ML19249A480
| ML19249A480 | |
| Person / Time | |
|---|---|
| Site: | 07000984 |
| Issue date: | 07/02/1979 |
| From: | Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | |
| Shared Package | |
| ML19249A475 | List: |
| References | |
| PNL-MA-527, NUDOCS 7908230126 | |
| Download: ML19249A480 (41) | |
Text
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70 - %y P :L-MA-527 Revisicn 6 APPLICATION FCR RENE'.iAL CF SPECIAL NUCLEAR fiATERI.aLS LICENSE SNM-942 Compiled by the Staff of Battel'e, Pacific Northwest Labcratories sevised s,u.iy -, Iw,-e c-
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iii CCNTENTS i.0 CRITERIA AND ACMINISTRATI'/E PRCCEDURES..
1.1-1 1.1 General............
1.1-1 1.2 Request for Approval of Alternate 'dethods..
1.2-1 Occupational Exposure limits.............
1.2-2 Calendar Quarter........
1.2-4 Reports to Prior Employees.................
1.2-5 Reports of Exposure en Termination...
1.2-6 Exposure Records and Reports for Current Exposure Year..
1.2-6 Caution Signs, Labels and Signal s.............
1.2-7 Records of Licuid Waste Disposals..
1.2-9 Critical i ty Cetection System................
1.2-9 1.3 Minimum Technical Specifications and Capabilities.....
1.3-1 Organization and Personnel Ccmpetence.....
1.3-1 Procedures...........
1.3-5 Criticality Cetection System..
1.3-1G Radiation Emergencies.....
1.3-18 Facilities and Equipment.
1.3-19 Materials...
1.3-21 1.a Certi fi ca te..........
1.4-1 2.0 LICENSE APPLICATION CESCRI?TI'/E SUPPLEMENT (Preface to Part 2).......................
2-0 2.1 The Hanford Site.
2.1-1 2.2 Battelle-Ncrthwest Ocerating Contract 2.2-1 Otner Hanford Contractors.......
2.2-3
?:searcn and :evelecment Wort for Battelle's Cwn Account.
2.2 2 2.3 Facilities Contro'.lec By Battelle, ?acific Northwest Laccratories.
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iv CONTENTS (continued) 325 Building - Radiochemistry.
2.3-3 303 Suilding - Plutenium Fuels Laboratory..
2.3-6 306 -W Building..........
2.3-8 231-Z Building...................
2.3-11 Other Battelle-Northwest Controlled Facilities Where Licen-sed Work with Small Quantities of Material May be Performed 2.3-14 2.4 3atte11e-Northwest Organization......
2.4-1 Operations and Services Division...
2.4-2 Occupational and Environmental Safety Cepartment.
2.4-3 Energy Systems Department.
2.4-8 The Battelle-Northwest Safety Review Council.....
2.4-9 2.5 Radiation Protection Procedures..............
2.5-1 Occupativnal Exposure Limits and Records..........
2.5-1 External Exposure Control.................
2.5-8 Internal Exposure Control 2.5-8 Measurement of Radiation Exposure 2.5-9 Visitor Controls........
2.5-10 Control of Access to Radiation Sources....
2.5-11 Radiation Protection Instruments...........
2.5-11 Calibration of Radiation Protecti n Instruments...... 2.5-16 Radiation Monitoring Survey Program.......
2.5-17 Radiation Occurrence, Investigations and Reports......
2.5-20 Training......... -
2.5-20 2.5 Criticality Safety Procedures.....
2.5-1 F3cility Classifications..
2.5-1 The Safety Analysis Re; ort.
2.5-1 i U #Sfss)yy
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v CONTENTS (centinued)
Content and Format.
2.6-2 Revision of Safety Analysis Reports............
2.6-5 The Criticality Safety Specification.
2.6-6 Centent and Format.
2.6-6 Review.
2.6-6 Special Conditions and Temporary Deviations........
2.6-10 Cri ticali ty Sa fety Audits............
2.6-13 Audits by Nuclear Safety.
2.5-13 Internal Audits by the Ocerating Group.
2.6-15 Criticality Safety Acpraisals 2. 6 - 13 Training........
2.5-21 Training Progr m Outlines.................
2.5-22 2.7 Shipment Procedures....................
2.7-1 2.3 Waste Disposal.......................
2.3-1 Gasecus Waste Streams..................
2.3-1 Liquic Waste Systems....
2.3-1 Solid Waste...
2.3 4 Environmental Surveillance...............
2.3-4 2.9 Emergency Capacilities and Plans..............
2.9-1 APPENDIX A:
SIGGRAPHICAL SKETCHES.....
A.1 APPENDIX 3:
MANAGEMENT GUIDE SAFETY REVIEW COUNCIL..
3.1 APPENDIX C: MANAGEMENT GUICE RADIATICN PROTECTION.
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1.1-1 A?cLICATION FOR RENE'nAL OF SPECIAL NUCLEAR MATERIALS LICENSE SNM-942 (Revisien 6, July 2,1979 1.0 CRITER!A AND ACMINISTRATIVE PROCEDURES 1.1 GENER_AL This is an application to the Nuclear Regulatory Commission (NRC) for the renewal of Special Nuclear Materials License, SNM-942, covering the re-ceipt, possession and use of special nuclear raterial for broad researcn and development.
Acolicant Pacific Nortnwest Laboratories of Pacific Nortawest Division of Battelle Memorial Institute,* Battelle Boulevard, Richland, Washington, (hereinafter referred to as Battelle-Northwest or BNN).
President Or. Sherwood L. Fawcett 2320 Margate Road Columcus, Ohio 43221 Executive Vice President Dr. Ronald S. Paul 303 Lookout Point Drive WorthingtOn, Ohio 43085 Vice President - Financial Advisor Mr. Wallace Sale 1104 S. Irby Kennewick, Washi..gton 99336 Vice-President, General '.aunsel and Secretary Paul T. Santilli, Esq.
1519 Lafayette Drive g (,;;;3[,[)
Columtus, Ohio 43220 Vice-President. Treasurer and Ccroor2:e Jirector - Finance
'dr. Maurice G. Stark 5754 Satinwcod Crive C lamous, Onic 23221
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5 5 (ing Avenue, Colum:us, : hic inc:rcora:ec in :ne State,161'
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1.1-2 Vice-President and Corcorate Directcr - Government and International Socnsor Rela:1cns Mr. George 3. Jchnson 8504 Atwell Road Potomac, Maryland 2C854 Vice-President and Corcorate Director, Communications and Public Affairs Mr. Clyde R. Tipton, Jr.
2155 Cheshire Columbus, Ohio 23221 Vice-President and Corocrate Director, Human Resources Mr. Lawrence L. German 2245 0xford Columbus, Ohio 43221 Vice President and Corcorate Director, Multi-Comconent Ocerations Dr. T. W. Amorose 505 King Avenue Columbus, Ohio 43221 Di rector, P'fific Northwest Division and Pacific Northwest Laboratories Dr. Ecuglas E. Olesen 1002 W. 23nd Place Kennewick, WA 99336 All of the above officers are United States citizens. No control or ownership is exercised over tne applicant by any alien, foreign corporation, or foreign government.
Crganization of the License Acolication This total apolication is divided into Part I and Part II.
Part I contains the criteria and adminis*-ative precedures set up to assure the maintenance of high quality health und safety conditions for all Batteile-Northwest work performed under this special nuclear Taterials license. The criteria and administrative procedures in Part I may not be changed without prior apcroval from the Nuclear Regulatory Ccemission.
Cart !I prasents additicnal descriative material as evidence of the technical ccmpetence, management centrol procedures and chiloscphy at Battelle-Nortnwest.
This ccmcetence, control, and pnilascony assure acecuate nuclea-health anc safety perfcrmance in all of the Laccratories' aci*ivities.
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1.1-3 Location 'Jhere Licensed "aterial Will be used The primary work locaticn is the Battelle-Nortnwest controlled buildings and facilities located en or adjacent to the Department of Energy's Hanford Site at Ricnland, Washington. These facilities include those of the pacific Mcrthwest Laboratcry (PNL) operated for the Department of Energy (CCE) by Battelle-Northwest (SNW) and those privately owned by SNW. Additional temporary work locations include sponscr's laboratories and facilities except in Agreement States.
