ML20311A200

Response to NRC Letter: Initial Review for NYSERDA Request for License Amendment: Retained Premises Radiation Protection Requirements (LAR-20-001), Dated March 11, 2020 (EPID L-2020-LLA-0023), Dated March 30, 2020

ML20311A200
Person / Time
Site:	West Valley Demonstration Project
Issue date:	10/28/2020
From:	Bembia P State of NY, Energy Research & Development Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2020-LLA-0023, LAR-20-001
Download: ML20311A200 (33)

Text

4 ANDREW Governor EWYORK TCOf ClPPORTIJmfY_

M. CUOMO

-NYSEROA RICHARD L. KAUFFMAN Chair DOREEN M. HARRIS Acting President and CEO October 28, 2020 10 C.F.R 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 New York State Energy Research and Development Authority Western New York Nuclear Service Center Docket No.: 50-201 Request for License Amendment: Retained Premises Radiation Protection Requirements (LAR-20-001)

SUBJECT:

Response to NRC Letter: INITIAL REVIEW FOR NYSERDA REQUEST FOR LICENSE AMENDMENT: RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (LAR-20-001),

DATED MARCH 11, 2020 (EPID L-2020-LLA-0023), dated March 30, 2020

References:

[1] NRC letter to NYSERDA,

Subject:

Authority Under License for Health and Safety, dated November 7, 2018 (ADAMS Accession No., ML18282A523)

[2] NYSERDA letter to NRC Subject NYSERDA REQUEST FOR LICENSE AMENDMENT: RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (LAR-20-001), dated March 11, 2020

[3] NRC letter to NYSERDA

Subject:

INITIAL REVIEW FOR NYSERDA REQUEST FOR LICENSE AMENDMENT: RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (LAR-20-001),

DATED MARCH 11, 2020 (EPID L-2020-LLA-0023), dated March 30, 2020 On August 9, 2019, the New York State Energy Research and Development Authority (NYSERDA) held a pre-amendment discussion with the NRC to discuss the short- and long-term licensing needs ofNYSERDA at West Valley (Reference [l]). The discussion concluded that NYSERDA would submit a narrow license amendment request (LAR) to modernize the radiation protection portions of the license and simplify NYSERDA' s radiation protection requirements.

NYSERDA's LAR was submitted by letter dated March 11, 2020 (Reference [2]). On March 30, 2020 (Reference

[3]), the NRC completed its initial review of the LAR and identified areas where additional information was needed in order for the NRC to complete its acceptance review process. Attachment 1 to this letter provides NYSERDA's response to Reference [3]. Attachment 2 contains a revised Radiation Protection Plan for the Retained Premises, RP- /

RPP500.02, which replaces Enclosure 2 of Reference [2]. ft O IJ PJB!20amd034 ft/f<_ /<._

New York State Energy Research 11nd Development Authority Albany Buffalo New York Clty West Valley S~e 17 Columolll Circle. Albany, NY 12203-6399 726 Exchange Street 1359 Broadway Management Program (P) 1-866-NYSERDA I (F) 51S-862-1091 Surte 821 19th Floor 9030-B RoJte 219 Buffalo, NY New York. NY West valley, NY nyserda.nygov I 1n'o'linyserda nygov 14210-1484 10018-7842 \4171-9500 (P) 716-842-1522 (P) 212-971-5342 (Pl 716-942-9960 (F) 716-842-0156 (F) 518-862-1091 (F) 716-942.9961

Document Control Desk October 28, 2020 Page2 The NRC comments request additional infonnation and descriptive discussion regarding NYSERDA's Retained Premises Radiation Protection Program, with specific focus on Radiological Safety Evaluations, action limits for the use of Radiological Work Permits, and action limits for the use of specific radiological work controls. The letter also asks questions about NYSERDA's use of information from the West Valley Demonstration Project environmental monitoring program, and the use of radiation protection practices from the State-Licensed Disposal Area Radiation Protection Program These items are addressed in the attached comment responses.

In response to NRC's questions and comments, this letter provides changes to the Retained Premises Radiation Protection Plan, RP-RPP500.02, which is included as Attachment 2, and provides information requested by NRC (such as additional descriptive information on NYSERDA's radiation safety evaluation process and the use of an RWP for implementing radiological work controls). It is important to note that the detailed information on actions limits, etc., is provided in Attachment 1 and is included in the implementing procedures for the Retained Premises Radiation Protection Plan, which are available for NRC' s inspection at NYSERDA' s West Valley Office.

NYSERDA looks forward to NRC's response to the information provided in this transmittal.

I certify under penalty of perjury that the foregoing is true and correct.

Executed on October 28, 2020.

Sincerely, g~~~~or West Valley Site Management Program NYSERDA PJB/amd Attachments:

1) Response to the NRC Initial Review Questions

2) Radiation Protection Plan for the Retained Premises, RP-RPP500.02 ecs:

New York State Energy Research and Development Authority J. A. Dean, NYSERDA-Albany (w/encl.) Janice.Dean@nyserda.ny.gov A. L. Mellon, NYSERDA-WV (w/encl.)Andrea.Mellon@nyserda.ny.gov D. W. Coble, NYSERDA-WV (w/encl) Douglas.Coble@nyserda.ny.gov P. Costello, NYSERDA-Albany (w/encl.) Peter.Costello@nyserda.ny.gov A. Peterson, NYSERDA-Albany, (w/encl.) designated State Official, Alyse.Peterson@nyserda.ny.gov PJM0amd034

Document Control Desk October 28, 2020 Page 3 Nuclear Regulatory Commission J. Lubinski, Director, NMSS, NRC (w/encl.)Jobn.Lubinski@nrc.gov P. Holahan, NRC (w/encl.)Trish.Holahan@nrc.gov B. Watson, NRC (w/encl.) Bruce.Watson@nrc.gov M. Doell (w/encl.) marlaynadoell@nrc.gov New York State Department of Environmental Conservation T. B. Rice, NYSDEC (w/encl.) Timothy.Rice@dec.ny.gov New York State Department of Health A. Damiani, NYSDOH (w/encl.)Alex.Damiani@health.ny.gov Seneca Nation of Indians Mr. Rickey L. Armstrong, Sr., President c/o Jackie Crouse (w/encl.)j.crouse@sni.org Department of Energy B. C. Bower, DOE-WVDP (w/encl.) Bryan.Bower@emcbc.doe.gov Audrey Seely, DOE-WVDP (w/encl.) Audrey.Seely@emcbc.doe.gov DOESupportstaff@emcbc.doe.gov (w/encl.)

Environmental Protection Agency A. Iglesias, EPA (w/encl.)Iglesias.Ariel@epa.gov p JB/20amd034

Attachment 1 Response to the NRC Initial Review Questions NRC Comment 1- Work Evaluation Process: A work evaluation process that contains action limits for when radiation controls for proposed work must be addressed in a radiation work permit or its equivalent. While NYSERDA states it will have an evaluation process and a procedure ("Retained Premises Radiological Safety Evaluation and Radiation Work Permits") to address evaluation of radiological work as referenced in Table 1 of the submittal, more descriptive information of its work evaluation process is needed to determine its adequacy.

