ML21202A212
| ML21202A212 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 07/15/2021 |
| From: | Bembia P State of NY, Energy Research & Development Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, State of NY, Energy Research & Development Authority |
| References | |
| EPID L-2020-LLA-0029, LAR-20-001 | |
| Download: ML21202A212 (69) | |
Text
WYORK JEOF ORJUNIJY:.
NYSERDA ANDREW M. CUOMO Governor July 15, 2021 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 RICHARD L. KAUFFMAN Chair 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)
DOREEN M. HARRIS President and CEO 10 C.F.R. 50.90
SUBJECT:
Response to NRC Letter: REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT TO INCORPORATE UPDATED RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (EPID L-2020-LLA-0029), dated June 3, 2021
References:
[1] NRC letter to NYSERDA,
Subject:
Authority Under License for Health and Safety, dated November 7, 2018 (ADAMS Accession No., MLl 8282A523)
[2] NYSERDA letter to NRC
Subject:
NYSERDA REQUEST FOR LICENSE AMENDMENT: RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (LAR-20-001), dated February 6, 2020
[3] NYSERDA resubmittal letter to NRC Subject NYSERDA REQUEST FOR LICENSE AMENDMENT:
RETAINED P_REMISES RADIATION PROTECTION REQUIREMENTS (LAR-20-001), dated March 11, 2020
[4] 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
[5] NYSERDA letter to NRC
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 October 28, 2020
[6] NRC Letter to NYSERDA
Subject:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT TO INCORPORATE UPDATED RETAINED PREMISES RADIATION PROTECTION REQUIREMENTS (EPID L-2020-LLA-0029), dated June 3, 2021 On August 9, 2019, the New York State Energy Research and Development Authority (NYSERDA) held a pre-application discussion with the U.S. Nuclear Regulatory Commission (NRC) to discuss the short-and long-terrn_A, !JD)
New York State Energy Research and Development Authority Albany Buffalo 17 Columbia Circle, Albany, NY 12203-6399 726 Exchange Street (Pl 1-866-NYSERDA I (Fl 518-862-1091 Suite 821 nyserda.ny.gov I info@nyserda.ny.gov Buffalo, NY 14210-1484 (Pl 716-842-1522 (Fl 716-842-0156 New York City 1359 Broadway 19th Floor New York, NY 10018-7842 (Pl 212-971-5342 (Fl 518-862-1091
)/~!(
West Valley Site Management Program 9030-B Route 219 West Valley, NY 14171-9500 (Pl 716-942-9960 (Fl 716-942-9961
Document Control Desk Page2 July 15, 2021 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.
By letter dated February 6, 2020 (Reference [2]), NYSERDA submitted an application to the NRC for an amendment to its provisional operating license, NRC License No. CSF-1, in accordance with the requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, "Application for amendment of license, construction permit, or early site permit."
On March 11, 2020, NYSERDA resubmitted the amendment application to address the requirements of 10 CFR 50.30, "Filing of application for licenses; oath or affirmation" (Reference [3]). The NRC staff completed an initial review of the resubmitted license amendment application and by letter dated March 30, 2020 (Reference [4])
identified areas of the resubmittal in which more information was necessary to complete the acceptance review.
NYSERDA responded with this additional information in a letter dated October 28, 2020 (Reference [5]).
By letter dated June 3, 2021 (Reference [6]), NRC staff provided NYSERDA with a Request for Additional Information (RAI) in order to complete its review. The NRC staffs RAI identified 14 items where more information was needed, including the structure ofNYSERDA's Radiation Protection Organization; use of implementing procedures and the document control process for those procedures; training; calibration of instruments, administrative contamination control limits, among other issues. NRC requested that NYSERDA respond to the request for additional information within 45 days. The requested information was also discussed with NYSERDA during a teleconference with the NRC staff on May 5, 2021.
This letter is the response to NRC's June 3, 2021 RAI. It includes Attachment 1, which provides a written response to each of the 14 RAI items, and Attachment 2, a revised version of the "Retained Premises Radiation Protection Plan," (RP-RPP500.03), with changes made to address the NRC RAI.
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 July 15, 2021 Paul J. Bembia, Director West Valley Site Management Program NYSERDA PJB/amd PJB/21amd034.amd
_ __J
Document Control Desk Page 3 July 15, 2021 Attachments:
- 1)
NYSERDA's Response to the NRC Request for Additional Information
- 2)
"Radiation Protection Plan for the Retained Premises," RP-RPPS00.03 ecs:
New York State Energy Research and Development Authority J. A. Dean, NYSERDA-Albany (w/atts.) Janice.Dean(ci;nyserda.ny.gov A. L. Mellon, NYSERDA-WV (w/atts.) Andrea.Mellon(a),nyserda.ny.gov P. Costello, NYSERDA-Albany (w/atts.) Peter.Costello(ci;nyserda.ny.gov A. Peterson, NYSERDA-Albany (w/atts.) designated State Official, Alyse.Peterson(lv,nyserda.ny.gov J. G. Williams, NYSERDA-Albany (w/atts.) John.Wil liams(m,nyserda.ny.gov Nuclear Regulatory Commission J. Lubinski, Director, NMSS, NRC (w/atts.) John.Lubinski(a),nrc.gov P. Holahan, NRC (w/atts.) Trish.Holahan@nrc.gov B. Watson, NRC (w/atts.) Bruce.Watson(w,nrc.gov M. Doell, NRC (w/atts.) marlayna.doell@nrc.gov K. Warner, NRC-Region 1, (w/atts.) Katherine.Warner(a),nrc.gov New York State Department of Environmental Conservation T. B. Rice, NYSDEC (w/atts.) Timothy.Rice(a),dec.ny.gov New York State Department of Health A. Damiani, NYSDOH (w/atts.) Alex.Damiani(al,health.ny.gov R. Dansereau, NYSDOH (w/atts.) Robert.Dansereau@health.ny.gov Seneca Nation of Indians Mr. Matthew Pagels, President Seneca Nation of Indians (w/atts.) matthew.pagels(cv,sni.org Department of Energy B. C. Bower, DOE-WVDP (w/atts.) B1yan.Bower(a),emcbc.doe.gov A. Seeley, DOE-WVDP (w/atts.) Audrey.Seeley(a),emcbc.doe.gov DOESupportstaff(a),emcbc.doe.gov (w/atts.)
Environmental Protection Agency A. Iglesias, EPA (w/atts.) Iglesias.Ariel(cu,epa.gov 0. Povetko, EPA (w/atts.) Povetko.Oleg@epa.gov PJB/21amd034.amd NYSERDA Responses to the NRC Request for Additional Information NYSERDA-RPP-RAl-1 Describe the NYSERDA Radiation Protection Organization and describe or confirm the minimum qualifications, position titles, and responsibilities of the individuals involved, as well as the individuals responsible for waste management and transportation of waste, should any radiological wastes be generated during activities in the retained premises.
Regulatory Basis:
1 0 CFR 20.1101, "Radiation protection programs" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-001, "Radiation Safety Committee for the Retained Premises" RP-RPP-002, "Radiation Safety Officer for the Retained Premises" RP-RPP-016, "Receipt, Opening and Transfer of Packages of Radioactive Material forthe Retained Premises" Path Forward: The applicant should provide existing information or revise the proposed RPP to incorporate a description of the Radiation Protection Organization (could be a line chart), as well as the responsibilities of the various positions and the minimum qualifications to fulfill those positions. Also describe or confirm the minimum qualifications, position title, and responsibilities for whomever will be responsible for waste management and transportation of any waste.
NYSERDA Response Incorporate a description of the Radiation Protection Organization (could"be a line chart) - Line charts were added as Appendix A to RP-RPPS00 that.*
graphically present NYSERDA's Radiation Protection Organization and NYSERDA's Line Management structure. These line charts show that the Radiation Protection Organization is separate and independent from the Line Management structure.
Description of the Radiation Protection Organization - RP-RPPS00 Section 4.4, Radiation Safety Support Contractor, was added to provide a complete description of the Radiation Protection Organization.
Responsibilities of the various positions and the minimum qualifications -
RP-RPPS00 Section 4.5, Minimum Qualifications was added to state that the position descriptions and minimum qualifications for the various positions of the Radiation Protection Organization and the minimum qualifications, position title, and responsibilities for the persons responsible for waste management and transportation of waste are provided in Appendix B.
Additional Clarifications:
Management Commitment to ALARA - Text was added to RP-RPPS00 Section 4.1, NYSERDA Management to provide a clear statement of NYSERDA management commitment to keep exposures to radiation and radioactive material on or from the Retained Premises ALARA.
Page 1 of 15
Independence from facility operations - Information was added to RP-RPP500 Section 4.2, Retained Premises Radiation Safety Committee, to describe the independence of the Radiation Safety Organization from the facility's operations.
The information described above, with additional detail, is also provided in RPP001
-.Radiation Safety Committee for the Retained Premises and RPP002 - Radiation Safety Officer for the Retained Premises.
NYSERDA-RPP-RAl-2 Discuss NYSERDA's Radiation Protection Training, and who is required to take the training, and at what frequency.
Regulatory Basis:
10 CFR 19.12, "Instruction to workers" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-004, "Training and Instruction of Radioactive Material Users on the Retained Premises"
- Path Forward: The applicant should provide existing information or revise the proposed RPP to include radiation training as a subject. At a minimum, the topics of training should include the subjects addressed in 10 CFR 19.12, as well as radiological exposure limits and administrative limits/ALARA goals. The applicant should state how training completion will be verified (e.g., testing with acceptable scoring) and commit to assessing and modifying the training at least every three years to incorporate changes in facilities or work practices, as appropriate. Radiation training should be required at some periodic frequency (annually is typical). In addition, the training program should include requirements for visitors or other categories of site personnel.
NYSERDA Response Provide existing information or revise the proposed RPP to include radiation training as a subject - NYSERDA added Section 7, Training, to RP-RPP500 to address RAl-2.
Commitment that the training program will include the topics addressed in 10 CFR 19.12-RP-RPP500 Section 7,, Training includes a commitment that the training program will include the topics addressed in 10 CFR 19.12, as well as radiological exposure limits and administrative limits and ALARA goals.
Verification of training by testing - RP-RPP500 Section 7, Training details the verification of training by testing every two years, 1 with the completion of a briefing package with a signed employee attestation during the intervening years.
Commitment to assess and modify the training if needed every three years
- RP-RPP500 Section 7, Training provides a commitment to assess and modify*
the training if needed every three years.
. I Under NYSERDA's agreements with DOE-WVDP, NYSERDA and NYSERDA's contractors participate in the USDOE's formal WVDP Rad Worker Training Program. Under DOE regulation 10 CFR 835.90 ( e) "Radiation safety training shall be provided to individuals when there is a significant change to radiation protection policies and procedures that may affect the individual and at intervals not to exceed 24 months."
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Training requirements for visit9rs and other categories of site personnel - RP-RPP500 Section 7, Training discusses the training requirements for visitors and other categories of site personnel.
The information described above, with additional detail, is also provided in RPP004 - Training and Instruction of Radioactive Material Users on the Retained Premises.
NYSERDA-RPP-RAl-3 Clarify the discussion of NYSERDA's Radiation Safety Evaluations (RSEs) and RWPs.
Regulatory Basis:
10 CFR 20.1501, "Surveys and monitoring; General"; 10 CFR 20.1101, "Radiation protection programs" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-005, "Radiological Surveys on the Retained Premises" RP-RPP-007, "Retai~ed Prernises Radiological Safety Evaluations and RWPs" Path Forward: The applicant should provide existing information or revise the proposed RPP to enhance the discussion of RS Es and RWPs in order to incorporate when additional
. work area characterization will occur to support the RSE. In addition, please provide additional discussion on how RWP instruction will be documented and explain how RWPs will be administered, how they can be modified, etc. (Note that RSEs and RWPs are administrative controls.)
NYSERDA Response Additional work area characterization to support the RSE - Language was added to RP-RPP500 Section 8.3, Radiological Surveys and Other Analytical Data to state that work in the restricted area that includes soil disturbance will require surveys from the work area to complete the RSE. If survey data is not available, surveys will be conducted to complete the RSE.
Additional work area characterization to support the RSE - Language was added to RP-RPP500 Section 8.3, Radiological Surveys and Other Analytical Data to state that for work not involving soil disturbance, the decision on whether surveys are needed to support the RSE will be based on the aerial radiation survey data, work history of the area, and surveys from the work area, if available.
How RWP instruction will be documented-RP-RPP500 Section 7, Training, and RPP004 - Training and Instruction of Radioactive Material Users on the Retained Premises, describes NYSERDA's training program which includes worksite training ( called the pre-job briefing) at the beginning of every work activity. The pre-job briefing includes a review of the requirements, work controls, limiting conditions, personal protective equipment (PPE), monitoring and other information specified for the task in the RWP. Each member of the field crew is required to sign that they have read and understand the requirements of the RWP. In addition, the requirements of the RWP are integrated into the work instruction package early in the planning process to ensure that radiological safety requirements are seamlessly addressed in the work steps.
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How RWPs will be administered, how they can be modified - The RWPs are prepared by the RSO, signed by the project manager in charge of the work activity and approved by the RSC. The RWP is included in the work instruc~ion package for the work activity. RWPs are provided to the work crews prior to the work activity and a briefing is held with the wo_rk crew before the work activity begins. Each member of the work crew is required to sign that they have read and understand the RWP. The signed RWPs are kept in th~ West Valley Site Management Program's (WVSMP) central files. RWPs can be modified only through review and approval of the RP-RSC.