Battelle-Northwest nas entered into two contracts with DCE involving these facilities:
- 1) a Prime Operating Contract, EY-76-C-06-1830, to operate both the government owned and certain of the Battelle-Northwest-owned labcratory facilities in carrying out cosigned DCE researcn and development programs, and
- 2) : Use Permit Ccntract, EY-76-C-C6-1831, permitting the use of certain government-owned laboratory facilities in conducting contract research for industry, for government agencies, and for its own account.
Battelle-Northwest also conducts contract research for its own acccont in privately owned facili-ties in the BNW Richland Research Complex located immediately south of the Hanford 3C0 Area. This license is intended to cover the work conducted under the Use Permit Contract, EY-76-C-06-1831, plus any other work conducted by Battelle-Northwest (predominately in the above location) wnicn requires a special nuclear materials license.
A map and description of the Hanford Site and environs with plot plans shcwing the locations of Battelle-Northwest controlled buildings and facilities, are in Part II of +.his apolicaticn.
50ecial Nuclear. Materials to be 4ndled in Battelle-Northwest Centrolled Fac111:1es License coverage is sougnt for enricned uranium and all isotopes of plutonium. These T.aterials may be handled in any pnysical and cnemical form for all researcn and development purposes except for administration to humans.
The maximum quantity of licensed materials which will be in inventory under the control of 3attelle-Nortnwest at any time will be less than one effective kilogram, as defined in subcaragraph 70.a(t) of 10 CFR Part 70, of uranium 233, uranium 235 and plutonium except that the cuantity of plutonium shall be no greater tnar, 200 g.
Since tne maximum cuantity of licensed material is relatively sma!! ccm-
- ared witn acrTal inventories in use by Sattelle-Ncrthwest for
- CE Or grams uncer C; erat ng Contract EY-76-C-C6-1330, tne pctantial risks to tne neal:n and safe:j 3 :ns' e anc offsita :erscnnel will not ce signi#'cantly ir. creased
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1.1-4 Radioactive Materials to ce Handled Temocrarily in Socnsor's Faciiltles Excect in Acreement 5tates License coverage is also sought for the tempora y use of special nuclear material for res earch and development purposes in a sponsor's facility ex-cept in Agreemer t States. Temporary work under the terms of tnis license will in each cas 3 be limited to a quantity less than a minimum critical mass.
The use of the licensed materials in sponsor's facilities will be limit.d as necessary to assure a high degree of safety using engineered and admini trative safeguards which are entirely under control of Battelle-Northwest and therefore do not create a situation of dual resconsibility between Battelle-Northwest and sponsor personnel. Alternatively, wnere the sponsor is licensed by the NRC, it may be preferable in some cases to transfer the material entirely to the sponsor's control.
In either case, responsi-bility will be clearly delineated.
Examoles of Work to be Performed Under the License Battelle-Northwest will perform centract research and development activities for its own account and for many sponsors, both government and industrial, in practically all areas of the physical and life sciences ex-cect human medicine. Much of this contract research work will be nonnuclear in character.
However, it is proposed to include the laboratcry's broad and competent nuclear research capabilities in the scectrum of research services offered.
Research actitities may involve handling quantities approacning one effective kilogram of fissile materials in both noncetallic and metallic forms. Small amounts of special nuclear materials are used in supcort of research and development work related to the production and processing of nuclear fuels and fuel material.
In addition, special nuclear materials are used in a wide variety of non-fuel researcn and develooment programs, includ-ing the following areas:
Research in radicciology 2evelocment of imprevec means fec tne dosimetry of icnizing radiation Veasuring, minimizing, and controlling rac4: activity released to tne envi.enment s,y q r
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1.1.5 Reactor system deveio; ment, as well as reactor materials anc comoonent development Study of irradiation effects Development of improved activation analysis tecnnicues Reprocessing of irradiated fuels and neutron target materials for recovery of croducts and radionuclides Development of radioactive waste processing procedures.
No special nuclear materials will be produced under this license since it does not cover the acerr. tion of a nuclear reactor nor insertien of any licensed material into a nuclear reactor.
Financial Qualifications The net worth of the Battelle Memorial Institute (BMI) is accroximately 5155 million. The SMI annual business volume for 1973 exceeded 5291 million.
Previous License Numbers No license numbers crior to SNM-942 have been issued to Pacific Northwest LaboratoHes of the Pacific Northwest Divisicn of Sattelle Memorial Institute by the Nuclear Regulatory Conriission.
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1.2-1 1.2 RECUEST FOR AP ROVAL OF ALTERNATE METHCDS The major portier. of the work with radioactive materials per#0rmed by Battelle-Northwest is under tne Operating Centract EY-76-C-06-IS30 with 00E.
That scrtion of the work with radioactive materials cerformed by SNW under the license represents a small amcunt botn in dollars and in amount of radio-active material involved. The work under the Operating Contract is closely related to activities of other Hanford contractors, including Rockwell Inter-national's Rockwell Hanford Operations, tne Westinghouse Hanford C0maany, and the Hanford Environmental Healtn Foundation. Because of the close relationsnip among the Hanford contractors, both geograpnically and progranmatically, it is very im ortant that radiation protection standards be maintained aniformly among tne various Hanford contractors.
In order to achieve and maintain this uniformity the Richland Operaticns Office of COE nas istaed directives in the form of DOE-RL Manual Chacters and tne Hanford Services and Facilities Cata-109 The Hanford Services and Facilities Catalog requires that all Hanforc contractors utilize certain Hanford-wide services provided by a scecified con-tractor; f or ex mole:
All maintenance, recair and calibration of radiation survey instrumen-tation is performed for all contractors by Battelle-Northwest.
All bicassay samples and perscnnel dosimeters for emolayees of all Hanford contractors, and all sam les cotained for tne Hanford Environ-mental Surveillance Program are processed by cne contractor - U. S.
Testing Ccepany.
Cne Battelle-Nortnwest ccmocnent makes all in-vivo determinations. evalu-ates the results of all cersonnel exacsure measurements, ccmpiles tne data obtained using one common cata processing program, routinely recorts the results to the concerned contractors, maintains the excesure record files. and makes all necessary recorts, agail for all Hanford contractors to meet tne requirements estaclished by CCE-;L.
Another Battelle-Nortnwest ccmconent conducts the r,/ironmental Surveil-lance ?*: gram, oy scheduling, cbtaining (but not crocess nc), evaluating and recorting 09e results of samcles taken and measurements made tnroupn-Out tne han#:rc environs.
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1.2-2 All of these ;r: grams are established and performed to meet the specific requirements of CCE-RL. Notwitnstanding tne fact tnat Battelle-Northwest may conduct a specific plant-wide radiation protection service program, Battella-Northwest cannot unilaterally cnange t. Hat program without the concurrerict of all involved contractors and CCE-RL.
The Richland Operations Office issues supolements to certain DCE Manual Chapters to provide specific guicance for Hanford contractors in interpre-tation of the requirements of the basic COE Manual Chapters. These Manua' Chapters are transmitted to the contractors #or compliance; Sattelle-Northwest and the other Hanford contractors have litt.le latitude in the appiication of tne contained limits and methods.
Work performed by Battelle-Northwest that requires a Special Nuclear Materials license is carried out in the same facilities at the same time and by the same people as work performed for DOE under the Operating Contract.
It is neither technically or administratively feasible to apply two different exposure measurement and control programs simultaneously to tne same employees.
The exposure wnich an employee may receive from licensed materials cannot be distinguished from that which he may receive from materials usec under the Operating Contract.
Because One Battelle-Northwest Radiation Protection Program is designed to comply with requirements in CSE Manual Chapters, certain radiation p otec-tion standardt or practices differ frca those specified in Title 10 parts 20 and 70 of tne Code of Federal Regulations.
Those radiation protection sta,-
dards or practices that differ from particular paragraphs are describec hers.
Occucaricnal Excosure Limits The annual and long-term exposure limits applied by Battelle-Northwest for work under tne Operating Contract are based on those contained in CCE Manual Chapter 0524 The SNW exposure limits are as folicws:
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1.2-3 Calendar Annual Cuarter
'Whole Body., Head and Trunk, 5 rem 3 rem Gonads, Lens of Eye, Red 31 cod Marrcw, Active 31ccd Ferming Organs Unlimitedareasofthesikin 15 rem
. re-(except nands, forearms and feet)
Other organs, tissues, and crgan systems (except bone)
Bene, Hands, Forearms, Feet (a) 30 rem 10 rem (a) All reasonable effort shall be made to keep excesures to forear s and hands to the general limit for the skin.