NYSERDA Response Procedure RP-RPP-007, Retained Premises Radiological Safety Evaluations and Radiological Work Permits identifies the work evaluation process that must be completed prior to the commencement of work activities on the Retained Premises. The work evaluation process, known as the Radiological Safety Evaluation, is described below.

Radiological Safety Evaluation (RSE) - An RSE is an administrative tool used to evaluate a proposed work activity and the radiological conditions of the specific location where upcoming work is planned, in order to determine if radiological controls are warranted for the protection of the worker, the public, and the environment. The RSE is completed by the Radiation Safety Officer (RSO) and includes:

a) A detailed review of the proposed work activity, including the work location and the work steps.

b) A review of historical activities in the work area, and whether the work area is in or near radioactive material effluent discharge points or areas of releases, or is located in or near areas where work was previously conducted with radioa6tive materials.

c) A review and evaluation of existing radiological surveys of the proposed work area to evaluate dose rates, including aerial radiation surveys.

d) A review and evaluation of analytical results from samples collected from the work area to identify concentrations and radionuclides present in the work area.

The RSO will review the work activity, work location, survey results, and sampling data to address the following:

a) Will the work be performed in areas where known removable activity exists in excess of 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha and or 200 dpm/100 cm2 beta/gamma?

b) Will the work be performed in known soil contamination area in excess of 22.5 pCi/g gross alpha and or 68.3 pCi/g gross beta/gamma?

c) Will workers be accessing posted radiologically controlled areas (i.e., Contamination Area, Soil Contamination Area, Airborne Radiation Area, Radiation Area, High Radiation Area)?

d) Will workers be exposed to dose rates of 2 mrern/hr or greater?

e) Is there a potential for workers to receive more than 500 rnrem for the year (i.e., greater than 10 percent of the annual limit for occupational exposure from external sources)?

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f) Will the work involve removable radioactive material (e.g., creek sediments downstream of the WVDP, contaminated soils, containerized wastes, etc.)?

g) Will the work cause airborne radioactivity greater than 10 percent of the Derived Air Concentration (DAC) value for the sum of the radionuclides based on the mix ratio or the most restrictive value from the mix of radionuclides (e.g., disturbing contaminated soil, cutting, grinding, or performing work on contaminated materials)?

h) Is there a potential for the worker to receive greater than 10 percent of the annual limit of intake for radionuclides of concern?

i) Will the work take place in a Restricted Area of the Center, or in an area with limited or no recent data?

j) Will work include excavating in an area with little or no historical data or process knowledge?

The RSO will evaluate the information identified above and make a determination as to whether work controls, dosimetry, PPB, monitoring, etc. are required to protect workers from radiological hazards associated with the work activity (the action levels for requiring such work controls are provided in the response to Comment 2). If work controls are required, they are implemented through the RWP, described below. \

NRC COMMENT 2 - Process for Implementing Radiation Controls: A process for implementing NYSERDA's radiation protection controls (e.g., a Radiation Work Permit (RWP) program that specifies the dosimetry, personnel protective equipment, contamination control, access control, and environmental monitoring suitable for the nature of the hazards/work) must be included in the submittal. While NYSERDA states it will have procedures for "Retained Premises Radiological Safety ¥valuation and RWPs" in Table 1 of the submittal, more descriptive discussion of the radiation control program is needed to determine its adequacy. Any such discussion should include appropriate action limits for when specific controls would be required.

NYSERDA Response Procedure RP-RPP-007, Retained Premises Radiological Safety Evaluations and Radiological Work Permits, describes NYSERDA's RWP process: That process is summarized below:

Implementation of the RWP Process:

RWPs are prepared by the NYSERDA Radiation Safety Officer (RSO). The RWP provides specific requirements for protecting workers from radiological hazards associated with the work activity, and contains seven subsections that provide the following information:

purpose current or anticipated radiological conditions in the work area (from the RSE) personal protective equipment (PPB) requirements monitoring requirements limiting conditions established to protect the workers special instructions approval signatures A2.

The RWPs are prepared and signed-off by the RSO and are approved by the project manager in charge of the work activity and the Retained Premises Radiation Safety Committee. RWPs are included in the work instruction package for the work activity. The RWP must be read and sign~ by each member of the work crew, which provides each worker's attestation to the following statement:

"Workers assigned to this job verify, by their signature, that they have read the RWP and received a radiation safety briefing, are aware of the hazards associated with the work, and will comply with the requirements-of this R WP for PPE and safety controls."

Action Limits for Specific Work Controls:

Radiological Work Permit-Action limits for the preparation of the RWP are as follows:

a) Removable activity levels are expected to be greater than 20 dpm/l00cni for alpha emitting radionuclides and/or greater than 200 dpm/100 cm2 for beta/gamma emitting radionuclides.

b) Work will involve accessing a posted radiologically controlled area.

c) Dose rates in the proposed work area are greater than 2 millirem per hour.

d) Areas where there is the potential to receive greater than 10 percent ofNYSBRDA's administrative annual limit for occupational exposure from external sources (i.e., 10% of the 500 millirem/year administrative lillllt or 50 millirem) for the duration of the job.

e) There is the potential for an individual to receive 10 percent of the annual limit on intake for the radionuclide(s) of concern.

• f) There is the potential for personal contamination due to the presence of removable radioactive material.

g) There is the potential for airborne contamination greater than 10 percent of the DAC values for the sum of the radionuclides based on the mix ratio or the most restrictive value from the mix radionuclides.

h) Areas where the radiological conditions are unknown.

Personal Protective Equipment (PPE) - Action limits for requiring PPB are as follows:

General

• PPE will be required for entry into an area where removable radioactivity is greater than 20 dpm/100 cm2 alpha, and/or greater than 200 dpm/100 cm2 beta/gamma (i.e., an area posted as a contamination area).

• PPB will be required for entry into Airborne Radiation Areas 1*

Thresholds for Specific Types of PPB include:

• Coveralls will be required for entry into areas where removable radioactivity levels are greater than 20 dpm/100 cm2 alpha, and/or200 dpm/100 cm2 beta/gamma.

1 The term Arrbome Radiation Area used here and throughout the RP RadrntJon Protection Program 1s as defined 10 CFR 20 1003. There are presently no areas on the Retained Prenuses that meet the defimtJ.on of an Airborne Rad1atJ.on Area If future work actiV1ttes may generate airborne concentratmns of rad10act1ve matenals meeting the defin1t1on of an Airborne Rad1at1on Area, NYSERDA will implement a respiratory protect10n program m accordance with IO CFR Part 20 Subpart H prior to approV!ng any such work activity A3

• For lyIIlOvable activity levels 100 times greater than the above values (i.e., 2,000 dpm/100 cm2 alpha, and/or 20,000 dpm/100 cm2 beta/gamma), two sets of coveralls are required.

