wilcox a McDermott company l

4

4. If #3 is positive, investi-Eate the cause and correct.
5. If the exposure is confirmed by #1 investigate to de-termine how exposure was incurredand correct it.

If the exposure exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposure until the Super-

visor, 11e alth Physics authorizes the lifting of this restriction.

c.

In vivo

< l.6E-8 Ci None Pu-239 d.

In vivo a 1.6E-8 C1

1. Restrict the worker from Pu-239 further exposure.
2. Resample the individual within 10 working days.
3. Determine if area surveys support the analysis results.
4. If #3 is positive, investi-gatethe cause and correct as needed.
5. If exposure is confirmed by
  1. 2, the Supervisor, Health Physics shall determine the organ dose. If the confirmed exposure exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposures until the Super-
visor, Health Physics authorizes the lifting of this restriction.

l License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-11 1

Babcock &Wilcox a McDermott company l

6. The restriction in #1 may be lifted by the Supervisor, Ilealth Physics if the results of the analysis performed under #2 fails to confirm the analysis.

3.2.4.3.3 Fission Product Bioassay Program 1.

The fission product bioassay program sampling frequency shall comply with Regulatory Guide 8.26, September, 1980.

2.

Additional bioassays shall be performed when in the opinion of the Supervisor, llealth Physics, conditions during the job were such that significant internal exposure may have occurred. The following are action criteria for additional bioassays.

Action Analysis Level Action to be Taken In vivo

>10% MPOB Remeasure subject to determine effective half life of the contaminant and plot decay curves. Follow-up program will continue until the contamination present is

<5%

MPOB or the effective half life has been determined.

Estimation

>10% MPOB Submit in vitro sample for from nasal analysis within 5 working days.

smears or air sample In vitro

>5% MPOB Resample excreta to confirm presence of contamination and to establish rate of climination.

Perform isotopic analysis if

>10% of MPOB is a possibility.

In vitro

>10% MPOB In vivo measurement to be made soon as practicable.

as License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-12 Babcock &Wilcox a McDermott company

i 3.

The Supervisor, Ilealth Physics shall be responsible for evaluations to determine the location and amount of depo.

sition; to provide data necessary for estimating internal dose j

rates, retention functions, and dose commitments; and to

)

determine if work restrictions or referrals for therapeutic treatment are required for any case where a result indicating a greater than 10%/MPOB deposition of a radionuclide is verified.

3.2.4.4 Protective Clothing 3.2.4.4.1 The use of protective clothing shall be specified in Area Operating Procedures and Radiation Work Permits.

3.2.4.4.2 Protective clothing may also be specified by the llealth Physics Group.

In the event of conflicts between the Area Operating Procedure, Radiation Work Permit, and the llealth Physics Group, the decision of the latter shall prevail.

3.2.4.5 Pespiratory Protection 3.2.4.5.1 The Respiratory Protection Program shall be conducted in ac-cordance with 10 CFR 20.103, and shall be a responsibility of the llealth Physics Group.

3.2.4.5.2 The Respiratory Protection Program shall be implemented through written and approved procedures.

3.2.4.6 Surface Contamination Monitoring 3.2.4.6.1 The llcalth Physics Group shall perform smear surveys in the below listed areas at the indicated minimum frequencies:

Action Level Area Frecuene_y (dom /100 cm2)

<.........................-ALPilA-----

Unirradiated, unencapsulated Weekly 5000 fuel handling areas Building B Counting Lab.

Monthly 200 Hot Cell Oper. Area Monthly 200 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-13 Babcock &Wilcox a McDermott company

Scanning Electron Monthly 200 Microscopy Lab.

Exit portals from Biweekly 200 controlled areas

<-.-_................---BETA + GAMMA---------------------->

Building B Counting Lab.

Monthly 2000 Scanning Electron Monthly 2000 Microscopy Lab.

Hot Cell Operations Area Bimonthly 2000 i

Cask Handling Area Bimonthly 22000 Radiochemistry Lab.

Bimonthly 22000 Exit portals from Biweekly 2000 controlled areas j

3.2.4.6.2 Large area smears are used to survey many square meters of surface area.

To determine if these smears indicate that an action level has been exceeded, the assumed area covered shall not exceed 1

1-square meter.

3.2.4.6.3 Daily surveys shall be performed in snack bars and vending machine j

areas located within the restricted area.

If contamination is l

detected in any of these areas, corrective action shall be taken at i

once.

3.2.4.7 Decontamination j

3.2.4.7.1 The Health Physics Group shall determine and direct the action to be i

taken to protect personnel and reduce the levels of contamination below those specified in Section 3.2.4.6.

3.2.4.7.2 Decontamination to reduce levels of contamination shall begin within 24-hours of the discovering survey.

If the survey is made just prior to the beginning of a holiday or weekend, the contamination shall be marked and labeled, and decontamination shall commence during the first regular workday after the survey.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-14 Babcock &Wilcox a McDermott company

3.2.4.7.3 Fixed contamination that, in the opinion of the Supervisor, Health Physics does not substantially contribute to a worker's exposure, shall be posted and its location and radiation level recorded and its removal shall be scheduled as soon as practicable.

3.2.4.7.4 Fixed contamination that, in the opinion of the Supervisor, Health Physics may substantially contribute to workers' exposure shall be posted and removed as soon as practicable.

3.2.4.8 Emergency Evacuation 3.2.4.8.1 Refer to the Radiological Contingency Plan, which is addressed in Section 8 of this License.

3.2.4.9 Personnel Monitoring 3.2.4.9.1 Site Workers, Non-Site Workers, and Visitors to Restricted and Controlled Areas shall be issued a thermoluminescent dosimeter (TLD) or a film badge.

3.2.4.9.2 Self-reading dosimeters (SRD) shall be issued to those workers expected to receive greater than 10% of the applicable limits set forth in 10 CFR 20.

3.2.4.9.3 Whole body dose equivalents to workers shall be limited to 300 mrem / week and 1.25 Rem / quarter by the appropriate Area Supervisor.

1 I

i 1

I License No SNM-778 Docket No.

74824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 3-15 Babcock &Wilcox a McDermott company

4 TABLE OF CONTENTS Section Page 5.0 ENVIRONMENTAL PROTECTION 5-1 5-1 5.1 EFFLUENT CONTROL SYSTEM,.

5-2 5.2 ENVIRONMENTAL MONITORING License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 5-1 Babcock &Wilcox a McDermott company

5.1.3.6 Waste tanks that indicate concentrations of activity greater than those specified in section 5.1.3.2 shall be appropriately diluted prior to release.

5.1.3.7 The NNFD aust approve the release of liquid waste to their waste treatment facility prior to the release.

5.1.3.8 The 10,000 sq. ft. Storm Drain Collection Pond shall be grab sampled quarterly.

The sample shall be analyzed for gross alpha and gross beta.

5.1.4 Gaseous Effluent - Discharge air from process areas is released to the general environment through the 50-meter high stack. The discharge rate of the stack is approximately 30,000 cubic feet per minute. The annual discharge volume is approximately 1.7E10 cubic feet. Planned discharges to the air shall be in compliance with 40 CFR 61.

The annual exposure resulting from these planned discharges shall not exceed 25 millirem whole body and 75 millirem to any organ.

5.1.4.1 Action Icvels - The action 1cvels for releases from the stack are specified in section 3.2.2.5 of this Part I.

5.1.4.2 Analyses - The fixed filter of the stack particulate monitor shall be l

counted on a low background alpha-beta counting system, after an appropriate decay period.

The results shall be recorded and main-tained on file.

5.1.4.3 Sampling - The stack shell be sampled isokineticalh on a continuous basis.

5.1.4.4 Monitoring - The stack sample will pass through a monitoring system that is capabic of measuring alpha and beta particulate and nobic gases. This monitoring system will have the capability of recording data and alarming when alarm set points are exceeded. The stack air will be sampled isokinetically.

5.2 ENVIRONMENTAL MONITORING 5.2.1 The environment surrounding the site and the Mount Athos plant site is sampled periodically to determine whether the radiation and radioactive material levels in the area surrounding the site have changed as a result of the operations at this location.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 5-2 Babcock &Wilcox a McDermott company

l 5.2.2 The following types of sampics shall be taken at the below indicated frequencies:

1.

Site boundary air sample - monthly.

2.

Grab sample of the J ame s River above and below the point of I

discharge - monthly.

3.

Continuous sampling of rain water.

4.

Crab sample of river silt - quarterly.

5.

Direct radiation survey shall be made of the water channel passing through the railroad right-of-way - annually.

6.

Direct radiation survey shall be made at the east end of the canal 1

- annually.

7.

Vegetation sample - semiannually.

8.

Direct radiation monitoring at the site boundary - continuously.

9.

Accumulated water from the soil retention basin shall be sampled annually and if its activity exceeds 10% of the concentration specified in Appendix B, Table 2, Column 2, of 10 CFR 20, the collected water shall be disposed of through the liquid waste disposal system.

10.

Accumulated water from the Temporary Storage Facility shall be sampled and analyzed once each calendar quarter and if activity exceeds 30 pCi/L Beta-Gamma, an investigation shall be made to determine the cause.

If the source is from a waste container, l

action will be taken to prevent further contamination.

If contamination is found, Sub-sections 7.2.3.8 and 7.4.1 of this application shall be amended to incorporate the decommissioning of the Temporary Storage Facility.

{

5.2.3 The evaluation of environmental sampling results shall be performed by l

either the site personnel or a qualified outside concern.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No.15 Page S-3 Babcock &Wilcox a McDermott company

1 5.3 GROUNDWATER MONITORING 5.3.1 Monitorine System The groundwater beneath the Liquid Waste Disposal Facility (IRDF) shall be sampled periodically to determine the presence of Cesium-137 and Cobalt-60; the primary contaminants (from historical sampling of the tanks prior to discharge) in the waste water that is collected in the iMDF.

5.3.2 Samplinn Each well shall be sampled on a quarterly basis for two years, beginning in November, 1987. After this period, if no action IcVel is exceeded, the sampling interval shall be one each year, either in the winter or spring.

5.3.3 Analysis Each well water sample shall be analyzed for gross beta-gamma activity.

Samples may be analyzed for alpha activity if warranted by storage tank sample results.

5.3.4 Action Levels and Actions to be Taken Cross beta-gamma activity exceeding 30 pCi/L shall require the following actions:

plan to determine the source of the 1.

Prepare and implement a

activity, to include checking for alpha activity if warranted.

2.