00E requires the total desa to include dose received both from external sources and internally deposited radioactive materials.
The 10 CFR 20 cuarterly pemissible dose limits acoear to have been estab-lished as one-fourth of the desired annual ex osure in order to eliminate the need for separately stating the approcriate annual limit.
In contrast, the COE quartarly limits are presented to demonstrate tne decree of acnuni-formity of accumulation of expcsure tnrough the year which is cemissible as establisned by the Federal Radiation Ccuncil (FRC) and tne International Ccmmission of Radiolecical Protection (!CRP). Since Battelle-florthwest cersonnel carely exceed the quarterly limits scecified in 10 CFR 20, selacm is it necessary or tesirable to ex:ose ersonnel as nonuniformly as the 20E quarterly limits cemi t.
The few cases wnere such ex:csure has been necessary have been rela ed to wnole bcdy ex osure rather than exposure to the skin or extremity.
In tnose cases, the 3 rem /q COE limit is applied [sar.e as permitted by paragrach 20.101 (b)] excect that the ccr.bined annual whole body exposure from external and internal scurces is limited to 5 rem in tne year.
he Battelle-ficr:nwest auarterly exposure limits descri::ed a::ove are sucmitted as an alternate to the quarterly limits cci tained in caragracn 20.101,' a ).
The purpose in recuesting accroval cf tne cuarterly linits in CCE :danual Chapter 0524 as an alternate to the 10 :FR 20 cuarterly limits
- s to avoid cessiale confusion, misuncerstanding, ce cancern en tne ; art of
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l.2-4 Battelle-Northwest er other Hanford employees.
This could result from the enange itself or fecm the resulting inconsistency bet.veen contractors ratner tnan :ne need for additional exposure.
i Every new employee is recuired to conplete an ex:osure history quest onnaire to aid in the evaluation of internal dose and to assure that tne new empicyee does not exceed a cuarterly or annual limit as a result of his/her combined excosure for the year (both onsite are offsite exposure).
In the event that the new employee has been cccupationai,. excosed prior to employment at Battelle-Nortnwest, administrative controls will be imposed to restrict ex;osure for the remainder of the year until such time that the ;rior exposure record is obtained.
These controls include the assumption that he/she has received 1.25 rem for each quarter or fraction thereof in the current year crior to emoloyment with Battelle-Northwest. Additionally, if the accrued or issumed exposure exceeds any quarterly or annual limit, the emoloyee will not be permitted to receive additional exposure while working for Battelle-Northwest until his/her exposure is within the appropriate limits. Any scecial excesure controls deemed necessary because of either real or assumed exposure will be provided in writinc to the employee'! supervisor, to Radiation Monitoring and to the emolayee's exposure records file.
This excosure history satisfied all requirements #cr NRC Form a with the exception of Item 9 (insertion of calculated dose) and Item 13 (pemissible dose remaining).
Previcusly, exemptions were recuested for these two items; however, since annual excosure in excess of 5 rem is not cermitted, it is not believed necessary te maintain an NRC Forn 4 Pursuant to caragraoh 20.501. it is recuested that Battelle-Northwest be granted an exemption from tne numericai values contained in paragraph 20.101(a) and to subs'.itute the Battelle-Northwest cccuoational exposure limits described on cage 1.2-2.
Calendar Zuarter The calandar quarter used in the Hanford-wide p-cgram is not as defined in paragrach 20.3.
The ex:csure year at Hanf:rd consists of four quarters ending en the last Friday of March, Ane, Sectember and Decemcer.
lo cuar er is lecs tnan '2 4ee<s nor acre than la weeks in length in accord with a particn of th(
defi ition presented in caragracn 20.3.
Mcwever, tne remaining days in Decemci,
n if any, :e::mc 1 cart of tne new ex:csure jear.
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1.2-5 A change of tne calendar quarter to meet one of the definitions presented in paragraon 20.3 would impact heavily across tne plant.
The DOE-RL centract with U.S. Testing Company scecified that dosimeter change shall be on the last Fricay of each month and that the calendar year will end on the last ~riday of Cecember. The U.S. Testing Comcany dosimeter prccessing schedules and the exposure records data processing program schedules are based on this definition.
The last Friday of each month was chosen since Friday is the only day of the week that all Hanford contractor employees other than firemen are at work, regard'ess of shift schedule.
Ptrsuantto paragrach 20.501, it is recuested that the calendar cuarter as cefined above be accepted in lieu of the definition of calendar quarter con-tained in paragrapn 20.3(a)(4).
Reccets to Prior Emoloyees Exposure reports are provided to pricr employees as required by DCE Manual Chapter 0525 and paragrapn 20.101(a), witnin 30 days of the request.
These reports include the accumulated exposures to beta particles, pnotons, and neutrons for tne er, tire period of emoloyment togetner with information regarding depositicn of radioactive material, if appropriate. The recorts also include a summary by calendar quarters of the whole bcay skin, wnole bcdy penetrating, and extremity exposures for tne current calendar year. Since ex-posures by calencar quarter are not maintained in the data crocessing file, and in some cases tne emoloyee's exposure may span a ceriod in excess of 30 years at the clant, the normal procedure dces not include the reconstruction of data to crevide exposures by cuarters or lesser ceriods as required by paragrach 20 201(a), other than for the current year.
Acditionally, if the emoloyee is en a cuarterly dosimeter exchange frecuency, it is ;nysically impossible to provide ex;osures for the current year by lesser ceriods than cuarterly. On an individual case, if there is a necessity to recort these cata cn a quarterly frequency, it would be ::ossible to do this for the e ttire emoicyment pericd.
This would be accomolished by obtaining data wnicr is cur-rently maintained on microfilm for each employee.
?ursuant to paragrach 20.501, it is recuestec :nat the recuirements for rovi::ing ex::osure by caleccar quarter for Otner tnan tqe currer.: ca!srcar year ard for lesser Ceriocs than ;uarterly as recuired in :aragra::h 20.lCi,3}
be na'ved.
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1.2-6 Recorts of Excosure on Termination COE Manual Chapter 0525 requires the reporting of exposure for termina-ted employees to the System Safety Development Center ($!CC) in Idaho Falls, Idaho within 30 days after the terminated employee's exposure has been de-termined or within 30 days after the individual's termination date, wnicnever is later. A copy is also provided to the employee uoan request. This report contains the same information which is to be submitted to the Director of Management and Program Analysis, USNRC, as required in paragrach 20.408. The past organization of the Federal Agencies desling with nuclear energy pre-sented tne situation in wnich two identical reports could nave been sent to the same agency by two different routes which could possibly result in an apparent doubling of an employee's exposure to radiation. This situation was alleviated with an exemption in license SNM-942. Although Federal Agency re-organizaticn has occurred, the possibility still remains that the compilation of the same exposure records by two separate records centers for whatever purposes presents the possibility of doubling an employee's apparent exposure.
Pursant to raragraph 20.501, it is requested the rtquirements of 00E Manual Chaptar 0525 be deemed to satisy the parallel of r scuirements of paragrapn 20.408 and that the requirements of paragraph 20.408 continue to be naivea.
Excosure Records and Recorts for Current Excosure Year All Hanford contractor employee's exposure records are ccmpiled using automatic data processing methods.
Eacn month, recorts reflecting any action in tne employee's exposure data file are reported in the form of computer printout reports.
For employees who are monitored ;ersuant to paragraon 20.202 or CCE Manual Chapters, a summary report provides tna dose for the current period, calendar year to date, and extrapolated dose to the end of the year, and is issued at least quarterly to management and R7.diation Mcnitoring.
The thermoluminescent F?Jltipurpose dosimeter u?es Li? chips to measure beta, pnoton and neutron radiaticn. The dosimeter is constructed to provide a measure of the skin cose and a one centimeter tissue oeotn dose to the wnoie body. Cuality factors of 10 and 3 are used to determine cose ecuivalents to Dccy organs for fast and thermal neutrons, resoectively.
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1.2-7 For ecoloyees wnc are provided extremity dosimeters, anctner data process-ing report is also proviced en a =cnthly frequency.
The sum of ne employee's accumulated derma dose plus any special measurements mace for the extremity is.cnsidered tr e emcloyee's extremity exposure.
Annual summations are provided for each employee's exposure recced file, and in tne form of an annual exposure report card to the encloyee.