• Water-resistant coveralls will be considered when there 1s the potential for contact with radioactive liquids or unknown liquids. Consideration of hazards associated with increased PPE (such as heat stress) will also be evaluated when making this decision.

• For work in contamination areas or for work with contaminated soil, hoods and/or caps will be required, based on the specifics of the work activity, to protect hair from becoming contaminated.

• For areas where removable radioactivity levels are greater than 20 dprn/100 cm2 alpha, and/or 200 dpm/100 crn2 beta/gamma, one pair of rubber or latex/nitrile gloves is required (with glove liners as an option). Alternatively, a combination of two pair of gloves may be worn in place of the rubber or latex/nitrile gloves.

• For tasks involving sharp tools, edges, or objects, puncture resistant gloves must be worn.

• For areas where the removable radioactivity levels are greater than 20 dpm/100 cm2 alpha, and/or 200 dpm/100 cm2 beta/gamma, one pair of shoe covers and rubbers are required.

• For areas where removable radioactivity levels are 100 times the contamination levels above (i.e., 2,000 dpm/100 cm2 alpha, and/or 20,000 dpm/100 cm2 beta/gamma), two pairs of shoe covers are required.

Respiratory Protection -There are no operating systems or emission sources on the RP, and the only radionuclides present on the RP outside of the SDA are found in slightly contaminated environmental media (soils and sediment).-

For activities that may create d,µst or other airborne contamination, NYSERDA will do a task-specific determination of the need for respiratory protection as part of the ~diological Safety Evaluation.

• Respiratory protection will be required for entry into Airborne Radiation Areas or when performing tasks that may generate airborne radioactivity meeting the definition of an Airborne Radiation Area.

Consideration will also be given to the use of engineering controls to reduce or contain airborne radioactivity so that respiratory protection devices are not necessary. 2 Dosimetry-Action Limits for requiring dosimetry are as follows:

• Dosimeters are required for radiological workers likely to recei_ve an occupational dose from sources external to the body for the calendar year in excess of exceed 10 percent of the dose limit appropriate for the individual as specified in 10 CFR 20.120l(a).

• Dosimeters for a declared pregnant woman likely to receive an occupational dose from sources external to the body for the entire gestation period greater than a deep dose equivalent of 0.1 rem.

• Dosimeters are required where there is the potential to receive radiation dose from external sources in excess of 2 mremlhour (0.02 mSwhour).

• Dosimeters and Self-Reading Dosimeters (SRD) such as pocket ion chamber or Alarming Electronic Dosimeters (ED) are required for entries where external dose rates greater than five mremlhour (0.05 mSv/hour) are anticipated.

In accordance with IO CFR 20.170 I.

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Monitoring -Action limits for monitoring are as follows:

• General Area air samples are required when completing tasks in areas that are expected to generate airborne radioactivity where an individual may receive greater than 10 percent of the annual limit of intake over the duration of the task.

• Breathing Zone Air Samples are required in a posted Airborne Radiation Area and for any work activity where respiratory protection is required.

• Radiation Protection Technicians - All work acti~ties that meet or exceed the requirements for posted Airborne Radiation Areas require the continuous presence of a Radiological Control Technician throughout the work activity.

training - Action limits for training are as follows:

• Workers accessmg restricted or radiologically controlled posted areas are required to have, at a minimum, Radiation Worker Level I training.

• Workers conducting hands on work with radioactive materials in any area are required to have Radiation Worker Level II training.

• A pre-job briefing is required for all work performed under an RWP.

Special Work Instructions/Restrictions-Sped.al work instructions are used to incorporate specific requirements for performing a task (e.g., the use of containment or ventilation systems). Special work instructions must be clear and are_ specifically covered during the radiation safety briefings.

If special work instructions/restrictions identify additional PPE requirements, NYSERDA requires a special PPE practical prior to initiation of work activities.

NRC COMMENT 3 - Environmental Monitoring Program: More information on NYSERDA's environmental monitoring program for the retained premises is needed to determine its adequacy. In the submittal, NYSERDA indicates that it proposes to take credit for the DOE program so long as it encompasses NYSERDA's environmental monitoring requirements for this area. There is no discussion or justification of the basis environmental monitoring requirements for the retained premises nor is there a discussion of what NYSERDA plans to do if any elevations or increasing trends are identified in its environmental monitoring program. Further, NYSERDA has not provided a com.ntltment to establish sampling/monitoring at appropriate locations either before or after work commences in radiological contaminated and potential contaminated areas it proposes to do work, especially for soil disturbing activities.

NYSERDA Response NRC's comment raises several issues regarding an environmental monitoring program for the Retained Premises.

NYSERDA addresses each issue separately below:

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"More information on NYSERDA 's environmental monitoring program for the retained premises is needed to determine its adequacy. "

NYSERDA's submittal provides information on the Retained Premises Radiation Protection Program, which was structured to comply with 10 CFR 20, Subpart F. The requirements of Subpart Fare as follows:

Each licensee shall make or cause to be made, sunieys of areas, including the subsuiface, that -

(I) May be oecessary for the licensee to comply with the regulations in this part; and (2) Are reasonable under the circumstances to evaluate-(i) The magnitude and extent of radiation levels; and (ii) Concentra_tions or quantities of residual radioactivity; and (iii) The potential radiological hazards of the radiation levels and residual radioactivity detected.

RP-RPP500 Section 5.3, Radiological Sunieys and Analytical Data, (as revised) describes the program requirements for monitoring environmental conditions inside the Retained Premises. Environmental data obtained from the WVDP Annual Site Environmental Report and SDA Annual Report will be evaluated annually by NYSERDA to determine whether there are indications of changed radiological conditions at the WVDP or SDA that may also have I >

an impact on the Retained Premises. Additionally, RP-RPP500, Section 5.3 requires that sampling/monitoring be conducted at appropriate locations both before and after work commences in radiological contaminated and potential contaminated areas it proposes to do work, especially for soil disturbing activities. Therefore_, NYSERDA has concluded that the Retained Premises Radiation Protection Program is in compliance with 10 CFR 20 Subpart F such that no additional monitoring framework is needed.

Because the Western New York Nuclear Service Center encompasses an area of over five square miles, NYSERDA uses several sources of data to identify the radiological conditions on the Retained Premises as needed for compliance with Subpart F, including:

• Rad.iation surveys and soil samples that will be conducted at the work location prior to or as part of current work activities;

• Radiation surveys and soil samples that were conducted in the vicinity of current work locations during previous work activities;

• Radiation surveys and soil sampling that were conducted in 2015-2016 as a follow-up to the 2014 aerial radiation survey;

• Aerial radiation surveys, with emphasis on the 2014 aerial radiation survey;

• Environmental data from th~ adjacent WVDP and SDA areas of the Center .

