ML20046A721
| ML20046A721 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/23/1993 |
| From: | Emeigh C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Winslow T GENERAL ELECTRIC CO. |
| References | |
| TAC-L30556, NUDOCS 9307290266 | |
| Download: ML20046A721 (4) | |
Text
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Docket 70-1113 License SNM-1097 Mr. T. Preston Winslow, Manager Licensing and Nuclear Materials Management M/C J88 Nuclear Fuel and Components Manufacturing General Electric Company P.O. Box 780 Wilmington, North Carolina 28402
Dear Mr. Winslow:
SUBJECT:
LIMITS ON INTAKE OR DERIVED AIR CONCENTRATIONS (TAC N0. L30556)
This refers to your application dated May 10, 1993, requestin an amendment to Materials License SNM-1097 for an authorization to adjust the annual limits on intake or the derived air concentration limits in certain process areas in order to account for particle size variations within your facility.
Our review of your submittal has identified additional information that is needed before further action can be taken. While the proposed effective date is January 1, 1994, we would appreciate receiving the additional information specified in the enclosure at your earliest convenience in order to complete the processing of this amendment.
Please reference the above TAC No. in future correspondence related to this request.
If you have any questions regarding these matters, please contact Mr. William Radcliffe of my staff at (301) 504-2009 or me at (301) 504-2396.
Sincerely, Original signed by Chades W.Emeigh Charles W. Emeigh, Section Leader Licensing Section 1 i
Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated l
DISTRIBUTION:
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1 Request for Additional Information Application Dated May 10, 1993 i
General Electric Co., Wilmington, NC SNM-1097, Docket No. 70-1113 Please provide the following:
Generic In order to fully evaluate this proposed amendment, it will be necessary to review the methodology used and the results of previous particle size studies. Please forward copies of the 1992 study by James et al, the 1993 study by Hickey et al, the 1985 article by Maher and Laird, and the 1975 article by Twomey.
Will adjusted DACs or ALIs be used to assign worker exposures during maintenance activities? If so, how will particle size distribution be determined during these activities?
Commitments to reassess particle size distributions after any process changes or during any irregular (e.g. maintenance) activities are required.
Please describe how DACs for personnel not assigned to a particular work station will be assigned / adjusted.
This may be addressed in the demonstration section if the appropriate data are presented.
What instruments would be available to assess possible changes to the measured activity median aerodynamic diameters (AMADs) due to changes in plant equipment or operating conditions?
How will particle size distributions which exhibit a geometric standard deviation (GSD) much greater than 4 or multi-modal distributions be dealt with?
Provide data to support the stated solubility classifications in the locations in which DACs will be adjusted.
Unless Y-class compounds can be exclusively demonstrated, the adjustments shown in your Figures 1.1 and 1.2 cannot be utilized.
Describe how individual sample results will be averaged to arrive at an actual AMAD for a work location. This will become crucial if a decision is made to group several work locations together as an " area."
Enclosure
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2 Specific Section 1.8.15 needs to state that the specifications outlined in Section 4 of Regulatory Guide (RG) 8.25, " Air Sampling in the Workplace, Revision 1," dated June 1992 will be followed; or it should specify requirements at least as comprehensive as those outlined in the RG.
Figure 1.1 on page I-1.20(b) appears to be in error. The DAC listed for 1 micron AMAD does not equal 2x10~" pCi/ml, the value listed in Appendix B to 10 CFR Part 20. Also, the DAC at 10 microns should be about 5 times the 1 micron value.
On page II-13.81(b), a reference is made to "the insoluble airborne uranium work areas discussed herein." Does this mean that ALIs will be adjusted only in areas strictly exposed to insoluble uranium? How will this solubility determination be made?
On page Il-13.81(c), it is noted that 26 workplace locations were sampled during the recent Battelle studies. What percent of the total work locations were sampled? If any work locations wtre not sampled, they will need to be. Was there overlap of workplace locations between the two studies?
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On page Il-13.8I(c), it is stated that Anderson cascade impactors were used. Will these be the same impactors used to reevaluate areas? If so, please respond to the following:
- 1) Anderson manufactures several models of impactors. What was the exact model used?
- 2) How many stages were involved and what was the particle size cutoff
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for each stage?
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- 3) What collection media was used?
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- 4) What was the efficiency of the back-up filter for 0.3 micron particles?
Section 13.4.6 should include, within the " Summary of Typical Particle Size Data," the data for pellet press, blender, powder warehouse, oxidation furnace and radioactive waste sorting areas. These data are necessary to address the adequacy of the review regarding the amendment criteria.
Furthermore, the data as presented is insufficient to support DAC/ALI adjustment.
Particle size data must be presented as AMADs not in the form of ranges or by the predominant peak. The values needed in order to use your Figures 1.1 and 1.2 are AMADs and only when the GSD of the distribution is less than 4.0.
Enclosure 1
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3 On page II-13.81(e), it is stated that " work function areas in which site specific particle size measurements have been made...."
Are these J
" areas" single sample locations or multi-sample locations which exhibit similar particle size distributions? How many work stations will be affected by the particle size measurements?
On page II-13.81(e), a commitment is included to the effect that GE will reassess the median diameters biennially " generally in accordance with the guidance given in Regulatory Guide 8.25."
Reg Guide 8.25 states that 25 percent of the work locations should be sampled every 6 months, selecting different locations each time. Although this works out to all locations being sampled in a two year cycle, it allows variations with time to be caught and corrected much sooner. Only if a facility can demonstrate, by reassessment, that particle size distributions do not vary with time, should the reassessment period be increased.
Furthermore, if a decision is made to combine work locations which exhibit similar particle size distributions together into " areas," then at least one work location per " area" should be represented during each six-month reassessment.
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1 Enclosure l
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