ML20203H284

Forwards Revision to Chapter 5.0 of License SNM-1097, Addressing Discrepancy Identified in Insp Rept 70-1113/97-07 by Recognizing Practice of Personnel Movement Between Controlled & Noncontrolled Areas

ML20203H284
Person / Time
Site:	07001113
Issue date:	12/05/1997
From:	Vaughan C GENERAL ELECTRIC CO.
To:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
70-1113-97-07, 70-1113-97-7, NUDOCS 9712180366
Download: ML20203H284 (18)

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December 5,1997 Mr, M. F. Wober, Licensing Brr.nch, NMSS U.S, Nuclear Regulatory Conunission Office of Nuclear Material Safety and Safeguards Mail Stop T 8-D 14 Washington, DC 20555-0001-

Subject:

License Submittal Revising Chapter 5.0 of the Referenced License

Reference:

NRC License SNM-1097, Docket 70-1113

Dear Mr. Weber:

GE's Nuclear Energy Production (NEP) facility in Wilmingtor N.C., hereby transmits a revision to Chapter 5.0 s

of our license. This revision addresses a discrepancy identified during NRC inspec: ion #97-07 (NCV 97-07-02 and IFl 97-07 03) by recognizing the practice of personnel movement between controlled areas and non-controlled areas through access points other than change rooms. *Ihis is necessitated when certain activities not j

accommodated by the change rooms are authorized by RWP's or approved operating procedures.

Attaclunent 1 is a Description of Revisions made to the license submittal by page and section.

At achment 2 contains Chapter 5.0 in its entirety. All pages of this chapter have been dated 12/05/97. Vertical lines ( l ) in the right hand margin indicate where changes have been made.

Ten copics of this submittal are being provided for your use.

Please contact me on (910) 675-5656, if you have any questions or would like to discuss this matter further.

Sincerely, GE NUCLEAR ENERGY Abh kW a4r

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b Charles M. Vaughan 9712190366 971205 g

PDR ADOCK 07001113 Acting Manager C

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l Mr M. F. Weber December 5,1997 l

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ATTACliMENT 1 -

Description of Revisions O

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1 Mr. M.17. Weber l

Decernier 5,1997 l' age I of 1 Q

Description oflinhloru l'agg Section Description 1

Itevisions by Chapter thanged the date on Chapter 5.0 to 12/04/97.

5.5 5.5.1 Changed the wording to read "when exiting the change rootns" instead of when " leaving the controlled areas".

5.6 5.5.2 Added the word "Itoutine" at the berinning of the O

sentence. Also, added a paragraph at the end of this section describing " Alternate access points".

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Mr. M. F. Weber December 5,1997 i

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i ATTACilMEN T 2 1

i Revision 11y Chapter

-and Chapter 5.0 in its entirety i

Changes are indicated with vertical lines ( l ) in the right hand margin.

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REVISIONS IlY Cl_I_ APTER

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i Application Application Page Date Page Date

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TAllLii OF CONTliNTS l

I CllAPTER 6.0 l

i 1 through 3 06/05/97 1 through 36 09/19/97 l

[ REVISIONS IlY CilAPTER ]

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1 12/05/97 l

1 through 3 06/05/97 t

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CilAPTER 8.0 l

1 through 22 06/27/97 1 through 5 06/05/97 i

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I through 11 06/05/97 1

06/05/97

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APPliNDIX l

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06/05/97 LICENSE SNM 1097 DATE 12/05/97 Page DOCKET 70-1113 REVISION 4

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CH APTER 5.0 0

RADI ATION SAFETY 5.1 ALARA (AS LOW AS IS REASONAHLY ACillEVAHLE) POLICY 1he GE Wilmington standard of care for occupationally exposed individuals is to maintain exposures below the limits established by the U.S. Nuclear Regulatory Commission. Ileyond the standard of care, the GE-Wilmington professional staff has a commitment to an ALARA program which is delineated by documented plant practices. Area Manauers are responsible for implementing the ALARA program via engineered control.

d supervision of operations personnel. The radiation safety function ensures thm :cupational radiation exposures are maintained ALARA via timely exposure monitoring and interaction with production personnel.