In the submittal, NYSERDA indicates that it proposes to take credit for the DOE pr.ogram so long as it encompasses NYSERDA 's environmental monitoring requirements for this area. There is no discussion or justification of the basis environmental monitoring requirements for the retained premises ... "

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While NYSERDA's submission nowhere states that NYSERDA will take credit" for the WVDP monitonng program in order to meet requirements for an environmental monitoring program for the Retained Premises, we appreciate the need to clarify the relationship between these different parts of the site. As identified above, the data from the WVDP environmental monitoring program is one source of information available to NYSERDA for the evaluation of radiological conditions on the Retained Premises in order to meet the requirements of 10 CFR 20 Subpart F. NYSERDA will review the data in the WVDP Annual Site EnVll"onmental Report for the purpose of evaluating whether there are indications of changed radiological conditions at the WVDP that may also have an impact on the Retained Premises. NYSERDA will evaluate the data from the SDA environmental monitoring program in the same manner. The other data sources identified above consist of Retained Premises radiological surveys and soil samples that were collected previously at qr near the proposed work location, new radiological surveys and soil samples that will be collected as part of the upcoming work activity, and aerial radiation surveys that can give an indication of general dose rates in an area.

" ... nor is there a discussion of what NYSERDA plans to do if any elevations or increasing trends are identified in its environmental monitoring program "

a) As described in RP-RPPS00, if off-normal results or increasing trends at the WVDP or SDA environmental monitoring results are identified, NYSERDA will evaluate the data to determine whether the results indicate that a) the Retained Premises could be impacted; and b) consider whether an environmental evaluation for that area of the Retained Premises, possibly including radiation surveys or the collection of samples. Based on the results of that evaluation, the RP Radiation Safety Committee will identify any needed follow up actions.

Further, NYSERDA has not provided a commitment to establish sampling/monitoring at appropriate locations either before or after work commences in radiological contaminated and potential contaminated areas it proposes to do work, especially for soil disturbing activities.

In response to this comment from Staff, NYSERDA has clarified and strengthened the language in RP-RPPSOO Section 5.3, that commits to establish sampling/monitoring at appropriate locations both before and after work commences in radiological contaminated and potential contaminated areas it proposes to do work, especially for soil disturbing activities.

We note that environmental monitoring requirements under Provisional Operating License CSP-Lare set out in Technical Specification 5 are currently in abeyance, and for that as well as the following addit10nal reasons, NYSERDA believes that these requirements are not applicable to NYSERDA's work on the Retained Premises today. Specifically:

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a) The environmental monitoring requirements in Technical Specification 5 were established to morutor releases and impacts from an operating spent nuclear fuel reprocessing facility. The reprocessing facility ceased operations in 1972, and the reprocessing facility and the systems that discharged radioactive materials 'to the environment were transferred to DOE in 1981 via License Change No. 31.

b) Most of the reprocessing facility syst~, buildings, and discharge points no longer exist today, Discharges from any remaining facilities or systems are extensively managed and monitored by the WVDP.

c) The Technical Specifications under License CSF-1 were put iri abeyance in 1981 by License Change No.

31 when the facility was transferred to DOE. As such, there is no formal requirement for an environmental monitpring program for the Retained Premises. It is important to note, however, that NYSERDA believes that the E,.etained Premises Radiation Protection Program provides the data collection and evaluation framework needed to fully ~mply with 10 CFR 20 Subpart F.

NRC 'Comment 4 - NYSERDA indicates that its implementing processes for its programs are adequate because they are consistent with those it has in place for the SDA. The SDA is not part of the NRC license and thus not inspectable under NRC License No. CSF-1.'Implementing procedures are reviewed in NRC inspection space to ensure they are consistent the license requirements.

NYSERDA Response NYSERDA recognizes that all components of the Retained PI:emises Radiation Protection Prograi:n must meet the requirements of 10 CFR 20 regardless of whether they are part of the SDA Radiation Pro~ection Program AB

Attachment 2 Retained Premises Radiation Protection Plan RP-RPPS00.02 r

New York State Energy Research and Development Authority West Valley Site Management Program vyest Valley, NY 10/28/2020

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1 Purpose The New York State Energy Research and Development Authority (NYSERDA), as a U.S. Nuclear Regulatory Commission (NRC) licensee, developed the Retained Premises Radiation Protection Program (RP-RPP) for the Western New York Nuclear Service Center (WNYNSC) to control the receipt, possession, use, transfer, and disposal of licensed materials to ensure that the total individual dose does not exceed the NRC's 10 CPR 20 standards for radiation protechon, and is as low as reasonably achievable (ALARA). The RP-RPP consists of this Radiation Protection Plan (RP-RPPS00) and a series of implementing procedures that provide the details of the management and technical framework and administrative and engineering controls needed to demonstrate NYSERJ)A's compliance with the 10 CPR 20 standards.

1.1 Definitions

a) ALARA - as low as is reasonably achievable; incltldes making every reasonable effort to maintain exposures to radiation as far below the dose limits as is practical. These measures include taking into the account the cost related to the reduction in dose to public health and safety, the state and cost of technology, and other societal and socioeconomic considerations, as they relate to the residual concentrations of licensed materials present on the RP.

b) Airborne Radiation Area 1 - is an area where an individual can be exposed to airborne radioactivity levels exceeding, or are likely to exceed, the Derived Air Concentration values listed in excess of the Derived Air Concentration specified in Appendix B to 10 CFR 20.1001-20.2401; or An individual present in the area without respiratory protective equipment could exceed, during

_ the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake or 12 Derived Air Concentration-hours.

I.

c) Controlled Area -An area of the WNYNSC outside of a restricted area, but inside the site boundary. Public access to this area is limited. The entire boundary of the WNYNSC property (approximately 3,300 acres) is controlled and marked by a three-stand barbed wire fence with posted signs displaying ipformation at regular intervals. Figure 1-1, WNYNSC Aerial Orthoimagery Acquired November 1, 2010, identifies the controlled area boundary of the WNYNSC in yellow.

Based on the aenal rad1at1on surveys and env1TOnmental morutonng sampling data, there are no areas on the RP that meet this defimtion. IfNYSERDA identifies an area meeting this defimtJon, NYSERDA wtll unplement rad1at10n safety controls m accordance wtth this document and its implementing procedures, includmg, but not !united to postmg of the area r

Retained Premises Radiabon ProtectJon Plan, RP-RPPSOO 02 -1

Figure 1-1 . WNYNSC Aerial Orthoimagery Acquired November 2, 2010 Source: NYSERDA Western New York Nuclear Service Center 3-inch Aerial Orthophotography Acquired 11/9/15

~ Controlled Area 0.25 0.5 C*\GIS_doto_LMG\Projects\Retained Premises\2020 01 30_WNYNSC_Ccnlrolled m,d Retained Premises Radiation Protection Plan, RP-RPPS00.02 2

d) High Radiation Area 1 - is defined as an area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving a dose equivalent in excess of0.1 rem (100 millirem or one mSv) in one hour at 30 centimeters

(

(approximately one foot) from the radiation source or 30 centimeters from any surface that the radiation penetrates.

e) Radiation Area 1 - is defined as an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem (five millirem or 0.05 mSv) in one hour at 30 centimeters (approximately one foot) from the radiation source or 30 centimeters from any surface that the radiation penetrates.

