ML20040E468
| ML20040E468 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1982 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Campbell R ENERGY, DEPT. OF |
| References | |
| REF-WM-55 NUDOCS 8202040374 | |
| Download: ML20040E468 (6) | |
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2 Mr. Richard H. Campbell, Project Manager JBMartin i i
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Dear Mr. Campbell:
Attached are NRC staff coments on the generic Health Physics and Safety Plan l
for Salt Lake City UMTPAP Wicinity properties. This plan was provided by the September 24, 1981 letter from David Ball of your staff to William M. Shaffer III of my staff.
These coments are being provided in the same context as my December 10, 1981 letter which provided oar comments on the gascric Salt Lake City vicinity properties Radiological Control Plan. We favor our interaction on generic DOE plans such as this as a means of HRC participation in the UMTRAP which will subsequently eliminate any potential need to repeat the same NRC overview function on a case by case basis.
Any questions you may have on these comments should be addressed to me or Dennis Sollenberger (FTS)(427-4111) of my staff.
Sincerely, l
i I5 Ross A. Scarano, Chief l
Uranium Recovery Licensing Branch l
Division of Waste Management l
cc: (with attachments)
Robert W. Ramsey, Jr., DOE-HQ Robert J. Stern DOE-HQ Dr. William E. Hott, DOE-HQ l
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ATTACHMENT Comment; On "UMTRAP-Salt Lake Of f-Site Properties, Health Physics and Safety Plan" (June, 1981)
General Comments:
The HP & S plan is generally lacking in depth and definition.
The plan should be written in enough detail to allow any health physicist to carry out the program without spending time to develop a new plan for each vicinity property.
The calculational techniques to be used in calculating internal radi.- ion doses should be specified.
Included in this cescription should be the recorakeeping requirements necessary to assign the appropriate amount of time at various airborne concentrations.
2.0 Safety and Health Training Presentation Comments:
One topic, the concept and goal of As Low As Is Reasonably Achie able (ALARA), was not listed under the areas to be discussed in the training program.
If ALARA is added to the training program, the proposed program appears adequate for those workers not involved in radiation safety.
The health physics staff should, however, have more extensive training or meet the qualifications, described in draft NRC.Reguitory Guide OH 941-4, titled "Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills Will Be As Low As Is Reasonably Achievable," dated August, 1980.
A copy of this draft NRC guide is enclosed f your consideration.
3.0 Complaints Comment:
The proposed complaint and resolution system appears adequate.
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2 4.0 Envi-onmental Monitoring Comment:
Definition of the required data, quality of the data, or uses of the data was not specified.
This lack of specificity does not allow a proper analysis of the adequacy of the environmental monitoring program.
The quality assurance (QA) program should be included as part c' this report.
The data to be collected should also be itemized.
The lower limits of detection (LLDs) or minimum detectable amounts (MDAs) should be specified for the data to be collected.
5.0 Radiological Monitoring Comment:
The three phase program appears adequate, if the monitoring program is conducted with sensitive enough equipment and consistent c.'itoring locations.
The sensitivity of the instruments should be b.
ed on the levels expected following the remedial action and the tyres of equipment acceptable to be used should be generally described.
5.5.1 Direct Radiation Sampling Comment:
All three of the gamma detection methods presented are acceptable assuming they are employed properly.
The TLD's should be placed in positions that will remain throughout the entire remedial action and following checkout time.
The change frequency should be specified. A monitoring grid should be developed and followed throughout all three phases of the program.
This grid should be used for both beta gamma and scintillation detectors.
Calibration frequencies should be specified.
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5.5.2 Air Sampling Comment:
The radionuclides to be analyzed for from the particulate filters should be specified.
5.5.3 Transport Monitoring Comment:
The contamination levels allowed on contaminated materials and transport vehicles should be specified.
6.0 Handling Radioactive Substances Comment:
The health physics plan should specify under what conditions protective clothing will be required for the employees.
This may be done by types of work areas or based on daily monitoring with control limits. above which protective clothing and/or respiratory protection will be required.
- 7. 0 Personnel Monitoring Comment:
A program should be developed that would require the health physicist to investigate any exposures that exceed 25% of the 10 CFR Part 20 limits.
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7.1.3 Comment
The radionuclides covered in the urinalysis should be specified including the LLDs and the appropriate action levels which would require an individual to be removed from specific work areas.
The radionuclides of greatest concern would be Th-230 and Ra-226.
The most appropriate bioassay would be in vivo counting to determine the lung burden of insoluble uranium, thorium-230, and radium-226.
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7.1.4 Comment l
Criteria should be stated below which air sampling would not be necessary.
These criteria should be specified prior to beginning any remedial action.
7.1.5 Comment What instrumentation will be used to survey the personnel leaving the site? What are the minimum detection limits of the instruments and what will be the set point on the instrument to alarm showing excessive contamination? The wash and laundry water, it appears, will be dumped into the sanitary sewer system without regard to the total activity sent to the sewer.
Consideration should also be given to establishing a maximum release amount similar to that specified in 10 CFR 20.303.
7.1.6 Comment There should be specific action levels or criteria which must be followed concerning protective clothing and respiratory protective devices.
7.1.7 Comment A procedure requiring that prior arrangements hcve been made with local medical facilities to accept contaminated accident victims should be outlined.
7.2 Comment What are the action levels that will require additional decontamination prior to leaving the site? The a-tion level >
2 or in simila, units.
should be specified in dpm/100cm
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8.0 Protective Equipment Comment Respiratory protective equipment should not be issued unless the user has had a medical examination and has been approved for respirator use.
In addition, each individual should be fitted for respirator use if protection factors are to be taken into account in calculating radiation doses.
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