An annual ALARA review is ernducted by the Wilmir.gton Safety Review Committee as described in Chapter 2.0. The Radiation Safety Committee, also described in Chapter 2.0, meets monthly to maintain a continual awareness of the status of projects, performance measurements and trends, and the current radiation safety conditions of shop activities.

O 5.2 RADIATION SAFETY PROCEDURES AND RADIATION WORK PERMITS (RWPS)

Routine work performed in radiatioa controlled areas is administered by the use of standard procedures described in Chapter 3.0. Non routine activities, particularly those performed by non GE employees, which generally are not covered by documented procedures, are administered by the RWP system. The RWP system is described in documented plant practices.

Radiation Work Permits are issued by a radiation safety technician or supervisor for non routine operations not addressed by an operating procedure when special radiation control requirements are necessary. The RWP specifies the necessary radiation safety controls, as appropriate, including personnel monitoring devices, protective clothing, respiratory protective equipment, special air sampling, and additional precautionary measures to be taken. RWPs are reviewed by radiation safety supervision.

LICENSE SNM 1097 DATE 12/05/97 Page (3

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The RWP requirements are reviewed by each affected individual and a copy is made f

Q available to the radiation safety function thmughout the duration of the activity.

Work is monitored by the radiation safety function as required. RWPs have expiration dates and the status ofissued RWPs is reviewed on a weekly basis by a radiation safety technician or supervisor.

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.5.3 VENTILATION REQUIREMENTS l

5.3.1 INTER AREA AIR FLOW DESIGN Ventilation equipment is designed to provide air flow from areas oflesser potential contamination to areas of higher potential contamination. Direction of air flow between areas is checked monthly or after significant changes to the ventilation system. Ifincufficient air flow results in altborne concentrations greater than 10 l

DAC, then the affected processes are shut down. Specific facilities and capabilities of ventilation systems are detailed in Table 5.1.

5.3.2 ENCLOSURES AND LOCALIZED VENTILATION lloods and other localized ventilation designs are utilized to minimize personnel nO excesure io airdome ura#ium. ^ctiviiies aad nrocess c9uinmeai thai seacraie altborne uranium are designed with filtered enclosures, hoods, dust capturing exhaust i

ports and other devices which maintein air concentrations of radioactivity in work t

areas such that personnel exposures are below 10 CFR 20 limits under normal operating conditions.

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Air flows through hood openings and locallred vents are maintained in accordance with Table 5.1. Additionally, differential pressure indicators are installed across exhaust system filters to monitor system performance. The flows and differential pressures are checked monthly or aller significant changes to the ventilation system.

Ifinsuflicient air flow results in airborne concentrations greater than 10 DAC, then the alTected processes are shut down in accordance with plant procedures.

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5.3.3 liXilAUST SYSTEM n

v) i Potentially contaminated air is exhausted through high efliciency filter media which are at least 99.97% efficient for removal of 0.3 micron particles. IIEPA filters in the exhaust system are equipped with a device for measuring differential pressure.

DifTerential pressures greater than four inches of water are investigated, in no case will filters be operated at a ditTerential pressure which exceeds the manufacturer's ratings for the filter.

Water scrubbers or other appropriate devices are provided where necessary to treat effluents before filtration. Such scrubbers are installed so that effectiveness of filters is maintained.

5.3.4 Allt itEClitCUI.ATION lloom air may be recirculated within the uranium processing areas aller being filtered. Itoom air recirculated within areas where airborne concentrations are likely to exceed 0.1 DAC is filtered by llEPA filters and/or water scrubbers.