The information describ~d above, with additional detail, is also provided in RPP007 - Retained Premises Radiological Safety Evaluations and Radiation Work Permits.
NYSERDA-RPP-RAl-4 Clarify what engineering controls NYSERDA will utilize for contamination control, or to suppress resuspension of licensed (radiological) material, during work activities in the retained premises.
Regulatory Basis:
- 10 CFR 20.1701, "Use of process or other engineering controls" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-005, "Radiological Surve~s on the Retained Premises" RP-RPP-007, "Retained Premises Radiological Safety Evaluations and RWPs" Path Forward: The applicant should provide existing information or'revise Section 7, "Respiratory Protection and Controls," of the proposed RPP to provide more detail on engineering controls that may be utilized for contamination control or to suppress resuspension of radiological material during work activities iri the retained premises. This discussion should include when and in what scenarios these controls will be required (e.g.,
pump to knock out tank with filtering/sampling for release of liquids, use of ground coverings to avoid disturbing soil, regular wetting of disturbed soil to minimize resuspension, installing berms around work sites to minimize runoff.transportation of contamination, any temporary containment that may be used, temporary HEPA filtered enclosures or other ventilation methods, etc.). The discussion should also include what measures may be taken to ensure the controls are working (e.g., differential pressure checks across HEPA and prefilters, visual
- inspection, etc.) and the frequf:lncy of such verification checks. (Note that these are engineering controls for the RPP.)
NYSERDA Response More detail on engineering controls during work activities in the Retained Premises - NYSERDA added new RP-RPP500 Section 11.2, Engineering Controls:
There are no operational or engineered systems or features within the restricted area of the Retained Premises, and the qnly radioactive material that may be encountered by individuals working under this RPP to conduct f\\JYSERDA 's* current licensed activities includes contaminated environmental media (soil and sediment). If a task-specific RSE for a work activity in the restricted area or a soil contamination area on the RP identifies the possibility that an unacceptable amount of dust from contaminated soil or sediment could be generated or contaminated surface soil could be mobilized by precipitation, engineering controls may be warranted to keep Page 4 of 15
potential exposures ALARA. Those engineering measures will be identified in the RWP and would likely include regular wetting of disturbed soil to minimize resuspension and installing berms around work sites to minimize runoff transportation of contamination. HEPA-filtered containment would be used if appropriate, but it is likely that wetting of the soil or sediment in the work area would provide adequate dust control. In some circumstances, runoff transport, or the generation of dust may be prevented by using ground coverings to avoid disturbing soil.
Measures to determine the effectiveness of controls will be identified in the RWP for the specific work activity, and could include visual observations for dust or runoff, surface soil surveys in areas of potential runoff, and the use of breathing zone particulate air samplers. The frequency of verification checks will be dependent on the specific circumstances of the task, and will be identified in the RWP.
The information described above, with additional detail, is also provided in RPP007 - Retained Premises Radiological Safety Evaluations and Radiation Work Permits.
NYSERDA-RPP-RAl-5
'Describe access controls for any work areas that will be established in the retained premises 1 ** and clarify the controls present at access points into any restricted areas.
Regulatory Basis:
10 CFR 20.1902, "Posting Requirements" 1 0 CFR 20.1702, "Use of other controls" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-008, "Personnel Decontamination Procedure for the Retained Premises" RP-RPP-009, "Use of Personnel Dosimetry on the Retained Premises" RP-RPP-010, "Monitoring of Personnel for Contamination on the Retained Premises" RP-RPP-015, "Posting and Labeling on the Retained Premises" Path Forward: The applicant should provide existing information or revise the proposed RPP to discuss access controls for any work areas that will be established in the retained premises. This discussion should include any control points that may be established if working in contaminated areas and state that control points will have facilities for donning
. and doffing personal protective equipment, as appropriate, and personnel frisking.
NYSERDA Response Access controls for any work areas that will be established in the Retained Premises.NYSERDA added the following information to RP-RPP500 Section 8, Radiological Safety Evaluation and Work Controls. This information is also provided in RPP007 - Retained Premises Radiological Safety Evaluations and Radiation Work Permits, and RP-RPP005; Radiological Surveys on the Retained Premises.
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8.3.3 Access Control Points a) Soi/ Contamination Area Access Control Points -NYSERDA will establish access control points for work activities in soil contamination areas. The details of access control points will be identified in the RWP and work instruction package for the specific work activity to be conducted. The access control point will generally be established as a transition point between the soil contamination area and the surrounding restricted area.
Depending upon the duration of the task, expected weather conditions, and magnitude of the work*activity, the access control point may be as simple as a temporary passage-way through the rad-roped boundary of the soil contamination area with a step-off pad; hand-held frisker, bags for used PPE, and some clean water. Additional supplies such as a folding table and temporary pop-up tent or canopy can be used, dependent upon the duration of the task and weather conditions. The equipment needed to establish the control point could be transported to the area using a four-wheel drive or all-terrain vehicle if needed.
For long-duration activities, the star;Jing area could include more weather-protective and durable structures such as a removable CONEX structure (or other temporary construction shelter or relocatable site building) for donning and doffing personnel, personnel frisking and storage of PPE and _other protective equipment. In that case, arrangements and logistics for transporting the structure to the work area will be required.
b) Restricted Area Access Control Points - The access control points for work in the restricted area (but not in a Soil Contamination Area) will be dependent upon the type of work activity and level of contamination in the soils in the work area. For example, non-soil disturbing work in an area without elevated levels of radionuc/ides in the soil will generally require only administrative access controls (see the description in item c below). Soil disturbing activities in an area that has elevated levels of radionuclides may require a step-off pad, frisking, etc. The details of Restricted Area Access Control Points will be identified in the RWP and work instruction package for the specific-work activity to be conducted.
c) Controlled Area Access Control Points - The access control points for work in the Controlled Area (but not in the Restricted Area or a Soil Contamination Area) will generally require only administrative access controls. NYSERDA will notify WVDP Security that there will be individuals on the Retained Premises, and the individuals are required to notify a specific NYSERDA contact point when they enter and leave the property.
NYSERDA-RPP-RAl-6 Describe the administrative limits for contamination control that NYSERDA will apply to the retained premises.
Regulatory Basis:
- 10 CFR 20.1702, "Use of other controls" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-008, "Personnel Decontamination Procedure for the Retained Premises" RP-RPP-009, "Use of Personnel Dosimetry on the Retained Premises" Page 6 of 15
RP-RPP-010, "Monitoring of Personnel for Contamination on th,e Retained Premises" Path Forward: The appli<:;ant should provide existing information or revise the proposed RPP (Section 5, "Surveys and Monitoring," and/or Section 11, "Dose Limits," and/or other sections as appropriate) to discuss the administrative contamination control limits that will be applied to the retained premises. This discussion may reference NRC Regulatory Guides (R.Gs) that address appropriate contamination control limits, such as RG 8.24, "Health Physics Surveys Duri.ng Enriched Uranium-235 Processing and Fuel Fabrication," Revision 2 (ADAMS Accession No. ML110400305), or other NRC RGs that may be more applicable to NYSERDA. The discussion should also address leak testing of sealed sources, if applicable to the potential work activities in the retained premises.
NYSERDA should also be aware that, as a 10 CFR Part 50 licensee, the unrestricted release criteria for materials and equipment is no detectable radioactivity (see IE Circular 81-07, "Control of Radioactively Contaminated Material" (ADAMS Accession No. ML103420362), and NUREG-1757, "Consolidated Decommissioning Guidance," Volume 1, "Decommissioning Process for Materials Licensees," Revision 2 (ADAMS Accession No. ML063000243), Section 15.11.1.1, "Release of Solid Materials with Surface Residual Radioactivity"). The NRC staff notes that it may be simpler to add a table to the proposed RPP on this subject which includes the various administrative limits for contamination control.
NYSERDA Response Administrative contamination control limits - NYSERDA added the following information to RP-RPP500 Section 8, Radiological Safety Evaluation and Work Controls:
8.3.4 Administrative Limits for Contamination Control NYSERDA has established administrative contamination control limits that will be applied to work activities on the Retained Premises. These administrative limits are taken from 1) NRG Regulatory Guide 8.24, "Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication," Revision 2 (ADAMS Accession No. ML110400305). The administrative contamination control limits for the RP-RPP are provided in Appendix C.
In addition to citing NRC Regulatory Guide 8.24 as a source for information on contamination control limits, NRC RAl-6 i_dentifies NUREG-1757, "Consolidated Decommissioning Guidance," Volume 1, "Decommissioning Process for Materials Licensees," Revision 2 (ADAMS Accession No. ML063000243), Section 15.11.1.1, "Release' of Solid Materials with Surface Residual Radioactivity") as a source for administrative limits for contamination control. Section 15.11.1.1 refers to NRC Regulatory Guide 1.86 and Fuel Cycle Policy and Guidance Directive FC 83-23 for tables of "surface contamination criteria which may be applied by licensees for use in demonstrating that solid material with surface contamination can be safely released with no further regulatory control." NYSERDA notes that the surface contamination criteria in the tables in the NRC Regulatory Guide 1.86 and FC 83-23 are the same contamination control limits as those found in NRC Regulatory Guide 8.24:
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NRC RAl-6 notes that as a Part 50 licensee, NYSERDA should be aware that the unrestricted release criteria for materials and equipment is no detectable radioactivity and refers NYSERDA to IE Circular 81-07, "Control of Radioactively Contaminated Material" (ADAMS Accession No. ML103420362). NYSERDA notes that the contamination control limits identified in Circular 81-07 (5000 dpm/100 cm2 total and 1000 dpm/100cm2 removable beta-gamma activity) are the minimum level of activity that can be routinely detected using direct survey methods. The circular states that taking into consideration the practicality of conducting surface contamination surveys, contamination control-limits should not be set below 5000 dpm/100cm2 total and 1000 dpm/100cm2 removable beta-gamma activity. IE Circular 81-07 also states that if alpha contamination is-suspected, appropriate surveys capable of detecting 100 dpm/100cm2 fixed and 20 dpm/100cm2 removable alpha activity should be performed.
NYSERDA notes that the detection-limit based contamination control criteria identified in IE Circular 81-07, while expressed in terms of beta-gamma and alpha activity, are also consistent with the contamination control, limits identified in NRC Regulatory Guide 8.24. Consequently, the NRC Regulatory Guide 8.24 contamination control limits are appropriate for application under this RP-RPP.
8.3.5 Leak Testing of Sealed Sources NYSERDA has sealed sources that are used as check sources for the radiation detection instruments. Sealed sources will be leaked tested on a semi-annual basis through the collection of swipe samples that are counted to confirm that removable
- contamination is not present on the outside of the sealed source. This information can also be found in RP-RPP018, Source Control on the Retained Premises.
NYSERDA-RPP-RAl-7 Further describe the use and development of the NYSERDA RPP implementing procedures flowing down from the proposed RPP for the retained premises.
Regulatory Basis:
10 CFR 20.1101, "Radiation protection programs" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-001, "Radiation Safety Committee for the Retained Premises" RP-RPP-002, "Radiation Safety Officer for the Retained Premises" RP-RPP-003, "Annual. Retained Premises Radiation Protection Program Audit" RP-RPP-004, '.'Training and Instruction of Radioactive Material Users on the Retained Premises" Path Forward: The applicant should provide existing information or revise the proposed RPP to further discuss the u~e of procedures in implementing the NYSERDA radiation protection program. The NRC staff notes that information related to this subject is present in the technical evaluation of a portion of the license amendment request (LAR) submitted on March 11, 2020, and believe it should also be included in the RPP. This includes subject areas that will be proceduralized, review frequency, and approval levels for any modifications. The discussion should also state what level of review is needed for original procedure documents and how training/verification on the implementing procedures occurs Page 8 of 15
(this information may also already be included in the LAR). Finally, NYSERDA should address how procedure control wi_ll b.e implemented such that only current procedures are in use in the retained premises.
NYSERDA Response Use and Development of Implementing Procedures - NYSERDA added RP-RPP500 Section 6, Use of Plans and Procedures to describe the use and
\\
development of the NYSERDA RPP implementing procedures and how the implementing procedures flow down from the RP-RPP for the retained premises. As suggested in NRC RAI comment RAl-7, the information in this section includes the information presented in the technical evaluation portion of the license amendment request (LAR) submitted on March 11, 2020.
Subject Areas Proceduralized - The subject areas that are proceduralized are presented in the list provided in RP-RPP500 Appendix D.
Review Frequency - NYSERDA added RP-RPP500 Section 19.3, Annual Review of the Radiation Protection Program, to Section 19, Records and Document Control. Section 19.3 states that NYSERDA wjll arrange to be conducted, on an annual basis, a formal review of the radiation protection program content and implementation. Generally, this review will be conducted by a person independent of the Radiation Protection Organization. NYSERDA expects that the annual review will focus on a different portion RP-RPP every year, such that the entire RPP is reviewed on a three-year cycle. This information is also included in RPP-003, Annual Retained Premises Radiation Protection Program Audit.
Approval levels for modifications and the level of review needed for original procedure documents - RP-RPP500 Section 19.2, Document Control, states: For the RP-RPP, new procedures are reviewed and approved by the RP-RSC before they are formally issued for use. Revisions to RP-RPPS00 and the associated procedures are not issued, and cannot be used, until they go through the same review, approval and issuance process.