Submit a report to the NRC Region II Office in the event that the investigation shows leakage in the tanks.

5.3.5 Pecords Records of well sampling and analyses shall be retained at the Site until the NRC authorizes their disposition. These records shall include the sample date, analytical results, each instance that the action level was exceeded, the actions taken, any changes made to the system, and all reports made to the NRC.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 5-4 Babcock &Wilcox a McDermott company

10.2.5.1 The Onan emergency generator will start automatically on loss of site power and provides emergency power to one llot Cell exhaust fan, the stack monitoring system, and emergency lighting.

This engine /

generator is fueled by natural gas and is provided with a source of propane gas as a backup source of fuel.

The Onan system is tested

[

weekly.

10.2.S.2 An Invertastat provides &n uninterruptable source of electrical power for the criticality monitors, emergency evacuation alarm, and the alarm panel in Building B.

The invertastat operates, upon loss of battery, with sufficient capacity to normal site power, from a provide its loads with power for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The invertastat and battery are tested weekly.

l 10.2.5.3 The stack fan is provided with a backup engine which start autc,-

matically upon loss of normal site power.

The fan supplies off gas for Building B.

It is coupled to the fan shaft by a centrifugal clutch, such that when the engine speed equals the fan speed, the clutch engages.

The engine is fueled with natural gas and this is backed up by a source of propane gas.

The emergency fan engine is tested weekly.

l 10.3 IIEATING. VENT 11ATION. AND AIR CONDITIONING 10.3.1 Heating - Space heating in Buildings B and C is provided by gas fired boilers. The room air in Building B is partially recirculated. Room air in Building C is recirculated.

10.3.2 Ventilation, Building B - The overall ventilation system for Building l

B (Figure 10-4) has been designed so that the flow of air is toward the areas of highest potential airborne contamination; the lowest pressure being within the hot cell.

All processing of licensed material in a form that could result in harmful airborne contamination or could generally contaminate personnel, equipment, or buildings, is carried out in the hot cells, glove boxes, and fume hoods.

Fume hoods and glove boxes for use with licensed material are provided with a HEPA filter, except for those specified for use with perchloric acid, in which case they exhaust directly to the atmosphere.

Fume hoods and glove boxes used in the handling of unirradiated Pu must exhaust through two llEPA filters connected in series.

Final HEPA filters are DOP tested annually or after the final filter is changed.

Final HEPA filters are provided with differential pressure indication and filters are changed when this differential pressure reaches 4-inches of water.

Special ventilation systems in Building B are described below:

License No SNM.778 Docket No.70-824 Date Fcb., 1993 Amendment No. 12 Revision No.15 Page 10-2 Babcock &Wilcox a McDermott company

e 10.3.2.1 Hot Cells - The hot cells are provided with off-gas that is passed through two stages of HEPA filters in series.

The ducting between the hot cells and the HEPA filters is constructed of steel. There is a fire damper positioned upstream of the filters that is operated by a fusible link that will close the damper in the event of fire and protect the filter.

The cells are provided with two off-gas fans that operate in "and/or" modes.

This provision permits increased off-gas when the cells are opened or maintenance of the off-gas system when one fan requires maintenance or fails.

The off-gas exhausts to the intake of the Building B stack fan.

The off-gas system provides sufficient capacity to maintain an air flow of 100 linear feet per minute through an opening. The minimum differential pressure across the hot cell face is 0.25 inches of water.

The system was designed so that either the roof slab or personnel door can be opened and a differential pressure of 0.6 inch of water would be maintained across the cell face. The opening of either of these major openings is controlled administrative 1y so that both are not opened at the same time. The volume of air removed is sufficient to remove the heat generated by lighting plus 7.5 kW from other sources and to maintain ambient temperatures below 120 degrees F during normal operations.

10.3.2.2 Radiochemistry Laboratory - The Radiochemistry Laboratory off-gas is generally provided with a provided by fume hoods.

The hoods are singic stage of HEPA filters.

Hoods that are used to handle unirradiated Pu will be provided with two stages of HEPA filters in series.

The minimum air flow rate through the hood opening is maintained at 100 linear feet per minute or greater.

Each final filter is provided with differential pressure indication. The filter will be changed when the differential pressure reaches 4 inches of water. The Radiochemistry Laboratory is provided with heating or air conditioning from the Building B room air handling system.

10.4 WASTE HANDLING 10.4.1 Liould Wastes 10.4.1.1 Liquid wastes that are potentially contaminated are piped to the Liquid Waste Disposal Facility (LWDF). A piping diagram of Building B is presented in Figure 10-5.

Vastes generated in the North-east end of Building B, which includes the Hot Cell Area, Radiochemistry Laboratory, Failure Analysis Laboratory, the Primary Equipment Cell (PEC), and the Containment, collect in a large tank located in the PEC and are pumped to the LWDF.

The remainder of the building is License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 10-3 Babcock &Wilcox a McDermott company

drained by gravity to the LWDF.

The LWDF is a below grade tank farm.

A schematic diagram of the tank arrangements, piping and pumps comprising the LWDF is shown in Figure 10-6.

Potentially contaminated waste water is piped from material handling areas to specific tanks so that the type of activity in any given tank can be anticipated. Each tank is provided with piping for thorough mixing by air spurge. The drain lines from each tank are located in the bottom of the tank to permit complete emptying.

Exceptions to this are the two 4000 gallon vaste tanks which have floating drains.

The rectangular tanks shown in Figure 10-6 are constructed of concrete with concrete tops.

The interiors are treated with a water-proofing material. Access to these tanks is gained through manholes.

The tanks indicated by circles are constructed of steel. The 300 gallon tanks are stainless steel and are not provided with inspection ports.

The 2000-gallon tanks are constructed of carbon steel, treated with an epoxy lining and are equipped with manholes for inspection.

l License No SNM-778 Docket No.70-824 Date Feb,, 1993 Amendment No. 12 Revision No. 15 Page 10-4 Babcock &Wilcox a McDermon company

Professional Affiliations:

American Nuclear Society Health Physics Society

- Uranium Section Steering Committee

- Member, Uranium Bioassay Ccmmittee 11.2.2 Supervisor, Health Physics - David L. Spangler Education:

B.S.

Biology, Core Study - Health Physics / Nuclear Science Engineering, Virginia Polytechnic Institute and State University, Blacksbur6, Virginia

- Radioactive Material Shipping Regulatory Awareness

- Contamination and Hot Particle Control.

Experience:

(1991-Present)

Babcock & Wilcox, Supervisor, Health Physics Nuclear Environmental

Services, Lynchburg Technology Center, Lynchburg, Virginia Mr. Spangler is responsible for administering the Health Physics Program at the site.

This includes respons,1bility for external and internal exposure control, shipping and receiving of radioactive material, respiratory protection, radiological safety training, and maintaining support for licensed activities.

(1988-1991)

Babcock & Wilcox, Health Physicist NNFD Research Laboratory, Lynchburg, Virginia Mr. Spangler was responsible for administering and implementing the Health Physics Program at the site. His duties included shipping and l

receiving radioactive material, shipping low-level waste, developing and implementing programs and procedures for; external exposure, contamination control, area surveillance, and instrument calibration.

(1982-1988)

Health Physicist, H.

B.

Robinson Nuclear Power Plant, Hartsville, South Carolina License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 11-9 Babcock &Wilcox a McDermott company

Mr. Spangler was responsible for developing and implementing radwaste, volume reduction and shipping programs and procedures. He was respon-sible for training and supervising waste processing and packaging groups.

Mr. Spangler's other duties included:

area surveys, radi-ation work permits, ALARA programs, instrument calibration and technical training and qualification programs.

Professional Affiliation:

American Nuclear Society (Member)

Health Physics Society (Member) 11.2.3 Industrial Safety Officer - Same as paragraph 11.2.5.

11.2.4 Accountability Specialist - Kenneth D. Long Education:

Craduate - White Sulphur Springs High School, 1958 Certificate - Bookkeeping, Central Virginia Community College, 1983 Experience:

(1974-Present)

Babcock & Wilcox, Accountability Specialist NNFD Research Laboratory, Lynchburg, Virginia Mr. Long, as the Accountability Specialist, is responsible for the accurate accounting of all Special Nuclear, Source, and Byproduct material at the site.

He is responsible for recording all transfers of SNM that are made within the site and for preparing the reports and records of off site transfers. He prepares all h7C/ DOE 741 Transaction Forms. He is responsible for the timely completion of inventories of licensed material.

He initiates the paper work required for all shipments of licensed material.

In addition to his normal duties he is a Document Custodian. In this capacity, he is responsible for the safe storage of all classified DOE and DOD documents at the site. He is also an authorized classifier and l

an authorized courier of classified material.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 11-10 Babcock &Wilcox a McDermott company

(1970-1974)

Babcock & Wilcox, Shipping & Receiving Clerk Lynchburg Research Center, Lynchburg, Virginia Mr. Long was responsible for the shipment and receipt of all materials at the site.

This assignment included the processing of all the l

necessary forms and documents used for shipping and receiving licensed materials as well as the many items that are required for operation of a research and development laboratory.

(1967-1970)

Babcock & Wilcox, Technician Lynchburg Research Center, Lynchburg, Virginia Mr. Long was a technician in the Plutonium Development Laboratory during this period. lie performed chemical operations utilizing uranium and plutonium materials and was responsible for the accountability of SNM materials in:o and out of his area.

l l

Professional Affiliations:

i Institute of Nuclear Materials Management (Senior Member)

Nuclear Materials Control Committee, B&W (Secretary)

American Nuclear Society, Virginia Chapter (Member) 11.2.5 Licensing & Compliance Officer - Charlie C. Boyd Education:

l B.S.

Physics, U. S. Naval Academy, 1976 Nuclear Criticality Safety Short Course, 1987 Nuclear Criticality Safety Workshop, 1986 t

Additional Training:

l Government Institutes, Inc.

OSHA Compliance, 1991 Preparing for EPA /OSilA Inspections, 1991 Industrial liygiene for Non-Industrial Hygienists, 1992 Professional Certification:

Professional Quality Assurance Auditor, 1989 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 11-11 Babcock &Wilcox a McDermott company

TABLE OF CONTENTS Section Page 12-1 12.0 RADIATION PROTECTION

. 12-1 12.1 PROGRAM

. 12-1 12.2 POSTING AND LABELING 12.2.1 Radioactive Materials Area

. 12-1

..... 12-1 12.2.2 Contamination Area

........... 12-2 12.2.3 Radiation Area

............... 12-2 12.2.4 High Radiation Area

. 12-2 12.2.5 Airborne Radioactivity Area 12.3 EXTERNAL RADIATION - PERSONNEL MONITORING

. 12-3

. 12-3 12.3.1 Administrative Exposure Control..