The exposure records and recorts for the current exposure year include all of the information required on Form NRC 5 with the exception of Item 13 (running total for calendar quarter) and Item 18 [ additional exposure alicwable under 5(N-18) rems] as required in paragraph 20.201.
The varicus data on tne acnthly exoosure reports have permitted management to effectively maintain BNW employees' exposure belcw 3 rem per cuarter.
The addition of the cuarterly total to these reports would not change the exposure control program but would increase the cost of the Hanford plant exco:ure records program since any cnange would neces:arily affect the entire plaat. No accounting is made of the amount of exposure remaini69 within the formula since an employee's annual excosure is limited to 5 rem.
Pursuant to paragraph 20.501, it is requested that exemotien to :ne require-ments of paragraph 20.401(a) be granted to the extent tha-Items 13 and 13 of Form NRC 5 need not be completed.
Caution Sicns. Labels and Sicnals The methods used by Battelle-Northwest in identifying those locations where radiation protection contrais are required, differ in detail from tncse s;ecified in paragrapn 20.203. All locations where significant radiation ex osure can be rece.'ved, wnether externally or internally, are posted uitn signs cearing the standard radiation symcol cgether with the nords " Radiation Zone".
Radiation Zones are established to limit casual (ncn-Radiation Zone) exposure to less tnan one-tenth of the occupational radiation exacsure limits.
All areas which would be required to be posted by paragrapn 20.203 (as a radiation arr '
- 1h radiation area, airborne radioactivity area or radicactive material area) are i"cluded within the Battelle-Northwest requirement for
- osting as a Radiation Zone. Ali significant cuantities of radioactive mate-rials or radiaticc generating machines are s
- Ored and used in :aciati:n : nes in can':rmance ait: established Radia-icn Protecticn Procecure.
The alacement ci signs der.cting Radiaticn ::nes is sucn tha: 3: leas :ne sign is.isi:le ' rem any avenue of accreacn.
These signs ncr al;y ma<e no QWb0 r ~.-,-
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1.2-8 reference to either the nature of existing radiation conditions cr the radia-tion protection measures required witnin the Radiation 20... Such information is contained on the Radiation Work Procedure which applies to that specific work location and to the personnel authorized to enter the area.
Tight control is exercised over all visitors by means of local building security for build-ings cutside of the exclusion area and by security patrol for buildings or areas witnin the Hanford site exclusion area.
Visitors are not permitted to enter any Radiation Zone unless escorted by an emoloyee thoroughly familiar with the radiological status and radiation protection requirements.
Radiation Work Procedures detail the requirements for protective clothing, eersonnel monitoring devices, surveillance of werk oy Radiation Monitoring, the lacking out of process equipment, and other such requirements which can best be defined by the local groups actually performing the work. Although ncrmally prepared for use over an extended period, occasionally a Radiation W]rk Procedure will authorize work for only a short period.
Radiation Work Frocedures require approvals of operating management, building management ind Radiation Monitoring supervision.
The radiation protection requirements on the Radiation Work Procedures are established by Radiation Monitoring based on either the exposure potential associated with the work planned or on the radiological status of the area as determined from frequent area surveys of locations accessible to personnel.
Results of all such measurements are preserved in the radiation orotecticn records.
This practice of 1) uniformly posting all areas where significant ex;osure may be received as " Radiation Zcnes" and 2) specifying the existent radiological ccnditicns anc radiation protection requirerents on the Radiation dark Procedure required to be prepared for every Radiation Zone has been used for many years within the laboratories and is consistent with the precedures of other hanford contractors.
The COE facilities operated by Battelle-Northwest are designed in accer-dance with Radiological Design Criteria (currently documented as 3Nbt-MA-3) wnich have been in effect for a number of years.
These criceria include a recuirement to provide locks or interlocks for areas wnere dose rates in excess of 1 rem /hr or air:crne concentrations in excess of ICCC MPCs may be enccuntered.
Since T.ucn of :Pe work for :CE involves kilecurie or megacurie ;uantities of fission products, transuranium elements, etc., it is not practical to orevide Y'
<:envyry W (JN Pe ( As
1.2-9 pnysical access controis below these levels. As described earlier, all acek in Radiation Zone., including areas where hign dose rates or airocrne concentra-tions may be e. Mtered, is centrolled by RWP provisions.
Nrsuant to paragraph 20.501, it is requested that the requirements in paragraphs 20.203(b) (use of the words
" Caution Radiation Area"), 20.203(c)(1)
(use of the words
" Caution High Radicactive Area"), 20.203(d) (use of the words
" Caution Airbcrne Radioactivity Area"), and 20.203(e) (use of the words
" Caution Radioactive Material") be waived in lieu of the use of the standard Hanford Radiation Zone sign described above together with the assc-ciated Radiation '.tcrk Procedure. All areas that would be required to be posted by paragraph 20.203 will be included witnin areas posted as Radiation Zones.
Additionally, it is requested that the leve' of I rem /hr be accepted as the dose rate at which physical safeguards including locks or interlocks shall be recuired rather than the levels specified in paragraon 20.203(c)(2).
Oecords of Liouid Waste Discosals Most of the buildings in the 300 area where Battelle-Northwest performs work under the license are connected to liquid radioactive waste systems operated by the Hanford Engineering Develcpment Laboratory (HEDL) contractor.
It is not possible to distinguish liquid wastes generated in licensed activities fecm those wa::es generated in DOE contract activities, anu in some cases, it is not possible tc identify the contributions to the system from a given building or tncss arisi1g from the activities of a given contractor. Measurements ara made anu ractrcs ara kept by tne r.CL contractor of :ne total radioactivity disposed to these systems.
Pursuant to paragraon 20.501 it is requested that an exemotion be granted relative to the recuirement in paragrapn 20.401(b) for maintaining records of discosal of licensed materials to the 300 area Licuid Waste systems.
Criticality Cetection System Paragraph 70.2a(a)(1) of 10 CFR 70 recuires that a criticality detector system be maintained "...in each area in anich special nuclear material subject to such license is handled, used or stored"...
In tncse buildings where EW
.vark; wita suostantial cuantities of fissile materials (e.g., 306-W, 325, 3C3; and the fissile material storage building (303-C), criticality ce:e::;e systems are provided.
Those :uil:ings where lesser cuantitias rf fissile mataria!s are used are established as 'sclated facilities as describec :i 3LL vA-25,
. u mo r( Okfs a O
1.2-10
" Criticality Safety Procedures", Procecure 1, part III.B. An isolated facility is any facility where the inventory of fissila matrial is limited to less than 455 of a minimum critical mass (MCM). An exception to tnis definition of an isolated facility has been made, with the concurrence of DOE-RL Manual Chapter 0530, for the Calibration Facility (3745 Building). Although the combined fissile inventory in the 3745 Building isolated facility exceeds a MCM, the bulk of the material is in the form of encapsulated calibration sources having a combined mass that is less than 10". of the critical mass of the material in that form.
Non-encapsulated fissil e material within the facility is limited to a total of 15 grams.
Buildings currently establisned as isolated facilities in wnich work with licensed materials may be perfor ed include the 3720, 3708, and L fe Sciences Laboratory I (LSL I) buildings in the 300 Area of the Han-ford Site. Criticality detection systems are not provided in these buildings.
Typical current uses of fissile materials in these buildings are performance of various chemical and physical analyses and measurements en samples or speci-mns and studies of the deposition, uptake or biological effects of thase materials on animals and plants.
Pursuant to paragraph 70.14 it is requested that conditions of inst.lling criticality detection systems only in facilities containing more than 45'; of a minimum critical mass be accepted as an alternate to the criteria described in paragraph 70.24(a).
70757t
1.3-1 1.3 MINIMUM TECHNICAL SPECIFICATICNS AND CAPABILITIES Crganization and Personnel Cercetence Crganizaticn (1) Battelle-Northwest will maintain a unique department responsible for tne establishment and conduct of all radiaticn protection and nuclear safety programs.
This department will be separate from the operating departments of 3attelle-Northwest. This department for radiation protection and nuclear safety will serve as tne Battelle-Nortnwest Official contact with the Nuclear Regulatory Commission for all matters concerning radiation protection, nuclear safety and criticality safety as they pertain to nis license renewal applicaticn.
Specific respcnsibilities of the cepartment will include:
Establishing the policies, standards and limits to be apolied throughcut Battelle Northwest in Nuclear Safety, Radiation Protecticn and Criticality Safety.
