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SHIELDALLOY METALLURGICAL CORPORATION

DAVID R. SMITH ENVIRONMENTAL MANAGER Aluminum Products 8 Powders Division

November 25, 1997

Mr. Michael Weber

WEST BOULEVARD P.O. BOX 768 NEWFIELD, NJ 08344

TELEPHONE (609) 692-4200 FAX (609) 692-4017

Chief, Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS U. S . Nuclear Regulatory Commission Washington, D.C. 20555-0001

Re: Application to Amend Source Material License No. SMB-743 (TAC No. L21474)

Dear Mr. Weber:

On October 20, 1997, source material license No. SMB-743 for Shieldalloy Metallurgical Corporation (SMC) was renewed. Provision 11 of the renewed license requires SMC to “submit a revised program description to replace the September 15, 1995 draft Radiation Safety Procedures”. To comply with that provision, SMC is submitting an application to amend SMB- 743 in its entirety (enclosed). This application supersedes all previous applications and submissions. Please note that, in addition to containing the revised program description requested in Provision 11, this application also requests authorization to use source material at the Newfield facility and at other off-site locations that have been approved, in advance, by the USNRC.

Included in this amendment application is a request that provision 13 of the license be removed in its entirety because it:

j Holds SMC to a higher standard of performance than is required of other 1 icensees;

‘ ,

Imposes an unduly restrictive procedural requirement that is not justifiable in light of radiological conditions actually measured for the operation.

1’ ! Title 10 CFR 20.1502(b)( 1) requires licensees to monitor the occupational intake of radioactive material for those adults likely to incur, in one (1) calendar year, an intake equivalent to 10 percent of the applicable Annual Limit on Intake (ALI). monitored airborne concentrations of source material in the involved in baghouse maintenance and emptying. The results

For the past few years, SMC has breathing zone of those individuals were all negative above a detection

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limit of about 3 x pCi (gross alpha) per milliliter. Since the annual duration of activities involving the baghouse is much less than 500 hours per year for the maximally-exposed individual, the highest possible "missed exposure", assuming a detection limit of about 3 x 1W2 pCi (gross alpha) per milliliter, would be about 90 DAC-hours.' This estimate is less than the equivalent monitoring limit in 10 CFR 20.1502@)(1) of 200 DAC-hours, thus the regulations do not require monitoring be performed.

SMC may monitor this or any other operation that involves source material, regardless of the radiological conditions during the work. However, the USNRC's imposition of a license provision that requires monitoring in the face of these data is not warranted. It is for this reason that SMC requests removal of Provision 13 from license No. SMB-743.

SMC understands that the amendment fees will be assessed and billed at a later date by the USNRC, thus no payments are enclosed. If you have any questions, please contact me at (609) 692-4200, ext. 226.

Sin rely, dias David R. Smith Radiation Safety Officer

cc: Nigel C. Morrison Mary B. Higgins James P. Valenti Hugo L. Nieves William J. Grabus Lidia M. Stasiuk Eric L. Schorndorf, Esq.- Metallurg Carol D. Berger - IEM Heather Astwood - USNRC Licensing Section 2 Penny Lanzisera - USNRC Region 1

'Using a thorium-to-gross alpha ratio of 0.076 and a uranium-to-gross alpha ratio of 0.061, along with Derived Air Concentrations for both isotopes that have been corrected for particle size (e.g., 1.3 x lo-'* and 3.5x10-" pCi/ml, respectively), the exposure estimate is:

X 500 = 90.3 DAC-hours 3 x x 0.076 + 3 x lo-" x 0.061

1.3 X 3.5x lo-"

2

8

t RAOIOACTIVE MATERIAL Elammlmdmmanumbr. b h m * . l m d / a 0 * u c l l l l a . m d c nmxmnwn.I I IOVl1

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Attachment 3 I WASTE MANAGEMENT

YRC FORM 313 'r. UX. NUCLEAR REGULATORY COHMISSION

I NRWSEIS l FOR WWICM LICENSED MATERIAL WILL BE USED Attachment 1

I TRAINING FOR INOIVIOUALSWORKING IN OR FREOUENTING n E s i n i c i E o AREAS

A t t b n t 3 I O RAOIATION SAFETY PROGRAM

A t t - 3 I2 LICENSEE FEES I S a IOCFR ItOendSrrron l7O3ll

FEE CATEGORY ENCLOSED $ AMOUNT

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APPLICATION FOR MATERIAL LICENSE

COMMENTS

INSTRUCTIONS: SEE TME APPROPRIATE LICENSE APPLICATION GUlOE FOR OETAILEO INSTRUCT10 Of TME ENTIRE COMPLETE0 APPLICATION TO THE NRC OFF ICE SPECIFIED BELOW.