. 12-3 12.3.2 Personnel Monitoring for Site and Non-site Workers 12.3.3 Visitor Monitoring and Escort Requirements 12-3

. 12-3 12.3.4 Monitoring Devices

. 12-4 12.4 DIRECT RADIATION SURVEYS

. 12-5 12.5 REPORTS AND RECORDS.

12.6 INSTRUMENTS

. 12-5 12.6.1 Types.

12-5 12.6.2 Calibration

... 12-7

. 12-7 12.7 PROTECTIVE CLOTHING License No SNM-778 Docket No.70-824 Date Feb., 1993

)

Amendment No. 12 Revision No. 15 Page 12-i j

Babcock &Wilcox f

a McDermott cornpany 1

TABLE OF CONTENTS (Cont'd)

Section Page

. 12-7 12.7.1 Clothing

. 12-8 12.7.2 Emergency Clothing 12-8 12.8 ADMINISTRATIVE CONTROL LEVELS

. 12-8 12.8.1 Internal Occupational Exposure 12-13 12.8.2 External Occupational Exposure 12-13 12.8.3 Airborne Activity 12.8.4 Liquid Activity 12-14 12-15 12.8.5 Surface Contamination 12-18 12.9 FESPIRATORY PROTECTION 12-19 12.10 OCCUPATIONAL EXPOSURE ANALYSIS 12.10.1 External Exposure 12-19 12-24 12.10.2 Internal Exposure 12-31 12.11 MEASURES TAKEN TO IMPLEMENT AIARA 12-32 12.12 BIOASSAY PROGRAM 12-34 12.13 AIR SAMPLING AND MONITORING 12-34 12.13.1 Air Sampling Program 12-35 12.13.2 Air Monitoring Program 12-35 12.14 SURFACE CONTAMINATION 12-35 12.14.1 Smear Surveying License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-11 Babcock &Wilcox a McDermott company

TABLE OF CONTENTS (Cont'd)

Section Pane 12-39 12.14.2 Direct Radiation Surveys 12.14.3 Personnel Contamination Surveys 12-40 LIST OF TABLES Tab 1e fPie 12-1 PORTABLE RADIATION PROTECTION INSTRUMENTATION 12-6 12-2 STATIONARY RADIATION PROTECTION INSTRUMENTATION

. 12-6 12-3 PLUTONIUM BI0 ASSAY ACTION CRITERIA

.............. 12-8

. 12-9 12-4 PLUTONIUM BI0 ASSAY ACTION CRITERIA 12-10 12-5 URANIUM BI0 ASSAY ACTION CRITERIA 12-12 12-6 FISSION PRODUCT ACTION CRITERIA 12-14 12-7 STACK RELEASE ACTION LEVELS 12-15 12-8 SMEAR SURVEYS IN k'ORK AREAS 12-16 12-9 ACTION LEVELS FOR 1ARGE AREA SMEARS 12-17 12-10 MAXIMUM PERMISSIBLE CONTAMINATION FOR PROTECTIVE CLOTHING 12-20 12-11 1984 EXPOSURES BY PANGE..

. 12-21 12-12 1985 EXPOSURES BY RANCE.

12-13 RADIATION EXPOSURE 12-22 12-23 12-14 EXPOSURE BY CROUP (PERSON REMS)

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-111 Babcock &Wilcox a McDermott company

LIST OF TABLES (cont'dl Table Pane 12-15 NUMBER OF URINE B10 ASSAY SAMPLES 12-24 12-16 1983 AIR ACTIVITY 12-25 12.-26 12-17 1984 AIR ACTIVITY.

12-29 12-18 UHOLE BODY COUNTS - 1983 12-29 12-19 Am - Pu LUNG COUNTING 1983 12-20 URANIUM LUNG COUNTING 1983 12-30 12-21 UHOLE BODY COUNTS 1984 12-31 12-22 ACTION LEVELS FOR LARGE AREA SMEARS 12-37 12-23 SMEAR SURVEY FREQUENCIES AND ACTION LEVELS 12-38 12-24 CONTAMINATION ACTION LEVELS.

12-39 License No SNM-778 Docket No.

70824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-iv Babcock &Wilcox a McDermott company

12.3 EXTERNAL RADIATION - PERSONNEL MONITORING 12.3.1 Administrative Exposure Control - Limits for external radiation exposure are set forth in 10 CFR 20.101 and these general limits are used at t.he site. The applicable exposure limits to be used for operations at the site are:

1.

Whole body - 300 mrem / week (with long-term exposure controlled within the 1.25 Rem / quarter limit by the worker's immediate supervisor) 2.

Skin of the whole body - 1.5 Rem / week 3.

Hands and forearms, feet and ankles - 3.0 Rem / week.

The Manager, ES&H has the authority to approve whole body exposures up to, but not exceeding, 3.0 Rem / calendar quarter. In emergencies, higher exposures may be authorized in accordance with the Radiological contingency Plan.

12.3.2 Personnel Monitoring for Site and Non-site Workers - All site and non-site workers accessing the restricted area will be issued a film badge o r a TLD.

SRD's shall be issued to those workers expected to receive greater than 10% of the applicable limits set forth in 10 CFR i

I 20.

This dosimetry will be worn by the workers when they are in the restricted area. When the workers leaves the restricted area they will place their dosimetry in a location provided for this purpose.

l 12.3.3 Visitor Monitoring and Escort Requirements - Visitors to the restricted area will be issued a TLD.

This dosimetry will be worn by the visitor when they are in the restricted area and will be surrendered when they l

depart the site. Visitors must be escorted by a site worker when in the restricted area.

12.3.4 Monitoring Devices The primary device used for monitoring exposure on site is the TLD or film badge. The exposure measured by this badge (reported in units of dose equivalent) becomes a part of the workers permanent exposure record.

In general, the worker should wear the dosimeters on the portion of the whole body expected to receive the highest dose (with the exception of extremity dosimetry issued in special cases).

The film or TLD badge l

I should always be worn in the proper orientation to ensure that exposure to non-penetrating radiation (e.g., beta radiation) is recorded.

For License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-3 Babcock & Wilcox a McDermott company L_________________._.--___________________

cases in which the exposure may vary significantly within a small area, several badges may be worn to ensure that the maximum whole body dose is measured. In this context, "whole body" means, for purposes of external exposure, head, trunk (including male gonads), the legs above the knees, and the arms above the elbows.

12.3.4.1 Self-Reading Dosimeters (SRD's)

- These dosimeters are small, l

air-filled ionization chambers used to provide a check of the daily exposure of workers and to ensure that the administrative limit for weekly exposure is not exceeded.

SRD's are capable of measuring l

external exposure to gamma radiation in the range O to 200 mR (other ranges are also available).

These dosimeters are read and recorded l

daily.

Daily readings are used also as an indication of the need to evaluate the primary dosimeter before the normal exchange period.

12.3.4.2 Thermoluminescent Dosimeters (TLD) - TLD's are small, solid-state dosimeters capable of measuring external exposure from beta and gamma radiation in the range 10 mRems to 10,000 Rem.

At the discretion of l

a Ikalth Physicist persons handling radioactive materials may be issued extremity dosimeters.

These dosimeters are small TLD chips attached to a ring and are to be worn on the fingers. TLD " finger rings" are capabic of measuring external exposure to beta and gamma radiation in the range 10 mRems to 10,000 Rems.

These dosimeters are evaluated on a frequency established by the Health Physics Group.

12.4 DIRECT RADIATION SURVEYS Surveys of the direct radiation exposure in areas on site are to be performed on a frequency established by the Health Physics Group.

In general, these surveys require the selection of the appropriate portable survey instruments based upon the anticipated radiation levels, the types of radiation expected, and the nature or type of survey to be performed.

Survey maps of the areas to be surveyed may be used to record the measured ambient radiation levels and/or, in some cases, to designate specific areas in which the exposure rates should be measured.

The survey should also include a visual examination of the area for any unusual conditions or work habits which could affect the exposures received by personnel working in these areas.

Items of this nature should be reported immediately to a Health Physicist or corrected immediately, if practical.

Results of these surveys should be reviewed by a Health Physicist to ensure that the proper posting requirements are in effect for the area and to ensure that appropriate actions are taken to keep all exposures AIARA.

License No SNM-778 Docket No.70-824 Date Feb., 1993 i

Amendment No. 12 Revision No. 15 Page 12-4 Babcock &Wilcox a McDermott company

12.5 REPORTS AND RECORDS The following records will be maintained by the IIcalth Physics Group for the periods indicated.

Ilealth Physics Supervisor audits 2 years Shipping and receiving RM forms 5 years Waste disposal records

(*)

Personnel dosimetry records

(*)

Results of Bioassays and Whole Body Counting

(*)

Releases to the environment

(*)

Radiation survey data 2 years Contamination survey data 2 years Radiation Work Permits (completed) 5 years Radiation detection instrument calibration 2 years Leak tests of sealed sources 2 years Worker training

(*)

Worker retraining

(*)

Airborne radioactivity sampling data

(*)

NRC-4 forms

(*)

NRC-5 forms

(*)

Indicates that the record will be retained until the NRC authorizes its disposition.

12.6 JFSTRUMENTS 12.6.1 Types - The commitment of site management to an effective radiation protection program includes the obligation to provide the adequate equipment and supplies for such a program. It is the responsibility of to ensure the l

the Manager, ES&H and the Supervisor of llealth Physics.

appropriate radiation protection instrumentation is available for use on site.

In addition, the Health Physics Group has the responsibility to ensure that this instrumentation is used properly, and is calibrated, maintained, and repaired as necessary.

Minimum instrumentation requirements for maintaining an effective radiation protection program are listed in Tables 12-1 and 12-2. Other specialized instrumentation may not be included in this list.

llowever, the exclusion of these instruments does not imply that their availability does not enhance the effectiveness of the radiation protection program.