5.4 AIR SAMPt.ING PROGRAM 5.4.1 AIR SAMPl.ING Air samples are continuously taken from each main process area where airborne concentrations are likely to exceed 0.1 DAC when averaged over 40 '1ours to assess the concentrations of uranium in air. The air samples are collected in such a way that the concentrations of uranium measured are representative of the air.vhich workers breathe. Air sampling results and individual personnel exposure assignments are monitored by the radiation safety function to evaluate the effectiveness of personnel exposure controls.

Fixed filter sampling points utilized for personnel exposure assignments are evaluated ihr representativeness annually and as part of each radiation safety function review for licensed process or equipment changes that may affect airborne concentratians. Evaluations of air sampling representativeness are performed in accordance with the methods and acceptance criteria in Table 2 of Regulatory Guide 8.25," Air Sampling in the Workplace".

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d Filters from air semplers are changed each shift during nonnal operating periods or at

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more frequent intervals following the detection of an event that may have released airborne uranlum, based upcm knowledge of the particular circumstances. Filters are not changed as frequently during periods when no work is in progress. The filters are processed to determine the uranium concentration in air for each area.

Each air sampler is equipped with a rotameter to indicate flow rate of air sampled.

These rotameters are calibrated or replaced at least every 18 months.

Air sampling results in excess of 2.5 DAC (8 hr. sample) and not resulting from a specific known cause are investigated to detennine the probable cause. Operations or equipment will be shut down, and immediate corrective action will be taken, at locations where an air sample exceeds 10 DAC without a specific known cause.

Corrective actions are implemented and documented based on the frequency and magnitude of events causing releases of airborne uranium.

Itoutine air sampling is supplemented by portable air sample surveys as required to evaluate non routine activities or breaches in containment flased on these surveys, additional radiation protection requirements for the particular operation may be established.

5.4.2 AIR SAMPLING ADJUSTMENTS O

Ad;ustmenis io Derived ^ir Concentration co^C) ana ^nnuai Limit efiniate c^i.i>

values in process areas to reflect actual physical characteristics of the airborne uranium are made in accordance with written operating procedures. GE-Wilmington site specific infonnation on characteristics of airbome uranium is documented in internal records. For those areas in which adjusted All/DACs are applied, controls me established to limit soluble uranium intakes using air sampling and urinalysis.

Assigned air adjustments are not made to All/DACs for operations, locations or incidents where the airborne uranium physical characteristics are not documented.

Established airbome uranium limits in each area that adjusted All/DACs are used pursuant to the above authorization are reassessed by the Radiation Safety function at one quarter of the work locations at 6 month intervals, selecting different locations each time, l

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if the reassessed limit (All) has changed by more than 30% from the previousiy f) established limit for an area, the limit for that area is either re-established or replaced with a default value based upon 1 micron AMAD.

In addition, a reassessment is performed following process or equipment changes likely to affect the airborne particle size distribution.

5.5 CONTAMINATION CONTROL 5.5.1 SURVl!YS Routine contamination survey monitoring is performed for uranium process and manufacturing areas including non controlled areas such as hallways and lunch rooms immediately adjacent to controlled areas. Removable contamination measurements are made based on the potential for contamination in these areas and operational experience. Survey frequencies are determined by the radiation safety function. Survey results are compared to action guide tatues as specified in plant procedures and appropriate responses are taken.

The minimum survey frequencies and maximum removable contamination action levels are as follows:

-b Action Limit Mrji Frequenn (dom a/100 cm')

Controlled Areas (Floors & Other Weekly 25,000 Readily Accessible Surfaces)

!!ating Areas used primarily by Weekly 2220 Controlled Area Personnel Non-controlled Areas Monthly 2220 When contamination levels in excess of action limits are found, mitigating actions are taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Personnel contamination surveys fbr external contamination on clothing and the body are required by personnel when exiting the change rooms. If contamination is I

found in excess of background levels, the individual r.ttempts self-decontamination at LICENSli SNM 1097 DATE 12/05/97 Page

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the facilities provided in the change rooms. If decontamination attempts are not O

successful, decontamination assistance will be provided by the radiation safety function if skin or personal clothing is still found contaminated above background levels, the individual may not leave the area without prior approval of the radiation protection function.