f) Removable Contamination Limits -Removable activity. in excess of 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha and/or 200 dpm/100 crn2 beta/gamma.

g) Restricted Area - 1s an area where access has been limited by NYSERDA because of the potential for exposure to radiation and radioactive materials. Based on aerial radiation surveys and environmental monitoring sampling data, NYSERDA has two areas on the RP that are potentially impacted as restricted areas. Work activities in these areas may require additional work controls or monitoring. These areas are identified in Figure 1-2. All other areas of the WNYNSC are controlled areas where public access is controlled and radiation levels are expected to be at or consistent with bjlckground levels.

h) Soil Contamination Area 1 - an area where soil contamination is known to exist or is likely to exist in concentrations greater than 20 dpm/gram (gm) alpha above background or 100 dpm/gm beta/gamma above background, and should be posed with the words Caution, Soil Contamination Area."

i) Site boundary - is the line beyond which the land or property is not owned or controlled by NYSERDA j) Very High Radiation Area 1 - is defined as an area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving an absorbed dose ~ excess of 500 rads (five gray) in one hour at one meter (approximately three feet) from a radiation source or one meter from any surface that the radiation penetrates.

Retained Premises Radiation Protection Plan, RP-RPP500 02 3

Figure 1-2. Restricted Areas of the Retained Premises Source: NYSERDA Western New York Nuclear Service Center 3-inchAerial Orthophotography Acquired 11/9/15 Controlled Area Restricted Areas Retained Premises Radiation Protection Plan, RP-RPPS00.02 4

/

1.2 Radiation Protection Program Requirements 10 CPR Part 20.1101, Purpose, provides the following specific requirements for Radiation Protection Programs:

(a) Each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part.

(b) The licensee shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is reasonably achievable (ALARA).

(c) The licensee shall periodically (at least annually) review the radiation protection program content and implementation.

( d) To implement the ALARA requirements of 1020.1101 (b ), and notwithstanding the requirements in 10 CPR 20 Subpart D Radiation Dose Limits for Individual Members of the Public, a constraint on air emissions of radioactive material to the environment, excluding Radon-222 and its daughters, snail be established by licensees other than those subject to 10 CPR 50.34a, such that the individual member of the public lik~ly to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 mrem (0.1 mSv) per year from these emissions. If a licensee subject to this requirement exceeds this dose constraint, the licensee shall report the exceedance as provided in 10 CPR 20.2203, Reports of exposures, radiation levels, and concentrations of radioactive material exceeding the constraints or limits, and promptly take appropriate corrective action to ensure against recurrence.

This RP-RPP provides the framework to demonstrate that NYSERDA is in compliance with the requirements of 10 CPR 20 Subpart B -Radiation Protection Programs. This plan is supported by a number of detailed implementing procedures that are available for NRC's inspection at NYSERDA's West Valley Office.

Revisions to this plan and associated implementing procedures will be approved by NYSERDA's Radiation Safety Committee (RSC) prior to implementation.

Retained Premises Radiation Protection Plan, RP-RPP500 02 5

2 Background NY SERDA holds title to the WNYNSC on behalf of the people of the State of New York. The WNYNSC, located near West Valley, New York, approximately 30 miles south of Buffalo, in the towns of Ashford and Concord, was operated as a licensed nuclear fuel reprocessing facility from 1966 to 1972.

The WNYNSC is approximately 3,300 acres and is divided into three separate operational areas: the 167-acre West Valley Demonstration Project (WVDP), the 15-acre State-Licensed Disposal Area (SDA), and the relatively undeveloped 3, 100-acre RP. The WNYNSC is licensed by the NRC under 10 CFR Part 50, except for the SDA, which is licensed and regulated by the State of New York. The 167-acre WVDP premises, containing the former reprocessing facility, the NRC-Licensed Disposal 'Area, High-Level Waste tanks, waste lagoons, aboveground storage areas, and other facilities, is currently under the U.S.

Department of Energy's (DOE) possession, control, and oversight in accordance with the WVDP Act and the Cooperative Agreement between the United States Department ofEnergy and the New York State Energy Rese~ch and Development Authority on the Western New York Nuclear Service ce,lter at West Valley New York (Cooperative Agreement 4). Separate radiation protection programs are in effect for the

• WVDP and SDA

~

4 Effective October 1, 1980, as amended September 18, 1981, U S. DOE and NYSERDA (Cooperanve Agreement).

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2.1 Retained Premises NYSERDA is the sole licensee under a provisional operating license (NRC License CSF-1 5) for the non-SDA portions of the WNYNSC. The Part 50 License is not presently applicable to the WVDP Premises and activities since DOE has exclusive possession and use of the 167-acre WVDP Premises. NYSERDA provides for radiation safety and the protection of individuals on the balance of the RP, excluding the SD.A, in accordance with NRC regulation 10 CFR, Part 20: Standards for Protection Against Radiation including the ALARA philosophy, and in accordance with this plan. Per the Cooper~tive Agreement, DOE has the authority to conduct work on the Retained Premises necessary to carry out the WVDP; and, as such, RP-RPP5Q0 does not apply to DOE or its contractors conducting WVDP actions on the Retained Premises.

2.2 West Valley Demonstration Project As described above, DOE has exclusive use and possession of 167 acres of the WNYNSC to perform the WVDP. Radiation protection for the WVDP is provided by DOE's contractors under the scope ofDOE's regulations and orders. RP-RPP500 does not apply tb the WVDP Premises, or to DOE or its contractors conducting WVDP actions on the Retained Premises.

2.3 State-Licensed Disposal Area Adjacent to the WVDP, the SDA was operated as a commercial low-level radioactive waste disposal facility from 1963 to 1975. NYSERDA holds a Radioactive Materials License for the SD.A, which is administered by the New York State Department of Health under the scope of New York State's ionizing radiation protection regulations. Work performed at the SDA is subject to the SDA Radiation Protection Program, which was developed m accordance with the SDA Radioactive Materials License and applicable New York State (NYS) regulations.

NYSERDA's management of the SDA is also subject to the requirements of a Radiation Control Permit issued by the New York State Department of Environmental Conservation under applicable NYS regulations.

Apnl 19, I %6 Issued under 10 CFR 50. Domestic L1censmg of Product.ton and Utihzatton Fac1hties."

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j 3 Re~ponsibilities 3.1 NYSERDA Management NYSERDA management is responsible for providing the resources, and creating or supporting the policies, direction, etc. needed to establish a radiation protecti9n program that is in compliance with 10 CFR Part 20. Resources include equipment (e.g., instruments, materials, and equipment); and qualified personnel needed to develop and implement the RP-RPP. These resources may be provided by contract organizations or directly by NYSERDA.