License No SNM-778 Docket No.70-824 Date Feb., 1993 i

Amendment No. 12 Revision No. 15 Page 12-5 Babcock &Wilcox a McDermott company j

TABLE 12-1 PORTABLE RADIATION PROTECTION INSTRUMENTATION Radiation Instrument Sensitivity Rance Window Thickness Low-range GM Beta, Camma Ekgd. to 30 mg/sq. cm.

mR/hr Intermediate Beta, Camma mR/hr to Beta:

1 og/sq. cm.

range ion R/hr chamber High range Gamma up to 500 R/hr

>100 mg/sq. cm.

ion chamber Proportional Alpha, Beta Bkgd. to 1 mg/sq. em.

counters 500,000 cpm Proportional Neutron, fast Bkgd. to N/A counters and thermal 5000 mrem /hr Portable air Air particulate N/A N/A samplers collection only TABLE 12-2 STATIONARY RADIATION FROTECTION INSTRUMENTATION Radiation Instrument Sensitivity Ranne Window Thickness Laboratory Alpha, Beta Bkgd. to

<1 mg/sq. cm.

proportional 100,000 cpm counter Air particulate Alpha, Beta Bkgd. up

<1 mg/sq. cm.

monitors Stack particulate Alpha, Beta Bkgd. up 0.4 mg/sq. cm.

l monitor Stack gas Beta, gamma Bkgd. up 5.0 mg/sq. cm.

l monitor License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-6 Babcock &Wilcox a McDermott company

12.6.2 Calibration - Portable survey instruments shall be calibrated twice annually using approved procedures and sources traceable to the National Institute of Standards and Technology (NIST).

In addition, frequent operational checks will be performed on survey instruments while in use.

For example, Geiger-Mueller survey instruments always indicate the presence of radiation above the ambient background.

This provides an indication that the instrument is functioning.

Portable alpha survey instruments are equipped with check sources which can be used to ensure that the instruments are operating correctly. Portable ionization chamber survey instruments are not equipped with an internal check source and the user must make sure these instruments are functioning before making a radiation survey.

Fixed and stationary radiation monitoring equipment is calibrated on either a semi-annual or annual basis depending on the applicable manufacturer's recommendations and established health physics procedures.

Operational checks are performed routinely by the Health Physics technicians on the laboratory counting equipment and " friskers" located at exits from selected areas on site.

12.7 PPOTECTIVE CLOTHING 12.7.1 Clothing - The following is a list of protective clothing that is available for use by personnel during normal and maintenance condi-tions:

1.

Laboratory coats 2.

Coveralls 3.

Shoc covers, treated fabric (reusable) 4.

Shoc covers, plastic 5.

Pants, plastic 6.

Coats, plastic 7.

Hoods, fabric (reusable) 8.

Shields, spatter 9.

Glasses, plastic

10. Glasses, glass
11. Gloves, plastic
12. Gloves, surgeons
13. Gloves, heat resistant
14. Coats, heat reflective
15. Hard-hats.

License No SNM-778 Docket No.

7G 824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-7 Babcock & Wilcox a McDermott company

12.7.2 Emergency Clothing - In the event of an accident that requires special clothing or personnel protective equipment, the Emergency Response Team is provided with the following:

1.

Hard-hats, heat resistant with face shields 2.

Coats, flame resistant 3.

Boots, high top rubber with steel toe shields 4.

Cloves, chemical resistant 12.8 ADMINISTRATIVE CONTROL LEVELS 12.8.1 Internal Occupational Exposure 12.8.1.1 Plutonium bioassay action criteria.

TABLE 12-3 PLUTONIUM BI0 ASSAY ACTION CRITERIA Bioassay Techniaue Action Level Action To Be Taken Urinalysis

< 0.2 dpm/L None

> 0.2 dpm/L 1.

Resample the individual within 5 working days.

2.

The Supervisor, Health Physics shall consider the need for worker restriction to prevent further exposure until the diagnostic evalu-ation is complete. Only the Supervisor, Health Physics may lif t any work restriction once it is imposed.

3.

If #1 is positive, investi-gate the cause and correct.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-8 Babcock &Wilcox a McDermott company

4.

If the exposure is confirmed by #1, investigate to de-termine how exposure was incurred and correct it.

If the exposure exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposure until the Super-

visor, Health Physics authorizes the lifting of their restriction.

TABLE 12-4 PLUTONIUM BI0 ASSAY ACTION CRITERIA Bionssay Technicue Action Level Action To Be Taken In-vivo

< 1.6E-8 Ci None Pu-239 2 1.6E-8 Ci 1.

Restrict worker from further Pu-239 exposure.

2.

Resample the individual within 10 working days.

3.

Determine if area surveys support the analysis results.

4.

If area surveys confirm result, investigate the cause and take corrective actions.

5.

If the resample results do not confirm the exposure, the Supervisor, Health Physics may lift the work re-strictions.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-9 Babcock &Wilcox a McDermott company

6.

If resample results confirm the exposure, the Supervisor, llealth Physics shall determine the organ dose.

7.

If the exposure has exceeded 50% of the maximum permiss-ible annual dose, the worker shall remain on a

work restriction until the Super-

visor, Health Physics authorizes the removal of the restriction.

12.8.1.2 Uranium bioassay action criteria.

TABLE 12-5 URANIUM BI0 ASSAY ACTION CRITERIA Bioassay Technique Action Level Action To Be Taken

a. Urinalysis

< 9 pg/L None

b. Urinalysis 9-16 pg/L 1.

Determine if area surveys support the analysis results.

2.

If #1 is positive, investi-gate and correct as needed.

3.

Make sure individual is in-vivo counted during the next time that the counting service is at the B&W site.

c. Urinalysis

> 16 pg/L 1.

Restrict the worker from further exposure.

Resample the individual within 5

working days.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-10 Babcock &Wilcox a McDermott company

2.

Determine if area surveys support the analysis results.

I 3.

If #2 is positive, investi-gate the cause and correct as needed.

4.

If exposure is confirmed by

  1. 2, investigate to determine how exposure was incurred and correct it.

If the exposure i

exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposure until the Supervisor, Health Physics authe>rizes the lif ting of this restriction.

d. In-vivo

< MDL*

1.

None l

U-235 l

e.

In-vivo MDL-120 pg 1.

Determine if area surveys

(

l support the analysis results.

2.

If

  1. 1 is
positive, i

investigate and correct as needed.

I

f. In-vivo

> 120 pg 1.

Resample the individual U-235 within 10 working days.

j 2.

Determine if area surveys support the analysis results.

3.

If #2 is positive, investi--

gate the cause and correct as needed.

  • The Minimum Detectable Limi.t (MDL) is the limit which is provided by the vendor performing the in-vivo analysis for each individual taking into account the individual's chest wall thickness.

On average, this value will range from 30 to 60 pg U-235.

License No SN M-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-11 Babcock &Wilcox a McDermott company

4.

If exposure is confirmed by

  1. 1, investigate to determine how exposure was incurred and correct it.

If the exposure exceeds 120 pg, the worker shall be restricted from further exposure until the Supervisor, Health Physics authorizes the lifting of this restriction.

12.8.1.3 Beta-gamma activity - Workers who work in areas where beta-gamma internal exposure is likely (Hot Cells, Radiochemistry, Health Physics) shall be in-vivo counted at approximately annual intervals.

TABLE 12-6 FISSION PRODUCT ACTION CRITERIA Analysis Action Level Action To Be Taken In-vivo

>10% MPOB Remeasure subject to determine effective half life of the con-taminant and plot decay curves.

Followup program will continue until the contamination present is <5%

MPOB or the effective half life has been determined.

Estimation

>10% MPOB Submit in vitro sample for from nasal analysis within 5 working days.

smears or air sample In-vitro

>5% MPOB Resample excreta to confirm presence of contamination and to establish rate of elimination.

Perform isotopic analysis if >10% MPOB is a posribility.

In-vitro

>10% MPOB In-vivo measurement to be made as soon as practicable.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-12 Babcock &Wilcox a McDermott company

9 The Supervisor, llealth Physics shall be responsible for evaluations to determine the location and amount of deposition; to provide data necessary for estimating internal dose rates, retention functions, and dose commitments; and to determine whether work restrictions or referrals for therapeutic treatment are required for any case where a greater than 10% MPOB deposition of a a result indicating radionuclide is verified.

12.8.2 External Occupational Exposure - Personnel monitors (TLD's or other l

suitable devices) are provided to measure the radiation exposure of visitors and workers.

The Area Supervisors are responsible for keeping exposures below 300 millirem per week and 1250 millirem per quarter. The Supervisor, llealth Physics may approve weekly exposures above 300 millirem, but the quarterly limit of 1250 millirem shall not be exceeded without the approval of the Manager, ESMI.

If a worker has received the quarterly limit and the Manager, ESMI has not authorized exceeding the limit, the worker shall be restricted to prevent further exposure for the remainder of the quarter.

12.8.3 Airborne Activity 12.8.3.1 Air Monitoring Program - Air monitoring in operating areas of the site is accomplished with continuous monitors in predetermined, fixed locations. A monitor is placed in each radioactive materials handling area in which there is a potential for the release of airborne radioactivity.

Locations are selected based upon the ability of the monitor to provide a reasonable evaluation of the airborne activity in a particular area and to provide adequate warnings to those in the area of changing conditions.

The determinations are made by the llealth Physics Group based upon the operations in the area, the potential for release, the quantity and chemical form of the material.

Alarms are set in accordance with a particular operation, the material being handled, and the potential for release. Actual alarm points are set :.s low as possible commensurate with the ambient radiation levels in the area. Personnel are instructed through procedures and training to evacuate, up wind, if an air monitor alarms and to notify the liealth Physics Group. Re-entry is controlled by the Health Physics Group.

12.8.3.2 Effluent Monitors - Potentially contaminated air from chemical hoods, hot cells, and glove boxes is discharged ultimately through the 50-meter stack. Generally, exhaust air containing beta-gamma activity is passed through a single-stage 11 EPA filter which is sufficient to License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-13 l

1 Babcock &Wilcox a McDermott company

\\

l remove airborne particulates.

Air from more hazardous operations, e.g., from glove boxes, is passed through a two-stage llEPA filter.

I i

Discharges through the st.ack are monitored with a sampling head located in the stack about 25 feet above the base. Air removed by the sampler passes through a fixed filter, into the chamber of the gas monitor, and is returned te the stack. The fixed filter is monitored continuously for alpha and beta activity by a gas-flow proportional counter.

The second monitor, is a sealed proportional counter that monitors continuously for noble gases. Thc stack monitor has an adjustable flow rate and is set to sample the stack isokinetically. Both monitors are equipped with adjustable alarms. The set points for these alarms are determined by the llealth Physics Group.

The alarms are connected to an alarm panel located in the llealth Physics Area in Building B.