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INFORMATION COLLECTION n E o u m 1.n nns Co(I*IARC

FOR COMPLETING APPLICATION. SEN0 lW0 COPIES

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LCRSONS L O U T E D IN AOREEYfNT STATES SEN0 UILICATIONS TO IWE U.C. NUCLEAR REOULATORY Q)(y(UIoI( ONLV IF TWEY W I W TO r o O E U A N 0 U E LKC#EO MATERIAl IN STATES .uUECT TO U.C. NUCLEAR REOULATORV couUoI loW JURI~ICTKWI.

I THIS IS AN APPLICATION FOR I M -ma rcntt 2. NAME AND MAILING A D O R E S OF APPLICANT llmdwabZ@ ColJ - A. NEW LICENSE

I. AMENDUENTTO LICENSE NUMOER SMB- 743

J C. RENEWAL OF LICENSE NUMOER

Shieldalloy Metallurgical Corporation West Boulevard, P.O.Box 768 Newfield, NJ 08344

I. AODRESSIESI WHERE LICENSED MATERIAL WILL I€ USED OR MSSESSED.

See Attachment 1

~~

TnE APPLICANT AND ANY OFFICIAL EXECUTING TMIS CERTIFICATION ON IEWALF OF TME APPLICANT. NAMED I N ITEM 1. CERTIFY TMAT THIS APPLICATION IS WECAREO I N CONFORMITY WITH TITLE 10. CODE OF FEDERAL REGULATIONS. CARTS 30.12.31. Y. 3s. AN0 40 AND THAT ALL INFORMATIOW CONTAINED WEREIN. (L TRUE ANO CORRECT m WE m c n OF TnEm UNOWLEDGL AND BELIEF.

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ATTACHMENT 1 Authorized Uses of Licensed Materials

1

Radioactive Material (Type, Form and Use):

Radionuclide

Thorium

UraniWn

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Any fom suitable for transport under DOT regulations

Any form suitable for transport under DOT regulations

Possession Limit w

303050

45000

Intended Use

~

Shipping, receiving, possession, use, processing, research, development and storage incident to the use of raw and byproduct materials to produce speckdty alloys, slag fluidizers, and other products.

Shipping, receiving, possession, use, processing, research, development and storage incident to the use of raw and byproduct materials to produce specialty alloys, slag fluidizers, and other products.