Training/verification on the implementing procedures occurs - According to Procedure RP-RPP004, initial training is required for all RPP implementing
. documents for RWT Levels I and II personnel, and for revisions to RPP implementing documents. The ADM003 tracking form identifies whether training is required on the new or revised procedure. Training records are maintained in WVSMP's central files.
Procedure control implemented such that only current procedures are in use - Per ADM003, the NYSERDA Cognizant Project Manager identifies each entity responsible for implementing the RP-RPP and NYSERDA transmits controlled copies of the latest version of the procedure to each entity with responsibilities for implementing this RP-RPP. Instructions are provided to destroy the previous version of the document.
NYSERDA-RPP-RAl-8 Clarify the discussion of radiation detection instrument maintenance in the NYSERDA RPP.
Regulatory Basis:
1 O CFR 20.1501, "Surveys and monitoring; General" Potential NYSERDA RPP Procedure Reference(s):
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RP-RPP-011, "Instrument Calibration for the Retained Premises" RP-RPP-014, "Operation and Maintenance of Portable Radiation Detection Instruments" Path Forward: The applicant should provide existing information or revise the proposed RPP to enhance the discussion of radiation detection instruments to include a minimum frequency of calibration, daily operating source checks/other operability checks, whether calibration of instruments will be performed consistent with the manufacturer's specifications, whether American National Standards Institute (ANSI) guides will be followed for instrumentation calibration/maintenance, whether NYSERDA personnel will use National Institute of Standards and Technology (NIST) traceable standards when servicing instrumentation, etc.
This discussion should address what corrective actions will occur when instrument response is found to be unacceptable. It is recognized that corrective actions may differ somewhat between field and laboratory instruments, so the applicant should specify appropriate quality control efforts for each. The discussion should also include a table listing the types of radiation detection instruments NYSERDA will maintain, the sensitivity expected, what types of radiation each instrument can detect, what use each instrument will have, etc. A. similar table is necessary for any air sampling equipment NYSE RDA may utilize. The NRC staff recommends that ariy instrumentation tables be titled or footnoted in some manner such that the actual instruments in use may vary and are not tied to a specific make/model.
NYSERDA Response NYSERDA implementing procedure RP-RPP011 - RP-RPP011, Instrument Calibration Procedure, includes the calibration information identified in the RAl-
- 8. This information is now briefly described in RP-RPP500 Section 9.
Calibration - Information on calibration was. added to RP-RPP500 new Section 9.1, Calibration of Instruments.
Table* of the NYSERDA instruments in use - Information was added to RP-.
RPP500 Section 9, Radiation Detection Instruments, to state that a table of the
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NYSERDA instruments in use, including the types of radiation detection instruments, what types of radiation each.instrument can detect, and the sensitivity expected is available for inspection in the WVSMP's central files.
Instruments that fail to meet the calibration requirements - The information provided in RP-RPP500 Section 9 also states that instruments that fail to meet the calibration requirements or the daily operational/source checks will be tagged, labeled, segregated to prevent inadvertent use, and sent for repajr or recalibration.
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NYSERDA-RPP-RAl-9 Clarify the dose monitoring requirements and methods in the Retained Premises RPP.
Regulatory Basis:
10 CFR 20.1201, "Occupational dose limits for adults" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-006, "ALARA Policy and Reviews for the Retained Premises" RP-RPP-009, "Use of Personnel Dosimetry on the Retained Premises" RP-RPP-010, "Monitoring of Personnel for Contamination on the Retained Premises" Page 10 of 15
Path Forward: The applicant should provide existing information or revise the proposed RPP (Section 12, "Personnel Radiation Exposure Monitoring") to enhance the discussion of dose monitoring to specifically call out: (1) when radiation exposure monitoring will be required (both internal and external); (2) how compliance with administrative daily limits (e.g., the use of self-reading dosimeters) will be demonstrated; (3) what the exchange frequency of thermo-luminescent dosimeters (TLDs) will be; and (4) that NYSERDA will use a National Voluntary Laboratory Accreditation Program (NVLAP) participating vendor to record and evaluate the dosimetry results.
This discussion should also address if more than a general whole body TLD may be used for any of the potential work activities in the retained premises. In addition, for internal exposure monitoring, the discussion should include the types of monitoring methods that will be used (e.g., derived air concentration per hour (DAC-hr) tracking based on air sampling) and how the applicant will account for unexpected exposures (e.g., bioassay, dose assessment, etc.).
This discussion may reference appropriate NRC RGs on this subject; such as Draft RG 8.34, "Monitoring Criteria and Methods to Calculate Occupational Radiation Doses," Revision 1 (ADAMS Accession No. ML14133A641 ), or other RGs that may be more applicable.
NYSERDA Response Enhance the discussion of dose monitoring - RP-RPP500 Section 16, Personnel Radiation Exposure Monitoring was modified to:
o Identify when external and internal radiation exposure monitoring will be required.
o Identify how compliance with administrative daily limits will be demonstrated.
o State that TLDs for use on the RP will be needed infrequently and will be obtained on a task-specific basis, so an exchange frequency is not applicable.
o State that NYSERDA will use a National Voluntary Laboratory Accreditation Program (NVLAP) participating vendor to record and evaluate the dosimetry results.
o Discuss internal monitoring methods.
NYSERDA-RPP-RAl-10 Discuss the corrective action system that will be utilized in association with the NYSERDA RPP.
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Regulatory Basis:
10 CFR 20.1101, "Radiation protection programs" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-001, "Radiation Safety Committee for the Retained* Premises" RP-RPP-002, "Radiation Safety Officer for the Retained Premises" RP-RPP-003, "Annual Retained Premises Radiation Protection Program Audit" RP-RPP-004, "Training and Instruction of Radioactive Material Users... "
Path Forward: The applicant should provide existing information or revise the proposed RPP to discuss the corrective action system that will be in place to address any deficiencies in the NYSE RDA RPP for the retained premises. The applicant should include a statement that any reportable incident (e.g., those listed under Subpart M, "Reports," of 10 CFR Part
- 20) will be addressed through the NYSERDA corrective action system. This discussion should confirm that if personnel contamination exceeds the administrative limits of the RPP it will be appropriately addressed in the NYSERDA corrective action system. The corrective action system should also address any deficiencies noted by NYSERDA staff or regulators Page 11 of 15
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and include investigation of root cause(s), identification of corrective action(s), and follow through to verify the effectiveness of the corrective action(s).
NYSERDA Response Corrective action system that will be in _place to address any deficiencies in the NYSERDA RPP - New RP-RPP500 Section 17, Corrective Action System was added to describe NYSERDA's corrective action system that will be in place to address any deficiencies in the NYSERDA RPP for the Retained Premises.
New implementing procedure RP-RPP017 - RP-RPP500 Section 17, Corrective Action System states that the details of NYSERDA's correction action plan are addressed in new WVSMP Corrective Action implementing
. procedure RP-RPP017 Corrective Action System.
Evaluation of reportable and other incidents - RP-RPP500 Section 17, Corrective Action System also states that any reportable incident (e.g., those.
listed under Subpart M, "Reports," of 10 CFR Part 20) will be addressed through the NYSERDA corrective action system. If personnel contamination exceeds the administrative lirriits of the RPP it will be appropriately addressed in the NYSERDA corrective action system. The corrective action system will also address any deficiencies impacting safety noted by NYSERDA staff or regulators and include investigation of root cause(s), identification of corrective action(s), and follow through to verify the effectiveness of the corrective action(s).
NYSERDA-RPP-RAl-11 Clarify that the NYSERDA reporting commitments include those required by 10 CFR Part 19, "Notices, Instructions and Report to Workers: Inspection and Investigations."
Regulatory Basis:
10 CFR 19.13, "Notifications and reports to individuals" Potential NYSERDA RPP Procedure Reference(s):
RP-RPP-003, "Annual Retained Premises Radiation Protection Program Audit" RP-RPP-009, "Use of Personnel Dosimetry on the Retained Premises" RP-RPP-010, "Monitoring of Personnel for Contamination on the Retained Premises" RP-RPP-015, "Posting and Labeling on the Retained Premises" Path Forward: The applicant should provide existing information or revise the proposed RPP to enhance the discussion on reporting to include the reporting requirements in 10 CFR Part 19.
NYSERDA Response 10 CFR 19.13, "Notifications and reports to individuals - NYSERDA added the following information to RP-RPP500 Section 16.5, Reporting:
Radiation exposure data, including the results of any measurements, analyses, and calculations of radioactive material deposited or retained* in the* body, will be reported in writing, on an annual basis, to any individual who was monitored for occupational exposure under this program in the previous year. In accordance with 10 CFR 19.13 Notifications and reports to individuals and 10 CFR 20.2106 Records of Individual Monitoring Results, dose reports will be.furnished on NRG Form 5 Page 12 of 15
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Occupational Dose Record for a Monitoring Period or equivalent. At the request of a former worker, a written report of exposure to radiation or radioactive material will be furnished within 30 days of the request or within 30 days that the records are made available. Additionally, the WVSMP will submit a written report to the U.S.
Nuclear Regulatory Commission and the involved individual should an individual's dose exceed the U.S. Nuclear Regulatory Commission's occupational dose limits.
This report will be furnished within 30 days upon learning of the exposure.
NYSERDA-RPP-RAl-12 Clarify the minimum requirements for the NYSERDA radiological data and/or environmental monitoring program, which will be employed to ensure the requirements of the RPP are met.
Regulatory Basis:
10 CFR 20.1302, "Compliance with dose limits for individual members of the public" Path Forward: The applicant should provide existing information or revise the proposed RPP to specify what the minimum required environmental monitoring data will be, such that if DOE-WVDP's environmental monitoring program does not adequately cover the minimum requirements, NYSERDA will assure appropriate environmental data is, available at those locations important to ensuring work done under the proposed RPP is ~nducted in accordance with the applicable regulatory requirements. This discussion should clarify whether NYSERDA'sbackup environmental data collection process would include the same sample collection, frequency, and analysis as DOE-WVDP had previously used, and whether NYSERDA would continue reporting and documenting the results using the same frequency and methods.
NYSERDA Response NYSERDA commitment to take appropriate actions to collect the needed data independent of the WVDP environmental monitoring program - Text was added to Section 8.3.2, WVDP Annual Site Environmental Report and SDA Annual Report that states that, in the event that the WVDP ceases to collect or provide environmental data needed to maintain or demonstrate compliance with 10 CFR Part 20 or needed for other requirements of the RP-RPP, NYSE RDA will take appropriate actions to collect the needed data independent of the WVDP environmental monitoring program. The data to be collected independently would be commensurate with NYSERDA's licensed activities at the time.
NYSERDA-RPP-RAl-13 As a technical clarification, please explain fully the radiological limits being applied by NYSERDA to "soil contaminated areas" in the retained premises.
Regulatory Basis:
10 CFR 20.1501, "Surveys and monitoring; General" Path Forward: The NRC staff notes that the limits defining "soil contaminated areas" appear to be based on gross alpha and/or beta measurements, and that significant variability can occur within these types of measurements. As such, the staff would like to better understand how NYSERDA will define background levels for these type measurements. In addition, the applicant may want tb identify alternative criteria for defining soil contaminated areas.
Page 13 of 15
NYSERDA Response How NYSERDA will define background levels - NYSE~DA understands that background concentrations can vary for gross alpha and gross beta measurements. NYSERDA presently has several background sample data points.for comparison with characterization samples collected within the controlled area, restricted area, and in any soil contamination areas.
How NYSERDA will define background levels - Language was added to Section 8.3, Radiological Surveys and Other Analytical Data to state that when the collection of task-specific work area surveys is required, NYSERDA will compare the survey data to background data from the same general geographical area and same soil/geologic unit as that of the work area.
This information is also provided in RPP005 - Radiological Surveys on the Retained Premises NYSERDA-RPP-RAl-14.
Confirm that the proposed "Retained Premises Radiation Protection" license condition will not apply to the WVDP or SDA portions of the site, and that DOE personnel and contractors will not be subject to the requirements of the NYSERDA RPP for the WNYNSC retained premises.
Path Forward: While most relevant information is already present in the proposed RPP or the associated LAR, the applicant should confirm that (1) in addition to the RPP, proposed License Condition E will not apply to the WVDP premises or DOE or its contractors conducting WVDP activities in the WNYNSC retained premises; and (2) NYSERDA will pursue an additional license amendment and approval of a full scale revised RPP for the WVDP portion of the site when the DOE activities are complete and the site is fully returned to NYSERDA.
The NRC staff's technical review is contingent on the proposed NYSERDA RPP only being applicable to the retained premises, and the applicant's proposed activities therein (e.g., tree removal, fence repair, foliage trimming or removal, etc.), such that use of the RPP in other areas of the site may be inappropriate and outside of compliance with the radiation protection requirements of 10 CFR Part 20. l'n addition, please confirm that the proposed RPP will be revised or otherwise updated using an established program, which will include periodic documentation of all changes. NYSERDA should provide a brief description of the RPP change management program and any other information*relevant to ensuring the RPP will be updated and maintained in a consistent fashion.