Alarms of the system are responded to by the 11ealth Physics Group. The alarm condition is first verified by the Health Physics Group. If the alarm is actual, the exhaust fan is secured, operations personnel are advised to stop all operations with radioactive material, the cause is investigated by the Health Physics Group, corrected by operations personnel, and the fan restarted.

TABLE 12-7 STACK RELEASE ACTION LEVELS Release Product Action Levels Beta Particulate 200 pCi/ week Alpha Particulate 1 pCi/2 weeks (long lived)

Kr-85 70 Ci/ week H-3 3 Ci/ week 1-131 200 pCi/ week 12.8.4 Liquid ' Activity - Liquids containing radioactive material are dis-charged from the area where they are generated, to the Liquid Vaste Disposal Facility.

This facility is comprised of a series of tanks.

All radioactive liquid waste is held in this facility for sampling prior to release.

If the concentration of radioactivity exceeds 25% of the MPC values listed in Table I, Col. 2, of 10 CFR 20, Appendix B, the License No SNM-778 Docket No.

74824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-14 Babcock &Wilcox a McDermott company

waste must be diluted to levels that meet this specification.

Liquid j

waste is discharged to the liquid waste processing system at the NNFD.

The NNFD must be notified and approve of each discharge from the site prior to discharge. No alarms are associated with this system because its operation is under the positive control of the Health Physics Group.

1 l

12.8.5 Surface Contamination 12.8.5.1 Work Areas - The Health Physics Group performs smear surveys in the work areas listed in Table 12 8.

The frequencies specified in Table 12-8 are minimum frequencies.

More frequent surveys are performed based on the level of work performed in the specified areas. Action is taken to protect personnel and reduce the levels of contamination below those specified.

The Health Physics Group will supervise and direct the protection and decontamination activities.

Decontamina-tion to reduce 1cvels of contamination will commence within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery.

The Supervisor, Health Physics shall evaluate and approve any delays on decontamination work that are longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

TABLE 12-8 SMEAR SURVEYS IN WORK AREAS Action Level 2

Area Frecuenev*

(dom /100 cm1

<..............................ALynA...............................>

Unitradiated, unencapsulated Weekly 5000 fuel handling areas Building B Counting Lab.

Monthly 200 Hot Cell Oper. Area Monthly 200 Scanning Electron Monthly 200 Microscopy Lab.

Exit portals from Biweekly 200 controlled areas License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-15 4

Babcock &Wilcox a McDermott company

<....................... B ET A + G AMMA - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - >

Building B Counting Lab.

Monthly 2000 Scanning Electron Monthly 2000 Microscopy Lab.

Ilot cell Operations Area Bimonthly 2000 Cask llandling Area Bimonthly 22000 Radiochemistry Lab.

Bimonthly 22000 Exit portals from Biweekly 2000 controlled areas

  • Minimum frequency specified. More frequent surveys are performed, based on work loads.

Large area smears are used to survey many square meters of surface Action levels for large area smears are given below.

area.

TABLE 12-9 ACTION LEVELS FOR IARGE AREA SMEARS 1.

Routine Large Area Smears (1000-5000 dpm) - Repeat the large area smear.

If results show levels of contamination above 1000 dpm, take smears in smaller areas to locate the source.

Decon-j taminate all areas in which the smear results indicate contami-nation above 1000 dpm/100 square feet.

2.

Routine Large Area Smears (5000-10,000 dpm) - Repeat the large area smear.

If results show levels of contamination above 5000 l

dpm, isolate the contaminated area. Take smears in smaller areas j

to locate the source. Decontaminate all areas in which the smear j

results show contamination in excess of 1000 dpm/100 square feet.

j 3.

Routine Large Area Smears (>10,000 dpm) - Isolate the contami-nated area. Survey all personnel in the contaminated area. Take smaller smears in the area to locate the source. Decontaminate License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-16 j

Babcock &Wilcox a McDermott company

all areas in which the smear results show contamination in excess of 1000 dpm/100 square feet.

Survey all persons leaving the building.

12.8.5.2 Personnel Contamination Surveys - Personnel are required to monitor themselves for activity present on their hands, shoes, clothing and person before exiti e. a contamination area.

Contamination monitors (friskers) are loce..d at all normal exits from contamination areas for this purpose. The detector should be held as close to the surface of the item being monitored as possible, without touching the item, and the probe should be moved at a slow speed over the surface. Allowable levels of contamination on skin surfaces and on items of clothing are given in Table 12-10.

Any contamination in excess of these limits should be reported immediately to the Health Physics Group. The Health Physics Group will supervise the decontamination and determine if clothing must be discarded.

The approval of the Supervisor, Health Physics shall be required to allow any individual to leave a contaminated area who is contaminated above background radiation levels.

TABLE 12-10 MAXIMUM PERMISSTBLE CONTAMINATION FOR PROTECTIVE CLOTHING 2

idom/100 cm1 Item Alpha Eeta 4 Gamma Clothing 2,200 22,000 Shoes 22,000 220,000 12.8.5.3 Release of Equipment or Packages - Packages and equipment are surveyed by the Health Physics Group.

The Health Physics Group has the authority to prohibit the release of items that are found to exceed the limits specified in Table 1, " Acceptable Surface Contamination Levels,"

d in " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Eyproduct, source, or Special Nuclear Material," dated May, 1987."

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-17 Babcock & Wilcox a McDermott company

12.9 RESPIRATORY PROTECTION The primary objective of a respiratory protection program is to limit the inhalation of airborne radioactive materials and other harardous materials.

This objective is normally accomplished through the use of engineering controls, including process, containment, and ventilation equipment.

When engineering controls are not feasible or cannot be applied, respiratory protection must be used.

The Health Physics Group is responsible for the implementation of the respiratory protection program.

The program is based on the guidance contained in 10 CFR 20, l

Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection,"

and NUREG-0041, " Manual of Respiratory Protection Against Airborne Radio-active Materials."

l The respiratory protection program will include the following:

1. Air sampling and other surveys sufficient to identify the hazard, to evaluate individual exposures, and to permit proper selection of respiratory protection equipment.
2. Written procedures to ensure proper selection, supervision, and j

training of personnel using such protective equipment.

3.

Written procedures to ensure the adequate individual fitting of respirators, as well as procedures to ensure the testing of respiratory protective equipment for operability immediately prior to each use.

4 Written procedures for maintenance to ensure full effectiveness of respiratory protective equipment, including procedures for cleaning and disinfecting, decontaminating, inspecting, repairing, and storing.

5. Written operational and administrative procedures for the control, issuance, proper use, and return of respiratory protective cquipment, l

including provisions for planned limitations on duration of respirator for any individual as necessitated by operational conditions.

use 6.

Bioassays and other surveys, as appropriate, to evaluate individual exposures and to assess the protection actually provided.

7.

Records suf ficient to permit periodic evaluation of the adequacy of the respiratory protection program.

8.

Determination prior to assignment of any individual to tasks requiring the use of respirators that such an individual is physically abic to perform the work and use the respiratory protective equipment.

A I

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revison No. 15 Page 12-18 Babcock &Wilcox a McDermott company

physician is to determine what health and physical conditions are pertinent.

The medical status of each respirator user is to be reviewed at 12-month intervals.

Other details of an effective respiratory protection program can be found in the above mentioned documents and the health physics procedures.

12.10 OCCUPATIONAL EXPOSURE ANALYSIS 12.10.1 External Exposure - The external radiation exposure received by workers is presented in Tables 12-11 through 12-14. Tables 12-11 and 12-12 show the exposures by ranges and the number of workers in each range for calendar years 1984 and 1985 respectively.

i License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-19 i

Babcock &Wilcox a McDermott company

TABLE 12-11 1984 EXPOSURES BY RANGE Annual Whole Body Dose Number of Individuals Ranres (Rems)

In Each Rance No Measurable Exposure 87 Measurable Exposure <0.100 77 0.100 to 0.250 33 0.250 to 0.500 12 0.500 to 0.750 6

0.750 to 1.000 1

1.000 to 2.000 3

2.000 to 3.000 1

3.000 to 4.000 0

4.000 to 5.000 0

5.000 to 6.000 0

6.000 to 7.000 0

7.000 to 8.000 0

8.000 to 9.000 0

9.000 to 10.000 0

10.000 to 11.000 0

11.000 to 12.000 0

>12.000 0

220 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-20 Babcock &Wilcox a McDermott company

TABLE 12-12 1985 EXPOSURES BY RANCE Annual Whole Body Dose Number of Individuals Rannes (R em s ')

In Each Ranre No Measurable Exposure 185 Measurable Exposure <0.100 83 0.100 to 0.250 21 0.250 to 0.500 17 0.500 to 0.750 5

0.750 to 1.000 3

1.000 to 2.000 2

2.000 to 3.000 2

3.000 to 4.000 0

4.000 to 5.000 0

5.000 to 6.000 0

6.000 to 7.000 0

7.000 to 8.000 0

8.000 to 9.000 0

9.000 to 10.000 0

10.000 to 11.000 0

11.000 to 12.000 0

>12.000 0

318 l

1 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-21 Babcock &Wilcox a McDermott company

Table 12-13 presents the exposures received by workers for calendar years 1981 through 1984.

The row entitled "Off Site" gives the exposures received by workers at other licensed facilities.

TABLE 12-13 RADIATION EXPOSURE 1984 1983 1982 1981 Total Person Rems 23.5 18.4 19.4 26.3 Off Site 3.5 2.0 2.5 3.0 1RC 20.0 16.4 16.9 23.3 Average Exposure 0.09 0.088

.105

.137 Number of Workers 220 208 184 192 Highest Exposure 2.25 2.04 1.9 1.7 l

l i

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-22 Babcock &Wilcox a McDermott company i

The exposure received by workers is categorized by group in Table 12-14 for exposures received for calendar years 1983 and 1984.

TABLE 12-14 EXPOSURE BY GROUP (PERSON REMS) f_r_o.un 1984 1983 Plant Engineering 5.10 2.25 Project Services 0.07 0.05 Health 6 Safety 1.85 2.16 Nuclear Materials 11.40 9.60 Chemical & Nucicar Engineering 1.30 1.53 Nondestructive Methods 0.58 0.17 Process Control 0.00 0.49 Systems Design 6 Engineering 2.12 2.09 Calendar year 1984 brought increased activity in our hot cell facility. This typically results in increased exposures to personnel in the Nuclear Materials, Plant Engineering, and llealth and Safety Groups.

Table 12-14 reflects this in all categories. Table 12-14 also reflects this increase in two of the three affected groups.