Place of Use

Existing facilities at 12 West Boulevard, Newfield, New Jersey, 08344, or at offsite locations that have been approved, in advance, by the USNRC.

~~~~~ ~ ~

Existing facilities at 12 West Boulevard, Newfield, New Jersey, 08344, or at offsite locations that have been approved, in advance, by the USNRC.

2

ATTACHMENT 2 Individuals Responsible for Radiation Safety Program

and their Experience

3

RADIATION SAFETY OFFICER David R. Smith

Environmental Manager

Education B.S. (Civil Engineering), Villanova University, 1971 H k d o u s Waste Operations and Emergency Response Training (29 CFR 1910.120), Naval Facilities Engineering Command, 1986.

HazardousIToxic Waste Management, Lion Technology SMC General Employee Training and Employee Right to Know Training Radiation Safety Training for Authorized Users of Radioactive Materials, IEM, 1994. Managing Radiation Protection Programs, IEM, 1996

Registrations/Cem-fica tions New Jersey Department of Environmental Protection, Class N2 Industrial Wastewater Treatment System Operator License

Experience and Background 1988-Present - Shieldalloy Metallurgical Corporation - Has been responsible for overall management and direction of the company’s environmental remedial investigations related to past operating practices, as well as its environmental management of current operations to assure compliance with appropriate local, state and Federal laws and regulations. Managed the Newfield NJ RI/FS and RCRA Lagoon closure programs. Supervise and manage &e groundwater remediation program, participated in radiological characterization including pressurized ion chamber measurements , gamma scintillation survey and surface soil sample collection at SMC Newfield. Has been a member of the Radiation Safety Committee, supervised and assisted with the management of the TLD program, performed bioassay sampling and air sampling to demonstrate license and regulatory compliance. Has conducted sampling for analysis to update source material inventory. Has been responsible for radiological decontamination efforts performed at the SMC Cambridge facility which excavated and consolidated the mislocated slags from the 16 areas identified by ORAU, and development of documents for submission to NRC for the Decontamination and Decommissioning Reports of 1991. Responsible for the SMC coordination of EAEIS efforts which NRC has been conducting at the Newfield facility as part of the license renewal and evaluation of the decommissioning options available to the company. Responsible for conducting environmental due diligence investigations associated with planned acquisition of property and companies.

1974-1988 - Naval Facilities Engineering Command - As a senior environmental manager was responsible for the management of CERCLA Site Assessments, Remedial InvestigatiodFeasibility Studies, RCRA Remedial Investigations and UST closures, development and auditing of NPDES programs; air pollution control program, and at various Naval shore facilities within the 24 state region. These programs were

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implemented and provided to the Commanding @cers of the following major naval shore facilities: N W S Earle, NJ; NAS Glenview, IL; NSB Groton, CT; NUSC London, CT; NTC Great Lakes, IL; NAEC Lakehurst, NJ; NSGA Winter Harbor, ME; NCU Cutler, ME; NWSC Crane!, IN; NAPC Trenton, NJ; NCBC Davisville, RI; and NETC Newport, RI. Responsibilities included coordination with local, state and Federal agencies. Radiological concern were addressed at several sites, particularly related to groundwater and soil contamination.

1972-1974 - United States Army Environmental Hygiene Agency - Assisted with the planning, management and accomplishment of baseline environmental surveys of US Army munition depots and manufacturing plants. The surveys established the basis for the US Army for applying for their fmt round of National Pollutant Discharge Elimination System (NPDES) permits. The surveys established sampling points/locations at the depots and munition manufacturing facilities for the collection and characterization of industrial wastewater, domestic sewer, and storm water discharges. These sampling locations were sampling over a two to four week period for a comprehensive list of analytes including BOD, COD, bacterial (fecal), chemical composition, metal and organics. The results were compiled into a report submitted to the Commanding Officer of the facility with recommendations for treatment, monitoring, etc.

5

ALTERNATE RADIATION SAFETY OFFICER James P. Valenti

Environmental Manager

Education B. A. (Geology), Lafayette College Graduate Studies in Soil Mechanics and Foundations - Syracuse University General Employee Training - GPU Nuclear Oyster Creek Training Department General Employee Training - Niagra Mohawk Power Corporation Basic Radiological Safety - Stone & Webster Engineering Corporation Radiation Safety Officer Training - Radiation Safety Associates Hazardous Waste Operations and Emergency Response (29 CFR 1910.120) - IT Corporation

Managing Radiation Protection Programs - IEM Basics of Decommissioning Workshop - NES Management of Hazardous Waste - ERC

Regis tra tionsKem-fica tions Certified Professional Geologist, Indiana (No. 644) NJDEP N2 Industrial Wastewater Treatment System Operator License (#N1343) American Red Cross, Standard First Aid and Adult CPR

Professional A filiations Society of Mining Engineers National Ground Water Association

Experience and Background 1989-Present - Shieldalloy Metallurgical Corporation - Has been responsible for conducting RI/FS and ground water remediation, participated in radiological characterization including pressurized ion chamber measurements, gamma scintillation survey and surface soil sample collection at SMC Newfield. Has been a member of the Radiation Safety Committee, managed TLD program, performed bioassay sampling and air sampling to demonstrate license and regulatory compliance. Has conducted sampling for analysis to update source material inventory. Has been responsible for conducting RI/FS at the SMC Cambridge facility and development of documents for submission to NRC for preparation of a draft environmental impact statement. Served as RSO for both the Newfield and Cambridge facilities from August 1993 to September 1994. Has been the point of contact during NRC inspections at both facilities. Provided general employee training at SMC Newfield for all employees at the facility.