NYSERDA Response Confirm that in addition to the RPP, proposed License Condition E will not apply to the WVDP premises or DOE or its contractors conducting WVDP activities in the WNYNSC retained premises. Confirmed. As established in the LAR on p. 2, the activities authorized under proposed License Condition E will not apply to the WVDP premises or DOE or its contractors conducting WVDP activities on the WNYNSC retained premises. While this is not established in the RP-RPP itself because it is included in the LAR, RP-RPP500 Section 3.1.1, Retained Premises and 3.1.2, West Valley Demonstration Project make clear that this RP-RPP applies only to NYSERDA-licensed activities on the RP and does not apply to the WVDP, SDA, orWVDP activities being carried out by WVDP personnel on the RP.
Page 14 of 15
Confirm that NYSERDA will pursue an additional license amendment and approval of a full scale revised RPP for the WVDP portion of the site when the DOE activities are complete and the site is fully returned to NYSERDA *
- NYSERDA confirms that an additional license amendment and approval of a revised RPP for the WVDP portion of the site will be pursued when DOE activities are complete and the site is returned to NYSERDA. RP-RPPS00 Section 3.1.1, Retained Premises states that, in accordance with License Change No. 31, a license amendment will be required for NYSERDA to reacquire any portion of the WVDP Premises when DOE activities are complete.
As such, NYSERDA will include with that license amendment a revised Radiation Protection P~ogram that is commensurate with the scope and extent of NYSERDA's licensed activities at that time.
Confirm that the NYSERDA RPP is only applicable to the retained premises, and the applicant's proposed activities therein (e.g., tree removal, fence repair, foliage trimming or removal, etc.) - Confirmed. RP-RPP500 Section 3.1.1, Retained Premises states that the NYSERDA RPP is applicable only to the Retained Premises and was developed to be commensurate with the scope and extent of NYSERDA's current licensed activities - the management of the non-SDA, non-WVDP portion of the Retained Premises. Specific work activities identified that will be conducted under this RPP include foliage cutting, trimming and removal; tree removal; fence repair; environmental surveys and monitoring; road repairs; construction, removal and maintenance of utilities, and other similar activities.
Acknowledge that the use of the RPP in other areas of the site may be inappropriate and outside of compliance with the radiation protection requirements of 10 CFR Part 20 - RP-RPP500 Section 3.1.1, Retained Premises acknowledges that the use of the RPP in other areas of the WNYNSC (WVDP Premises or the SbA) may be inappropriate and outside of compliance with the radiation protection requirements of 10 CFR Part 20.
In addition, please confirm that the proposed RPP will be revised or otherwise updated using an established program, which will include periodic documentation of all changes - Confirmed. RP-RPP500 Section 19.2, Document Control states that the NYSERDA Document Control Procedure for the West Valley Site Management Program (ADM003), provides uniform guidance for preparing, reviewing, approving, and issuing WVSMP procedures, including the RP-RPP and its implementing procedures. The use of ADM003 ensures that all procedures are documented from their original issue and through subsequent revisions; and the WVSMP Record of Revision Form is used to track changes made with each revision.
Provide a brief description of the RPP change management program and any other information relevant to ensuring the RPP will be updated and maintained in a consistent fashion - RP-RPP500 Section" 19.2, Document Control, states that the NYSERDA Document_ Control Procedure for the West Valley Site Management Program (ADM003), provides uniform guidance for I
preparing, reviewing, approving and issuing WVSMP procedures, including the RP-RPP and its implementing procedures.
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Retained Premises Radiation Protection Plan RP-RPPS00.03 New York State Energy Research and Development Authority West Valley Site Management Program West Valley, NY 07/15/2021
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Table of Contents List of Figures...................,....................................................... *................................................. iv List of Tables.............. *.:*........................................................................ *...................................... v 1
Purpose...................................................................................... ~........................................ 1 1.1 Radiation Protection Program Requirements................................................................ 1 2
Definitions............................................................................................................................ 2 3
Background and Radiation Safety Responsibilities.............................................................. 6 3.1 Division of Radiation Safety Responsibilities at the WNYNSC...................................... 6 3.1.1 Retained Premises.................................................................. :............................. 6 3.1.2 West Valley Demonstration Project....................................................................... 7 3.1.3 State-Licensed Disposal Area............................ :................................................... 7 4
Retained Premises Radiation Protection Program Responsibilities.......................... *:**********8
. 4.1 NYSE RDA Ma11agement............................................................................................... 8 4.2 Retained Premises Radiation Safety Committee.......................................................... 8 4.3 Radiation Safety Officer................................................................................................ 9 4.4 Radiation Safety Support Contractor............................................................................ 9 4.5 Minimum Qualifications................................................................................................. 9 5
ALARA Policy........................................................................................................................ 9 6
.Use of Plans and Procedures............................ :................................................................ 10 7
Training.............................................................................................................................. 11 7.1 Categories of Training................................................................................................ 11 7.2 Training Topics........................................................................................................... 12 7.3 Training Verification and Testing*********************************************************:********************** 12 7.4 Worksite Training............................................................................. :....................... _
... 13 7.5 Review and Update of Training.................... :.............................................................. 13 8
Radiological Safety Evaluation and Work Controls............................................................ 13 8.1 Radiological Safety Evaluations.................................................................................. 13 8.2 Radiological Work Permits.......................................................................................... 14 8.3 Radiological Surveys and Analytical Data....,.. ****************************************:******************* 15
Table of Contents continued 8.3.1 Surveys............................................................................................................... 15 8.~.2 WVDP Annual Site Environmental Report and SDA Annual Report..................... 16 8.3.3 Access Control Points......................................................................................... 17 8.3.4 Administrative Limits for Contamination Control................................................... 18 8.3.5 LeakTesting of Sealed Sources...................................... :................................... 18 8.3.6 Recordkeeping................... *................................. *................................................ 18 9
Radiation Detection Instruments........................................................................................ 18 9.1 Calibration of Instruments................................................................. :'......................... 18 9.1.1 Record keeping..................................................................................................... 19 10 Control of Exposure from External Sources in Restricted Areas..................................... 19 11 Respiratory Protection and Engineering Controls........................................................... 19 1 '1.1 Respiratory Protection........................................... *....................-................................. 19 1 '1.2 Engineering Controls.................................................................................................. 20 12 Storage and Control of Licensed Materials..................................................................... 21 13 Posting and Labeling............................................................................... :...................... 21
- 13.1 Notices to Workers..................................................................................................... 21 B.2 Posting.................. *.......... :.......................................................................................... 21 13.3 Labeling...................................................................................................................... 21 14 Receipt, Opening, and Transfer of Packages...........................................................-...... 22 15 Dose Limits.................................................................................................................... 22 16 Personnel Radiation Exposure Monitoring..................................................................... 24 16.1 External Radiation Exposure...................................................................................... 24 16.2 Internal Radiation Exposure........................................................................................ 25 16.3 Processing and Evaluation of Dosimetry Data............................................................ 25 16.4 Reporting...................................... :..... _........................................................................ 26 17 Corrective Action System.......................................................................... ~.................... 27 18 Waste Management and Disposal.................................................................................. 27 19 Records and Document Control..................................................................................... 28 19.1 Records.................................................................................... *.................................. 28 ii
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Table of Contents continued 19.2 Document Control........ '.........................................................,..................................... 28 19.3 Annual Review of the Radiation Protection Program.................................................. 29 20 Reports.......................................................................................................................... 29 21 Exemptions and Additional Requirements..................... :................................................ 29 Appendix A - WVSMP Organizational Charts.......................................................................... A 1 Appendix B - Position Descriptions and Minimum Qualifications for Participation in the NYSERDA RP-RPP................................................................................................................................... 81 Appendix C - Administrative Limits for Contamination Control................................................ C1 Appendix D - Topics Proceduralized.......... :............................................................................ D1 iii
List of Figures Figure 2-1. WNYNSC Aerial Orthoimagery Acquired November 2010...................................,.... 3 Figure 2-2. Restricted Areas of the Retained Premises.............................................................. 5 Figure A-1. NYSERDA Retained Premises Radiation Protection Organization........................ A 1 Figure A-2. West Valley Site Management Program Organization Chart................................. A2 iv
List of Tables Table 15-1. Dose Limits-........................... *................................................................................. 23 Table C-1. Acceptable Surface Contamination Levels (per 100 cm2)....***..*...**..***..****..*********** C1 Table D-1. List of RP-RPP Documents.................................................................................... D1 V
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 CFR20 standards for radiation protection, and is as low as reasonably achievable (ALARA).
The RP-RPP consists of this Radiation Protection Plan (RP-RPP500) and a series of implementing procedures that provide the details of the management and technical framework and administrative and engineering controls needed to demonstrate NYSERDA's compliance with the 10 CFR 20 standards.
- 1. 1 Radiation Protection Program Requirements 10 CFR 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 oflicensed 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 CFR 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, 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. 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.
This RP-RPP provides the framework to demonstrate that NYSERDA 1s m compliance with the requirements of 10 CFR 20. This plan is supported by a number of detailed implementing procedures that are available for NRC's inspection at NYSERDA's West Valley Office. A list of the implementing proc1edures in provided in Appendix D.
Retained Premises Radiation Protection Plan, RP-RPP500.03
Revisions to this plan and associated implementing procedures will be approved by NYSERDA's Radiation Safety Committee (RSC) prior to implementation.
2 a)
Definitions ALARA - as low as is reasonably achievable; includes 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 (DAC) values listed in excess of the DAC 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 DAC-hours.
c)
Controlled Area - the WNYNSC, outside of the State-Licensed Disposal Area (SDA) and West Valley Demonstration Project (WVDP), 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 information at regular intervals. Figure 2-1, WNYNSC Aerial Orthoimagery Acquired November 2010, identifies the controlled area boundary of the WNYNSC in yellow.
d)
High Radiation Area' - 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 of 0.1 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.
Based on the aerial radiation surveys and environmental monitoring sampling data, there are no areas on the RP that meet this definition. If NYSERDA identifies an area meeting this definition, NYSERDA will implement radiation safety controls in accordance with this document and its implementing procedures, including, but not limited to posting of the area.
Retained Premises Radiation Protection Plan, RP-RPPS00.03 2
Figure 2-1. WNYNSC Aerial Orthoimagery Acquired November 2010 Source:
NYSERDA Western New York Nuclear Service Center 3-inch Aerial Orthophotography Acquired 11/9/15
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Controlled Area C:IGIS_dala_LMG\\Projecls\\Retalned Premises\\2020 01 J0_WNYNSC_Controlled.mxd Retained Premises Radiation Protection Plan, RP-RPP500.03 3
f)
Removable Contamination Limits - Removable activity in excess of 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha and/or 200 dpm/100 cm2 beta/gamma.
g)
Restricted Area - is an area where access has been limited by NYSERDA because the area has or may have elevated levels of radioactive materials. Based on aerial radiation surveys and environmental monitoring sampling data, NYSERDA has two areas on the RP that are restricted areas. Work activities in these areas may require additional work controls or monitoring. These areas are identified in Figure 2-2.2 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 background levels.
h)
Soil Contamination Area3 - 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 in 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.
Restricted areas were defined using the 20 14 aerial radiation survey data, soil sampling and survey data, and conservatively designating additional areas as restricted areas until additional data is collected for this area. Buttermilk Creek, downstream of the WVDP, is included in the restricted area even though soil the aerial radiation survey did not identify this entire area as having an elevated level of radioactivity. The restricted area shown on Figure 2-2 wi ll be regularly reevaluated with the collection of soil surveys and sampled in the restricted area.
3 Based on the aerial radiation surveys and environmental monitoring sampling data, there is one area in a remote portion of the RP that meets the definition for a soil contamination area. Once the LAR is approved by NRC, controls will be established in accordance with RP-RPP500 and its implementing procedures, including, but not limited to, posting of the area.
Retained Premises Radiation Protection Plan, RP-RPP500.03 4
Figure 2-2. Restricted Areas of the Retained Premises Source:
NYSERDA Western New York Nuclear Service Center 3-mch Aerial Orthophotography Acquired 11 /9/15 Controlled Area Restricted Areas C:IGIS_data_LMG\\Prqects\\Reta,ned Premlses\\2020.01.30_Restricted /Veas.mxd Retained Premises Radiation Protection Plan, RP-RPPS00.03 5
3 Background and Radiation Safety Responsibilities NYSERDA 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.
Approximately 170 acres of the WNYNSC was transferred to the control of the U.S. Department of Energy
3.1 Division of Radiation Safety Responsibilities at the WNYNSC The WNYNSC is approximately 3,300 acres and is divided into three separate operational areas: the 167-acre WVDP, the 15-acre 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 DOE's possession, control, and oversight in accordance with the WVDP Act and the
. Cooperative Agreement between the United States Department of Energy and the New York.State Energy Research and Development Authority on the Western New York Nuclear Service Center at West Valley New York (Cooperative Agreement4). Separate radiation protection programs are in effect for the WVDP and SDA.
3.1.1 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 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 SDA, in accordance with NRC regulation 10 CFR Part 20: Standards for Protection Against Radiation ~ncluding the ALARA philosophy, and in acco:i;dance with this plan. The NYSERDA RPP is applicable only to the Retained Premises and was developed to be commensurate with the scope and extent of NYSERDA's current licensed activities - the management of the non-SD A, non-WVDP portion of the Retained Premises.
This program does not apply to WVDP or to SDA-area activities. Specific work activities include foliage cutting, trimming and removal; tree removal; fence repair; environmental surveys and monitoring; road 4
Effective October 1, 1980, as amended September 18, 1981, U.S. DOE and NYSERDA (Cooperative Agreement).
