Numerous safety issues are dealt with by the NTLF staff over the course of a year. 1. HTO emissions reductions have been achieved over the past seven years by a number of changes in Facility design, including the incorporation of tritium recycling and use of oil-less vacuum pumps. We have continued to closely monitor weekly releases and correlate them with experimental activities and any hardware problems. The contribution of various tritiation system components (e.g. the copper oxide tubes) to routine releases is still being investigated and evaluated. 2. One procedure not previously addressed from the point of view of waste control is sample processing after a tritiation reaction. Previously, during sample workup, the low volume, high activity solvent used for tritiation was co-mingled with larger volumes of much lower activity. We have separated these functions by inserting a liquid nitrogen cooled solvent trap filled with silica gel and placing it between the tritiation reaction vessel and the lyophilization trap. Thus, the high level tritiated solvent is rapidly adsorbed and sealed in this intermediate trap. Larger solvent volumes can then be trapped into the lyophilizer. Following this procedure, tritium release to the work boxes has become barely detectable during the draining of the lyophilizer. The treatment of the resultant mixed wastes is the subject of a separate sub-project. 3. Contamination control and personnel exposure have become very important priorities at LBNL. In addition to the routine floor swipes within the Facility, a program of sampling other sites in and around the NTLF has been undertaken. DOE reviews of personal dosimetry and contamination control procedures and performance are conducted at least annually. 4. Safety documents are under constant review. The actual form and overlap of various DOE and regulatory agency rules and orders is continually evolving and requires frequent changes in existing documents, as well as creation and documentation of new procedures. The formalization and documentation of training procedures for Users of tritium is a high priority at LBNL. 5. A Technical and Safety Advisory Committee was proposed for the NTLF in the most recent competitive renewal. As distinct from the Scientific Advisory Committee, this group focuses on keeping the NTLF staff current on all the safety issues, procedures and equipment they should understand and have for smooth operation of the Facility. We had the initial meeting of this group in April 1995, with further meetings in January 1996 and June 1997. 6. A member of the NTLF staff is a representative on the Physical Biosciences Division Safety Committee, and attends monthly meetings. This representative ensures the effective communication of safety requirements and information between the Division management and NTLF staff. This role has become very important with the much higher priority of chemical safety, and the need for increased awareness of waste disposal procedures and requirements. 7. A member of the NTLF staff is also a representative on the LBNL Radiation Safety Committee, and attends regular meetings. This group has been newly created to address all aspects of radiation exposure and oversee radiation use at LBNL, and to make recommendations to management regarding radiation safety practices and procedures. 8. A Chemical Inventory is maintained at LBNL, and is submitted to local Regulatory agencies on a yearly basis. The NTLF needs to maintain and report its own Chemical Inventory, for incorporation into the larger LBNL database. TITLE: NTLF Chemical, Radiation Safety and Emissions Reduction (Continued) 9. During 1995 the NTLF was chosen as a pilot for the DOE """"""""Necessary and Sufficient Standards"""""""" process. This involved the selection of only those standards deemed to add EH&S value to a given operation, and has allowed movement away from excessive and burdensome regulation. In the short term, this process required considerable work in implementation, with the promise of long-term gain in reduced EH&S oversight. After completion of the pilot in late September 1995, the NTLF was designated a DOE Radiological Facility, thus avoiding compliance with the DOE Nuclear Facility orders. Based on his experience with this Pilot, Williams was heavily involved in execution of the re-named Work Smart Standards process for the entire LBNL site in 1996. In the past year, Williams spearheaded a change to DOE-STD-1027-92, raising the Category 3 nuclear facility threshold to 16,000 Ci (from 1,000 Ci). 10. During 1996 a major new influence affected the amount of time the NTLF staff spends on EH&S issues. At the urging of a citizens group named the Committee to Minimize Toxic Waste (CMTW), the City of Berkeley passed a resolution demanding the closure of the NTLF due to the threat of tritium emissions from the facility. The NTLF release history and public impact has always been a matter of public record, through publication of the Berkeley Laboratory's annual Site Environmental Report. In 1995, the EPA-mandated dispersion model predicted that NTLF tritium emissions gave approximately 1.3% (0.13 mrem) of the Federally allowed radiation dose to an off-site individual, assuming 8,760 hours annual occupancy at that site (i.e. 24 hours per day, 365 days per year). Other activities of the CMTW and related groups have included initiation of letter-writing campaigns, newspaper and television articles, further representations to the City of Berkeley and the Berkeley Unified School District, and display of placards on the UC Berkeley campus, and at the Lawrence Hall of Science (LHS, a children's museum close to the NTLF). NTLF staff have been involved in Berkeley Laboratory presentations to the City council, the School District, the LHS staff and management, the UCB management, in numerous newspaper and some television interviews, and a host of other public relations activities. These activities continued through 1997, but at a slightly lower intensity. Berkeley Laboratory is pursuing several responses to these public relations issues: i. In 1994, Berkeley Laboratory initiated a """"""""Tritium Health Risk Assessment"""""""" to address many of the public questions regarding the health impacts of the NTLF operations. After an extended and torturous review path, the risk assessment document was released to the public in April 1997. Considerable debate and review is still taking place. ii. LBNL Director Shank has set aside $100,000 of Laboratory funds to support a third party monitoring study of the level of tritium emissions from
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