Only llealth and Safety saw a reduction in the group's exposure. The amount of exposure received from off-site work reversed a three year period of decreases.

Table 12-14 reflects this in the increase in the Systems Design & Engineering Group's exposure.

The increases noted in Tables 12-13 and 12-14 do not indicate a i

decrease in the vigilance given by site management to personnel exposures nor do they suggest a decreased AIARA emphasis.

Exposure 1

history at the site shows wide variances because of the variety of work that is performed here. Clear trends have not been evident. If l

the amount of hot cell work is considered and the fact that objects received for examination exhibit higher levels of radioactivity, the effectiveness of the A1 ARA programcan be appreciated.

The pre-liminary exposure information required on the Radiation Work Permit form was increased in early 1985. This has resulted in many improve-i ments in the manner that cell entries are made.

i License No SNM 778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-23 Babcock &Wilcox a McDermott company i

i

12.10.2 Internal Exposure - The bioassay sampling, lung counting, and air sampling programs show that the worker is exposed to extremely low levels of respirable activity.

12.10.2.1 Bioassay Results - Urine bioassay samples are taken primarily of workers who perform work with unclad uranium and those involved in any work with plutonium. Table 12-15 below presents the number of urine bioassay samples taken during 1983 and 1984.

TABLE l2-15 NUMBER OF URINE BI0 ASSAY SAMPLES 1983 1984 Month U

Pu U

Pu January 5

20 4

February 13 6

March 15 12 April 19 19 18 9

i 13 5

m.ne 16 16 17 8

July 11 8

15 6

August 10 8

15 7

September 11 14 14 7

October 11 9

16 5

November 3

1 December 5

5 14 6

In 1983, t.11 samples for uranium were less than 5 micrograms / liter (lower 1:mit of detection), except on four occasions when the analysis indicated the presence of uranium but none met the resample limit of 20 micrograms / liter. All plutonium analyses were below the minimum sensitivity which varied from 0.00 1 0.1 to 0.3 1 0.4 dpm per sample.

In 1984, all samples for uranium were less than 5 micrograms / liter (lower limit of detection), except on one occasion 27 micrograms /

liter was reported. A resample showed that the level had returned below the lower limit of detection.

All plutonium samples indi-cated 0.0 1 (0.01 to 0.6) dpm per sample.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-24 Babcock &Wilcox a McDermott company

12.10.2.2 Air Sampling Results - The air sampling program is the first line of defense for all operations of this type, but the bio-assay program, along with lung counts, is the final step in the estimation of exposure that may occur.

12.10.2.2.1 Table 12-16 presents a summary of the air sampling program for calendar year 1983, for fixed air samplers.

TABLE 12-16 1983 AIR ACTIVITY (VALUES IN pCi/ml)

Recirculated Ai r "C"

Anproximate Concentratips MPC 15 3 x10-"

1.2x10-"

1x10*

16 3 x10-"

1. 5x10-"

1x1&"

17 8.7x1045 1.8x1042 4x1&"

19 7x10-"

8. 7 x10-"

1x10*

27 2. 4 x10'"

5.7x1048 1x10*

44*

2x1045 6. 5x10-"

1x10*

Cask Handling Area

1. 9x1042 1.27x10" 9x10'
6. 7 x10-"

4. 5x10 "

4x1&"

Hot Cell 1x10 "

1. 25x10 "

9x10*

5x104'

1. 2x10 "

4x10" Recirculated Air "C"

1. 5x10-"

3.5x104) 9x10*

4x1045

1. 93 x10-"

4x10" Vaste Storage Area

1. 5x10-"
2. 6x10 "

9x10' 7x1048

1. 7x10-"

4x10~"

Laundry 3x10-"

1. 5 x10-"

9x104 3x1045 2.5x10" 4x10-"

Radio Chem Lab 7x10 "

2. 3x10 42 9x10*

1.5x10-"

1.5x10-"

4x10-"

  • Discontinued in Sept.

12.10.2.2.2 On 338 occasions in 1983, breathing zone air samples were taken to measure the airborne activity to which workers were exposed. In no case was anyone exposed to greater than 2 MPC of airborne activity in any one week. In most cases, respiratory protection was used and License No SNM-778 Docket No. 70824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-25 Babcock &Wilcox a McDermott company

I exposure Icvels were at least a factor of 1,000 below the limits.

There are three major operations which require respiratory protection, and several minor ones.

1.

Entries into the isolation area behind the hot cell. A supplied air respiratory system was installed in January, 1980, in the hot cell area which has a protection factor of at least 1,000.

This system incorporates a double bib hood which has reduced airborne activity to which a worker is exposed to below detectable levels.

2. Operations outside of the isolation area in the cask handling area using the 3M hood and the supplied air respiratory system.

This system incorporates the 3M hard hat which is NIOSil approved with a protection factor of 1,000.

Breathing zone samples are taken outside of the hood each time this system is used.

3.

Other minor operations requiring respiratory protection are:

changing HEPA filters, repair work on NPD site support equipment, and any other operations where Health Physics believes that there is a potential of airborne activity.

12.10.2.2.3 Table 12-17 presents a summary of the air sampling program for calendar year 1984, for fixed air samplers.

TABLE 12-17 1984 AIR ACTIVITY (VALUES IN Ci/ml)

Approximate Maximum Labs Average Concentration MPC 15*

3E-15 1.6E-14 1E-10 16*

2E-15 SE-15 1E-10 17*

SE-15 3.9E-13 4E-11 19 7E-15 1E-13 1E-10 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-26 Babcock &Wilcox a McDermott company

27**

2.4E-14 7.5E-15 1E-10 Soil Processing ***

IE-15 7.4E-15 4E-11 Cask llandling Area SE-13 1.2E-11 9E-9 SE-15 SE-13 4E-ll llot Cell 8E-15 6.7E-13 9E-9 SE-16 1.5E-14 4E-ll Recirculated Air 1.5E-14 1.1E-13 9E-9 Building C 1.5E-15 3.3E-13 4E-ll Waste Storage 1.5E-14 2.9E-14 9E-9 7E-16 3.3E-15 4E-ll Laundry 3E-14 6.3E-14 9E-9 2E-15 3.3E-15 4E-11 Radio Chem 3E-14 1.0E-12 9E-9 1.5E-15 2.4E-15 4E-11

  • Discontinued November 1984
    • Discontinued June 1984
      • Begun May 1984 License No SNM 778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-27 Babcock &Wilcox a McDermott company

12.10.2.2.4 On 278 occasions in 1984, breathing zone air samples were taken to measure the airborne activity to which workers were exposed. In no case was anyone exposed to greater than 3 MPC hour of airborne activity in any one week. In most cases, respiratory protection was used and exposure levels were at least a factor of 1000 below the limits.

There are three major operations which require respiratory pro-tection, and several minor ones.

1.

Entries into the isolation area behind the hot cell. A supplied air respiratory system was installed in January,1980 in the hot cell area which has a protection factor of at least 1000. This system incorporates a double bib hood which has reduced airborne activity to which a worker is exposed to below measurable levels.

2.

Operations outside of the isolation area in the cask handling area use the 3M hood and the supnied air respiratory system.

This system incorporated the 3M hard hat which is NIOSil approved with a protection factor of 1000.

Breathing zone samples are taken outside of the hood each time this system is used.

3.

Other minor operations requiring respiratory protection are:

changing of HEPA filters, repair work on NPD site support equipment, and any other operation where Health Physics believes that there is a potential of airborne activity.

12.10.2.3 In-vivo Results (1983) - k' hole body counting was performed by Helgeson Scientific Services, Inc. on 32 workers during 1983.

Three had detectable activities, no other workers indicated detectable activity.

The results of the three workers with detectabic activity is presented in Table 12-18.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-28 Babcock &Wilcox a McDermott company

TABLE 12-18 VHOLE BODY COUNTS - 1983 (ALL VALUES IN NAN 0 CURIES)

Worker Isotope

.MPEB 1

2 3

Cs-137 3E4 8

2 4

2 Mn-54 3.6E3 5

2 411 Co-60 1.1E3 311 711 In-vivo counting was performed on seven workers during 1983, for plutonium and Americium-241. These results are summarized in Table 12-19.

TABLE 12-19 Am - Pu LUNG COUNTING 1983 (ALL VALUES IN NAN 0 CURIES)

Vorker b

Am 1

0 0.00 1 0.10 2

0 0.00 0.11 3

0 0.13 0.13 4

0 0.00 1 0.14 5

0 0.00 0.15 6

0 0.00 1 0.19 7

0 0.00 1 0.16 License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-29 Babcock &Wilcox a McDermott company

In-vivo lung counting was performed on nine workers in 1983, for 2ranium.

The results are listed in Table 12-20.

Four of the nine

'ndicated positive results. However, these results were not confirmed in followup urinalyses.

TABLE 12-20 URANIUM LUNG COUNTING 1983 (ALL VALUES IN MICROGRAMS)

Vorker U-235 1

0 30 2

O i 43 3

0 39 4

42 37 5

0 41 6

38 33 7

76 45 8

0 39 9

49 44 12.10.2.4 In-vivo results (1984) - Whole body counting was performed by Helgeson Scientific Services, Inc. on 99 workers during 1984.

Twelve had positive results but these were very low levels.

A summary is presented in Table 12-21.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-30 Babcock &Wilcox a McDermott company

TABLE 12-21 UHOLE BODY COUNTS 1984 (EXPOSURE VALUES IN NAN 0 CURIES) l Number of Maximum l

Isotope Workers Observed MPBB Cs-134 1

3.0 2E4 Cs-137 7

9.0 3E4 l

Co-60 4

4.0 1.1E3 In-vivo lung counting was performed on 14 workers during 1984 for Plutonium-239 and Americium-241.

No plutonium was reported.

The presence of Americium-241 was indicated for 5 workers with the highest quantity being 0.26 NanoCuries ( 0.14) for one person.

In-vivo lung counting was performed on 20 workers during 1984 for Uranium-235.

In 5 instances, the results were positive with the highest result being 48 micrograms (137) for one person.

12.11 MEASURES TAKEN TO IMPLEMENT AIARA l

12.11.1 Irradiated metal specimens had been stored on the roof of the hot cells l

in an open top cave.

This configuration caused this roof to be I

designated as a high radiation area.

Several small totally enclosed caves have been constructed for the storage of these specimens which has climinated the high radiation area on the cell roof, thus reducing exposures received by workers who periodically enter the area for maintenance on the HEPA filters and to calibrate an area monitor.

