ML20249B122

Responds to 980302 Request That NRC Perform Review & Provide Written Response Re NIOSH Health Hazard Evaluation Rept Heta 96-0198-2651,dtd 970905.NIOSH Rept Prepared Between Nov 1996 & Feb 1997.NRC Did Not Have Authority Until 970303

ML20249B122
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	06/15/1998
From:	Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Haberthy J AFFILIATION NOT ASSIGNED
References
NUDOCS 9806220085
Download: ML20249B122 (4)

Text

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' June 15, 1998 I

. Mr. John Haberthy'

' President, United Plant Guard

-Workers of America -

' Local No. 66 385 Adkins Hoffer Hill Road

- Otway, OH '45657.

SUBJECT:

NIOSH REPORT HETA 96-0198-2651 DATED SEPTEMBER 5,1997 :

References:

1.; UPGWA letter, Lawson to Cox, dated September 26,1997

2. NRC letter, Ten Eyck to Haberthy, dated May 4,1998

Dear Mr. Haberthy:

' I am responding to your March 2,1998, request that the U.S.' Nuclear Regulatory Commission

'. (NRC) perform a review and provide a written response regarding the subject National Institute for Occupational Safety and Health (NIOSH) Health Hazard Evaluation Report HETA 96-0198-

' 2651 dated September 5,1997. Your March 2 request was made during discussions with the' Portsmouth Senior Resident inspector, Mr. Dave Hartland, and Region ll1 Specialist, Mr. Jay

. Hopkins regarding an earlier request from the previous United Plant Guard Workers of America p

(UPGWA) Safety Representative, Mr. Chick Lawson (Reference 1).'

The NIOSH report was prepared between November 1996 and February 1997.' As you are -

aware, the NRC did not have regulatory authonty over the Portsmouth Gaseous Diffusion Plant until March 3,1997. The Department of Energy (DOE) had regulatory authority at the time of.

the report; therefore, if the UPGWA desires to pursue any regulatory Isa.ues regarding the NIOSH report, I encourage you to discuss the matter with DOE. The NRC regulatory authority '

)

. extends only to the areas of the Portsmouth plant which are leased by the United States

( Enrichment Corporation (USEC). DOE retains regulatory authority for all non-leased areas of Lthe Portsmouth plant.

The dosimetry programs at the Portsmouth Gaseous Diffusion Plant are consistent with the NRC required National Voluntary Laboratory Accreditation Program and the DOE Laboratory

Accreditation Program which account for potential neutron doses. ' Under current NRC L regulation 10 CFR Part 20.1502, individual monitoring is not required for adults who are not L

l expected to receive more than ten percent of the allowable regulatory liinits identified in 10 CFR Part 20.1201(a). ' The areas leased by USEC which fall under NRC jurisdiction meet the

requirements of 10 CFR Part 20 such that monitoring is not required. Although not required, the certificate has chosen to monitor for potential neutron exposures.

E The' NIOSH report identified three primary neutron radiation sources at the Portsmouth

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Gasecus Diffusion Plent.1The most significant acute exposure would result from a criticality h

! accident. Additionally, an acute exposure can result from a build-up of uranium in the process system causing multiplication of neutrons below the criticality threshold. This phenomenon is termed by the gaseous diffusion industry as a " slow cooker." We believe that an acute L

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exposure potential is limited to cases of accidental criticality or an exceptionally strong, E

prolonged, undetected " slow cooker." The chronic exposure to low levels of neutron radiation is j

considered far more likely at the Portsmouth Gaseous Diffusion Plant and within NRC requirements.

I encourage the UPGWA to pursue any issues relating to the Occupational Safety and Health

~

Administration, Department of Labor with them or DOE who had regulatory jurisdiction.

With regards to a pre 0ious commitment to get back to the UPGWA regarding a " legacy issue"

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made during the October 1997 UPGWA meeting between USEC, DOE, and the NRC's Office of -

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- Nuclear Material Safety and Safeguards, I believe the NRC has most recently responded to L

your questions via letter (Ten Eyck to Haberthy) dated May 4,1998 (Reference 2).

If you have any further questions, please contact Mr. Patrick Hiland of my staff at L (630) 829-9603.

Sincere!y, 1

Original. Signed by

)

.i Cynthia D. Pederson, Director Division of Nuclear Materials Safety -

j Docket No. 70-7002 Certificate No.' GDP-2 1

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' DOCUMENT NAME:.G:\\SEC\\NIOSH.RPT

• See Previous Concurrences i To receive a copy of this document, Indicate in the box: "C" = Cow w/o atter#encr%*

w/ attach /end *N" = No copy OFFICE Rlll:DNMS l

HQ:NMSS Rill:DNhff l

l NAME

• Hiland:irb

• Pierson Pedhtsd6 DATE 06/ /98-06/ /98 06&v198 OFFICIAL RECORD COPY -

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J. Ha'berthy c The NIOSH report identified three primary neutron radiation sources at the Portsmouth Gaseous Diffusion Plant. The most significant acute exposure would result from a criticality accident.

i Additionally, an acute exposure can result from a build-up of uranium in the process system

' causing multiplication of nsutrons below the criticality threshold. This phenomenon is termed by the gaseous diffusion industry as's, " slow cooker." We believe that an acute exposure potential

' is limited to cases of accidental criticality or an exceptionally strong, prolonged, undetected " slow cooker " The chronic exposure to low levels of neutron radiation is considered far more likely at the Portsmouth Gaseous Diffusion Plant, with the exposure levels not constituting a potential health hazard. However, we support the NIOSH report conclusion that neutron radiation can

-occur at the Portsmouth Gaseous Diffusion Plant and exposure to neutrons should be monitored.

i I encourage the UPGWA to pursue issues relating to the Occupational Safety and Health

. Administration, Department of Labor (OSHA-DOL) with them or the DOE who had regulatory

- Jurisdiction.

.With regards to a previous commitment to get back to the UPGWA regarding a " legacy issue" made during the October 1997 UPGWA meeting between USEC, DOE, and the NRC's Office of Nuclear Material Safety and Safeguards (NMSS), I believe the NRC has most recently responded 1

to your questions via letter (Ten Eyck to Haberthy) dated May 4,1998 (Reference 2).

]

1 If you have any further questions, please contact Mr. Patrick Hiland of my staff at (630) 829-9603.

Sincerely, I

I Original Signed by-Cynthia D. Pederson, Director -

Division of Nuclear Materials Safety

. Docket No. 70-7002 4

' Certificate No. GDP-2 DOCUMENT NAME: G:\\SEC\\NIOSH.RPT Ta receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E* = Copy with enclosure"N'= No copy OFFICE Rlll'

- l C-NMSS l C-Rill l

l NAME Hiland:ib M 4' Pierson @% 4*wil Pederson DATE 06/3/98-06/% /98 ~

06/ /98

' 0FFICIAL RECORD COPY e

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- -___ - ____- ____ __________-__ _-_-__ ______ _______=_- _-_ ________

. J. Haberthy Distnbution:

Docket File PUBLIC IE-07 R. Pierson, NMSS P. Ting,' NMSS

.W. Troskoski, NMSS '

P. Harich, NMSS Y. H. Faraz, NMSS ~

g C. J. Paperiello, Rlli J. L. Caldwell, Rlll C. D. Pederson, Rill-Rlli Enf. Coordinator R. Bellamy, RI.

EJM, Ril (e-mail)

D. Spitzberg, RIV/WCFO Greens l

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