1986-1989 - Naval Facilities Engineering Command - Managed CERCLA Remedial Investigations/Feasibility Studies, RCRA Facility Investigations and UST closures at

6

NAEC Lakehurst, NJ, NWSC Crane, IN, NCC Davisville, RI, and NSY Newport, RI under the Navy Installation Restoration Program. Responsibilities included coordination with local, state and Federal agencies. Radiological concerns were addressed at several sites, particularly related to ground water and soil contamination.

1979-1986 - Stone & Webster Engineering Corporation - Conducted blast monitoring, geologic inspection, mapping and photographic documentation during excavation, preparing weekly summary reports. Site geology and seismic design criteria documentation provided for preparation of construction permit application, primary safety analysis and final safety analysis reports at the USDOE Clinch River Breeder Reactor Plant Project and NMPC Nine Mile Point 2 nuclear power plant sites. Provided geo- technicayengineering support services during construction activities at various nuclear and fossil fuel power plant facilities. Also identified lithologies and located formations on a suite of geophysical logs from more than 400 exploratory and production wells drilled in the vicinity of the proposed Permian Basin nuclear waste repository site in Texas for the Office of Nuclear Waste Isolation.

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ATTACHMENT 3 Radiation Protection Program Plan

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9712030267 971125 FDR ADUCU 04007102 C F13R

RADIATION PROTECTION PROGRAM PLAN Shieldalloy Metallurgical Corporation

November 24, 1997

1 PURPOSE

The goals of the Shieldalloy Metallurgical Corporation (SMC) policy on radiological protection are to minimize the total risk of harm or injury incurred by employees, contractors, or visitors as a result of work-related activities at sites that are licensed to possess radioactive materials, and to demonstrate compliance with applicable laws and regulations on control of radioactive materials. This Radiation Protection Program Plan (Plan) has been developed to guide generation and implementation of SMC Radiation Safety Procedures as they pertain to licensing and radiation protection issues.

2 SCOPE

This Plan applies to all facilities, equipment and operations at the Newfield, New Jersey site or at specific off-site locations that are licensed by the USNRC to possess radioactive materials. Facilities, equipment and operations that do not require a license are exempt from the requirements of this Plan.

3 REFERENCES

3.1 Title 10, Code of Federal Regulations, Part 19, "Notices, Instructions and Reports for Workers; Inspection and Investigations"

3.2 Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation".

3.3 Title 10, Code of Federal Regulations, Part 40, "Domestic Licensing of Source Material ".

3.4 Title 10, Code of Federal Regulations, Part 71, "Packaging and Transportation of Radioactive Material".

3.5 Title 10, Code of Federal Regulations, Part 110, "Export and Import of Nuclear Equipment and Material".

3.6 Title 29, Code of Federal Regulations, Part 191 0, "Occupational Safety and Health Standards".

3.7 Title 40, Code of Federal Regulations, Part 68, "Chemical Accident Prevention Provisions".

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3.8 ANSI N323 - American National Standard Institute, "Radiation Protection Instrumentation Test and Calibration," N323-1978m. 1 977.

3.9 U. S. Nuclear Regulatory Commission Source Material License Number SMB- 743.

4 PROCEDURE

4.1 Radiation Protection Organization and Administration

4.1 . 1 Senior Corporate Official

4.1.1.1 Overall control and authority for radiation protection shall rest with the Senior Corporate Official .

4.1.1.2 The responsibility of the Senior Corporate Official includes, but is not limited to, the following:

4.1 .1.2.1 Establish SMC policy and prepare/amend this Plan accordingly;

4.1.1 -2.2 Appoint and empower the SMC Radiation Safety Committee (RSC); and

4.1.1.2.3 Assure that SMC radiation protection services are sufficient to meet the requirements of this Plan and USNRC license requirements.

4.1.2 Radiation Safety Officer (RSO)

4.1.2.1 The Senior Corporate Official may designate the authority for implementing the radiation protection program described herein to the RSO.

4.1.2.2 The RSO shall be responsible for recommending the type and quantity of staff and resources necessary for full implementation of the Plan.

4.1.2.3 The RSO shall have the responsibility and authority to terminate any work activities that do or may violate regulatory or SMC requirements for radiological protection.

4.1.2.3.1 Specific work activities shall be permitted to proceed to a safe condition after issuance of the stop-work order.

10

4.1.2.3.2 Stop-work orders shall be lifted only after the initiating conditions have been alleviated.

4.1.2.4 The minimum qualifications of the RSO shall include the following:

4.1.2.4.1 An Associate's degree (or equivalent)

4.1.2.4.2 Course work and/or have experience with the following:

4.1.2.4.2.1 Principles and practices of radiation protection;

4.1.2.4.2.2 Radioactivity measurements, monitoring techniques, and the use of instruments;

4.1.2.4.2.3 Mathematics and calculations basic to the use and measurement of radioactivity;

4.1.2.4.2.4 Biological effects of radiation;

4.1.2.4.2.5 Safety practices applicable to protection from the radiation, chemical toxicity, and other properties of the radioactive materials in use at SMC facilities;

4.1.2.4.2.6 Conducting radiological surveys and evaluating results;

