ML20205A134

Forwards Supplemental Info Re Implementing Details of Urinalysis Program in Response to Insp Rept 70-1113/88-08. Urinalysis Sampling by Work Area & Relevant Action Levels Explained in Figure 1

ML20205A134
Person / Time
Site:	07001113
Issue date:	09/28/1988
From:	Winslow T GENERAL ELECTRIC CO.
To:	Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8810250400
Download: ML20205A134 (5)

Text

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a a9: 49 September 28, 1988 Mr. Doug Collins, Chief Emergency Preparedness &

Radiological Protection Branch US NRC - Region II 101 Marietta St.,

NW Atlanta, GA 30323

Subject:

Request for Additional Information Regarding Urinalysis Program

Reference:

(1)

NRC License SNM 1097, Docket 70-1113 (2)

NRC Inspection Report 70-1113/88-08 (3)

GE Response to Inspection Report 70-1113/88-08 dated 8/26/88 Attached is the supplemental information regarding implementing details of our urinalysis program your staff members recently requested by telephone.

We hope this information clarifies our 8/26/88 response to violation B of the referenced inspection report and will suffice to allow for its closure in accordance with the action plan as described in the 8/26 response.

If you should have any further questions, please do not hesitate to write or call.

Sincerely, GE iFJCLEAR ENERGY MN I

T.

Preston Winslow, Manager Licensing & Nuclear Materials Management Attachments cc:

US NRC Document Control Desk Washington, DC 20555 8910250400 880928 PDR ADOCK 0700111:3 l (

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Mr. Doug Collins September 28, 1988 ATTACHMENT Urinalysis sampling by work area and the relevant action levels are explained in Figure 1 which war derived from implementing procedures and REMTRAC computer functional requirements.

The action levels of 15 and 35 pg/l specified in SNM-1097 are based on the equations given in the attached Appendix C to NSI O-2.0 and the restriction level of 2.5 mg uranium intake.

The action level of 35 pg/l applies to uranium hexafluoride and related compounds.

It assures and demonstrates that intakes within the previous 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> have not exceeded the intake restriction level.

The action level of 15 pg/l applies only to uranyl nitrate und related compounds.

It assures and demonstrates that intakes within the previous 7.3 days have not exceeded 2.5 mg.

REMTRAC is designed to screen every urinalysis result against one or the other of these action levels.

For both routine and non-roatAne urinalysis samples, the individual submitting the sample indicates the job function area (JFA) in which he had been working (along with name, pay number, date, and time).

If the JFA indicated is one of the two manufacturing areas where uranyl nitrate is processed (i.e., UPS and URU scrap recovery operations), 15 pg/l is used as the action level and the uranyl nitrate retention equation given in Appendix C is used to compute intakes as appropriate.

Samples from laboratory areas are also evaluated using the 15 pg/l action level.

Should an individual submitting a sample indicate any other JFA, the sample is evaluated as if it were a uranium hexafluoride r

related compound (35 pg/l action level).

This is justified as a prudent practice because of the nature of the compounds and their prevalence.

Uranyl nftrate is only processed in scrap recovery operations in specific areas of the factory (i.e., UPS and URU) and is in the form of r,queous solutions and rarely becomes airborne.

On the other hand, uranium hexafluoride is a gas during the vaporization and hydrolysis processes.

Should it escape the process equipment, it reacts with ambient 1,ater vapor to form uranyl fluoride, a powdery substance with nolubility/ retention characteristics identical to UF During a ges release, UO,F, can 3

be found in many parts of the chemical area until it deposits on surfaces or is filtered out by the HVAC equipment.

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o Mr. Doug Collins September 28, 1988 Attachment Page 2 of 2 For all other process areas, with the exception of lab areas noted above, the shorter half-time UF, retention equation and the corresponding 35 ug/l action level is used as the default value to compute intakes in a conservative manner.

As a result, it is possible that results between 15 and 35 pg/l can exist without an investigation because the material is conservatively assumed to be a UF,-related compound.

This assumption is prudent because of factory configuration and the nature of the compounds involved.

In the special case of two or more sample results submitted in the same 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, REMTRAC performs a preliminary automatic investigation taking into account the short time (<24 hours) between samples.

In these cases, sar.ple results up to 95 pg/l back calculate to an intake of less than the 2.5 mg restriction level regardless of whether the compound is assumed to be UF, related or uranyl nitrate.

Because re-samples are usually submitted promptly (i.e., within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), the special case provisions avoid the unneeded flagging of re-samples subsequent to an initial intake.

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FIGURE 1 URINALYSIS SAMPLING REQUIREMENTS ITEM DESCRIPTION REQUIREMENT PROCESS AREAS VAPORIZATION UPS, URU (UPMP)

ALL OTHER

& HYDROLYSIS Soluble U Compounds UF and Uranyl nitrate UO F, i

Related and similar (ilany)

Sampling Frequency:

- Routine Worker Daily Weekly None

- Non-Routine Worker Each day as Each week as None applicable applicable

- Maintenance Worker Each day as Each day as Nonw applicable applicable

- Engineers, Supervisors, Each day as Each day as None etc. with mask time applicable applicable

- Special work including Per RWP Per RWP Per RWP contractors

- Requested (incidents As submitted As submitted As submitted investigation, elective, 4

etc.)

Submitter Codes for Area Vaporization.

UPS or URU Other Worked (JFA) or hydrolysis S g. le result 35 15 35 action level (pg U/1)

REMTRAC Computer Evaluation Protocol

[

(Start)

> Action Level (15 or 35)

Current

< Action Level Sample Result i

Time of I I previous sample Yes

< 24.0 hrs and 0:

Uptake 4

urrent sample

< 2.5 mg i,

< 95 pg/l (Stop) l 7

i i

j k No

1. Alert Rad i

Protection to Is i

investigate and Then Uptake Yes calculate uptake.

Less Than 2.5 mg

2. Record uptake.

?

i

3. Print resample request.

No Restrict Individual l

PSS 9/28/88

t NSI No. 0-2.0

Subject:

BIOASSAY - URINALYSIS PROGRAM Page 1 Of 1 APPENDIX C EQUATIONS AND SUPPORTIVE DATA FOR NF&CM U1,INALYSIS PROGRAM The exposure potential for soluble uranium compounds are as follows:

Area Compound l

Vaporization and Hydrolysis Uranium Hexafluoride (UP ) and Uranyl Fluoride (UO,F,)

UPS and UPMP Uranyl Nitrate (UO,(NH ),)

3 9

I Chemet Lab Uranyl Nitrate 4

The equation for uranyl nitrate and compounds of similar colubility given by WASH-1251 is:

i.5 Iu = 0.0084 Ct where:

4 Iu = uptake (mg of uranium) time in days since uptake (for fractions of a day t

n less than one, use t = 1) concentration of uranium in urine in pg/t C

=

i The equation for UF., UO,F,.

and other highly soluble compounds given in the draft ANSI N341 (July 1974) is:

u = 0.0025 Ce.1155(At-4) 0 I

i where:

At = lapsed time between intake and sample collection (at must be greater than 4.0) 1 4

The maximura times after a 2.5 mg uptake that a urinalysis result above the assumed detection threshold of 5.0 pg/t of the Scintrex UA-3 analyzer could be observed are:

l 1) 49.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> for the highly soluble (UP.) compounds and 2) 15.2 days for soluble uranium (uranyl nitrate) compounds

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