3.2 Retained Premises Radiation Safety Committee As described in NYSERDA's implementing procedures for RP-RPP500, NYSERDA has established a

\

Radiation Safety Committee for the Retained Premises (RP-RSC). The RP-RSC is responsible for developing radiation safety policies and exercising effective oversight of the RP~RPP in accordance with 10 CFR Part 20. The RP-RSC will also conduct, or cause to be conducted, an annual audit of the content and implementation of the RP-RPP, as required under 10 CFR 20.1101, Radiation protection programs, and as specified in NYSERDA's implementing procedures.

3.3 Radiation Safety Officer In order to ensure consistent and effective implementation of this RP-RPP, a qualified 1Radiation Safety Officer (RSO) will oversee the day-to-day implementation of the RP-RPP. The RSO ensures that the details of the program are implemented in compliance with applicable regulations, the RP-RPP500, and the implementing procedures. The RSO has direct access to the NYSERDA West Valley Site Management Program Director and the RSC in order to address iss_ues that affect radiation protection on the RP. The RSO (and any worker) also has,the authority to stop work if unsafe conditions exist. The duties and responsibilities of the RSO are described in-NYSERDA's detailed implementing procedures.

r Retained Premises Racltatlon Protection Plan, RP-RPP500.02 8

4 ALARA Policy NYSERDA is committed to maintaining radiation exposures and releases of radioactive material as far below the regulatory limits in 10 CFR Part 20 as is practical, as defined in Section 1.1 of this RP-RPP.

The RP-RSC will review work activities planned for the RP to assure that every reasonable effort to maintain exposures to radiation are as low as reasonably achievable, and in compliance with 10 CFR 20.

Work activities conducted in restricted areas of the RP are evaluated using a formal Radiological Safety Evaluation (RSE) process, and any required work controls are implemented through a Radiological Work Permit (RWP) process, as described in NYSERDA's detailed implementing procedures.

Per 10 CFR 20.1101 (d), in order to implement the ALARA requirements of 10 CFR 20.1101 (b), and notwithstanding the requirements in 10 CFR 20.1301, Dose limits for individual members of the public, a constraint on air emissions of radioactive material to the environment, excluding Radon-222 and its daughters, shall be established by licensees other than those subject to 10 CFR 50.34a, such that the individual member of the public likely to receive the highest dose will not be expected to receive a total

-effective dose equivalent in excess of 10 mrem (0.1 mSv) per year from these emissions. Also, 10 CFR 20.1101 (d) states that if a licensee subject to this requirement exceeds this dose constraint, the licensee shall report the exceedance as provided in 10 CFR 20.2203, Reports of exposures, radiation levels, and concentrations of radioactive material exceeding the constraints or limits, and promptly take appropriate corrective action to ensure against recurrence. NYSERDA notes that there are presently no operating systems on the RP and no active sources of emissions to the air. If any operating systems are constructed or mitigation work is initiated on the RP that could result rn emission of radioactive material to the air, NYSERDA will ensure that those work activities are conducted in a manner that will meet the requirements of 10 CFR 20.1101 (d). Examples of measures that could be implemented include the use of engineered emission controls and applying water or fixatives to suppress dust emissions.

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5 Radiological Surveys and Monitoring 5.1 Radiological Safety Evaluation To comply with the requirements of 10 CFR 20 Subpart F - Surveys and Monitonng, NYSERDA's RP-RPP includes a framework of surveying and monitoring on the RP necessary to comply with 10 CFR Part

20. The details of the survey and monitoring requirements are presented in the implementing procedures for the RP-RPP. All restricted area work activities on the RP require the completion of a Radiological Safety Evaluation.

Radiological Safety Evaluation (RSE) - An RSE is an administrative tool used to evaluate the radiological haz.ards of the specific Retained Premises area where upcoming work is planned in order to determine if radiological controls are warranted for the protection of the worker, the public, and/or the environment. The RSE is completed by the RSO and includes:

a) Adetailed review of the proposed work activity, including the work location and the work steps.

b) A review of historical activities in the work area, and whether the work area is in or near radioactive material effluent discharge points ~r areas of releases, or is located in or near areas where work was previously conducted,with radioactive materials.

c) "

A review and evaluation of existing radiological surveys of the proposed work area to evaluate d(?Se rates, including aerial radiation surveys.

d) A review and evaluation of analytical results from samples collected from the work area to identify concentratio~ and radionuclides present in the work area. * -

The RSO will, evaluate the information identified above and will make a determination as to whether work controls, dosimetry, personal protective equipment (PPE), monitoring, etc. are required_ to protect workers from radiological haz.ards associated with the work activity. If controls are required, an RWP is required. NYSERDA'-s detailed implementpig procedµres include specific action limits for when an RWP will be used to implement radiation work controls.

5.2 Radiological Wo~k Permit 5.2.1 Radiological Work Permits -An RWP is prepared by the NYSERDA RSO. The RWP provides specific requirements for protecting workers from radiological haz.ards associated with the work activity, an4 contains seven subsections that provide the following information:

a) purpose, Retained Premises Radiation Protecbon Plan, RP-RPPSOO 02 -. 10

b) current or anticipated radiological conditions in the work area (from the Radiological Safety Evaluation) c) PPE requirements d) monitoring requirements e) limiting conditions established to protect the workers f) approval signatures g) special instructions The RWPs are prepared and signed-off by the RSO and approved by the project manager in charge of the work activity and the RSC. The RWP is included in th'e work instruction package for the work activity.

NYSE;RDA's detailed implementing procedures include specific action limits for requiring various radiological work controls, including training, dosimetry, PPE, respiratory protection, and work area monitoring.

5.3 Radiological Surveys and Analytical Data 5.3.1 Surveys Surveys of the Retained Premises are conducted as follows:

a) Aerial Radiation Surveys - In order to evaluate the status of radiological conditions on the 1 entire, five-square mile RP, NYSERDA conducted an aerial radiation survey of the entire WNYNSC property in 2014. Additional aerial radiation surveys will be conducted at a frequency sufficient to comply with the 10 CFR 20 Subpart F requirements, considering existing contaminat10n on the RP and the potential for releases of radioactive material to the RP. The aerial radiation survey provides a general indication of dose rates over broad areas of the WNYNSC and will be supported by detailed radiation surveys of the specific work location if such surveys do not already exist.