5.5.2 ACCESS CONTROL Routine access points to controlled areas are established through ci;ange rooms.

1 Each change room includes a step-ofrarca provided between the hot and cold sides.

Instructions controlling entry and exit from controlled area are posted at the entry points. Personnel survey meters are provided in the step-off area of each change room for use by personnel leaving the controlled areas. Posted instructions address the use of the survey meters and appropriate decontamination methods.

Alternate access points to controlled areas are established for specific activities that are not accommodated by the change rooms. Such access is governed by approved procedures, or Radiation Work Permits, which establish controls to prevent the spread of contamination to non-controlled areas.

5.5.3 PROTECTIVli CLOTilING Protective clothing is provided to persons who are required to enter the controlled areas where personnel contamination potential exists as determined by the radiation safety function. The amount and type of protective clothing required for a specific area or operation is determined by operational experience and the contamination potential. Available clothing includes caps, hoods, laboratory coats, coveralls, safety glasses, boots overshoes, shoe covers, rubber and cloth gloves and safety shoes.

The minimum clothing requirement for airborne controlled area entry is as follows:

Inspectors and Visitors Only Area Workers Observing Operations Shoe covers or work area shoes Shoe covers Coveralls Laboratory coats licad covers llead covers Rubber gloves Rubber gloves (as needed)

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'Q The protective clothing is removed upon exit in the controlled area change rooms, v

in laboratory areas where uranium is handled the minimum protective clothing requirement for entry is a laboratory coat and safety glasses.

5.5.4 LEAK TESTING OP PLUTONIUM ALPilA SOURCES 1he sources when not in use shall be stored in a closed container adequately designed and constructed to contain plutonium which might otherwise be released during storage.

The sources shall be tested for loss of plutonium at intervals not to exceed 110 days, using radiation detection instrumentation capable of detecting 0.005 pCi of alpha contamination.

If any survey or measurement performed as required by the preceding paragraph discloses the loss of more than 0.005 pCi of plutonium from the source, or if a source has been damaged or broken, the source shall be deemed to be losing plutonium. The licensee shall immediately withdraw it from use, and cause the source to be decontaminated and repaired, or disposed ofin accordance with the Commission regulations.

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Records of test results shall be kept in units of microcuries and maintained for inspection by the Commission.

Notwithstanding the periodic test required above, any plutonium alpha source containing not more than 0.1 pCi of plutonium is exempted frora the above requirements.

5.6 EXTERNAL EXPOSURE Deep-dose equivalent and shallow-dose equivalent from external sources of radiation are determined by individually assigned dosimeters. Personnel dosimeters are exchanged quarterly and processed by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited vendor. The capability exists to process dosimeters expeditiously if there is an indication of an exposure in excess of established action guides. Action guides for extemal exposures are established in LICENSE SNM 1097 DATE 12/05/97 Page IXX'KET 70-1113 REVISION 1

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i plant procedures. Maximum radiation exposure action levels are specified in Section Q

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External exposures may be calculated by the radiation safety function on the basis of data obtained by investigation when the results ofindividual monitoring are unavailable or are invalidated by unusual exposure conditions.

y 5.7 INTERNAL EXPOSURE Intakes are assigned to individuals based upon one or more types of measurements as follows: air sampling (described in Section SA), urinalysis and in vivo lung counting.

intakes are converted to committed dose equivalent (CDE) and committed effective dose equivalent (CEDE) for the purposes oflimiting and recording occupational doses. Action levels are established in plant procedures to prevent an individual from exceeding the occupational exposure limits specified in 10 CFR 20. Maximum radiation exposure action levels are specified in Section 5.9. Control actions include -

temporarily restricting the individual from working in an area containing airbome radioactivity, and actions are taken as necessary to assure against recurrence.