Providing review and acproval cn the design, modification or develop-ment of facilities, equipment, and methods to be used in all work.
Included in these approvals are Project Proposals, Facility Design Criteria, Facility Mcdification Permits, Safety Analysis Reports, Safety Assessment Dccuments, Raciation Work Procedures and Criticality Safety Specifications.
Performing inspecticns, audits, and reviens of facilities and pro-cedures and initiating changes necessary to assure a high level of personnel radiation protection and compliance with all Battelle-Northwest and State and Federal requirements.
Evaluating, recording, and reporting radiatica ex::csure received by personnel witnin Battelle-Nortnwest controlled facilities and :y all Battelle-Northwest employees.
Measuring and recording radiological conditicns in all work locaticns where scurces of radiaticn are present and prescribing the protection methods to be employed in performing the work.
Conducting a surveillance program to cefine the geographical and biologia! districution of radicactive materials in the plant envi-rcns, cetermining tne status of tne piant envirens with respect to applica::le limits anc guices, anc estaclisning apcropriate ;uices for
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1.3-2 the controlled release of radioactive materials from Battelle-Northwest controlled facilities.
Establishing procedures and maintaining records of the snipment of radioactive mate"ials from Battelle-Northwest to other locations either en or off the Hanford Site.
Performing nuclear safety analyses for reactors, critical facilities, and laboratcries containing fissile materials or large inventories of radienuclides.
Planning and coordinating programs designed to cope with serious accidents within Battelle-Northwest facilities.
Participating in formal investigations or radiological incidents involving Battelle-Northwest personnel or Battelle-Northwest controlled facilities.
Maintaining records and providing necessary reports to meet all Battelle-Northwest as well as State and Federal requirements in the areas described aoove.
(2) Battelle-Northwest will maintain a unicue department responsible for security and safeguards for nuclear materials. This department will be separate from the operating departments of Battelle-Northwest.
This department will serve as the Battelle Northwest official contact for all matters concerning security, safeguards and management of special nuclear materials as they pertain to,this license renewal application.
Resconsibilities of the department will include:
Estaclishing the policies, standards and limits for security and nuclear material safeguards to be applied througnout Battelle-Northwest.
Maintaining a system of centrol and management of nuclear materials which will optimize procurement cost, use and recovery.
Providing tne custodial care and special procedures to prevent diversion or urauthorized use.
Providing audits to assure ccmpliance with aporopriate security and safeguard procedures.
Establishing and maintaining an inventory, material transfer and forecast system for special nuclear materials.
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1.3-3 (3) Battelle-Northwest will maintain a Safety Review Council as established in Management Guide 12.7 of the Battelle, Pacific Northwest Divisicn Management Guide to review program designs and safety analyses where the direct or indirect consequences of a credible accident are deemed to be of substantial magnitude. Matters may be submitted to the Safety Review Council for consideraticn by any Department Manager, nigner authority, or a memcer of the Safety Review Council.
The Safety Review Council or ceuocil chairman can determine whetner a formal review is required in each case. Copies of the prepared procedure and analysis are provided to all members of the Council for review and comment. A formal review by the Council as a group is held if requested oy any memcer.
The Ccuncil has access to all information and facilities required in ne discharge of its responsibilities.
Review by tnis Council provides the Battelle-Northwest safety system with an additional authoritative step which is intended to assure that necessary engineering and administrative capabilities are incorporated to minimize the likelihocd and consequences of a serious accident.
Results of reviews performed by the Council are reported to tne Director, Battelle-Northwest.
Examples of imcortant matters to be considered for review by the Safety Review Council include:
Nuclear safety criteria for the cesign and operaticn of facilities and equipment.
Procosals for conducting safety analyses or researcn prcgrams involving significant risks for sponscrs.
Safety Analysis Reports or Operating Safety Analysis Reports.
Plans for implementing operating safety limits, audit anc inspection orograms, and operator training programs.
Departmental plans for response and recovery from major accidents in facilities requiring safety analysis reports.
Prcposed :hanges in the Tode of oceration of facilities modification that increase either the prceability or ccnsecuences of a significant accident.
Evaluaticns of potentially signi#icant safety interactions within Bat elle faci',ities or with otner Hanfcrd centractors.
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1.3-4 proposed nuclear safety policies and programs and other selected policies and programs of the pacific Northwest Laboratories.
Any activity not covered abcve tnat could have substantial safety imolications.
Members of the Council are selected by the Director of Battelle-Northwest from persens recogn1 zed as authorities in specific fields such as atmospheric dispersicn, biological effects of radiaticn, chemistry, containment, critical mass physics, fluid flow, heat transfer, legal liabilities, metallurgy, pressure vessels, reactor physics, operation and engineering, risk evaluation, and industrial safety. The Council may be supplemented by other resources or specialists within Battelle.
Cualificaticns and Resocnsibilities (1) The manager of the organi:ation responsible for administering the radiation,,rotecticn and nuclear safety program will be a college graduate (preferably also a Certified Health physicist) with recogni:ed substantial experience in the field of raciation protecticn and nuclear safety. A minimun of seven years experience, including at least tnree years in tne general area of nuclear safety and/or health physics, will be required for this position. This organization will be staffed with at least five people collectively experi aced in nuclear safety and radiation protection.
(2) The manager of the organi:ation responsible for approving Criticality Safety Specificitions for technical adequacy and for performing technical reviews of Battelle-Northwest fccilities and operaticns from a criticality safety standpoint will be a college graduate with a minimum of seven years exoerience, including at least five years in critict.lity scfety work.
(3) The Senior Engineer, Nuclear Safety, wno is respcnsible for directing independent audits will have at least five years of technical experience with at least three years in criticality safety work.
(4) The Safety Review Council will be appointed by the Director of Battelle-Nortnwest. Members of this group will be selected frcm persons recognized as authorities in specific fielcs related to safety.
(5) The T.anager of each Battelle-Nortnwest Orogram will be technically trained in the field of endeaver (or an associated #ield of endeavor? whicn is One basis Of One nork to te perfor*"ed.
He/sne will have experience recuired to Ooer3te in accordance with 3attelle-1crtnwest pol'cy and One ;;ntractual
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1.3-5 obligations es ablished by DOE-Rt that may affect the program.
He/she will be responsible for coerating safety and insuring that personnel follow established rules.
(6) A Criticality Safety Recresentative is a;: pointed for each facility by operations management. The representative is respcnsible for auditing, approving Criticality Safety Specifications and providing liascn with Nuclear Safety.
(7) The manager of the organization responsible for security and safeguards will be an individual with substantial experience in the field of security, safeguards and/or nuclear material management. This crganization will be stW:d with a number of people sufficient to fulfill tne organization's. responsibilities.
Procedures Radiation Protection Formal administrative procedures for radiation protecticn are maintained by Battelle-Northwest.
Periodic reviews are made of these procedures by trained health physicists to assure their Mequacy. These procedures are changed only with the approval of the manager, radiation protection department, or cualified higher authority. Radiation Protection Procedures and specific Radiation Work Procedures are reviewed pericdically with employees and are kept readily available to them.
Ccmprehensive dosimeter, monitoring, survey, bicassay, and whole body counting programs are maintained by Battelle-Northwest.
The evaluating, re-cording, and reporting of radiation exposure, as determined by these ::r: grams for all Battelle-Nerthwest employees and visitors, me' hign professicnal standards and will continue to ref!
- he contractual recuirements. Any changes in the programs or the exp, are evaluation and recording precedures will require the review and approval of the manager respor.sible for radiaticn protection.
A hign cuality envirencental surveillance program is maintained for ClE-RL to permit a continuing evaluation of the status of the envircns with reso:ct to acclicable limits and the 'mpact of environmental ::ntaminaticn On the surr%nding CCulaticn.
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1.3-6 Radiaticn protecticn traini: g is a continuing program under Battelle-Northwest. The for al training programs range frca tncse for the professional in radiaticn protection to pragrams for indivicuals.vhose knowledge of radiation 1s incidental to their work. An initial general radiation protection orientation is presented to new employees o/ Sattelle-Northwest. This program is supplemented throughout the service of the employee to assure sufficient knowledge of radi-ation protection practices and procedurcs and changes in these practices and procedures. Specific training is presented to radiation monitoring personnel, and others who require special skills ir. the conduct of safe work. This program of aining will be continued at a level to assure that radiation protection recuirements are met and that the work with radiation or radicactive materials is conducted safely.