4.1.2.4.2.7 Evaluating radioactive material processing facilities for proper operations from a radiological safety standpoint; and

4.1.2.4.2.8 Familiarity with applicable USNRC, USEPA, and OSHA regulations, as well as the terms and conditions of any licenses and permits issued to SMC by these agencies.

4.1.3 In the absence or unavailability of the RSO (e.g., vacations, illness, attendance at off-site training, or work-related duties at locations other than the Newfield facility), the authority for implementing the radiation protection program described herein shall be delegated to the Alternate Radiation Safety Officer (ARSO).

1 1

4.1.4 If the RSO is absent for more than 60 calendar days, a new RSO shall be named and notification of such, including the name, qualifications and authority of the new RSO, shall be submitted to the USNRC.

4.1.5 Radiation Safety Committee (RSC)

4.1.5.1 The SMC Radiation Safety Committee shall provide oversight for the radiation protection program.

4.1.5.2 The permanent members of the SMC Radiation Safety Committee (RSC) shall include the RSO, the ARSO, the Vice President of Human Resources, the Safety Manager, the Shipping/Receiving/Warehousing Manager, and the Production Manager. .

4.1.5.3 Depending upon the topic(s) to be addressed, the composition of the RSC may be expanded to include an environmental department representative, operations department representative, an engineering department representative, a maintenance department representative, a union steward, a Certified Health Physicist, and/or others deemed appropriate by the Senior Corporate Official or the RSO.

4.1.5.4 The RSC shall be responsible for the review and approval of all elements of the radiation protection program and for assessing compliance with USNRC license requirements.

4.1.5.5 The RSC shall be responsible for confirming that activities are performed safely and in a manner that will protect health and minimize hazards to life, property, and the environment.

4.1.5.6 Other responsibilities of the RSC shall include the following:

4.1.5.6.1 Monitoring compliance with Radiation Safety Procedures;

4.1.5.6.2 Reviewing and approving Radiation Safety Procedures for currency and adequacy, recommending revisions as appropriate;

4.1.5.6.3 Reviewing unusual incidents involving radioactive materials or radiation-producing machines and provide recommendations on how their recurrence shall be prevented; and

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4.1.5.6.4 Initiating safety evaluations of all proposed uses of radioactive material or radiation-producing machines.

4.1.5.6.5 Reviewing and approving all license-related correspondence.

4.1.5.7 Members of the RSC shall receive training in the topics shown in Appendix B.

4.1.6 Authorized Users

4.1.6.1 The RSO may designate authority for implementing certain aspects of the radiation protection program to Authorized Users.

4.1.6.2 Authorized Users shall have the following minimum qualifications:

4.1.6.2.1 Knowledge of work authorization and Radiation Work Permit (RWP) requirements.

4.1.6.2.2 An understanding of the type, form, and authorized uses of radioactive materials in the restricted areas at the Newfield plant or at off-site locations.

4.1.6.2.3 An understanding of the provisions of this Plan.

4.1.6.2.4 Training in the topics shown in Appendix B.

4.1.6.3 The responsibilities and authority of Authorized Users may include the following:

4.1.6.3.1

4.1.6.3.2

4.1.6.3.3

4.1.6.3.4

4.1.6.3.5

Monitoring and maintaining equipment associated with the use, storage, and disposal of licensed radioactive material under their control.

Preparing products for shipment;

Performing product testing;

Performing research and development with licensed radioactive materials; and

Ensuring that personnel under their supervision comply with the requirements of this Plan.

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.

4.1.7 Radiation Surveyors

4.1.7.1 The RSO may designate authority for implementing certain aspects of the radiation protection program to Radiation Surveyors.

4.1.7.2 Radiation Surveyors shall have demonstrable course work and/or experience in the following:

4.1.7.2.1 Radiation fundamentals including science/math review; radioactivity; interactions, biological effects quantities and units.

4.1.7.2.2 Measurement methods including survey instruments, external and internal monitoring systems, environmental monitoring systems.

4.1.7.2.3 Operational aspects including protection principles, surveys and inspections, waste management, contamination control, emergencies, protective clothing/equipment use.

4.1.7.2.4 Regulations, standards, guidelines and industry- standard radiation safety procedures

Note: Current (active) registration by the National Registry of Radiation Protection Technologists (NRRPT) may, at the discretion of the RSO, satisfy these requirements.

4.1.7.3 The responsibilities and authority of Radiation Surveyors may include the following:

4.1.7.3.1 Ascertain .compliance with rules and regulations, license conditions, and the guidelines approved and specified by the RSC;

4.1.7.3.2 Provide technical support for all aspects of radiation protection, including field operations;

4.1.7.3.3 Monitor and maintain equipment associated with the use, storage, and disposal of radioactive material and radiation-producing machines;

4.1 -7.3.4 Provide consultation on all aspects of radiation protection to personnel at all levels of responsibility;

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4.1.7.3.5 Administer and coordinate the distribution of internal and external personnel monitoring devices and supplies on an as-needed basis;

4.1.7.3.6 Maintain personneVarea monitoring records, notify personnel and management of exposures approaching maximum permissible limits, recommend appropriate corrective action, and evaluate exposures reported by contract dosimetry services;

4.1.7.3.7 Perform an investigation in cases of apparent overexposure to radiation or radioactive materials;