5.7.1 URINALYSIS PROGRAM O

The urinalysis program is conducted primarily to evaluate the intake of soluble uranium to assure that the 10 CFR 20 intake limit of 10 mg is not exceeded.

Individuals assigned to work in areas where soluble airborne uranium compounds are present in concentrations that are likely to result in intakes in excess of 10 percent of the applicable limits in 10 CFR 20 are monitored by urinalysis. The minimum sampling frequency for these individuals is biweekly. Urinalysis may also be used to monitor individuals involved in non routine operations, perturbations or incidents.

Urine sampling frequencies and action levels are established in plant procedures based on the appropriate biokinetic models for the uranium compounds present.

Results above the applictble action level are investigated. Urinalysis action levels are based on maximum radiation exposure action levels specified in Section 5.9.

Results that exceed action levels result in a temporary work restriction for the individual to prevent additional exposure and allow a more accurate assessment of the intake.

LICENSE SNM-1997 DATE 12/05/97 Page DOCKET 70-1113 REVISION 1

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4 5.7.2 IN VIVO LUNO COUNTING j

,0 Routine in vivo lung counting frequencies are established for individuals who normally work in areas where non transportable uranium compounds are processed, liaseline and temiination counts are performed when feasible. Lung counting j

frequencies are based upon individual airborne exposure assignments and previous counting results. The minimum count frequency is annual for individuals with an assigned intake greater than 10 percent of the Annual Limit on intake (All).

Appropriate actions are taken based upon in vivo lung counting results to ensure the i

All will not be exceeded. if an individual's lung burden indicates an intake greater than the applicable action level, the individual is temporarily restricted from working in areas containing airborne uranium. In vivo lung counting action levels are based on the maximum radiation exposure action levels specilled in Section 5.9 5.8 SUMMING INTERNAL AND EXTERNAL EXPOSURE Intemal and external exposures determined as descr; bed in the preceding sections of this application are summed in accordance with the requirements of 10 CFR 20 for the purposes oflimiting occupational doses and recording individual monitoring results.

5.9 ACTION LEVELS FOR RADIATION EXPOSURES Work activity restrictions will be imposed when an individual's exposure exceeds 80% of the applicable 10 CFR 20 limit; i.e.,0.8 All, !600 DAC Ilours,4.0 rem CEDE,4.0 rem TEDE,4.0 rem DDE,40 rem CDE and 40 rem SDE.

5.10 RESPIRATORY PROTECTION PROGRAM The respiratory protection program shall be conducted in accordance with the applic6cle portions of 10 CFR 20. Respiratory protection equipment specifically approved by the National Institute for occupational Safety and IIcalth (NIOSil) is utilized.

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5.10.1 QUALIFICATIONS OF RESPIRATOR USERS V

Individuals designated to use respiratory protection equipment are evaluated by the medical function and periodically thereafter at a frequency specified by the medical function to detennine if the individual is medically fit to use respiratory protection devices, if the individual has no restrictions, he is provided respiratory training and fitting by a qualified instructor. Additional training on the use and limitations of self-contained breathing devices is provided to designated individuals.

An adequate mask fit is detennined using qualitative (irritant smoke) methods. Mask fits are re evaluated annually.

5.10.2 RESPIRATORY PROTECTION EQUIPMENT llalf mask respirators equipped with particulate filters are utilized as a precautionary measure and to further reduce exposures during routine operations which may generate uranium dt ts. A protection factor of 10 is taken for this type of respirator usage.

Full face mask respirators, equipped with an appropriate canister, are utilized as a precautionary measure and to funher reduce exposures for routine and emergency actions which may require additional protection capabilities when there exists a q

potential for releases of soluble uranium gases. A protection factor of 50 is taken for V

this type of respirator usage.

NIOSil approved continuous flow airline supplied hoods and full face respirators, and self-contained breathing devices are also available for certain operations.