Criticality Safety For work that involves fissionable materials, Battelle-Northwest follows the Two-Contingency Policy. A sufficient numcer of limits and controls are exercised to assure that before a criticality accident is possible, at least
- wo unlikely, ;ndependent and concurrent errors or accidents must occur in one er more of the conditions specified as essential to nuclear safety. To implement this Two-Contingency Policy, formal procedures for the control of fissicnable materials are maintained.
The principal procedure for centrol of fissionable materials is the Criti-cality Safety Specification (CSS). Criticality Safety Specifications are written pr cedures wnich give limits that, when followed, will ensure criticality saiety in facilities processing, storing, or otherwise nandling significant quantities of fissionable material. Any work involving more than 45% of tne minimum critical mass of fissionaole materials is conducted in a nuclear facility under an approved Criticality Safety Specification. An approved Criticality Safety Specification is required for any work involving fissionable materials, with the folicwing exceptions:
Natural and depleted uranium, and thorium.
Work in a facility wnere only exempt quantities, less tnan about 35 of tne minimum critical mass assuming spher' cal geometry and cotimum water reflection and mcderation, are present.
Wort in an isolated facility unere the amcunt of #issiccaole material aces not exceed one of :ne limits in Ta le 1.3-1 cr Table 1.3-2.
- f more than One type of centrolled materials are invcivec ', an isclated
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1.3-7 TABLE 1.3-1 Weight Percent Allowable Weignt 235 235 U
kg U g
g 1.0 900 9000 1.5 168.3 2532 1.7 121.4 2065 2.0 31.1 1622 2.5 49.1 1228 a.0 35.1 1053 3.5 27.9 977 4.0 22.0 880 1.5 18.3 823 5.0 15.6 733 3.0 7.9 632 10.0 5.85 585 20.0 2.28 496 25.0 1.38 472 30.0 1.5 450 10.0 1.07 429 50.0 0.826 413 75.0 0.501 376 93.0 0.396 369 96.0 0.384 369 97.0 0.380 369 100.0 0.369 369 TABLE 1.3-2 Isotoce Linit No-237 13,900 g Am-241 32,100 g Cm-244 6,345 g Pu (Fuel)
- Less than 50% Pu-238 230 g (total Pu)
- More tnan 50", Pu-233 1957 g (totai Pu)
Uranium (any enrichment)
(see Tacle 1.3-1)
U-233 256 g Cm-243 67 g Cm-247 67 g 4m-242 9g Cm-245 9g Cf-229 9g
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1.3-8 facility, the sum of the fractions of the allcwed masses snall not exceed cne. Also, fissionable material in the form of encapsulated sources con:aining more than Table 1.3-1 or Table 1.3-2 values may be handled under isolation control upon written agreemen: with DOE-RL.
An isolated facility is defined as one which may contain more than 35 but less than 45% of the minimum critical mass, assuming spherical geometry and optimum water reflecticn and mcderation.
Fiss'onable material in the form of encapsulated sources containing more than 45% of a minimum critical mass may be handled under isolation control upon agreement between Battelle-Northwest and DOE-RL. An isolated facility shall be physcially separated by at least 6 feet from any other work involving fissionable materials.
Each isolated facility is established by mutual agreement between the nuclear safety group and the responsible manager of the operating component.
The mandatory criticality safety limits are identified through a technical analysis of the specified work involving fissicnable material. The analysis will be made by a competent criticality safety specialiat and will be documented by issuance of a Basis Letter. These technical bases will be reviewed and approved by the Senior Specialist, Criticality Safety. The Basis Letters will be main-tained in a permanent file by tne nuclear safety group.
Facility Criticality Safety Rrepresentatives or their apcointed delegates will be responsiole for obtaining new or revised Criticality Safety Specifications.
Assistance of tne Senior Specialist, Criticality Safety is available to provide techr.ical bases for establishing criticality safety limits. The nuclear safety group will provide assistance in preparing and distributing tne Criticality Safety Specifications.
Each Crit';ality Safety Specification snail be acproved cr ccncurred to by the following or their authorized representatives:
Criticality Safety Specialist Senior Specialist, Criticality Safety Senior Engineer, Nuclear Safety Technical Leader, Nuclear Safety Building Manager of the building in which tne CSS uill be used Cnticality Safety Reoresentative of the builcing Manager of the Operating Ccmpcnent in the affected facility.
Aporoval by the res:cnsible manager for atly estaclishes the sceci#ication as a written instruction to all remcers of :ne organi:a-ion. Accreval :y tne manager af the nuclear safety grcup sncws na re speci#icaticn is ccnsistent
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1.3-9 with DCE and Battelle-Northwest policies and regulations and witn gcod safety practices. The signature of the Senior Specialist, Criticality Safety, estao-lishes that the technical bases for the specification are correct.
The steps to be follcwed in obtaining a CSS are cutiined in Table 1.3-3.
In establishing Criciality Safety Specifications, fissionable ma,erial is defined as material which will support a neutron chain reaction with fast 239Pu, 221 Pu, "*3, 23 U, 42Am, a3Cm, '
Cm.
9' 9
?
'O and/or thermal neutrons. This means U
947Cm, 249Cf, and 51Cf, in any form (metal, alloy, solution or compouno).
7
"" Pu, 740 241
?'8 Pu, 242Pu, 237Np, 244Cm and Am are fissionable for these nuclides are expected to support a chain reaction, but only eith fast neutrons.
Criticality is not possible with these nuc! ides in aqueous soluticn. Any other fissionable transuranium nuclides will be considered that may be sce-cifically identified in the future. Natural uranium, althougn fissionable, is excluded due to its large minimum critical mass.
Before a building can ce designated as a nuclear facility in which greater than J5% of a minimum critical mass of fissionable material may be handled, a Safety Analysis Report (SAR) is required. Also, any significant modification or additional work not previcusly covered in an SAR recuires a safety analysis in a supplemental SAR. A Safety Analysis Report is the result of a thorough study and analysis that is performed to assure that potential major nuclear hazards have been incorporated to reduce the probabil-ity of major accidents and to minimice the consecuences in the unlikely event of their occurrence. The safety analysis considers foreseeable nuclear accidents that wculd substantially threaten 1) the safety of perscnnel or the puclic, 2) the use of or damage to prcperty and 3) the centinuity of operation of facilities.
Eacn SAR, anc each revisien, requires ne approval of the responsible Department Manager and the Safety Review Cauncil.
Adciticnally, review bj the Richland Cperations Office of DCE is required by Manual Chapter C530 if the facility is allowed to contain more than one minimum critical mass of fissionacle materials.
Safety Factors and Assumctions. Criticality safety limits used in establishing Criticality Safety Scecifications will be based on data from experimental Teasurements or, if direct experimental data are not available, en limits obtained from a calculaticnal method that can be shcwn to be accurate er ccnservative wnen compared to excerimentai measurements.
Safe limits will be obtained by recucing the critical value of a safe margin ccmmensura:e uita nta-colaticns and extracolations c measurements and cal cu l at' an s.
~~e ax::um #ractions nat incecencently satisfy ne two c ou &>>
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1.3-10 l
l CRITICALITY SAFETY SPECIFICATIONS I
f l
TABLE 1.3-3 l
l Steos Ocerating Organization Criticalitv Safety I Nuclear Safety I
Determines that a new or revised CSS is needed.
1 Inform Nuclear Safety of need.
Submits request for a Basis Letter to Criticality Safety.
Reviews operation, eval-uates criticality poten-tial cnd contingencies.
2 Prepares technical basis in form of a Basis Letter to Operating Organization with copy to Nuclear Safety.
Prepares CSS on standard Places Basis Letter master forms.
in "Sasis Letter File kept by Nuclear l
3 Safety. Assists in preparation of CSS as recuested by origin-l l
ator.
Reviews and approves CSS.
Signatures: Senior 3
i Specialist, Criticality Safety.
l Reviews and aporoves CSS.
5 Signatures:
Sr. Eng.
and Technical Leader, Nuclear Safety.
l l
l l
Reviews and acproves i
I j
l CSS.
Signatures:
Bldg.
l 5 i Manager; Criticality I
Safety Oecresentative; I
I Operating "anager.
i i
i I,
l l Dates, duplicates, l
l j and districutes i
/
I
.l laccroved CSS.