4.1.7.3.8 Coordinate or conduct training programs and instruction in the acceptable methods for the use of radioactive materials and radiation-producing machines;

4.1.7.3.9 Provide refresher training as appropriate (e.g., changes in procedures, equipment, regulation);

4.1.7.3.1 0 Monitor the storage of all radioactive materials;

4.1.7.3.1 1 Monitor the shipping and receiving of all radioactive materials;

4.1.7.3.1 2 Maintain a radioactive materials inventory to assure continued compliance with the possession limits specified in the USNRC license;

4.1.7.3.1 3 Coordinate and conduct emergency response activities;

4.1.7.3.14 Perform other monitoring/surveillance tasks as directed by the RSO.

4.2 Facilities and Equipment

4.2.1 Licensed radioactive materials shall be used/stored in the restricted areas listed in Appendix A.

4.2.2 Temporary use/storage areas at the Newfield facility or at off-site locations may be instituted by the RSO.

4.2.3 Laboratory facilities, remote handling equipment, storage containers, shielding, fume hoods, ventilation systems, barriers, access controls,

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administrative controls, and other items may be used for controlling exposures from licensed radioactive materials.

4.2.4 In restricted areas, all pertinent general industry regulations in 29 CFR 191 0, including those that pertain to chemical and fire safety, and all substantive requirements in 40 CFR 68 shall apply.

4.2.4.1 The amount of non-licensed raw materials used to initiate the aluminothermic process shall be minimized.

4.2.4.2 Hazardous materials storage locations and practices shall be subject to planned and periodic inspection by in-house safety personnel and by state/federal inspectors.

4.3 Training in Radiation Protection

4.3.1 All personnel permitted unescorted access to the controlled area shall receive training in radiation protection.

4.3.2 Training may consist of Visitor Training, Hazard Communication Training, General Employee Training (GET), Radiation Worker Training, and/or special briefings, as determined by the RSO.

4.3.3 Training programs shall address the pertinent requirements of 10 CFR 19, 29 CFR 191 0, and 40 CFR 68, as applicable and shall include, as a minimum, the topics shown in Appendix B.

4.4 Radiation Exposure Control

4.4.1 Radiation Dose Limits and Goals

4.4.1.1 Internal and external exposure limits for employees, visitors and contractors shall be equivalent to those established by the USNRC in 10 CFR 20.1 201.

4.4.1.2

4.4.1.3

4.4.1.4

Administrative exposure goals for monitored personnel shall be less than 2500 millirem TEDE.

The Senior Corporate Official shall ensure that sufficient trained personnel are available to perform each operation such that administrative exposure goals are not reached.

Persons under 18 years of age shall not be permitted access to radiologically-restricted areas at SMC facilities.

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4.4.1.5 Exposure limits for the unborn child shall not exceed those established by the USNRC for the entire gestation period.

4.4.1.5.1 Any employee, contractor or visitor that has the potential for occupational exposure shall be informed of the potential effects that may result to an embryo-fetus at low exposure levels.

4.4.1.5.2 Individuals shall be encouraged to notify the RSO regarding "declared" pregnancies.

4.4.1.5.3 An evaluation shall be performed by the RSO to determine the potential for an employee to exceed the regulatory exposure limit during the nine month gestation period.

4.4.1.5.4 If the potential exists or if an employee's request for transfer is approved, the employee shall be transferred to a different job assignment.

4.4.1.5.5 Declared pregnant females with the potential to exceed 50 millirem CEDE during a calendar year shall be monitored for internal and external exposure.

4.4.2 All employees with the potential to exceed 500 millirem deep dose equivalent (H,) within the calendar year shall be assigned a personnel dosimeter.

4.4.2.1 The personnel dosimetry program shall be accredited by the National Voluntary Laboratory Accreditation Program (NVLAP).

4.4.2.2 A formal investigation shall be performed by the RSO in the event that a personnel dosimeter shows an unexpected exposure or if a personnel dosimeter is lost.

4.4.2.3 A written report shall be submitted to the RSC within ten working days for review and approval of follow-up actions intended to prevent the exposure or loss from re- occurring.

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4.4.2.4 Dosimeter deployment durations shall be selected, in conjunction with 'dosimeter detection capabilities to ensure identification of doses above the applicable limits.

Note: In general, quarterly (every three months) exchanges are typical.

4.4.3 All employees with the potential to exceed 500 millirem CEDE or 5,000 millirem CDE from internal sources within the calendar year shall participate in a routine internal radiation monitoring program.

4.4.3.1 The routine internal radiation monitoring program shall consist of:

4.4.3.1.1 Personal air monitoring;

4.4.3.1.2 Indirect bioassay sampling at the beginning and end of employment and on a planned and periodic basis thereafter; or

4.4.3.1.3 A combination of air monitoring and bioassay.

4.4.3.2 Routine monitoring for intakes by inhalation by indirect bioassay shall be performed at the following frequency, depending upon the methodology used:

4.4.3.2.1 Once within 14 calendar days of the last work experience with licensed material or at least once per calendar quarter if urine bioassay is used.

4.4.3.2.2 Once every calendar year if fecal bioassay is used.

4.4.3.2.3 At any greater frequency deemed appropriate by the RSO.

4.4.3.3 Special bioassay monitoring may be performed whenever an administrative goal may have been exceeded, a nasal smear reveals the presence of detectable radioactivity, or whenever the RSO deems it appropriate.

4.4.3.4 Personal air monitoring, if used for internal dose assessment, shall include provision for the following:

4.4.3.4.1 Samples taken in a work location occupied by a worker should be drawn from a point or series of points within the breathing zone of that worker.

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4.4.3.4.2 The sampling location shall be selected so as to be as close to the breathing zone as is practical without interfering with the work or the worker.

4.4.3.4.3 The sampling methodology shall not fractionate by particle size or in other ways distort the physical and chemical properties of the airborne radioactive constituents.

4.4.3.4.4 Airborne radioactivity shall be collected with an air pump connected to a filter cartridge.

4.4.3.4.5 Filters may be submitted to an analytical laboratory or counted in-house for determination of gross alpha activity.

A 2 3 2 T h - t o - g r ~ ~ ~ alpha ratio of 0.076 and a 238U- to-gross alpha ratio of 0.061 shall be used to determine the isotopic activity from the gross alpha activity.

Note: The basis for this value can be found in SMC's response to Confirmatory Action Letter No. 1-95-004, March 14, 1995.

4.4.3.5 A formal investigation shall be performed by the RSO in the event that any monitoring result is unexpected.

4.4.3.6 A written report shall be submitted to the RSC within ten working days for review and approval of follow-up actions intended to prevent the exposure from re-occurring.

4.4.3.7 For dose assessment purposes, the Annual Limit on Intake (ALII for 232Th and 238U shall be 4x1 O3 pCi and 7x1 04 pCi, respectively.

Note: These values of ALI are based upon a measured particle size of two (2) micrometers (AMAD) in the workplace as described in SMC's response to Confirmatory Action Letter No. 1-95-004. May 14, 1995.

4.5 Control of Work

4.5.1 Routine working conditions at the Newfield facility or at off-site locations that may subject an individual to exposures that are less than 100 millirem TEDE per calendar year shall require no specific controls.

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4.5.2 Control of work at off-site locations or for work at the Newfield facility that may subject an individual to exposures equal to or greater than 100 millirem TEDE per calendar year shall be accomplished by:

4.5.2.1 Establishing radiological standards and responsibilities.

4.5.2.2 Using operations line management and the RSO to monitor performance of radiological work.

4.5.2.3 Training workers in recognition of radiation hazards and their responsibility to prevent their occurrence.

4.5.2.4 Providing personnel with Radiation Safety Procedures and/or RWPs that include the radiological protection measures and controls necessary for safe completion of the job.

4.5.3 Authorized Users shall not initiate work in areas that may subject members of the general population to exposures equal to or greater than 100 millirem per year TEDE.

4.5.4 An RWP shall be prepared for construction, demolition, maintenance, and repair activities, and all non-routine operations in restricted areas.

4.5.5 Temporary Restricted Areas

4.5.5.1 USNRC approval shall be obtained prior to instituting a temporary restricted area at any off-site location.

4.5.5.2 An RWP shall be prepared for work in all temporary restricted areas.

4.5.5.3 The RSO shall terminate (remove) the RWP and other restrictions from the area after:

4.5.5.3.1 Confirming that the work performed under the RWP is complete.

4.5.5.3.2 Confirming that all licensable radioactive materials and contaminated equipment/supplies have been removed.

4.5.5.3.3 Performing and documenting an ambient and contamination survey of equipment and surfaces that came in contact with the radioactive material to ensure they meet applicable criteria for release.

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4.6 ALARA Program

4.6.1 While occupational radiation exposures incurred by employees or visitors of SMC historically are low, all exposures shall be assumed to entail some risk to the employee.

I 4.6.2 Line management shall adopt the following three principles to govern all work activities with the potential for exposure to radiation or radioactive materials:

4.6.2.1 Activities and operations shall produce a positive net benefit.

4.6.2.2 All radiation exposures shall be kept as low as reasonable achievable (ALARA) in light of economic and societal costs.

4.6.2.3 Radiation exposures received by individuals shall not exceed the radiation dose limits described above.

4.6.3 ALARA activities shall include the following:

4.6.3.1 A corporate program shall be established that integrates management philosophy and regulatory requirements, with specific goals and objectives for implementation included.

4.6.3.2 The RSC shall establish applicable and appropriate radiological goals to direct all levels of management and workers at SMC toward improvement in radiological performance.

4.6.3.3 ALARA goals shall be reviewed and approved at each routine meeting of the RSC.

4.7 Contamination Control

4.7.1 Loose and fixed radioactive contamination shall be maintained at concentrations that are as low as reasonably achievable (ALARA).

4.7.2 Equipment, components or surfaces where loose contamination in excess of the following is detected shall be classified as contaminated:

4.7.2.1 1,000 dpm (alpha) per 100 cm2 for natural uranium

4.7.2.2 200 dpm (alpha) per 100 cm2 for natural thorium

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4.9.2 Non-routine surveys may be performed at the discretion of the RSO or any time there is reason to suspedt that radiation or contamination levels may have changed unexpectedly.

4.10 Posting

Postingnabeling requirements shall be as described in 10 CFR 20, Subpart J.

4.1 1 Receipt and Control of Radioactive Material

4.1 1.1 Incoming packages, known or suspected to contain radioactivity at levels significantly higher than background, shall be monitored for exposure rate and removable external contamination, pursuant to 10 CFR 20.1906.

4.1 1.2 Radioactive material shall be marked as such to ensure proper handling and storage.

Note: Markings may include tags or stickers indicating "Radioactive Materials".