It also eliminated the radiation area on the roof of Building B which no longer contributes to the exposure of workers who maintain the building ventilation system.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendrnent No. 12 Revision No. 15 Page 12-31 Babcock &Wilcox a McDermott company

12.11.2 Cleaning of the hot cells contributed significantly to exposure doses of workers.

This cleaning operation, which is perforned at three or four year intervals, requires the set-up table in the cell to be dismantled.

In 1985, this operation was performed remotely with a modified saw so that workers did not enter the cell for this high exposure work.

12.11.3 Trash removal from the hot cell during cell cleaning operations was significant in the past. During the c1 caning operation in 1985, trash was remotely loaded into special metal drum liners that were designated to fit into 30-gallon drums and to be handled with long poles.

This process modification reduced personnel exposures for this part of the operation considerably.

12.11.4 The site has purchased a TLD reader which provides immediate informa-tion on worker exposure.

This system is not intended to replace the normal contract service for dose measurement but rather to provide prept indication of unexpected exposures for non-routine operations.

The system makes possible the estimation of exposures to hard to measure areas of the body such as the soles of feet, hands and fingers.

12.11.5 A supplied air respiratory system has been installed to support hot cell work, principally during hot cell entries.

This system provides a

greater protection factor for workers in addition to providing greater worker comfort while performing the strenuous work.

12.11.6 The Radiation Work Permit (RWP) approval process has been revised.

Previously, the worker or his supervisor completed the RWP form and carried it to those personnel who were required to sign it.

This method has been changed such that the workers, Area Supervisors and signators of the RWP gather at a meeting where the proposed work scope and methods are discussed in detail. All facets of work are agreed to before any authorization signatures are placed on the RWP.

This new approval process requires more time being spent for the planning stage of a task but considerable exposure savings have resulted.

12.12 BIOASSAY PROGRAM Those workers routinely working in contamination or airborne radio-activit.y areas will be scheduled for participation in the bioassay program.

The Health Physics Group will select those workers to be sampled in the program. This selection will be based on the probability of exposure, the worker's work habits, the type of work in the area, air License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-32 Babcock &Wilcox a McDermott company

sample data, previous bioassay data, etc.

Routine bioassay may consist of check or whole-body counting (in-vivo bioassay) or excretion analysis (in-vitro bioassay).

In-vivo bioassay is performed routinely by a

bioassay service which comes on-site for the evaluations.

In-vitro bioassay is performed by a commercial laboratory located off-site.

Bioassay action criteria for plutonium are outlined in Tables 12-3 6 12-4.

In general, no action is required if the excretion result (i.e.,

urinalysis) is less than 0.2 dpm/ liter or the in vivo measurement of material in the lung is less than 16 nanoCuries.

All compounds of plutonium are considered to be either class W or Y.

This classification refers to the most recent evaluation of the ICRP for internal dose calculations.

Class W compounds are moderately soluble and clear from the pulmonary region of the lung with half-times in the range 10 to 100 days. Class Y compounds are essentially insoluble and are considered to clear f rom the pulmonary region with halftimes of >100 days.

No com--

pounds of plutonium are considered by the ICRP to be readily solubic (i.e., class D compounds which clear from the lungs in <10 days).

The bioassay program for uranium generally follows that outlined in Regulatory Guide 8.11, " Application of Bioassay For Uranium," June 1974.

There are two exceptions to this general guidance:

1.

Workers off-site during the regular visit of the bioassay service will not be scheduled for a special, make-up count, if the count was scheduled oniv for routine exnosure control monitorinn.

2.

Bioassays of workers working in areas in which both plutonium and uranium may be airborne shall be evaluated for both plutonium and uranium.

The Supervisor, Ilealth Physics may decide to analyze for only one of these elements, if it can be demonstrated that the analysis for a single element is a more sensitive indicator of an uptake.

Bioassay action criteria for uranium are outlined in Table 12-5.

Workers working primarily with beta and gamma emitting radionuclides will also be included in the in-vivo bioassay analysis program.

Any worker suspected of an exposure greater than 40 MPC-hours will be scheduled for bioassay evaluation as soon as practicabic after the exposure.

a Bioassay action criteria for beta-gamma are outlined in Table 12-6.

License No SN M-778 Docket No.70-824 Date Feb., 1993 l

Amendment No. 12 Revision No. 15 Page 12-33 Babcock & Wilcox a McDermott company

12.13 AIR SAMPLING AND MONITORING The presence of airborne radioactive materials in the working areas is determined through the combined use of air samplers and monitors. These programs are discussed below:

12.13.1 Air Sampling Program The air sampling program can be divided into two categories; fixed and portable.

Selection of the sampling category and the frequency of sampling is lef t to the discretion of the Supervisor,11ealth Physics.

12.13.1.1 Fixed Air Samplers - Air samples are obtained at designated points through the use of a central vacuum system.

Sampling points are located as close as possible to a permanent operator station to permit continuous sampling of the air near the worker's breathing zone.

These samples are usually co11ceted weekly.

11owever, the frequency may vary as the situation dictates.

Normally, these are evaluated within two vecks, after allowing the appropriate decay period for the radon daughter products. llowever, based on the particular operation, etc.,

a llealth Physicist may determine that it is necessary to evaluate the sampics without allowing for the decay period.

In these cases, an applicable radon decay correction factor must be applied to the results.

12.13.1.2 Portable Samplers - Air samples in the approximate breathing zone of a worker may be obtained through the use of a lapel sanpler.

The lapel sampler consists of a small sampling head attached to the worker's lapel (or collar) connected through a small flexible tube to a small air-pump worn at the waist.

The flow rates through these samplers are quite low when compared to the fixed system..

liowever, since the sampler is located near the nose and mouth and moves with the worket as he moves about the area, it provides a reasonabic estimate of the concentration of airborne radioactivity in the breathing zone of the worker.

Air sampics obtained with these samplers are evaluated on a low background, proportional counting system. Factors are applied to the counting results to account for background activity and detector j

efficiency. All results are reported in units of activity / unit volume i

of air sampled.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-34 Babcock &Wilcox a McDermott company

12.13.2 Air Monitoring Pronram Air monitoring in operating areas is accomplished with continuous monitors in predetermined, fixed locations.

Normally, a monitor is placed in each radioactive materials handling area in which there is a potential for the release of airborne radioactivity.

Locations are selected based upon the ability of the monitor to provide a reasonable evaluation of the airborne activity in a particular area and to provide adequate warnings to those in the area of changing conditions. These determinations are made by the Health Physics Group based upon the operationsin the area, the potential for release, and the quantity and chemical form of the material.

Alarms are set in accordance with the particular operation, the material being handled, and the potential for release, Actual alarm points are set as low as possible commensurate with the ambient radiation levels in the area.

12.14 SUPFACE CONTAMINATION a

1 12.14.1 Smear Surveyint I

Smear surveys are performed in all areas specified in the license and which, in the judgment of the Supervisor, llealth Physics, have a potential for surface contamination.

The frequency of these surveys will be based upon the potential for contamination in the area, previous experience with contamination in the area, and the need to keep the area free from contamination. Typical areas and survey schedules are listed in Table 12-8, however, both the areas included and the frequencies of surveys are subject to change based upon the current research activities. The frequency of smear surveys in areas not included in the table are generally specified in the procedure covering the.particular i

area.

12.14.1.1 Smear Samples - Smear samples are obtained with small, absorbent filter papers. The smear paper is moved across an area of approxi-mately 100 sq. cm. using about 5 pounds of pressure. The smear may be counted with a portable gas-flow proportional counter capable of detecting alpha or beta radiation.

Normally, smear samples are evaluated in a stationary counter located in the Health Physics Laboratory.

Appropriate conversion factors are applied to the net counts to express the smear results in units of disintegrations per

{

minute.

License No SNM-778 Docket No.

70 824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-35 I

Babcock &Wilcox i

a McDermott company i

12.14.1.2 Large Area Smears - Large area smears are obtained using the dust mop technique in areas around the site, the hot cell operations area, the change room and main hallways in Building B.

These smears are intended to indicate the general contamination environment in an area and may lead to a more extensive survey, if unexpected contamination is indicated. Normally, large area smears are evaluated with a hand-held, portable survey instrument (e.g.,

a gas-flow proportional counter such as the PAC 4G). Actions to be taken in response to the results of large area smears are outlined in Table 12-22.

12.14.1.3 Action Levels - Included in Table 12-24 are the appropriate action levels to be used in designated areas.

Decontamination shall be initiated in areas in which the removable surface contamination levels exceed these action icycls. The Health Physics Group shall determine and direct the actions to be taken to protect workers working in these areas and to reduce contamination levels as far below those listed in Table 12-1 as is possible. Normally, decontamination of an identified area shall begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the discovery.

In some cases, for example, if the contamination is discovered just prior to a weekend or a regularly scheduled holiday, the contaminated area may be marked and posted appropriately.

Such a determination shall be made by the Health Physics Group based upon the severity and extent of the contamination and the potential for further contami-nation of equipment and/or personnel during the interval. Decontami-nation of the area shall begin on the first regular work-day after discovery.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-36 Babcock &Wilcox a McDermott company

TABLE 12-22 ACTION LEVELS FOR IARGE AREA SMEARS 1.

Routine Large Area Smears (1000 - 5000 dom)

Repeat the large area smear.

If results show levels of con-tamination above 1000 dpm, take smears in smaller areas to locate the source.

Decontaminate all areas in which the smear results indicate contamination above 1000 dpm per 100 sq. ft.

2.

Routine Larre Area Smears (5000 - 10.000 dom)

Repeat the large area smear.

If results show levels of cun-tamination above 5000 dpm, isolate the contaminated area.

Take smears in smaller areas to locate the source.

Decontaminate all areas in which the smear results show con-tamination in excess of 1000 dpm per 100 sq. ft.

3.

Routine Larre Area Smears (>10.000 dom)

Isolate the contaminated area.

Survey all personnel in the contaminated area.

k Take smaller smears in the area to locate the source.

Decontaminate all areas in which the smear results show contamination in excess of 1000 dpm per 100 sq. ft.

Survey all persons leaving the building.

NOTE:

Routine large area smears are normally taken in the early afternoon to facilitate clean-up of areas found to be contaminated before the end of the normal work-day.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-37 Babcock &Wilcox a McDermott company

TABLE 12-23 SMEAR SURVEY FREOUENCIES AND ACTION 1.EVELS Alpha Radiation Smear Survey Action Level Area Freauency (dom /100 sa.cm.)