If, in the future, site decommissioning activities that could result in the release of radioactive material to the RP are no longer being conducted, the RP-RSC may consider whether it is /

necessary to continue aerial radiation surveys in order to comply with the requirements of 10 CFR 20 Subpart F - Surveys and Monitoring. If the RSC determines that the likelihood of releases are low and aerial radiation surveys are no longer needed to comply with the requirements of Subpart F, the detailed implementing procedure will be modified accordingly and approved by the RSC.

b) Work Area Radiological Surveys - Prior to performing work in a restricted area, NYSERDA will consider the need for work area surveys, based on existing aerial radiation surveys, historical site knowledge, and other relevant data and information. NYSERDA will perform the surveys of Retained Prermses Rad1abon Protection Plan, RP-RPPS00.02 11

the work area, if needed, to meet the Subpart F requirements and to prepare an RSE and RWP as described in NYSERDA's detailed implementing procedures. Relevant radiological haz.ard identification information will be included in the RSE, and the RWP will identify the work controls needed to safely perform the task. If the RSE shows that detailed information is needed for dose rates, specific radionuclides and concentrations, and that information is not otherwise available, the activity will include surveys and collecting both surface and subsurface soil samples, per 10 CPR 20, Subpart F - Surveys and Monitoring.

c) WVDP Annual Site Environmental Report and SDA Annual Report-Annually, NY SERDA will evaluate the WVDP Annual Site Environmental ReJ>?rt data provided by DOE for the purpose of evaluating whether there are indications of changed radiological conditions at the WVDP that may also have an impact on the Retained Premises.

d) State-Licensed Disposal Area at West Valley: Annual Report - NYSERDA will evaluate the data from the SDA environmental monitoring program, which is annually compiled and published in the State-Licens-ed Disposal Area at West Valley: Annual Report for the purpose of evaluating whether th~ are indications of changed radiological conditions at the SDA that may also have an impact on the Retained Premises.

I The review of the environmental reports will be document~ in an annual memo to file.

Significant results will be brought to the attention of the RP-RSC for consideration .of follow-up actions.

5.3.2 Radiation Detection Instruments All radiation detection instruments and equipment used for quantitative radiation measurements will be calibrated periodically for the radiation measured in accordance with 10 CPR 20.1501, General, (c), and 1

as described in NYSERDA's detailed implementing procedures.

5.3.3 Recordkeeping NYSERDA will report measurements ofradioactivity consistent with 10 CPR 20.1005, Units of radioactivity, and '_Vill maintain all records showing the results of surveys and calibrations in accordance with 10 CPR 20.1501 (b) and 10 CPR 20.2103, Records of surveys.

5.4 Monitoring Personnel monitoring for external and internal occupational dose will be performed in accordance with 10 CPR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose.

Retained Premises Radiation Protection Plan, RP-RPPSOO 02 12

Dosimetry used for external occupational exposure will conform to the requirements in 10 CFR 20.1501 I (d).

5.4.1 Reporting NYSERDA will report radiation doses consistent with 10 CFR 20.1004, Units of radiation dose, and will maintain records of external and internal occupational exposure in accordance with 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose, and 10 CFR 20 Subpart L - Records.

5.4.2 Records NYSERDA will maintain records from surveys in accordance with 10 CFR 20.2103, Records ofsurveys, and 10 CFR 20.1501 (b).

6 Control of Exposure from External Sources in Restricted Areas Based on the 2014 Aerial Radiation Survey, work area surveys, and environmental monitoring data provided in the WVDP Annual Site Environmental Report, there are no areas on the Retained Premises where the radiation levels from radiation sources external to the body could result in an individual receiving a dose equivai'ent in excess of 100 millirem per hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates (dose rates from in 10 CFR 20.1601, Control of access to high radiation areas, and 10 CFR 20.1602, Control of access to very high radiation areas.) If future surveys identify an area exceeding these thresholds, NYSERDA will include the needed work controls, monitoring, etc., in the pertinent implementing procedures.

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7 Respiratory Protection and Controls I

Subpart Hof 10 CFR 20 provides the requirements for respiratory protection and controls to restrict internal exposure in restricted areas. Based on the surveys and monitoring described above, along with records of historical site operations, there are no conditions present on the RP that would require respiratory protection to i;estrict internal exposure. Regardless, all work activities on the RP will be

-: reviewed in accordance with NYSERDA's RSE process described in the detailed implementing procedures arid NYSERDA will identify internal exposure hazards, if present. If such conditions on the RP are identified, detailed implementing procedures will be prepared, or exist~g procedures modified, as required to meet the requirements for <l respiratory protection program compliant with Subpart H.

Necessary training and other requirements will be met prior to the RSC approving the work activity. In addition, NYSERDA will consider the use of engineering cqntrols (e.g., dust suppression, containment, decontamination, or ventilation), if needed, to control the concentr~tion of radioactive material in the air, per 10 CFR 20, Subpart H - Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas.

8 Storage and Control of Licensed Materials Based on the aerial radiation surveys, work area surveys, and environmental monitoring data provided in the WVDP AnnuaI ,Site'Environm~tal Report, the only Part SO-licensed materials, that may be present on "

the RP are found in slightly contaminated soils and stream sediments. If radioactive waste is generated from work activities in restricted areas, it will be surveyed, characterized, and contained in a secure facility on the RP until it can be disposed of.consistent with the 10 CFR 20 Subpart K - Waste Disposal

, requirements.

9 Posting and Labeling 9.1 Notices to Workers Notices to workers are provided in accordance with 10 CFR 19.11, Posting of Notices to Workers.

9.2 Posting Notwithstanding the exceptions in 10 CFR 20.1903, Exceptions to posting requirements, postings and labeling is conducted in accordance with the requirements of 10 CFR 20.1901 and 10 CFR 20.1902, Caution signs and Posting requirements, respectively.

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NYSERDA's detailed implementing procedures provide posting requirements 6 for:

• radiation areas

• high radiation areas

• very high radiation ~reas

• soil contamination areas

• airborne radioactivity area

• radioactive material storag~ areas 7 9.3 Labeling Notwithstanding exemptions in 10 CFR 20.1905, Exemptions to labeling requirements, containers requiring labeling as specified by 10 CFR 20.1904, Labeling containers, will be affixed with a durable, clearly visible label bearing the standard radiation symbol and the words "CAUTION, RADIOACTIVE MATERIAL" as detailed in NYSERDA's posting and labeling procedures.

Prior to removal or disposal of empty uncontaminated containers, Radioactive Material labels will be removed or defaced, or will otherwise clearly indicate that the container no longer contains radioactive materials.

WhI!e the mfonnat10n from site h1stoncal operations, radiological surveys, s01l sampling and the 2014 aenal radiation survey do not identify areas of the Reta.med Premises where such postings would be required today, NYSERDA's Radiation Protection Program is structured such that the detailed implementing procedures can be revised at any time to properly address the hazards from rad10logical conditions that may be identified rn the future. -

7 NYSERDA does not expect to routinely store rad1oactJ.ve matenals on the RP that would contain IO tunes the quantity specified rn Append!X C to Part 20 However, the posting of an area as a Rad10act1ve Maten al Storage Area could be requrred 1f waste generated through a work activity was to be temporarily staged on the RP for transport and disposal.

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10 Receipt, Opening, and Transfer of Packages NYSERDA does not anticipate receiving packages of radioactive material on the RP. If the receipt of such packages is necessary, the requirements for the receipt, opening, and transfer of packages on the RP

'will be completed in accordance with NY SERDA' s implementing procedures and 10 CPR 20.1906, Procedures for receiving and_ opening packages.

11 Dose Limits r NYSERDA has established administrative dose limits that/are lower than the dose limits codified in 10 CPR Part 20. These administrative limits were established to help ensure that personnel radiation exposures are kept below the regulatory limits in 10 CPR 20 Subpart C- Occupational Dose Limits.