Respiratory protection equipment of these o pes are operated in accordance with 10 CFR 20 and specified protection factors are utilized.

5.10.3 TESTING AND CLEANING OF EQUIPMENT Each respirator is processed for cleaning, inspection, and replacement of parts as necessary. Air puiifying cartridges and canisters are challenge atmosphere penetration and differential pressure tested r inst p rameters according to internal proce< lures. The respirator and canister ar 31y is challenge atm.. sphere tested and pres:. tested prior to reuse. New respi. ors and canisters are similarly tested on a quality control basis.

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4 Self contained breathing devices are inspected for operational capability and are

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cleaned and re inspected after each use.

5.11 INSTRUMLa fATION Appropriate radiation detection instruments are available in sufficient number to ensure adequate radiation surveillanca can be accomplished. Selection criteria of portable and laboratory counting equipment is based on the types of radiation l

detected, maintenance requirements, ruggedness, interchangeability and upper and lower limits of detection capabilities. The radiation safety function annually reviews the appropriateness of the types ofinstruments being used for each monitoring function. Table 5.2 lists examples of the types and uses of available instrumentation.

5.11.1 CAI.li1 RATION Instrumentation is calibrated before initial use, afler major maintenance, and on a routine basis at least six months following the last calibration. Calibration consists of a perfonnance check on each range scale of the instrument with a radioactive source of known activity traceable to a recognized standard such as the National Institute of Standards and Technology (NIST).

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Prior to each use, operability checks are performed on monitoring and laboratory counting instruments. The background and ciri:lency oflaboratory counting instruments are determined on a daily basis when in use.

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Q TABLE 5.1 SPECIFIC FACILITIES & CAPABILITIES OF VENTILATION SYSTEMS Facility Alarms. Interlocks & Safety Etatures Purnose Iloods-Air flow during operation 2 80 linear feet Prevents spread of radioactive per minute materials -

i Effluent air filtered with IIEPA filters Prevents release of radioactive materials to environs i

liigh Velocity Local Air flow designated to maintain an Prevents spread of radioactive Ventilation average of 200 linear feet pei minute materials from work area to immediate room area i

UF, Vaporization Vented enclosure Provides containment in event Chambers of cylinder rupture or abnormalleakage Reckculating' Air Air filtered in potentially contaminated Removes essentially all Systems & Exhaust zones with IIEPA filters or water contaminants from room and

O Air Symms sc & rs exhausuo endons Pressure drop indicator set to alarm at Maintains adequate circulation 24"110AP across final filter for removal ofdust and 2

contaminants from the room i

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Ellluent air filtered with IIEPA filters Prevents release of radioactive materials in environs t

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O TAllLE 5.2 TYPES & USES OF AVAILAllLE INSTRUMENTATION (TYPICAL)

Typs Tvnical Rangs Routine Use DOSli RKl'l! hiliTliRS Gh1 Low Range 0.01 mR 2000 mR Area Dose Rate Survey, Shipment Survey Ghi liigh Range 0.1 mR 1000 R Emergency hionitoring lon Chamber - Low Range 0.1 mR - 10 R Area Dose Rate Survey, Shipment Survey lon Chamber liigh Range 1 mR 1000 R Emergency hinnitoring Al Pila SURVliY hiliTl!RS 50 cpm - 2 x 10' cpm Direct Personnel &

Equipment Surveys NEUTRON hiETl!RS 0.5 mR 5 R Special Dose Rate Surveys LAllORATORY INSTRl!MJiNTATION Automatic air sample counter N/A Lab Analysis 17ixed geometry Geiger hiueller N/A Lab Analysis counter Scintillation Counter N/A 1 ab Analysis in Vivo Lung Counter N/A Lung Deposition hicasurements 1.1C EN':E SNM 1097 DATE 12/05/97 l' age DOCKET 70-1113 REVISION I

5.13

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