April 19, 1966. Issued under 10 CFR 50. "Domestic Licensing of Production and Utilization Facilities."
Retained Premises Radiation Protection Plan, RP-RPP500.03 6
repairs; construction, removal and maintenance of utilities, and other similar activities.
NYSERDA also notes the following in regard to this Retained Premises Radiation Protection Program:
This RPP only applies to the Retained Premises (i.e., the non-SDA, non-WVDP portion of the NRC-Licensed property). The use of the RPP in other areas of the WNYNSC (WVDP Premises or the SDA) may be inappropriate and outside of compliance with the radiation protection requirements of 10 CFR Part 20.
In accordance with License Change No. 31, a license amendment will be required for NYSERDA to reacquire any portion of the WVDP Premises when DOE activities are complete.6 As such, NYSERDA will include with that license amendment a revised Radiation Protection Program that is commensurate with the scope and extent ofNYSERDA's licensed activities at that time.
Per the Cooperative Agreement, DOE has the authority to conduct work on the Retained Premises necessary to carry out the WVDP. That work by the WVDP on the Retained Premises is conducted in accordance with the WVDP Radiation Safety Program, and RP-RPPS00 does not apply to DOE or its contractors conducting WVDP actions on the Retained Premises.
3.1.:2 West Valley Demonstration Project As described above, DOE has exclusive use and possession of 167 acres of the WNYNSC to perform the WVDP, and a Radiation Protection Program for the WVDP is provided by DOE's contractors under the authority ofDOE's regulations and orders. RP-RPPS00 does not apply to the WVDP Premises, or to DOE or its contractors conducting WVDP actions on the Retained Premises.
3.1.3 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 SDA, 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 in accordance with the SDA Radioactive Materials License and applicable New York State (NYS) regulations.
Under Subparagraph E of Paragraph 7 of license CSF-1 (added via Change No. 31) NYSERDA shall reacquire and possess the facility upon completion of the Project, in accordance with such technical specifications and subject to* such other provisions as the Commission finds necessary and proper under the Atomic Energy Act and Commission regulations; and (2) make timely submissions to the Commission, in anticipation of completion of the Project, as may be required by the Commission to determine such technical specifications and other provisions.
Retained Premises Radiation Protection Plan, RP-RPP500.03 7
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.
4 Retained Premises Radiation Protection Program Responsibilities NYSERDA's Retained Premises Radiation Protection Program responsibilities are described below. The Radiation Protection Organization chart and NYSERDA line management charts are provided in Appendix A. The two charts show the separation and independence of the Radiation Protection Organization from the line management organization.
4.1 NYSERDA Management NYSERDA management is committed to keep exposures to radiation and radioactive material on or from the Retained Premises ALARA. In fulfilling that commitment, management provides the resources and supports the policies, direction, and recommendations of the RSC needed to establish a radiation protection.
program that is in compliance with 10 CFR Part 20. Resources include equipment (e.g., instruments, materials, and equipment); and qualified personnel, training, and procedures needed to develop and implement the RP-RPP. These resources may be provided by contract organizations or directly by NYSERDA.
4.2 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) as specified in NYSERDA's implementing procedure RP-RPP00l, Radiation Safety Committee for the Retained Premises. 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 procedure RP-RPP003, Annual Retained Premises Radiation Protection Audit.
To ensure independence of the Retained Premises Radiation Protection Program from the operations functions of the West Valley Site Management Program (WVSMP), the RSC members include middle Retained Premises Radiation Protection Plan, RP-RPP500.03 8
managers from across the WVSMP and NYSERDA's senior manager based at West Valley. This cross-program management participation* provides broad perspective and oversight beyond the manager
\\
responsible for the operations function of the Retained Premises. It is also important to note that the RSC makes decisions on a consensus basis. The cross-program membership and consensus decision process for the RSC provide independence for the RP Radiation Protection Program from the RP operations function.
In addition, all members of the RSC review and approve, by signature, the original version of this RP-RPP and all implementing procedures that flow from it, as well as revisions to these documents.
4.3 Radiation Safety Officer
- In order to ensure consistent and effective implementation of this RP-RPP, a qualified Radiation 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, 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 issues 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 procedure RP-RPP002, Radiation Safety Officer for the Retained Premises.
4.4 Radiation Safety Support Contractor NYSERDA provides the remaining staff, equipment, and other resources needed to implement the RP radiation protection program through a radiation safety support contractor. The radiation safety support contractor provides radiation safety technicians, equipment, laboratory services, and health physics support.
- The radiation safety support contractor conducts field activities such as routine radiation surveys and is available to implement radiation safety activities for nonroutine projects such as fence repair, utility maintenance or repair, or tree removal.
4.5 Minimum Qualifications The position descriptions and minimum qualifications for the members of the RSC, RSO, and Waste Management and Transportation Manager are provided in Appendix B.
5 ALARA Policy NYSERDA's management is committed to* maintaining radiation exposures and releases of radioactive material As Low As Reasonably Achievable (ALARA). The RP-RSC will review work activities planned Retained Premises Radiation Protection Plan, RP-RPP500.03 9
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 CPR 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 procedure RP-RPP007, Retained Premises Radiological Safety Evaluations and RWPs.
Per 10 CPR _20.1101 (d), in order to implement the ALARA requirements of 10 CPR 20.1101 (b), and notwithstanding the requirements in 10 CPR 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 CPR 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 CPR 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 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. 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 in 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 CPR 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, as discussed in Section 11.2, Engineering Controls.
6 Use of Plans and Procedures NYSERDA's Retained Premises Radiation Protection Program consists of this Retained Premises Radiation Protection Plan (RP-RPP500) as well as implementing procedures developed to keep doses to workers and the public both ALARA, and in complianpe with the NRC standards for radiation protection.
This radiation protection plan was prepared to provide a structured process for the review and approval of work activities that will be conducted on the non-SD A, non-WVDP portions of the Center (i.e., the Retained Premises) where Part 50-Licensed radioactive materials are or may be present. The radiation protection plan was developed under the guidance and approval of an RSC, and is implemented under the oversight of a qualified RSO. This radiation protection plan provides the structured process for the evaluation of radiological hazards and identification of radiological work controls for activities in areas of the Retained Retained Premises Radiation Protection Plan, RP-RPP500.03 10
Premises that may contain radioactive materials in excess of background or fallout levels.
As documented in Procedure RP-RPP004, Training and Instruction of Radioactive Material Users on the Retained Premises, initial training is required for all RPP implementing documents for RWT Levels I and II personnel, and for revisions to RPP implementing documents.
A list of the Retained Premises Radiation Protection Program procedures used to. implement this Plan are provided in Appendix D.
7 Training As described in RP-RPP004, Training and Instruction of Radioactive Material Users on the Retained Premises, NYSERDA provides radiation safety training for all individuals who will conduct work activities under the scope of this RPP. The radiation safety training is provided in part, by the US DOE-WVDP, supplemented with training provided by NYSERDA.
7.1 Categories of Training The WVSMP has three levels of training for individuals requiring unescorted access into the restricted area.
These are referred to as Radiological Worker Training (RWT) Levels I and II and Retained Premises Briefing.
RWT I is for individuals who require unescorted entry into the Restricted Area. Persons with RWT I are not authorized to conduct any "hands on" work involving radioactive and contaminated materials, and are not authorized to enter any designated radiation areas or contamination areas.
RWT II provides the background needed to enter and conduct hands-on work in radiation areas and contamination areas. Such work must also be conducted in accordance with the work controls, limits, personal protection equipment (PPE) requirements (potentially including respiratory protection) and additional training requirements for specific radiological or contamination area conditions and work
)
activities. 7 Retained Premises Briefing is for individuals who will require unescorted access to the Restricted Area to conduct work in a portion of the restricted area that is determined, by radiation survey, to be at background levels of radioactivity and radioactive materials.
7 Any such additional requirements will be identified in a task-specific RWP.
Retained Premises Radiation Protection Plan, RP-RPP500.03 11
Visitors will generally not be provided unescorted access to the Retained Premises Restricted Area. For any other categories of workers, the minimum level of training required for any unescorted access to the Restricted Area is the Retained Premises Briefing.
7.2 Training Topics The training provided by the WVDP addresses a broad range of radioactive material and radiation safety fundamentals, including the following topics required under 10 CFR 19.12:
health protection problems associated with exposure to radiation and/or radioactive material, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation and/or radioactive material.
In addition, NYSERDA provides a written supplement to the WVDP training that will inform workers of the following:
radiological exposure limits, administrative limits, and ALARA considerations.
their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licenses or unnecessary exposure to radiation and/or radioactive material.
the storage, transfer, or use of radiation and/or radioactive material (i.e., a current description of radiological conditions on the Retained Premises.
the radiation exposure reports which workers may request pursuant to § 19.13.
The Retained Premises Briefing will include a summary of the work history of the area, the surveys that were done to determine that the work controls identified are appropriate for the work area, and the additional surveys and instrumentation that may be used by radiation safety personnel as the work proceeds.
7.3 Training Verification and Testing RWT Level I and II workers must satisfactorily pass an exam every two years8 to demonstrate their knowledge and understanding of the radiation training topics that apply to their radiation worker category.
In the intervening years, the radiation worker must read a briefing package and provide a signed acknowledgment that the briefing was completed. With the self-study briefing every second year, there is a component of training that is completed every 12 months.
Under NYSERDA's agreements with DOE-WVDP, NYSERDA and NYSERDA's contractors participate in the USDOE's formal WVDP Rad Worker Training Program. Under DOE regulation 10 CFR 835.90 (e) "Radiation safety training shall be provided to individuals when there is a significant change to radiation protection policies and procedures that may affect the individual and at intervals not to exceed 24 months."
Retained Premises Radiation Protection Plan, RP-RPP500.03 12
The Retained Premises briefing is provided on a task-specific basis.for nonroutine jobs. Workers receive the briefing from NYSERDA
- staff at the beginning of that job. The Retained Premises Briefing is
- documented using a standard training sign-off form~
7.4.
Worksite Training NYSERDA's written training program is supplemented by a worksite pre-job briefing for the work crew prior to the start of all work activities. The pre-job briefing includes a review of the work activity, the specific requirements of the procedures or work* i~struction package, and task-specific safety controls (including the RWP) and emergency communications.
In addition, the worksite training includes a hands-on.demonstration of frisking for personnel contamination, donning and doffing of protective clothing,* and proper use of dosimetry. Each member of the work crew is required to sign that they have read and understand the RWP. The signed RWPs are kept in the WVSMP's central files.
7.5 Review and Update of Training NYSERDA will assess and modify the radiation safety training program at least every three years to incorporate changes in facilities or work practices, as appropriate. Records of the review will be kept in the WVSMP's central files.
8 Radiological Safety Evaluation and Work Controls To comply with the requirements of 10 CFR 20, NYSERDA has established this Radiation Protection.
Program that uses proc~dures, work controls, and engineering controls (if needed) based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is ~easonably achievable (ALARA). All work in the Retained Premises restricted area requires the completion of a Radiological Safety Evaluation (RSE). Based upon the results of the RSE, a Radiation*
Work Permit may or may not be required.
8.1 Radiological Safety Evaluations An RSE is an administrative control used to evaluate the radiological hazards 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:
Retained Premises Radiation Protection Plan, RP-RPP500.03 13
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 radioactive materials.
c)
A review and evaluation of existing radiological surveys of the proposed work area to evalu~te dose rates, including aerial radiation surveys (as described in Section 8.3).
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 evaluate the information identified above and will make a determination as to whether work controls, dosimetry, PPE, monitoring, or other measures are required to protect workers from radiological hazards associated with the work activity. If controls are required, an RWP is required. NYSERDA's detailed implementing procedure RP-RPP007, Retained Premises Radiological Safety Evaluations and RWPs, includes specific action limits for when an RWP will be used to implement radiation work controls.
8.2 Radiological Work Permits An RWP is prepared by the NYSERDA 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:
a) purpose 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 by the RSO, signed by the project manager in charge of the work activity, and_
approved by the RSC as part of the Work Instruction Package for the work activity. NYSERDA's detailed implementing procedure RP-RPPQ07, Retained Premises Radiological Safety Evaluations and RWPs, includes specific action limits for requiring various radiological work controls, including training, dosimetry, PPE, respiratory protection, and work area monitoring.
(
RWPs can be modified only through review and approval of the RP RSC.
Retained Premises Radiation Protection Plan, RP-RPP500.03 14
RWPs are provided to the work crews prior to the work activity and a briefing is held with the work crew before the work activity begins. Each member of the work crew is required to sign that they have read and understand the RWP. The signed RWPs are kept in the WVSMP's central files.
8.3 Radiological Surveys and Analytical Data 8.3.1 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 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 contamination 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 (RP-RPP005, Radiological Surveys on the Retained Premises) 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, existing surveys of the work area,9 historical site knowledge, and other relevant data and information.
NYSERDA will perform the surveys of the work area, if needed, to meet the Subpart F
)
requirements and to prepare an RSE and RWP. Relevant radiological hazard 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,
- Survey information for the Restricted Area has been collected during work activities such as the soil sampling work that was conducted as a follow up to aerial radiation surveys, utility work, and road and bridge repair and maintenance work.
Retained Premises Radiation Protection Plan, RP-RPPS00.03 15
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 CFR 20, Subpart F - Surveys and Monitoring.