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1.3-11 contingency criteria for criticality safecy are:
0.45 of critical mass 0.75 of critical volume 0.75 of critical mass per unit area 0.85 of critical slab thickness 0.85 of critical cylinder diameter 0.95 keff fleutron Reflection. Safe limits will be based on full water reflection except uhen less reflection can be assured by the Two-Contingency Policy.
Instances in which less than full water reflection may be assumed are:
Fixed, unreflected process vessels in a sealed hood or cell into which access is controlled.
Unreflected containers of vessels urapped with sufficient cadmium of other nuclear poison sheeting to assure ncminal reflection.
Individual storage units in a storage array (less than full aater reflection may be assumed for some arrays in the interaction calculations).
Pleutron Moderation. Safe limits will Le based on optimum water moderation, unless other than optimum moceration can be assured by the Two-Contingency Policy.
Instances in which nonoptimum water mcderation may be assumed are:
Fissionable material in watertight containers.
Fissionable material in wa?.ertign: glove boxes in which the arrount of moderating material introcuced into the glove box is limited and centrolled.
(Automatic over1ead room fire scrinklers are pernitted if the glove boxes are critically safe by gecmetry under flood conditions. Under the situation where a glove box is not safe by geometry under flooded conditicns, the mass limit is reduced such tnat criticality would not be possible.)
Fissionable material stored in a vault or rcom anich specifically excluces water 'looding or significant mcceration by o*.ner materials.
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1.3-12 Fuel rods securely bundled (close packed).
Systems in wnich the mouerator is solid, thus fixing a H/X ratio to a certain value or range of values as in the case of fission-able materials in polystyrene or other compact substance.
Fuel rods or groups of fuel rods separated by sufficient water or equivalent material to prevent neutron interaction.
Systems in which the concentration of fissionable material is other than optimum and the concentration can be limited within a safe range by the Two-Contingency Policy.
For vessels or units in arrays in which neutron interaction contrib-utes to reactivity, allewance factors to obtain safety margins depend on the method used tc calculate the critical number of units in the array and on how well the method predicts criticality for arrays that have been mea-sured excerimentally.
For those arrays that can be accurately computed, the maximum allowable keff will be 0.95 at a 957, confidence level; and for arrays for the that compare less f avorably with experimental measurements, keff array will be less than 0.95, depending on comparisons to measurer. ~.its.
Scecial Reflectors and Moderators. The above limits are based on reflection and moderation of light water.
For instances where fissionable material pro-cessing or handling involves special reflectors or mcderators, such as D 0, 3
carbon, beryllium or heavy metal reflectors, criticality safety will be assessed on an individual basis.
Emchasis is placed on mcderation control in glove boxes in whicn unmoder-ated special nuclear material is processed. Controls emoloyed are as folicws:
Whenever the supply of water or oil is unlimited, potential flooding due to the rupture of a water or oil line is c0ntrolled by means of continuous operatcr sarveillance, quick acting shut-off valves, or water detectors located on the floor of the g10' box.
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1.3-13 A limited quantity of hydrogenous liquid is permitted in a glove cox for cleaning purposes, provided that the liauid is not mixed with the special nuclear material.
As an acded margin of safety, the amount of liquid permitted is limited to an amount that would be safe, even if mixed with the fissionable material.
Other Administrative and Technical Controls. Geometry control of fis-sionable material is the preferred means of criticality safety control and is used wherever feasible. When processing fuel elements of more than one plutonium or uranium enrichment, at least two positive means of identifying each enrichment are required (e.g., fuel dimensions, color coding, label-ing,etc.).
Prior ta blending pug with UO, criticality safety is based entirely 2
2 on the critical parameters for Pu0, with na credit for reduced reactivity 2
due to UO. After blending, allowance in the limits may be given for UO2 2
content if the correctness of the blend is confirmed by a sample analysis.
Plutonium polymer is assumed present in plutonium solution systems unless absence of such polymer is assured by acid concentration control and routine cleanouts of equipment.
Criticality safety dimensicns are attributed to spherical gecretry, unless equipment design assures a secmetry less favorable to criticality than spherical (e.g., cylinder or slab).
Safe cylinder and slab dimensions for process vessels are based en the most reactive form of the fissionable material that can reach tne vessels.
The structural integrity of safety re'ated items such as shelving for fissile material storage is at least three times the load capacity permitted by Criticality Safety Specifications.
Sumps are required to be safe in the event of a credible leakage and accidental spillage from vessels and oiping linked to the sumo.
Vacuum neaders, vent headers, and similar header systems are reviewed in detail for potential criticality hazards.
? ice connections are not permitted between a f'ssicnable sclution system controlled by safe gecre:ry and a system controlled by safe mass.
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1.3-14 In processes conducted behind massive shielding, soluole and fixed neutron poisons such as boron in solution, Pyrex Raschig rings, and steel plates containing baron or gadolinium may be used as a primary means of criticality safety control. When asoluble neutron poison is used as a pri-mary means of criticality control in a solution system, at least two inde-pendent administrative controls must be used against omission of the poison (e.g., combinations of attenuation instrument, chemical analysis, dcuble check of addition, etc.).
In processes not conducted behind massive shielding, fixed poisons may be used as a primary means of criticality control, if the positive design measures and maintenance controls assure that the poison is always present, and that leaching of the poison away from the matrix does not occur.
Soluble poisons may not be used as a primary criticality control in unshielded facilities.
Applicable Criticality Safety Specifications are available in all processing and storage areas.
Criticality Safety Specifications and other procedures for the control of fissionable material are reviewed periodically for compliance with DOE and Battelle-Northwest policies and regulations and good safety practice.
Also, the contents of Criticality Safety Specifications and other procedures are periodically reviewed with employees to assure their familiarity. Audits are performed monthly by a member of the facility coerating staff to assure that the operation of a facility comolies with the accrocriate procedures and Criticality Scfety Specifications.
Audits will be conducted to assure that a facility is being operated within tne proper category of criticality safety control; that ti.a handling of fissionable material is adequately covered by a CSS; that tne limits and centrols of applicable CS3 are being met; and that good safety practices are in effect.
The Chairman of the Safety Review Council will be provided a ccoy of each audit report. A summary report of these audit activities will te made to the Battelle-Northwest Director at monthly intervals.
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1.3-15 Criticality Safety Train.no Criticality safety training is required to acquaint all personnel with the criticality alarm signal and emergency response, and to inform personnel handling or using fissionable material of tne basic Battelle-Northwest criti-cality safety rules.
Periodic training (minimum annual frequency) in emergency action required for an accidental nuclear criticality shall be con-ducted for all nonreactor nuclear facility personnel.
The minimum training program requirements for all personnel involved in working with fissionable materials at nonreactor nuclear facilities (those perfoming work and those providing supervisory guidance) consist of-(1) Three of four quarterly training sessions which may be crimarily work oriented criticality safety topics such as new procedures or specifications, unusual occurrences involving criticality safety, discussion of selected criticality safety specifications for clarity and understanding, and discussion of audit and appraisal results. The following topics shall be covered in at least one training meeting each 24 month period:
basic criticali.ty principles; methods of criticality safety centrol; and ccmpany poiicy and procedures for maintaining criticality safety.
(2) Each individual snail demonstrate a satisfactory knowledge of the recuirements and procedures ::ertinent to the individual job assignment.
The demonstration may be oral, written, operational, or ali three.
Reexaminaticn is recuired:
at least annually on emergency procedures; and at least once every two years on all other subjects in which the examinee is expected to be proficient.
(3) A file record of the t-aining, including an auditable record of the testing, shall be maintained for each individual.
The training records snall be maintained for a minimum of two years, Records shall be sufficient to snow
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1.3-16 Training material covered and its relevancy to criticality safety.
Clear indication of the presence or absence of those individuals required to receive the training.
Demonstrates that each individual has a satisfactory kncwledge of the subjects and procedures pertinent to his job assignment.
Criticality Detection System A criticality detection and alarm system is required in any facility containing greater than exempt quantities of fissile materials except those facilities administratively controlled as isolated facilities..The criticality detection and alarm system consists of detectors, comparator panel, howler circuit, audible alarms, power-loss annuaciator, a central annunciator and the necessary w1: Ing and controls. Audit and trip signals are fed to an annunciator and comparator unit which provides 2-out-of-n coincidence operation and signals anf malfunction or loss of power to the system. When two or more detectors in one location are tripped, cycling klaxon howlers, which are provided through-out the building, are activated. A detailed description of the system design criteria, performance tests, detector placecent, calibration and maintenance instructions, and operating experience is available in Criticality Detection and Alam Sysm, edited by C. R. Richey and T. W. Jeffs, Battelle, Pacific Northwest Laboratories, December 1977.