Unirradiated, Unencapsulated Weekly 5,000 Fuel Handling AREAS Building B Counting Laboratory Monthly 200 Hot Cell Operations Area Monthly 200 Scanning Electron Microscopy Monthly 200 Laboratory Exit Portals from Controlled Twice Weekly 200 Areas heta Radiation Smear Survey Action Level Area Freauency (dom /100 so. em.)

Building B Counting Laboratory Monthly 2,000 Scanning Electron Microscopy Monthly 2,000 Laboratory Hot Cell Operations Area Twice Monthly 2,000 Cask Handling Area Twice Monthly 22,000 Radiochemistry Laboratory Twice Monthly 22,000 Exit Portals from Controlled Twice Monthly 2,000 Areas License No SNM-778 Docket No.70-824 Date Feb., 1993 l

Amendment No. 12 Revision No. 15 Page 12-38 Babcock &Wilcox a McDermott company l

12.14.2 Direct Radiation Surveys Surveys of the direct radiation exposure are to be performed on a frequency established by a Health Physicist. In general, these surveys require the selection of the appropriate portable survey instruments based upon the anticipated radiation 1cvels, the types of radiation expected, and the nature or type of survey to be performed.

General maps of the areas to be surveyed may be used to record the measured ambient radiation levels and/or, in some cases, to designate specific areas in which the exposure rates should be measured. The survey should also include a visual examination of the area for any unusual conditions or work habits which could affect the exposures received by personnel working in these areas.

Items of this nature should be reported immediately to the Supervisor, Health Physics.or corrected immediately, if practical.

Results of these surveys should be reviewed by a Health Physicist to ensure that the proper posting requirements are in effect for the area and to ensure that appropriate actions are taken to keep all exposures AIJGA.

Action levels for direct radiation surveys are presented in Table 12-24.

TABLE 12-24 CONTAMINATION ACTION LEVELS Transferable Surface Type of Fixed Contamination Area Fadiation Surface Readinn (dom /100 sa. em.)

Uncontrolled Alpha 300 dpm/100 sq. cm.

30 Beta-Camma 0.1 mrad /h 220 Contamination

  • Alpha 3000 dpm/100 sq. cm.

2,200 Beta-Gamma 1.0 mrad /h**

22,000

  • The Supervisor, Health Physics may raise these action levels.

Justification for this action must be documented and forwarded to the Safety Review Committee for their review and approval.

License No SNM-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-39 Babcock &Wilcox a McDermott company

i

    • This action limit applies to contamination areas which are normally radiation areas.

This level of contamination will not cause a significant increase in radiation exposure.

l NOTE:

This tabic provides limits above which decontamination must be initiated. These action levels pertain to areas normally accessible to personnel performing normal work functions.

The levels do not apply to areas requiring extraordinary precautions for entry, e.g.,

the Isolation Area, waste water tanks, etc.

In these cases, direct health physics coverage is the primary control mechanism.

12.14.3 Personnel contamination Surveys Workers are required to monitor themselves for activity present on their hands, shoes, clothing, and person before exiting a contami-nation area. Contamination monitors (friskers) are located at all exits from contamination areas for this purpose.

The detector (probe) should be held as close to the surface of the item being monitored as possible (without touching the item) and the probe should be moved at a speed of about 0.5 inch /second.

Allowable levels of contamination on skin surfaces and personal clothing must not exceed background. Permissible levels of contamination on protective clothing are given in Table 12-10.

Any contamination in excess of these limits should be reported immediately to the Health Physics Group.

l License No SN M-778 Docket No.70-824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 12-40 Babcock &Wilcox a McDermott company

e I

)

TABLE OF CONTENTJ_

i Section Pare 13.0 ENVIRONMENTAL SAFETY.

13-1

. 13-1 13.1 ENVIRONMENTAL MONITORING

.......... 13-1 13.2 EFFLUENT AIR MONITORING

. 13-2 13.3 LIQUID EFFLUENT MONITORING.

. 13-3 13.4 GROUNDWATER MONITORING.

List of Firures Firure Pare 13-1 SITE

. 13-7

. 13-8 13-2 VECETATION & WATER SAMPLE LOCATIONS 13-9 13-3 MONITORING WELL LOCATIONS License No SNM-778 Docket No.

70 824 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 13-1 Babcock &Wilcox a McDermott company

i l

l 1

Discharge through the stack is accomplished with a large blower, powered normally by a large electric motor operated on off-site power.

Emer-gency power is supplied by an internal combustion engine coupled to the blower shaft through a centrifugal clutch.

On loss of off-site power, the engine starts automatically and takes over the load upon reaching the proper speed.

Discharges through the stack are monitored with a sampling head located in the stack about 25 feet above the base.

Air removed by the sampler passes through a fixed filter, into the chamber of the gas monitor, and is returned to the stack. The fixed filter is monitored continuously for alpha and beta activity by a gas-flow proportional counter. The second monitor is a sealed proportional counter that monitors continuously for nobic gases.

The stack monitor has an adjustable flow rate and is set to sample the stack isokinetically.

Both monitors are equipped with adj us tabic alarms.

Set points for these alarms are determined by the Health Physics Group. These alarms are connected to an alarm panel located in the Health Physics Laboratory in Building B.

Air from areas equipped with continuous air monitors (and which is below the applicable MFC for an unrestricted area) may be exhausted, through HEPA filters, directly to the roof of the building. Air from areas which have a low potential for airborne activity may be exhausted directly to the roof of the building.

13.3 LIOUID EFFLUENT MONITORING All potentially radioactive liquids are collected in tanks located in the Liquid Waste Disposal Facility.

The contents of each tank are mixed, samples are obtained, and are analyzed for radioactivity before the liquids are released to the waste treatment plant at the Naval Nuclear Fuel Division (NNFD).

Liquid waste tanks are sampled on a quarterly frequency, before release to the NNFD or at other times determined by the Health Physics Group.

Results of all analyses are reported in units of activity per unit volume and records of these evaluations are retained by the Health Physics Group.

Water samples are also obtained on a quarterly basis from the retention basin located behind Building C,

the sample pit and collection tank located adj acent to the Temporary Storage Facility, and the holding pond located near Building J.

License No SNM.778 Docket No.

704?4 Date Feb., 1993 Amendment No. 12 Revision No. 15 Page 13-2 Babcock & Wilcox a McDermott company

.. ~... ~....

/p

~

of r

k k

e B!

,.._E *$10R u ~,

q

,- g " 5 TOR M SEwtR tb b C 0-

  1. s 8 UIL DIN G C

TOP ELi v. 19 t.18 5

'O (FLOOR ( L ( V. 195.10 1

}

=

M z

y y

s 2

e a

C l

z E

L

~

2m i sw.

w-wi r i s id r < i s 3' ~;

8 TE$T wtLL NO 9 (TCP OF CONCKETE SL A B - E LE V. 49 3.16 )

N 45'-6" l

.,<.u, N,

w_

\\

-..,".,g j I l

s l

8,i 2 SamiTART siwtR-WM, TEST w f'.L k'J 5

(TCP OF CONCRETC

"'I L A 8 - E LEY.

192.*

/-

-')

8'- 5' N s sTcau s t wt a.

(

Lgcygg Y

n.c. 2 '

. a si c- ~ ~

w I,*, 8,".

_e v d o in O

cy u.o.. -

rtoonetcap c o. 4-

..c t..

O e

'N 4 3' -4"

/

I 2

y

_{

TEST WELL No. 7 g, _),, \\

G

'z m

p (s L}*

3*C. 0 TESTWELLNh

-,e j

st eint= T -~

TAWK d

,-esow._

e utt 04N G 9

e (FLOOM (Lt v.19 L 5 0 3 1

)

  • / -.

/j_

e rtuet,

e.

~

r

~ ~ -. -. ~ ~

e-m e.

ly

+\\

J A u t$

anyt'R _

tt

)UIL DI N G C - P A A KING LOT

~

NNFO l

s 1

2 NN*D t' f i

e oy Ris! ARCH LAa.

S" u. N.

TCP e

(L t v.19 2.4 8

,4 C n o m AI(ROAD g

B ABCOCK 6 wit COI C O.

PROPt # TY.WOUNT ATHos LYNCMmu R 4 vs.

D

\\

1 FIGURE 13-3 5

'l

=

g(TEsf

-tu no TCP or CONCR('[

Qg SL A S -tttv.

p o4 892.65l s.

1 n th E.. RTOjg CARD g

O_

=.

d.IhD AQik 5;le On 8

Apmure Card 13'- O"--

E po S.

p l

i.....,

)I {

o F **~. *~-**]

,)

() M. H.

[*

T[sflVfLL NO. 3 I!g

l TOP [ LEY, 152.25 iToe C-C0fCKtTE

[.

jl 4r ! ll 60 stes. ttt v. e s e.3s l

?:l 1

L.... J s..... J L

...J

,3.....

s i

G)

STORAGE TANKS 1

. 59-4 l'- 6, e

i d

pipI.i e

57 1.

2000 G A L. T ANK - UNDtAGRouN0 l

7 I;

8 2.

2000 G A L. T A N K - UNOC RCA DUND l

{s 4

r s...__...t...

o 3.

2000 GAL.1ANK - UNotnomouNo f

  • g

\\

E 4

S00 G1.L. Te hn - UNCE AG PDum D S.

300 G A L. T A NK - UNDtRG P0uMD

,4 6.

AC00 GAL TANK -

g 8

w

++

~

T.

  • dCO *'G A L. T A N K ettow GRADE.CONCRtJ(

1+

4.80000 C A L. Ti.fi K H

~

e e

H,

++

v. Ocoo G A L. T ANK

>14NKs wirn coNCatic

+ - ta.cacuMo y

~ o r'l I.

no. iso 00 c AL. TANK n as ovin.

t.

J is sooe 2At TAN,

?!

car

v. A s t e l

(Test i2. s ooo Ge t. T& 6 K -

fay,UT,.

I wt u ne. 4

'*" #i"'S

  • *'**SE

1 To, or Cou:nt T t c o N C a t,T t tA NKs s-ir sonow. its.o (Lev.

++

'o st As. ti.t v. is s.4 e SCALE l * = 19 '

NOT E :

MEAN SE A LEVEL AT SIT E 5BO TT.

T R ANSL ATED TO 2 00.0 FT. ON ALL DR AWING S f

License No SNM 778 Docket No.70-824 Date May, 1992 l

1 Amendment No. 11 Revi:. ion No.

14 Page 13-9 3p g/j f

Babcock &Wilcox a McDermott company

.