Work Activities Involving Soil Disturbance - Work activities involving soil disturbance will require surveys from the work area in order to complete the RSE. If existing surveys are not available for the work area, surveys will be conducted to support the preparation of the RSE.
Work Activities Not Involving Soil Disturbance-Work activities that require access to the restricted areas with no soil disturbance will be evaluated during the RSE process using data from the latest aerial radiation survey combined with existing survey data and the operations history of the work area. This information will be used identify radiological conditions in the area where access is required to determine whether the work can proceed without the collection of additional survey data.
Comparison to Background Data - When the collection of task-specific work area surveys is required, NYSERDA will compare the survey data to background data from the same general geographical area and same soil/geologic unit as that of the work area.
8.3.2 WVDP Annual Site Environmental Report and SDA Annual Report a) WVDP Annual Site Environmental Report - Annually, NYSERDA will evaluate the WVDP Annual Site Environmental Report 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.
In the event that the WVDP ceases to collect or provide environmental data needed to maintain or demonstrate compliance with 10 CFR Part 20 or needed for other requirements of the RP-RPP, NYSERDA will take appropriate actions to collect the needed data independent of the WVDP environmental monitoring program. The data to be collected independently would be commensurate with NYSERDA's licensed activities at the time.
b) State-Licensed Disposal Area at West Valley: Annual Report -Annually, NYSERDA will evaluate the data from the SDA environmeptal monitoring program, which is annually compiled and published in the State-Licensed Disposal Area at West Valley: Annual Report for the purpose of evaluating whether there are indications of changed radiological conditions at the SDA that may also have an impact on the Retained Premises.
Retained Premises Radiation Protection Plan, RP-RPP500.03 16
c) Annual Memo to File - The review of the environmental reports will be documented in an annual memo to file. Significant results will be brought to the attention of the RP-RSC for consideration of follow-up actions.
8.3.3 Access Control Points a) Contamination Area Access Control Points - NYSERDA will establish access control points for work activities in soil contamination areas. The details of access control points will be identified in the RWP and work instruction package for the specific work activity to be conducted. The access control point will generally be established as a transition point between the soil contamination area and the surrounding restricted area.
Depending upon the duration of the task, expected weather conditions, and magnitude of the work activity, the access control point may be as simple as a temporary passage-way through the rad-roped boundary of the soil contamination area with a step-off pad, hand-held frisker, bags for used PPE, and some clean water. Additional supplies such as a folding table and temporary pop-up tent or canopy can be used, dependent upon the duration of the task and weather conditions. The equipment needed to establish the control point could be transported to the area in using a four-wheel drive or all-terrain vehicle if needed.
For long-duration activities, the staging area could include more weather-protective and durable structures such as a removable CONEX structure ( or other temporary construction shelter or relocatable site building) for donning and doffing PPE, personnel frisking, and storage of PPE and other protective equipment. In that case, arrangements and logistics for transporting the structure to the work area will be required.
b) Restricted Area Access Control Points - The access control points for work in the restricted area (but not in a soil contamination area) will be dependent upon the type of work activity and level of contamination in the soils in the work area. For example, non-soil disturbing work in an area without elevated levels of radionuclides in the soil will generally require only administrative access controls (see the description in item c below). Soil disturbing activities in an area that has elevated levels of radionuclides may require a step-off pad, frisking, etc.
The details of Restricted Area Access Control Points will be identified in the RWP and work instruction package for the specific work activity to be conducted.
c) Cont'rolled Area Access Control Points - The access control points for work in the Controlled Area (but not in the Restricted Area or a soil contamination area) will generally require only administrative access controls (i.e., NYSERDA will notify WVDP Security that Retained Premises Radiation Protection Plan, RP-RPP500.03 17
there will be individuals on the Retained Premises, and the individuals are required to notify a specific NYSERDA contact point when they enter and leave the property).
8.3.4 Administrative Limits for Contamination Control NYSERDA has established administrative contamination control limits that will be applied to work activities on the Retained Premises. These administrative limits. are taken from NRC Regulatory Guide 8.24, "Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication," Revision 2 (ADAMS Accession No. MLl 10400305). The administrative contamination control limits are provided in Appendix C.
8.3.5 Leak Testing of Sealed Sources NYSERDA has sealed sources that are used as check sources for the radiation detection instruments. Sealed sources will be leaked tested on a semiannual basis through the collection of swipe samples that are counted to confirm that removable contamination is not present on the outside of the sealed source. Leak testing of sealed sources is described in RP-RPP018, Source Control on the Retained Premises.
8.3.6 Recordkeeping NYSERDA will report measurements of radioactivity consistent with 10 CFR 20.1005, Units of radioactivity, and will maintain all records showing the results of surveys in accordance with 10 CFR 20.1501 (b) Surveys and Monitoring, and 10 CFR 20.2103, Records of Surveys.
9 Radiation Detection Instruments In implementing this RP-RPP, NYSERDA uses a combination of NYSERDA-owned, and contractor-owned radiation detection and quantification instruments and equipment. Equipment will be operated only by individuals who are qualified to use the instrument and will be operated in accordance with manufacturer's procedures and guidance and specific NYSERDA or contractor procedures, including daily operational/source checks. A table of the NYSERDA instruments in use, including the types qf radiation detection instruments, what types of radiation each instrument can detect, and the sensitivity expected is available for inspection in the WVSMP's central files.
9.1 Calibration of Instruments All radiation detection instruments and equipment used for quantitative radiation measurements will be calibrated annually (at a minimum) as well as following maintenance or repair.of the meter, in accordance Retained Premises Radiation Protection Plan, RP-RPP500.03 18
with 10 CFR 20.1501, General, ( c ), and as described inNYSERDA's detailed implementing procedure RP-RPP011, Instrument Calibration for the RetainedPremises. NYSERDA's RSO is responsible for arranging for instruments to be calibrated. Calibration of instruments will be performed using procedures developed specifically for each instrument type. Calibration sources will be traceable by documented measurements to the National Institute of Standards and Technology (NIST) sources appropriate for the isotopes and energy ranges of interest.
After receipt of the instrument from the calibration facility, the NYSERDA RSO will obtain a reference reading from the on-site check source and attach a label to the instrument showing the acceptable response range.
Instruments that fail to meet the calibration requirements or the daily operational/source checks will be tagged, labeled, segregated to prevent inadvertent use, and sent for repair or recalibration.
9.. 1.1 Recordkeeping NYSERDA will report measurements of radioactivity consistent with 10 CFR 20.1005, Units of radioactivity, and will maintain all records showing the results of calibrations.
10 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 equivalent 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.
11 Respiratory Protection and Engineering Controls 11.1 Respiratory Protection Subpart H of 10 CFR 20 provides the requirements for respiratory protection and controls to restrict internal Retained Premises Radiation Protection Plan, RP-RPP500.03 19
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 restrict internal exposure. Regardless, all work activities on the RP will be reviewed in accordance with NYSERDA's RSE process described in the detailed implementing procedure RP-RPP007, Retained Premises Radiological Safety Evaluations and RWPs, and NYSERDA will identify internal exposure hazards, if present. If such conditions on the RP are identified, detailed implementing procedures will be prepared, or existing procedures modified, as required to meet the requirements for a respiratory protection program compliant with Subpart H. Necessary training and other requirements will be met prior to the RSC approving the work activity.
11.2 Engineering Controls NYSERDA will consider the use of engineering controls, if needed, for contamination control or to suppress resuspension of radiological material during work activities in the Retained Premises, per 10 CPR 20, Subpart H -Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas.
There are no operational or engineered systems or features within the restricted area of the Retained Premises, and the only radioactive material that may be encountered by individuals working under this RPP to conduct NYSERDA's current licensed activities includes contaminated environmental media (soil and sediment). If a task-specific RSE for a work activity in the restricted area or a soil contamination area on the RP identifies the possibility that an unacceptable amount of dust from contaminated soil or sediment could be generated or contaminated surface soil could be mobilized by precipitation, engineering controls may be warranted to keep potential exposures ALARA. Those engineering measures will be identified in the RWP and would likely include regular wetting of disturbed soil to minimize resuspension and installing berms around work sites to minimize runoff transportation of contamination. HEPA-filtered containment would be used if appropriate, but it is likely that wetting of the.soil or sediment in the work area would provide adequate dust control. In some circumstances, runoff transport or the generation of dust may be prevented by using ground coverings to avoid disturbing soil.
Measures to determine the effectiveness of controls will be identified in the RWP for the specific work activity, and could include visual observations for dust or runoff, surface soil surveys in areas of potential runoff, and the used of breathing zone particulate air samplers. The frequency of verification checks will be dependent on the specific circumstances of the task, and will be identified in the R WP.
Retained Premises Radiation Protection Plan, RP-RPP500.03 20
12 Storage and Control of Licensed Materials Based on the aerial radiation surveys, work area surveys, and environmental monitoring data provided in the WVDP Annual Site Environmental 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 gel).erated 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.
13 Posting and Labeling 13.1 Notices to Workers Notices to workers are provided in accordance with 10 CFR 19.11, Posting of Notices to Workers.
13.2 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.
NYSERDA's detailed implementing procedures provi~e posting requirements for:
o radiation areas o
very high radiation areas 11 soil contamination areas o
airborne radioactivity area 11 radioactive material.storage areas10 13.3 Labeling Notwithstanding exemptions in 10 CFR 20.1905, Exemptions to labeling requirements, containers requiring labeling as specified by 10 CPR 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.
10 NYSERDA does not expect to routinely store radioactive materials on the RP that would contain 10 times the quantity specified in Appendix C to Part 20.. However,*the posting of an area as a Radioactive Material Storage Area could be required if waste generated through a work activity was to be temporarily staged on the RP for transport and disposal.
Retained Premises Radiation Protection Plan, RP-RPP500.03 21
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.
14 Receipt, Opening, and Transfer of Packages NY SERDA 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 NYSERDA's implementing procedure RP-RPP016, Receipt, Opening and Transfer of Packages of Radioactive Material for the Retained Premises, and 10 CFR 20.1906, Procedures for receiving and opening packages.
15 Dose Limits NYSERDA has established administrative dose limits that are lower than the dose limits codified in 10 CFR Part 20. These administrative limits were established to help ensure that personnel radiation exposures are kept below the regulatory limits in 10 CFR 20 Subpart C-Occupational Dose Limits.
Table 15-1 provides NYSERDA's administrative dose limits and a comparison with the 10 CF~ 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, NYSERDA will implement radiation safety controls in accordance with 10 CFR 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 CFR 20 Subpart M - Reports.
NYSERDA does not expect to authorize "planned special exposures" as identified in 10 CFR 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 CFR 20.1206.
Retained Premises Radiation Protection Plan, RP-RPPS00.03 22
Table 15-1. Dose Limits Source:
NYSERDA 10 CFR Part NYSERDA NYSERDA Daily 20 Limit Annual Limit Administrative (rem/year)
(rem/year)
Limit (rem/day)
Adult Radiological Worker The more limiting of:
Total effective 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 tissue other than lens of eye Dose equivalent to leris of eye 15 1.5 0.3 Shallow-dose equivalent to skin or any extremity 50 5
1 Minor Radiological Workera The more limiting of:
N/A N/A Total effective dose equivalent to whole body, or 0.5 5.0 Sum of deep-dose equivalent and committed dose equivalent to any organ or tissue other than lens of eye Dose ~quivalent to lens of eye 1.5 N/A N/A Shallow-dose equivalent to skin or any extremity
. 5.0 N/A N/A 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 gestation
.o.1 rem per N/A embryo/fetus from radionuclides in the embryo/fetus and the period gestation period woman
(
Air Emissions to Individual Members of the Publicb Total effective dose equivalent 0.01 0.01 NIN Individual Members of the Publicb Total effective dose equivalent 0.1 0.1 NIN a
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.
b In addition, the dose in any unrestricted area from external sources cannot exceed 0.002 rem (0.02 millisievert) in any one hour.
- c.
The NYSERDA Daily Administrative Limits are not applicable to individual members of the public.
Retained Premises Radiation Protection Plan, RP-RPP500.03 23
16 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 equivalent in excess of0.l 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).
As required by 10 CFR 20.1202, Compliance with requirements for summation of external 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 calculated using Intake by inhalation [10 CFR 20.1202(b)], Intake by oral ingestion [10 CFR 20.1202(c)], and Intake through wounds or absorption through skin [10 CFR 20.1202(d)].
16.1 External Radiation Exposure NYSERDA will assign do'simeters to workers on the RP when the job-specific external dose rate exceeds 2 mRem/hour or has the potential to exceed 10 percent of the occupation dose limits in 10 CFR Part 20.1201(a) or a deep-dose equivalent of 0.1 rem for a declared pregnant woman.
Based on aerial radiation surveys, work area surveys, and personnel monitoring data, external radiation levels on the RP are well below these levels and do not require the use of personnel monitoring for routine I
work (e.g., perimeter fence line maintenance, vegetation maintenance). NYSERDA will, however, consider the issuance of external dosimetry for activities on the RP on a job-specific basis or for the purpose of collecting confirmatory dose rate information.
In order to collect data to confirm compliance with the daily dose limits, an electronic dosimeter can be used to collect data to confirm that RP dose limits are orders of magnitude below levels that would approach the daily limits.
Retained Premises Radiation Protection Plan, RP-RPP500.03 24
Thennoluminescent dosimeters for use on the RP will be needed infrequently and will be obtained on a task-specific basis, so an exchange frequency is not applicable.