4.1 1.3 Items identified as radioactive materials shall be maintained in a radioactive material storage area established for this purpose within a restricted area.

4.1 1.4 Radioactive material received by SMC shall be entered in a radioactive material inventory log.

4.1 1.4.1 The log shall be maintained to assure compliance with maximum possession limits established in the USNRC license.

4.1 1.4.2 The source material inventory shall be updated at least once per calendar quarter to reflect new acquisitions.

4.1 2 Packaging and Transportation of Radioactive Materials

4.12.1 Licensed radioactive material shipped from SMC shall be packaged, surveyed, labeled, and shipped in accordance with 10 CFR 71.

4.1 2.2 Prior to shipment of specifically-licensed materials, the RSO shall obtain confirmation that the receiver is licensed to receive the type, quantity and form of radioactive material present in the shipment.

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4.12.3 Material shipments to non-domestic (foreign) locations shall be in accordance with 10 CFR 110.

4.1 2.4 Radioactive material shipped by SMC shall be entered in a radioactive material inventory log.

4.1 2.4.1 The log shall be maintained to assure compliance with maximum possession limits established in the USNRC license .

4.12.4.2 The source material inventory shall be updated at least once per calendar quarter to reflect usage.

4.13 Control of Radioactive Waste

4.1 3.1 Control of radioactive waste materials shall be accomplished by the following:

4.13.1.1 Preventing materials from becoming unnecessarily and/or excessively contaminated;

4.13.1.2 Decontaminating and reusing radioactive materials such as tools and equipment;

4.1 3.1.3 Monitoring materials for radioactivity and removing non- radioactive materials prior to disposal; and

4.1 3.1.4 Using waste volume reduction techniques when practical.

4.1 3.2 Radioactive waste may be stored on site or disposed of by one of the following means:

4.1 3.2.1 Transfer to an authorized recipient as provided in 10 CFR 20.2001 ;

4.13.2.2 Release into the sanitary sewer in conformance with USNRC 10 CFR 20.2003; or

4.1 3.2.3 Any other means specifically approved in advance by the USNRC.

4.1 3.3 Manifests, Certificates of Disposal or other documentation to confirm transfer/disposal shall be maintained by the RSO.

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4.14 Radiation Protection Records

4.14.1 The RSO shall maintain records sufficient to document implementation of this Plan and to demonstrate compliance with applicable USNRC license requirements.

4.14.2 The following records shall be preserved and maintained until license termination, at which time the records shall be transferred to the USNRC:

4.14.2.1 Individual employee records and analyses performed using employee exposure records.

4.14.2.2 Records of dose to members of the general public.

4.1 4.2.3 Records of waste disposal.

4.1 5 Documentation

4.1 5.1 Radiation Safety Procedures (RSPs) shall be generated to guide the implementation of this Plan.

4.1 5.2 The preparation, distribution and use of RSPs shall be controlled.

4.1 5.3 All Radiation Safety Procedures shall be signed by the Senior Corporate Official, the RSO and the chair of the RSC prior to implementation.

4.15.4 Approval signatures shall signify the RSP is adequate for its intended use, that it meets the requirements of this Plan, and that all provisions of License No. SMB-743 are met.

4.1 5.5 RSPs shall be reviewed by the RSC for continued applicability, effectiveness and compliance with this Plan at least once per year.

4.1 6 Emergency Response and Notifications

4.16.1 For emergencies where radioactive materials may be involved, consideration shall be given to exposure to radioactive materials and ionizing radiation in addition to the other hazards present.

4.1 6.2 If it is known or suspected that an internal or external dose limit has been exceeded or that contamination levels are not as expected:

4.16.2.1 The RSO shall be notified immediately.

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4.16.2.2 The RSO shall evaluate the likelihood and magnitude of the exposure or' contamination status, and shall implement appropriate follow-up actions as soon as possible after notification.

4.1 6.3 The RSO and the Senior Corporate Official shall notify the USNRC of events as required in 10 CFR 20 Subpart M and 10 CFR 40.60.

4.17 Quality Assurance in Radiological Protection

4.17.1 All activities conducted as part of this Plan shall be subject to quality assurance and review as required in 10 CFR 20.1 101.

4.17.2 Radiation Safety Procedures shall be developed to implement this Plan.

4.1 7.3 Limited-scope audits/assessments of the radiation protection program should be conducted by the RSO (or designee) to determine compliance with applicable federaktate regulations, applicable license requirements, and this Plan.

4.1 7.4 The following programmatic elements shall be audited for compliance and continued applicability at a frequency of at least once per year:

4.1 7.4.1 Radiation safety training

4.1 7.4.2 Training of radiation protection personnel

4.1 7.4.3 Documentation and records

4.1 7.4.4 Exposure control

4.1 7.4.5 Instrumentation and surveillance

4.1 7.4.6 Control of work

4.1 7.4.7 Waste management/disposal

4.1 7.4.8 Contamination control

4.1 7.4.9 ALARA

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5 EXEMPTION PROVISIONS

5.1 Minor changes to this Plan shall be permitted pursuant to the written authorization of the RSO, the RSC and the Senior Corporate Official.

5.2 Other variances and exceptions to the requirements of this Plan shall be permitted pursuant to the written authorization of the RSO, the RSC and the Senior Corporate Official, and after approval by the USNRC.

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6 DOCUMENTATION

None

7 APPENDICES

7.1 Appendix A - Locations Where Licensed Materials are Used/Stored at the Newfield Facility.

7.2 Appendix B - Training Topics

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