ML21281A021
| ML21281A021 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 09/09/2021 |
| From: | Bembia P State of NY, Energy Research & Development Authority |
| To: | Kimberly Conway, Amy Snyder Reactor Decommissioning Branch |
| Snyder A | |
| Shared Package | |
| ML21281A019 | List: |
| References | |
| Download: ML21281A021 (3) | |
Text
New York State Energy Research and Development Authority (NYSERDA)
September 9, 2021 Response to the U.S. Nuclear Regulatory Commissions (NRC) August 27, 2021 email entitled Final Clarifications on the WNYNSC RPP
- 1. Contamination Control Limits. Please confirm that NYSERDAs intent is to have the sensitivity of radiological detection instruments be at least that provided in Appendix C to the Retained Premises RPP, while also ensuring that no materials or equipment with detectable radioactivity will be allowed to be released from restricted or soil contamination areas of the site.
Confirmed. To prevent the transfer of contamination to uncontrolled areas, NYSERDA will perform routine monitoring for both removable and total surface contamination before the release of potentially contaminated materials and/or equipment from controlled areas of the Retained Premises.
Prior to site work, all detectors utilized by NYSERDA or its contracted radiological support staff for the purposes of surface contamination detection on the Retained Premises will be verified to have a minimum detectable concentration (MDC) sensitivity at or below the required action levels identified in RP-RPP500, Appendix C, which have been adopted from NRC Regulatory Guide 8.24, Appendix A - Acceptable Surface Contamination Levels. The action levels identified in NRC Regulatory Guide 8.24 are the same as those identified in IE Circular 81-07, Control of Radioactively Contaminated Material (ADAMS Accession No. ML103420362) as the minimum level of activity that can be routinely detected using direct survey methods. As such, the contamination control limits identified in RP-RPP500 for the Retained Premises are set at the minimum level that can be routinely detected using direct survey methods, and provides assurance that no materials or equipment with detectable radioactivity will be allowed to be released from restricted or soil contamination areas of the site.
If contamination is detected at or above the action levels identified in RP-RPP500, Appendix C, NYSERDA shall make reasonable efforts to eliminate the contamination (i.e., decontamination activities will be conducted and repeated until additional efforts do not significantly reduce contamination levels). Contaminated materials and/or equipment shall be segregated and remain in a controlled/restricted location within the Western New York Nuclear Service Centers (WNYNSC) Retained Premises, pending disposal as radioactive waste, in accordance with 10 CFR 20.2001 Subpart K - Waste Disposal, or limited to use inside the controlled area.
- 2. Please confirm that NYSERDA will consider revising the WNYNSC RPP to include this or a similar statement/discussion during a future revision.
Confirmed. The WNYNSC RPP will be modified to include the aforementioned information regarding contamination control limits and detector MDC sensitivity when RP-RPP500 is next revised.
- 3. Action Limits for Leak Testing. Please specify an action limit (e.g., 0.005 uCi) for leak testing of sealed sources and confirm that NYSERDA would (1) report and document any exceedance of the action limit and (2) appropriately repair or dispose of the source (see NRC Regulatory Guide 8.24,
Health Physics Surveys during Enriched Uranium-235 Processing and Fuel Fabrication, Appendix C for additional information).
Confirmed. Procedure RP-RPP018 - Source Control, establishes the West Valley Site Management Program (WVSMP) guidelines for storing, inventorying, leak testing, transferring, disposing, and controlling radioactive sources at the WNYNSC, and this procedure specifies a 0.005 microcurie action limit for leak testing of sealed sources. Although all sources possessed by NYSERDA are exempt from periodic leak testing per 10 CFR 39.35(e), Leak testing of sealed sources, source leak testing on all radioactive sources is performed on a biannual basis, concurrent with the radioactive source inventory, for purposes of mitigating contamination risk and maintaining dose exposures As Low As Reasonably Achievable (ALARA). Records of leak test results are kept in units of disintegrations per minute (dpm) and microcuries and maintained for inspection by the NRC.
Per 10 CFR 34.27, Leak Testing and replacement of sealed sources, NYSERDA's source leak testing analyses must be capable of detecting the presence of 0.005 microcuries (11,100 dpm) of radioactive material on the leak test sample. Sample counting MDC with WVSMP field instrumentation at a 95 percent confidence level is calculated using the following equation from NUREG-1507:
3 + 3.29 ( [1 + ])
( )=
Where:
- MDCsmear = minimum detectable concentration level (dpm)
- RB = background count rate in counts per minute (cpm)
- TS+B = sample count time (minutes)
- TB = background count time (minutes)
- K = proportionality constant (e.g., instrument efficiency) that relates the detector response to the activity level in a sample for a given set of measurement conditions Source leak testing will be performed and analyzed using WVSMP field instruments by the Radiation Safety Officer (RSO) or other qualified personnel trained and approved by the WVSMP RSO. A record of qualified personnel will be kept in NYSERDAs WVSMP central files. Formal training will encompass the following:
- 1. Radiation Worker II training
- a. fundamentals of radiation, radioactive material, and radioactive contamination
- b. principles and practices of radiation protection
- c. biological effects of radiation
- d. radiation dose limits
- e. ALARA principles
- f. personnel monitoring programs
- g. radioactivity measurements, monitoring techniques, and the use of instruments
- 2. general knowledge of the mathematics, statistics, and calculations for the measurement of radioactivity
- 3. on-the-job training encompassing hands-on training in leak testing, including performing independent analysis of leak test samples Source leak tests may also be conducted by a commercially licensed facility authorized by the NRC or an Agreement State.
The RSO will be notified of the test results by the individual or laboratory conducting leak testing. If a source leak test analysis indicates that the sample has removable activity above the 0.005 microcurie (11,100 dpm) action limit, the source will be controlled in a manner that minimizes the spread of radioactive contamination and the RSO will be notified immediately.
The source will be removed from service and secured in a controlled location, pending repair or disposal in accordance with the NRC regulations. In accordance with NRC Regulatory Guide 8.24, Appendix C - Leak Test Requirements, NYSERDA shall file a report with the Director, Division of Fuel Cycle Safety and Safeguards, NRC, Washington, DC 20555 within five days after determining that any source has leaked. This report will describe the source, test results, extent of contamination, apparent or suspected cause of source failure, and corrective action taken. A copy of the report will also be sent to the administrator of the nearest NRC regional office (Region I) listed below:
USNRC, Region I 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713
- 4. Please confirm that NYSERDA will consider revising the Retained Premises RPP to include this or a similar statement/discussion during a future revision.
Confirmed. The WNYNSC RPP will be modified to include the aforementioned information regarding action limits for leak testing and leak test requirements when RP-RPP500 is next revised.