16.2 Internal Radiation Exposure Based on aerial radiation surveys, work area surveys, and air monitoring data from WVDP ambient air sample locations on the RP, monitoring for occupational intake of radioactive material and assessing the committed effective dose equivalent on the RP is not required unless:
Adults are likely to receive an annual intake in excess of 10 percent of the applicable ALI(s) in table 1, Columns 1 and 2, of Appendix B to 10 CPR 20.1001-20.2402; and Declared pregnant women are likely to receive, during the entire pregnancy, a committed effective dose equivalent in excess of 0.1 rem (1 mSv).
NYSERDA does not anticipate any of these conditions to exist on the restricted areas of the RP during current licensed activities. In the event that work is required in a soil contamination area, timely internal dose assessments will be completed in accordance with 10 CPR 20.1204. These measurements will include at a minimum:
Sampling of the work area to determine the concentrations of the radioactive materials present in air and in soil.
Whole Body Dose Monitoring Pre-and post-work activity bioassay sampling.
The sample data will be used to calculate the sum of the ratios of the concentrations to the appropriate DAC value from Appendix B to 10 CPR 20.1001-20.2402 for each radionuclide present in the mixture, or the
- ratio of the total concentration for all radionuclides in the mixture to the most restrictive DAC value for any
- radionuclide in the mixture.
NYSERDA will confirm that calculated committed effective dose equivalent for one Annual Limit of Intake (or an exposure of 2,000 DAC-hours) is less than of 5 rem (0.05 Sv) for radionuclides that have their ALis or DACs based on the committed effective dose equivalent.
16.3 Processing and Evaluation of Dosimetry Data In accordance with 10 CPR 20.1501(d), all personnel dosimeters (except for direct and indirect reading pocket ionization chambers and those dosimeters used to measure the dose to the extremities) requiring processing to determine the radiation dose and that are used by licensees to comply with 10 CPR 20.1201, Retained Premises Radiation Protection Plan, RP-RPP500.03 25
or with conditions specified in the license, must be processed, and evaluated by a dosimetry processor currently:
holding personnel dosimetry accreditation froin the National Voluntary Laboratory Accreditation Program of the National Institute of Standards and Technology; and approved in this accreditation process for the type of radiation or radiations included in the National Voluntary Laboratory Accreditation Program of the National Institute of Standards and Technology program that most closely approximates the type of radiation or radiations for which the individual wearing the dosimeter is monitored.
16.4 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.
Dosimetry records or a summary ?f the records will be reviewed quarterly by the RSO and the RP-RSC. If an individual is monitored for both internal and external exposure, the internal and external doses will be summed to demonstrate compliance with the administrative dose limits. Doses will be determined by monitoring or calculations in accordance with 10 CFR 20.1202 through 1204.
Radiation exposure data, including the results of any measurements, analyses, and calculations of radioactive material deposited or retained in the body, will be reported in writing, on an annual basis, to any individual who was monitored for occupational exposure under this program in the previous year. In accordance with 10 CFR 19.13 Notifications and reports to individuals and 10 CFR 20.2106 Records of Individual Monitoring Results, dose reports will be furnished on NRC Form 5 Occupational Dose Record for a Monitoring Period or equivalent. At the request of a former worker, a written report of exposure to radiation or radioactive material will be furnished within 30 days of the request or within 30 days that the records are made available. Additionally, the WVSMP will submit a written report to the NRC and th~
involved individual should an individual's dose exceed the NRC's occupational dose limits. This report will be furnished within 30 days upon learning of the exposure.
Retained Premises Radiation Protection Plan, RP-RPPS00.03 26
17 Corrective Action System NYSERDA uses a corrective action system to provide for prompt evaluation of conditions adverse to safety,
- quality, and compliance. The correction action system provides a detailed evaluation of the root cause of the condition to determine the actions needed to address the condition. NYSERDA will track corrective actions to completion to ensure they are effectively implemented to prevent future recurrence. The timing for implementation of the corrective actions is commensurate with the risk significance of the adverse condition. The details ofNYSERDA's correction action system are addressed in implementing procedure r
RP-RPP0l 7, Corrective Action System.
For conditions that are significant from a safety perspective, the corrective action process includes an I
incident investigation. The incident investigation process begins with establishing an investigation team.
The incident investigation team evaluate~ the incident, makes a root cause determination, recommends correction action, and documents the. process used for identifying the root cause and recommended corrective actions. NYSERDA implements the corrective actions and applies lessons learned to other activities in order to prevent the occurrence of similar incidents.
Any reportable incident ( e.g., those listed under Subpart M, "Reports," of 10 CFR Part* 20)'will be addressed
- by NYSERDA through the corrective action system, as will incidents of personnel contamination exceeding the administrative limits of the RPP. The corrective action system will also be used to address any deficiencies impacting safety noted by NYSERDA staff or regulators and will include investigation of root cause(s), identification of corrective action(s), and follow~through to verify the effectiveness of the corrective action(s).
All fecords associated with the Corrective Action Program will be filed in the WVSMP's central files and 10 CFR Part 20, Subpart L.
18 Waste Management and Disposal NYSERDA's activities on the RP are not expected tq result in the routine generation of waste. On occasion, however, activities on the RP, including erosion monitoring and control, 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 oh the location where the waste was generated as follows:
Retained Premises Radiation Protection Plan, RP-RPPS00.03 27
( 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 concentrations, and will be managed for disposal per NYSERDA's waste management-procedures.
(2)
Waste Generated in a Restricted or Soil Contamination Area - Waste generated in the Restricted or soil contamination 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 CFR 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.
NYSERDA 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.
19 Records and Document Control 19.1 Records All records generated in accordance with this plan and implementing procedures will be maintained pursuant to 10 CFR 20 Subpart L - Records.
19.2 Document Control NYSERDA's Document Control Procedure for the West Valley Site Management Program (ADM003),
provides uniform guidance for preparing, reviewing, approving and issuing WVSMP procedures, including the RP-RPP and its implementing procedures. The use of ADM003 ensures that all procedures are documented from their original issue and through subsequent revisions.
ADM003 includes tracking forms to document the review and approval process for both new and revised documents. It specifies the author, reviewers; the type of change; the audience; if training is required; if the Retained Premises Radiation Protection Plan, RP-RPP500.03 28
plan or procedure is a tie-down to a permit/license; if it requires a regulatory submittal; the transmittal method; a brief description of the changes to the document; and a requested completion date.
For the RP-RPP, new procedures are reviewed and approved by the RP-RSC before they are formally issued for use. Revisions to RP-RPPS00 and the implementing procedures are not issued for use until they go through the same review, approval, and issuance process. The WVSMP Record of Revision Form is used to track changes made with each revision, includes the dates of each revision's issuance and provides a distribution list for controlled copies of the revised document.
19.:3 Annual Review of the Radiation Protection Program As discussed in RP-RPP003, Annual Retained Premises Radiation Protection Program Audit, NYSERDA will arrange to be conducted, on an annual basis, a formal review the radiation protection program content and implementation. Generally, this review will be conducted by a person independent of the Radiation Protection Organization. NYSERDA expects that the annual review will focus on a different portion RP-RPP every year, such that the entire RPP is reviewed on a three-year cycle. The review will include the evaluation of the RPP against current NRC regulations. The results of the review will be provided to the RP RSO, and any areas of noncompliance with the requirements of this RPP or regulatory requirements, or safety significant deficiencies will be addressed through the corrective action program.
20 Reports All reports generated in support of this plan and implementing procedures, including required notifications will be provided to NRC in accordance with 10 CFR 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 CFR 20 Subpart M -Reports.
21 Exemptions and Additional Requirements NYSERDA is not seeking an exemption from the requirements identified in 10 CFR 20 Subpart N -
Exe~1ptions and Additional Requirements.
Retained Premises Radiation Protection Plan, RP-RPP500.03 29
Appendix A - WVSMP Organizational Charts Figure A-1. NYSERDA Retained Premises Radiation Protection Organization Source:
NYSERDA Radiation Safety Technician NYSERDA MANAGEMENT Radiation Safety Committee Radiation Safety Officer Radiation Safety Support Contractor Radiation Laboratory Suppmt Al Radiation Instrument Calibration 7
I I
I I
I I
I I
I I
I
~ -
Health Physics Suppo1t
Figure A-2. West Valley Site Management Program Organization Chart Source: NYSERDA I WVSM P Di recto,. I Office Administration Sr. Office Manager I
SDA and Retained Premises Program Manager" Project Manager2" Project Manager1..
ProJect Manager I
Office Administrator Office Administrator WVDPand End State Planning Program Manager*
Sr. Project Manager Project Manager Project Manager A2 Radiation Safety Committee Member Radiation Safety Officer 2
Health Safety and Emergency Response Project Manager
Appendix B - Position Descriptions and Minimum Qualifications for Participation in the NYSERDA RP-RPP
- 1.
Position and Responsibility Descriptions 1.1 Senior On-Site Manager The senior on-site manager is the individual at the senior on-site management level who is responsible for "corporate" oversight and support of the RP radiation protection program and has the ultimate responsibility for the license and the activities associated with the license. The senior on-site manager has the highest level of facility management responsibility and has the authority to delegate resources for the program and appropriate funds in a timely manner. The senior on-site manager has the authority to support whatever action is necessary to ensure that all radiation safety practices are in accordance with the regulations and conditions of the license.
The senior on-site manager may depend upon the RSO and RSC for advice and consultation on technical matters, but this individual has ultimate responsibility for the radiation safety program. As such, the senior-on-site manager actively participates as a inember of the radiation safety committee (RSC) and has the authority to acquire the necessary resources for the radiation safety program, as identified by the RSC and RSO.
The senior on-site manager's administrative responsibilities include maintaining a qualified staff, budgeting.
and acquiring funding, evaluating employee performance, public information, and coordination with NYSERDA's Albany office.
1.2 Middle Management Middle managers participate in the RP-RSC in order to bring perspective on radiation safety issues and work activities with more in-depth knowledge than that of the senior on-site manager.
Middle managers are responsible for development and implementation of programs and the implementation of policies in their specific area of operations and oversight. They may have one or more project managers and other technical staff reporting to them.
Bl
The operations middle manager brings to the RSC detailed knowledge of the work activities to be conducted and site conditions in the work area. Because the operations middle manager has line management responsibility for safety in addition to the role on the RSC, they also bring to the committee detailed knowledge of any particularly challenging issues or concerns. Other middle managers participating in the RSC bring an independent perspective on radiation safety issues.
1.3 Radiation Safety Officer The Radiation Safety Officer is responsible for implementing the radiation protection program. The RSO's primary responsibility is to ensure work is done in accordance with the applicable portions of License CSF-1, applicable NRC regulations, and the task-specific RWP and work instruction package. The RSO has independent authority to immediately terminate an unsafe practice or work activity with unchallenged authority and without prior coordination with the RSC or management.
The RSO also communicates specific needs for materials, equipment, instrumentation, staffing, training, etc., to management so management can provide the resources necessary to implement the Radiation Protection Program.
Specific duties and responsibilities of the RSO include but are not limited to:
surveys of all areas in which radioactive material is present or suspected; preparation of Radiation Safety Evaluations (RSEs) and Radiat.ion Work Permits (RWPs);
determining the need for and evaluating the results ofbioassays; monitoring personnel exposure records; and developing corrective actions for those exposures approaching maximum permissible limits; arranging or otherwise providing for radiation safety training of all personnel; monitoring inventory and leak tests of sealed sources; overseeing decontamination; responding to emergencies and working with emergency responders on radiation safety issues; maintaining all required records.
1.4 Industrial Safety and Emergency Response Staff NYSERDA's RSC includes the participation of industrial health and safety and emergency response staff, who bring to the RSC broad perspective on safety issues including the recognition of physical and industrial hazards, and preplanning for emergencies.
I The industrial safety staff identify nonradiological hazards of a work activity* such as heat and cold stress, slips trips and falls, animal encounters, and crush or fall hazards. Formal Hazard Identification evaluations B2
I are completed by safety staff, and mitigation measures for any identified hazards are presented in an Industrial Work Permit. Emergency response considerations, plans and contacts are included in every work package.
Industrial safety and emergency staff are involved in task planning at an early stage and work closely with the RSO to ensure that industrial hazards are addressed in a complimentary and integrated manner with radiological hazards.
1.5 Waste Management and Transportation Staff The Waste Management and Transportation staff are responsible for overseeing the generation, characterization, packaging, documentation, and transportation of radioactive, mixed, hazardous, universal and non-radioactive, non-hazardous debris for proper disposition or disposal.
Waste Management and Transportation staff work with the RSO to ensure that work activities are properly planned to minimize waste generation. Where waste generation cannot be avoided, waste management staff work with the cognizant project manager and RSO ensure that the waste is properly identified, characterized, packaged, and documented for transportation and disposal at an appropriate facility.
The Waste Management and Transportation Manager is ultimately responsible for certifying that the waste meets all criteria and requirements to be shipped and will sign the shipping manifest. This individual will also track the shipment through arrival at the disposal facility and will close out the shipment upon receipt of the paperwork certifying that the shipment arrived safely at the offsite facility for disposal or other disposition.
2 Minimum Qualifications Minimum qualifications for the following positions to participate in the Radiation Protection Organization are provided below. The qualification metrics identified below may be modified or fulfilled with alternate or equivalent education or experience commensurate with the hazards and licensed activities.
2.1 Senior On-Site Manager Education Bachelor's Degree in physical, chemical, or biological sciences or engineering, or related disciplines.