A description of the system follows.
Detector Neutron sensitive detectors are located where at least two detectors will trip with a minimum foreseeable criticality burst from either a liouid or metal system. This burst produces 20 rads in soft tissue of combined neutron and gamma radiation c an unshielded distance of two meters from the reacting material within one minute. The neutron to gamma ratio is taken to be 0.3 with an average neutron energy of 1 MeV. At least three detectors shall be located within 300 feet of any fissionable material.
Lesser detectors snall be used to compensate for intervening shielding and to ensure the alarm system will trip following the minimum foreseeable curst.
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1.3-17 Ccmoarator The comparator panel annunciates both visually and audibly any failure or alarm condition of any detector in the building.
The comparator will activate the alarm when two-out-of-n (n>3) detectors trip the alarm circuit.
Redundant trip circuits shall be included in the comparator.
All circuiuy and controls associated with the comparator unit shall te protected against unauthorized tampering by the use of key lock doors and switches or key lock switches.
Howler Control Circuit The hcwler control circuit shall be fail-safe.
The fail-safe solid-state electronic timing device should be used for the howler timer.
Calibration and Testino Each criticality detector contains an internal audit circuit which will function at least once per minute to detect failure of the detectors.
To further assure optimal operation of the criticality detectors, the detectors shall be replaced annually with others newly tested and calibrated by personnel of the plant radiation instrument calibration and repair facility. The electronics of the comparator unit shall be tested annually. The criticality alarm system in each building shall be tested quarterly by tripping the system with a neutron source.
Emergency Power The criticality alarm system in all buildings will be connected to emergency power if it is available. For those buildings, where emergency power is not avail-able, in the event of an emergency or planned pcwer outage, all acrk witn radio-active materials including fissible materials will be terminated immediately.
Process areas in which activities with fissionable materials continue during a power outage will have emergency acwer supplied to all portiens of the criticality alarm system.
An annunciator of signal pcwer loss to the criticality alarm system will be installed in eacn building at a locatic whicn is cccuoied during ncrmal building use.
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1.3-18 Criticaiity Alarm Sicnal The criticality alarm signal (ah-co-gah) is unique and will not be used for any purposes other than to signal immediate evacuation in the event of accidental criticality. The alarm signal will be audible throughout the building and at any lccation along the outside of the building.
Radiation Emercencies Battelle-Northwest emergency procedures are maintained in conformance with COE-RL directives which require that each separate facility enrgency procedure conform to the plan for that plant area in which the facility is located regardless of which of the several Hanford contractors may operate the facility.
The objectives of these procedures are to minimize the risk to empicyees and members of the public in the vicinity of the Hanford Site, and seconjarily to minimize damage to or loss to use of valuable facilities and equipmeit in tne event of an accidental criticality, fire, explosion, or release et radio-active materials.
Procedures applying to Battelle-Northwest and Pacific Northwest Laboratory (PNL) facil1 ties are reviewed aeriodically by trained radiation protection and safety personnel to assure both tneir adequacy and their conformance to DOE-RL directives. These procedures contain specific infor 1ation regarding the scund of the various emergency signals, their meaning, the appraoriate action to be taken, the location of the staging area to which employees are to evacuate, and tne saecific plan of accountability for personnel.
The criticality alarm signals and the apprcoriate personr.el rescanse to these signals will remain uniform in accordance with tne established Hanford Standards throughout Battelle-Northwest and PNL facilities.
The response to other alarm signals such as fire alarms is maintained uni-form throughout the laboratories.
Hcwever, the signals in Battelle-Northwest cwned facilities may be different from those in the COE cwned facilities. The fire alarm system for the Battelle-Ncrthwest facilities is connected to the Richland fire de;artment; the fire alarm system for COE facilities is connected to tne COE fire decar=ent. The criticality alarm signals will be tested cuar-9 0%2.9.C
1.3-19 terly, and the fire alarm signals will be tested semiannually.
Facility emergency procedures will be reviewed annually with the involved personnel. Evacuation drills will be performed in all Battelle-Nortnwest facilities at least annually to assure that employees knew the meaning of emergency signals, and know the immediate action response appropriate to each.
De systems established by COE-RL, whereby COE-RL, management of Hanford contracu.,rs and members o# established emergency and technical support teams are notified, will be used in emergency situations.
The authorities and responsbilities of the emergency director and the members of the radiological emergency staff are defined in writing.
Speciali:ed plans for Battelle-Northwest groucs who have special responsi-bilities in emergencies (vi:., environmental monitoring, radiatico monitoring, and the radiological emergency staff) are maintained togethe with special train-ing programs by Battelle-Northwest. These plans will be reviewed at least annually.
Medical, firefighting, and access control personnel are emoloyees of contractors other than Battelle-Northwest.
Emergency plans and training programs for these groups are established by management of tae contractor organizations involved to meet COE-RL requirements.
Kits containing instruments capable of measuring dose rates that might be encountered curing rescue entries foilcwing a nuclear ext r: ion or similarly serious accident and self-reading pocket ionization dosimeter a capa le of mea-suring gama deses up to 600 R are maintained at locations near but nct in Battelle-Northwest or PNL facilities wnere radioactive and/cr fissicnable materiais are used. These kits also contain respiratory protective ecuipment and pro-tective clothing necessary for building re-entry.
Facilities and Ecui ment Plans for new facilities or significant modification of existing facilities will be reviewed by radiation protection, safety, and operating organi:3 tion personnel for acequacy of shielcing, intericcks, alarms, ventilaticn, containment, and Radiation Zona posting.
In addition, new facilities, major mcdifications of
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1.3-20 facilities, or the establishment of alternate uses for existing facilities may be reviewed by the Safety Review Council. This review will cover the adequacy of engineered safety features and the administrative controls to be provided. The suitability of a facility for performance of licensed work will be judged by the sama standards which are used when similar decisions are made for work under the Operating Contract.
The work performed under this license will be so planned and controlled as to not materially increase radiation or criticality safety hazards over s
those encountered in the performance of work under the Operating Contract witn DC E.
Gaseous effluent treatment systems are installed on the e. Saust system of any building where a potential exists for the evolution of airborne radioactive contamination. The gaseous effluent systems are designed to maintain effluent releas,es as far below the limits specified in 10 CFR 20 as practicable.
Except for certain filters installed directly in or on the hood or glove box in such a way that periodic testing is not feasible, all HEPA filters are tested upon installation to assure that they meet design objective of 99.95% efficiency test for cold DOP smoke with particle sizes between 0.3 and 0.8 um.
All HEPA filters, with the excepticn of those identified above, are tested at least annually thereafter to assure continued proper function.
Failure to meet the requirements result in replacement and testing as soon as practicable.
If continued generation of effluents prior to replacement is deemed unadvisable, the operation is terminated pending replacement of the treatment system.
Protective clothing, respiratory protective equipment, radiat.qn detectiori and measurement instruments, and dose rate measurement systems and eculoment are intended to be uniform for license and Operating Contract work. The scr<itss, equipment, and procedures used will be in accordance with DOE contractual requirements established by DOE-RL.
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1.2-21 Materials Scecial nuclear materials used in Battelle-Northwest controlled facilities under this license will be identified as sucn and maintained separately frem materials used under the Operating Contract.
Special nuclear materials handled temporarily in a sponsor's facility, except in Agreement States, under the terms of this license, will be retained in Battelle-Northwest custody at all times while in the sponsor's facility and will be identified and maintained separately from any other radioactive materials.
If fissionable, the material will be kept at least ten feet from other fission-able materials.
Shipment of special nuclear materials other than those specified in 10 CFR 71 paragraphs 71.11 and 71.12 will not be made until proposed procedures have been approved by NRC.
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1.4-1
-A 1.4 CERT!?ICATE The a'plicant and the official executing this certificate on behalf of the applicant nimed in Part 1.1 above, certify that all information contained in this applicition, including any supplements attached hereto, is true and correct to the best of our knowledge and belief.
Pacific Northwest Laboratories of Par.ific Northwest Division of Battelle Memorial Institute Applicant f
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Director, Pacific Northwest Laboratories Pacific Northwest Civision Battelle Memorial Institute Date: July 2, 1979 t-e er)*: N s' *U M fs WJ ks E