Table 11-1 provides NYSERDA's administrative dose limits and a comparison with the 10 CPR Part 20 limits. NYSERDA expects radiological direct exposures on the RP to be at or consistent with background radiation levels. Based on the 2014 Aerial Radiation Survey, the WVDP Annual Site Environmental Reports, and other surveys and samples collected on the RP, NYSERDA does not anticipate any areas that will meet the definition of a Radiation Area. If NYSERDA identifies an area ,meeting this definition, I

NYSERDA will implement radiation safety controls in accordance with 10 CPR 20 Subpart B.

If any recorded dose is determined to exceed NYSERDA's administrative dose limits, an investigation will be conducted to determine the circumstances that resulted in that exposure. Additionally, any exceedances of statutory dose limits shall be reported to NRC in accordance with 10 CPR 20 Subpart M -

Reports.

NYSERDA does not expect to authorize "planned special exposures" as identified in 10 CPR 20.1206, Planned special exposures. If planned special exposures are ever required at the RP, NYSERDA will modify the applicable implementing procedures as needed to meet the requirements 10 CPR 20.1206.

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,..16

Table 11-1. Dose Limits Source NYSERDA 10 CFR Part NYSERDA NYSERDA Dally 20 Limit Annual Limit Administrative (rem/year) (rem/year) Limit (rem/day)

Adult Radlologlcal Worker The more llmltlng of:

Total effect1Ve dose equivalent to whole body, or 5 0.5 0.1 Sum of deep-dose equivalent and committed dose equivalent to 50 5 1 any organ or bssue other than lens of eye Dose equivalent to lens of eye 15 1.5 0.3 Shallow-dose equivalent to skin or any extremity 50 5 1 Minor Radiological Worker" The more limiting of: NIA NIA

,Total effective dose equivalent to whole body, or 05 5.0 Sum of deep-dose equivalent and committed dose equivalent to any organ or tissue other than lens of eye Dose equivalent to lens of eye 15 NIA NIA r

Shallow-dose equivalent to skin or any extremity 50 NIA NIA Dose Equivalent to the Embryo /Fetus Dose to embryo/fetus during the entire pregnancy taken as the sum 0.5 rem per of the deep-dose equivalent to the woman and the dose to the 0.1 rem per gestation NIA embryo/fetus from rad1onuchdes in the embryo/fetus and the gestation period period woman Air Emissions to lndMdual Members of the Publlcb Total effective dose equivalent 0 01 0.01 NIA" Individual Members of the Publlcb Total effective dose equ1Valent 0.1 01 NIN

• Mmors will not be Rad1at1on Worker trained by NYSERDA and will not be authonzed access to work m restricted areas where there 1s the potential for the minor to be exposed to rad10active materials or above-background dose fields b In add1tion, the dose rn any unrestncted area from external sources cannot exceed 0 002 rem (0.02 m1lhs1evert) m any one hour.

c The NYSERDA Datly Admrnistranve Liilllts are not applicable to rnd1v1dual members of the public.

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12 Personnel Radiation Exposure Monitoring*

To comply with 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose, individual monitoring devices are required for:

(1) Adults likely to receive in 1 year from sources external to the body, a dose in excess of 10 percent of the limits in 10 CFR 20.1201 (a);

(2) External and internal occupational dose requirements for minors detailed in 10 CFR 20.1502 (2) are not applicable as minors will not be Radiation Worker-trained by NYSERDA, and will not be authorized access to work in restricted areas where there is the potential for the minor to be exposed to radioactive materials or above-background dose fields; (3) Declared pregnant women likely to receive during the entire pregnancy, from radiation sources external _to the body, a deep dose equiv~lent in excess of 0.1 rem (1 mSv); and (4) Individuals entering a high or very high radiation area (NYSERDA does not expect that radiological conditions on the Retained Premises will ever reach the threshold dose rates of high or very high radiation areas).

In addition, NYSERDA will monitor the radioactive material intake in the following instances:

1

• the intake in a calendar year,is likely to exceed 10 percent of the appl~cable annual limit on intake for an adult worker

• the committed effective dose equivalent is likely to exceed"0.l rem (one mSv) for the declared pregnant woman Individual monitoring requirements for external and internal occupational dose will be described in task-specific safety documentation prepared for each job as described m NYSERDA's detailed implementation

'procedures.

As required by 10 CFR 20.1202, Compliance with requirements for summation of extemal and internal doses, when monitoring for both external and internal radiation dose, NYSERDA will demonstrate compliance with the dose limits by summing external and internal doses Cl:!,lculated using Intake by inhalation [10 CFR 20.1202(b)], Intake by oral ingestion [10 CFR 20.1202(c)J, and Intake through wounds or absorption through skin [10 CPR 20.1202(d)].

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13 Waste Management and Disp*osal NYSERDA's activities on the RP are not expected to result in the routine generation of waste. On occasion, however, activities on the RP, including erosion monitoring and contrpl, fence and vegetation maintenance, utility work, environmental measurements, and investigative efforts, may result in the generation of waste. NYSERDA will manage and dispose of the waste based on the location where the waste was generated as follows:

( 1) Waste Generated in the Controlled Area Outside of the Restricted Areas - Based on the 2014 Aerial Radiation survey, work area surveys, and environmental monitoring sampling data, waste generated in the Controlled Area of the WNYNSC outside of the Restricted Areas is expected to be at or consistent with background radionuclide C<?ncentrations, and will be managed for disposal per NYSERDA' s waste management procedures.

(2) Waste Generated in a Restricted Area - Waste generated in the Restricted Areas of the WNYNSC will be surveyed, characterized, and contained in a secure facility on the RP consistent with 10 CFR 20 Subpart K - Waste Disposal requirements. The waste will be dispositioned per 10 CPR 20 Subpart K, NYSERDA's implementing waste management procedures, and disposal facility waste acceptance criteria.

Waste minimization practices will be incorporated into work planning documents for any work that may result in the generation of radioactive waste.

All radioactive waste generated will be posted, labeled, and stored in a secure location in accordance with 10 CFR 20.1904, Labeling containers, until such time it is transferred to an appropriate disposal facility.

NY SERDA will dispose of radioactive waste in accordance with 10 CFR 20.2006, Transfer for disposal and manifests, or as otherwise required.by 10 CFR 20 Subpart K - Waste Disposal.

14 Records All records generated in accordance with this plan and implementing procedures will be maintained pursuant to 10 CPR 20 Subpart L - Records.

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15 Reports All reports generated in support of this plan and implementing procedures, includmg required notifications will be provided to NRC in accordance _with 10 CPR 20 Subpart M - Reports. In addition, NYSERDA will provide all required reports and make all required notifications to individuals working on the*RP under the RP-RPP in accordance with 10 CPR 20 Subpart M - Reports.

16 Exemptions and Additional Requirements I

NYSERDA is not seeking an exemption from the requirements identified in 10 CFR 20 Subpart N -

I Exemptions and Additional Requirements.

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