83
)
Exp1erience Radioactive material and nuclear fadlity experience, including a combination of the following topics, to total five years:
Nuclear facility decommissioning; radioactive and hazardous waste management; radioactive and hazardous waste transportation and disposal; environmental cleanup of radioactive materials; fundamentals of radiation and radiation safety.
Supervisory or management experience - five years Additional Requirements The Senior On-Site Manager must maintain cognizance of:
the type, quantity and location of radioactive materials under their cognizance.
the applicable parts of License CSF-1, 10 CFR Part 50 and 10 CFR Part 20 regulations.
the results of periodic audits and the annual review of the licensed program to ensure all
- activities comply with regulatory requireme~is and the conditions of the applicable portions of the license and that activities are being conducted in a safe manner..
Within six months of entry into this position, the Senior On-site Manager must complete the following training:
WVSMP Site-Specific Training 24-hour HAZWOPER Radiation Worker Training Hazard Communications Training Radiation Protection Program Plan for the Retained Premises Emergency Response Plan for the Retained Premises Safety and Health Program Plan 2.2 Middle Management Education Bachelor's Degree in physical, chemical or biological sciences or engineering, or related disciplines.
I Experience Radioactive Materials experience, including a combination of the following topics, to total three years:
Nuclear facility decommissioning, radioactive and hazardous waste management; radioactive and hazardous waste transportation and disposal; environmental cleanup ofhazardous and radioactive materials, fundamentals of radiation and radiation safety.
Supervisory or management experience in implementing program activities - three years
\\
Additional Requirements The Program Manager must maintain a working knowledge of:
the type, quantity and location of radioactive materials under their cognizance.
the applicable parts of License CSF-1, 10 CFR Part 50 and 10 CFR Part 20 regulations.
84 I
the results of periodic audits and the annual review of the licensed program to ensure all activities comply with regulatory requirements and the conditions of the applicable portions of the license and that activities are being conducted in a safe manner.
Within six months of entry into this position, Middle Managers must complete the following training:
WVSMP Site-Specific Training 24-hour HAZWOPER Radiation Worker Training Hazard Communications Training Radiation Protection Program Plan for the Retained Premises Emergency Response Plan for the Retained Premises Safety and Health Program Plan 2.3 Radiation Safety Officer Education Bachelor's Degree or equivalent training and experience in physical, chemical, biological sciences, or engineering.
Experience Radiation safety experience, including a combination of the following topics, to total three years:
personnel monitoring, bioassay, contamination control, investigation of incidents, training personnel, instrumentation and calibration, radioactive waste disposal, radioactive materials transportation.
Specialized RSO Training The RSO must attend a formal course designed for RSOs presented by an academic institution, commercial radiation safety consulting company, or professional organization of radiation protection experts. Training should include the following subjects:
Radiation protection principles Characteristics of ionizing radiation Units and quantities of radiation dose Radiation detection instrumentation Biological hazards of exposure to radiation (appropriate to types and forms of byproduct material to be used)
NRC regulatory requirements and standards Additional Requirements The RSO must maintain a working knowledge of:
the type, quantity and location of radioactive materials under their cognizance.
the applicable parts of License CSF-1, 10 CFR Part 50 and 10 CFR Part 20 regulations.
the results of periodic audits and the annual review of the licensed program to ensure all activities comply with regulatory requirements and the conditions of the applicable portions of the license and that activities are being conducted in a safe manner.
The RSO's training and experience should be sufficient to identify and control the anticipated radiation hazards. RS Os must have specific experience with the types and quantities of radioactive material that may be encountered as part of work activities under the license.
Within six months of entry into this position, the RSO must complete the following training:
WVSMP Site-Specific Training 24-hour HAZWOPER Radiation Worker Training Hazard Communications Training Radiation Protection Program Plan for the Retained Premises Emergency Response Plan for the Retained Premises Safety and Health Program Plan 2.4 Industrial Safety and Emergency Response Staff Education Bachelor's Degree or equivalent training and experience in industrial hygiene, physical, chemical, biological sciences, or engineering.
Experience Industrial safety and emergency response experience, including a combination of the following topics, to total three years: industrial hygiene; OSHA worker safety regulations; Federal Emergency Management Agency (FEMA) National Incident Management System (NIMS); ICS-100 Incident Command System.
Additional Requirements The Health Safety and Emergency Response Project Manager must maintain a working knowledge of:
)
the type, quantity and location where hazardous chemicals will be used on the Retained Premises.
industri~I, weather, ergonomic and biological hazards associated with work activities on the Retained Premises.
Within six months of entry into this position, the following training must be completed:
WVSMP Site-Specific Training 24-hour HAZWOPER Radiation Worker Training Hazard Communications Training Radiation Protection Program Plan for the Retained Premises Emergency Response Plan for the Retained Premises Safety and Health Program Plan B6
2.5 Waste Management and Transportation Manager Education Bachelor's Degree or equivalent training and experience in physical, chemical, biological sciences, or engmeenng.
Experience Waste management and transportation experience, including a combination of the following topics, to total 3 years: State and federal radioactive waste management and disposal regulations and guidance, US DOT hazardous materials shipping regulations, radioactive waste classification, characterization, packaging, and shipping; FEMA National Incident Management System (NIMS).
Specialized Training The Waste Management and Transportation Manager should attend courses on waste management, shipping, and disposal of radioactive and hazardoi{s wastes.
Training should include the following subjects:
US Department of Transportation 49 CFR 172 Hazardous Materials Shipper Certification Federal Emergency Management Agency (FEMA) National Incident Management System (NIMS)
ICS-100, Introduction to the Incident Command System IS-700- National Incident Management System, An introduction Additional Requirements The Waste Management and Transportation Manager must maintain a working knowledge of:
the type, quantity and location where radioactive and hazardous wastes will be used on the Retained Premises.
the applicable parts of License CSF-1, 10 CFR Part 50, 10 CFR Part 71, and 10 CFR Part 20 regulations.
the waste acceptance criteria for disposal facilities the waste shipment manifest requirements Within six months of entry into this position, the following training must be completed:
WVSMP Site-Specific Training 24-hour HAZWOPER Radiation Worker Training Hazard Communications Training Radiation Protection Program Plan for the Retained Premises Emergency Response Plan for the Retained Premises Safety and Health Program Plan B7
Appendix C - Administrative Limits for Contamination Cc>ntrol Table C-1. Acceptable Surface Contamination Levels (per 100 cm2)
Source:
NYSERDA U-nat, U-235, U-238, and associated decay products
.'Jransuranics; P:1-25, 1°129, Ra-226;' Ra- *.
- 228,
- Pa~23.1, Ac-227 (, Jh~228;Th-230..
1-126, 1-131, 1-133, Ra-223, Ra-224, Sr-90, U-232, Th-nat, Th-232
. Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontaneous fission) except those noted above.
83.3 Bq 5,000 dpm a
. 1i7 Bq o'100 dpm __.
16.7 Bq 1,000 dpm 83.3 Bq 5,000 dpm 15,000 dpm a
- 30.0dpm 3,000 dpm 15,000 dpm 16.7 Bq 1,000 dpm a
'9.3 Bq 2Q 9pm
- 3.3 Bq 200 dpm 16.7 Bq 1,000 dpm 1Where surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting radionuclides should apply independently.
2As used in this table, disintegrations per minute (dpm) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
- 3 Measurements of average contaminants should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object.
4 The maximum contamination level applies to an area of not more than 100 square centimeter ( cm2).
5The average and maxim.um radiation levels associated with surface contamination resulting frc:im beta-gamma emitters should not exceed 0.2 millirad/h at 1 cm and 1.0 millirad/h at 1 cm, respectively, measured through not more than 7 milligram/cm2 of total absorber.
6The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with a filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally, and the entire surface should be wiped.
/
Cl
Appendix D - Topics Proceduralized Table D-1. List of RP-RPP Documents Source: NYSERDA Title Document Number Radiation Protection Plan Radiation Protection Plan for the Retained Premises RP-RPP500 Radiation Protection Procedures Radiation Safety Committee for the Retained Premises RP-RPP001 Radiation Safety Officer for the Retained Premises RP-RPP002 Annual Retained Premises Radiation Protection Program Audit RP-RPP003 Training and Instruction of Radioactive Material Users on the Retained Premises RP-RPP004 Radiological Surveys on the Retained Premises RP-RPP005 ALARA Policy and Reviews for the Retained Premises RP-RPP006 Retained Premises Radiological Safety Evaluations and RWPs RP-RPP007 Personnel Decontamination Procedure for the Retained Premises RP-RPP008 Use of Personnel Dosimetry on the Retained Premises RP-RPP009 Monitoring of Personnel for Contamination on the Retained Premises RP-RPP010 Instrument Calibration for the Retained Premises RP-RPP011 Bicron MicroRem Survey Meter, Operation Procedure for the Retained Premises RP-RPP012 (Cancelled and replaced by RP-RPP014)
Ludlum 2241-2 Ratemeter/Scaler, Operation Procedure for the Retained RP-RPP013 Premises (Cancelled and replaced by RP-RPP014)
Operation and Maintenance of Portable Radiation Detection Instruments RP-RPP014 Posting and Labeling on the Retained Premises RP-RPP015 Receipt, Opening and Transfer of Packages of Radioactive Material for the RP-RPP016 Retained Premises Corrective Action System RP-RPP017 Source Control on the Retained Premises RP-RPP-018 DI
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West Valley Site Management Program RECORD OF REVISION AND DISTRIBUTION TITLE:
Radiation Protection Plan for the Retained Premises Record of Revision:
Description of Change(s)
( and pages affected)
RP-RPPS00.00 RP-RPPS00.01 RP-RPPS00.02 Original issue General Revision to update the controlled and restricted areas of the Retained Premises, and to submit for the License Amendment Request General revision to address comments and questions from the NRC (added descriptive detail on the Radiological Safety Evaluation and Radiological Work Permit processes, and to improve technical content where needed).
RP-RPP500.03 General revision to address NRC RAJ.
Record of Distribution:
Record of Distribution (Distribution List)
RP-RPP500.00 RP-RPP500.00 FRM002.07 WVSMP Plans and Procedures Manuals (AOC Office, SDA and Annex)
Central Files (Original with green sheets)
Transmittal to Chad Glenn, NRC
( under separate cover P JB/12amd019. ej t)
Edward Traverso, RSO, RP-RSC, Controlled Binder 1 Tom Attridge, RP-RSC Controlled Binder 2 Paul Bembia, RP-RSC Controlled Binder 3 RP-RSC Controlled Binder 4 (never issued)
Jean Williams, RP-RSC Controlled Binder 5 Duane Quayle, EnergySolutions, (Radiation and Safety Contractor Manager) RP-RSC Controlled Binder 6 Central Files 10512 RP-RSC Controlled Binder 7 Elizabeth Lowes, RP-RSC Controlled Binder 8 Alita Dueringer, RP-RSC Controlled Binder 9 RP-RPPS00.03 Date Issued 04/19/2012 02/03/2020 10/28/2020 07/ 15/2021 Date Distributed 04/19/2012 07/30/2012
RP-RPPS00.03 Record of Distribution ( continued)
(Distribution List)
RP-RPP500.01 WVSMP Plans and Procedures Manual (AOC Office)
Central Files (Original with green sheets)
RP-RPP500.02 Doug Coble, RSO, RP-RSC, Controlled Binder 1 Andrea Mellon, RP-RSC Controlled Binder 2 Paul Bembia, RP-RSC Controlled Binder 3 RP-RSC Controlled Binder 4 (never issued)
RP-RSC Controlled Binder 5 Lou Henry, MJW, (Radiation and Safety Contractor Manager) RP-RSC Controlled Binder 6 Central Files 10512 RP-RSC Controlled Binder 7 Brad Frank, RP-RSC Controlled Binder 8 Alita Dueringer, RP-RSC Controlled Binder 9 WVSMP Plans and Procedures Manual (AOC Office)
Central Files (Original with green sheets)
Doug Coble, RSO, RP-RSC, Controlled Binder 1 Andrea Mellon, RP-RSC Controlled Binder 2 Paul Bembia, RP-RSC Controlled Binder 3 RP-RSC Controlled Binder 4 (never issued)
RP-RSC Controlled Binder 5, Jeff Brayer 07/15/2021 Date Distributed 02/03/2020 10/28/2020 Dan Cray, MJW, (Radiation &Safety Contracto~ Mgr.) RP-RSC Controlled Binder 6 Central Files 10512 RP-RSC Controlled Binder 7 RP-RPP500.03 FRM002.07 Brad Frank, RP-RSC Controlled Binder 8 Alita Dueringer, RP-RSC Controlled Binder 9 U.S. NRC Document Control Desk WVSMP Plans and Procedures Manual (AOC Office)
Central Files (Original with green sheets)
RSO, RP-RSC, Controlled Binder 1 Andrea Mellon, RP-RSC Controlled Binder 2 Paul Bembia, RP-RSC Controlled Binder 3 RP-RSC Controlled Binder 4 (never issued)
Jeff Brayer, RP-RSC Controlled Binder 5 07/15/2021 Dan Cray, MJW, (Radiation & Safety Contractor) RP-RSC Controlled Binder 6 Central Files 10512 RP-RSC Controlled Binder 7 Brad Frank, RP-RSC Controlled Binder 8 Alita Dueringer, RP-RSC Controlled Binder 9