ML20040E917

Forwards NRC Comments on Umtrap - Salt Lake Offsite Properties,Health Physics & Safety Plan. Comments Provided What Health Physics Staff Consider Min Requirement for Acceptable Program

ML20040E917
Person / Time
Issue date:	01/04/1982
From:	Sollenberger D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Shaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-41 82002, NUDOCS 8202080087
Download: ML20040E917 (6)

Text

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%) ss iect File WM-4L JAN 4 1982 WMUR w/f WMUR r/f WM R/f UM-41/DMS/SB/81/12/21 NMSS r/f PDR l

OMSollenberger BFisher l

WMVP,:DMS HPettengill WM-41 JLinehan DMartin RScarano MEMORANDUl1 FOR:

William Shaffer, Project Manager REBrowniyg BMar New Facilities Section y-Uranium Recovery Licensing Branch

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\\l/}f arry J. Pettengill, Section Leader m. 'a !$36 'sg THRU:

Operating FacilitiesSection II Uranium Recovery Licensing Branch a ~ 7 7, e,.

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Dennis M. Sollenberger, Project Manager g

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SUBJECT:

REVIEW 0F 00E REPORT " URANIUM MILL TAILINGS REMEDIAL ACTION PROGRAM (UMTRAP)-SALT LAKE OFF-SITE PROPERTIES, HEALTH PHYSICS AND SAFETY PLAN" Attached are the staff comments on the Health Physics and Safety Plan for the Salt Lake Off-Site Properties.

These written comments provide what the health physics staff considers the minimum requirements for an acceptable health physics program at the remedial action sites, d

Dennis So len erger, Project Manager Operating FacilitiesSection II Uranium Recovery Licensing Branch 8202080087 820104 PDR WASTE WM-41 PDR

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ATTACHMENT

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Comments On "UMTRAP-Salt Lake Off-Site Properties, Health Physics and Safety Plan" (June, 1981) l a

i 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 I

for each vicinity property.

The calculational

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techniques to be used in calculating internal radiation doses should be specified.

Included in this description should be the recordkeeping i

requirements necessary to assign the appropriate amount of time at various airborne concentrations.

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i 2.0 Safety and Health Training Presentation t

Comments:

One topic, the concept and goal of As Low As Is Reasonably Achievable (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 i

more extensive training or meet the qualifications, described in draft i

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 for your consideration.

3.0 Complaints Comment:

The proposed complaint and resolution system appears adequate.

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1 4.0 Environmental Monitoring Comment:

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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 of this report' The data to be collected should j

also be itemized.

The lower limits of detection (LLDs) or minimum detectable amounts (MDAs) shor'd be specified for the data to be collected.

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i 5.0 Radiological Monitoring i

Comment:

The three phase program appears adequate, if the monitoring program l

I is conducted with sensitive enough equipment and consistent monitoring locations.

The sensitivity of the instruments should be based on the lesels expected following the remedial action and the types of equipment acceptable to be used should be generally described.

5.5.1 Direct Radiation Sampling Comment:

All three of the gamma detection method 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 Sa-91inc Comment:

The radionuclides to be analyzed for from the particulate filters should be specified.

5.5.3 Transport Monitoring I

Comment:

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The contamination levels allowed on contaminated materials and i

transport vehicles should be specified.

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i 6.0 Handling Radioactive Substances Comment:

L 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.

I 7.0 Personnel Monitoring Comment:

A program should be developed that would require the health l

physicist to investigate any exposures that exceed 25% of the 10 CFR j

Part 20 limits.

7.1.3 Comment

The radionuclides covered in the urinalysis should be specified i

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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1 7.1.4 Comment Criteria should be stated below which air sampling would not be neces sary.

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 laundary water, it appears, will be dumped into the sanitary sewer system without regard to the total activity sent to the sewer.

There should be a maximum release amount as 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 have 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 action levels 2 or in similar units.

should be specified in dpm/100cm i

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5 8.0 Protective Equipment

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Comment 1

i 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 I

respirator use if protection factors are to be taken into account l

in calculating radiation doses.

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