ML19310A689
| ML19310A689 | |
| Person / Time | |
|---|---|
| Site: | 07000984 |
| Issue date: | 03/19/1980 |
| From: | Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | |
| Shared Package | |
| ML19310A684 | List: |
| References | |
| 15943, NUDOCS 8006230026 | |
| Download: ML19310A689 (48) | |
Text
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PNL-MA-527 Revision 7 9
APPLICATION FOR RENEWAL OF SPECIAL NUCLEAR MATERIALS LICENSE SN.-942 Compiled by the Staff of Battelle, Pacific Northwest Laboratories Revised !1 arch 19, 1980 153.43 BATTELLE PACIFIC NORTHWEST LABORATORIES RICHLAND, WASHINGTON 99352 80062aug g
e iii CONTENTS 1.0. CRITERIA AND ADMINISTRATIVE PROCEDURES.............
- 1. l '-l 1.1 General..........................
1.1 -1 1.2 -Request -for Approval of Alternate Methods.........
1.2-1
~0ccupational Exposure limits................
1.2-2 Calendar: Quarter......................
1.2-4 Reports to Prior Employees.................
1.2-5 Reports of Exposure on Termination.............
1.2-6 Exposure Records and Reports for Current Exposure Year...
1.2-6 Caution Signs, Labels and Signals.............
1.2-7 Records of Liquid Waste Disposals.............
1.2-9 Criticality Detection System................
1.2-9 1.3 Minimum Technical Specifications and Capabilit.ies.....
1.3-1 Organization and Personnel Competence...........
1.3-1 Procedures.........................
1.3-6 Criticality Detection System................
1.3-18 Radiation Emergencies................... 1.3-20 Facilities 'and Equipment...............
1.3-21 Materials......................... 1.3-22 1.4 Ce r t i fi c a te........................
1.4-1
-2.0 ' LICENSE APPLICATION DESCRIPTIVE SUPPLEMENT (Preface ~to Part 2).......................
2-0 2.1 The Hanford Site......................
2.1-1 2.2 Battelle-Northwest Operating Contract....
2.2-1 Other Hanford Contractors.................
2.2-3
'Research and. Development Work for Battelle's Own Account..
2.2-4 2.3 Facilities Controlled By Battelle, Pacific Northwest Laboratories........................
2.3-1
iv
-CONTENTS (continued) 325 Building'- Radiochemistry...............
2.3-3 308 Building - Plutonium 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
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2.4 Battelle-Northwest Organization..............
2.4-1 Operations and Services Division..............
2.4-2 Occupational and Environmental Safety Department......
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 Occupational 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 Protection Instruments......
2.5-16 Radiation Monitoring Survey Program............ 2.5-17 Radiation Occurrence, Investigations and Reports...... 2.5-20 I
Training..........................
2.5-20 2.6 Criticality Safety Procedures...............
2.6-1 Facility Classifications..................
2.6-1 The Safety Analysis Report.
2.6-1 i
1.:
v CONTENTS (continued)
Content and Format....
2.6-2 Revision of Safety Analysis Reports............
2.6-5 The Criticality Safety Specification............
2.6-6 Conten t and Fo rmat.....................
2.6-6
-Review..=.........................
2.6-6 Special Conditions and Temporary Deviations........ 2.6-10 Criticality Safety Audits................. 2.6-13 Audits by Nuclear Safety..................
2.6-13 Internal Audits by the Operating Group........... 2.6-15 Criticality Safety Appraisals............... 2.6-18 Training.......................... 2.6-21 Training Program Outlines................. 2.6-22 2.7 Shipment Procedures....................
2.7-1 2.8 Waste Disposal.......................
2.8-1
. Gaseous Waste Streams...................
2.8-1 Liquid Waste Systems....................
2.8-1 Solid Waste........................
2.8-4 Environmental Surveillance.................
2.8-4 2.9 Emergency Capabilities and Plans..............
2.9-1 APPENDIX A: BIOGRAPHICAL SKETCHES.................. A.1 APPENDIX B: MANAGEMENT GUIDE SAFETY REVIEW COUNCIL......... 8.1 APPENDIX.C: MANAGEMENT GUIDE RADIATION PROTECTION.......... C.1
S
-1.1-1 APPLICATION FOR RENEWAL OF SPECIAL NUCLEAR MATERIALS LICENSE SNM-942 (Revision 6, July 2, 1979 1.0 CRITERIA AND ADMINISTRATIVE PROCEDURES 1.1. GENERAL 1
This is an application to the Nuclear Regulatory Commission (NRC) for
.t e renewal of Special Nuclear Materials License, SNM-942, covering the re-h ceipt. possession and use of special nuclear material for broad research and development.
Applicant Pacific Northwest Laboratories of Pacific Northwest Division of Battelle Memorial Institute,* Battelle Boulevard, Richland, Washington, (hereinafter referred to as Battelle-Northwest or BNW).
President Dr. Sherwood L. Fawcett 2820 Margate Road
. Columbus, Ohio 43221 Executive Vice-President Dr. Ronald S. Paul 803: Lookout Point Drive 4
Worthington, Ohio 43085 Vice-President - Financial Advisor Mr. Wallace-Sale 1104 S. Irby Kennewick, Washington 99336 Vice-President, General Counsel and Secretary Paul T. Santilli, Esq.
1519 Lafayette Drive Columbus, Ohio 43220 Vice-President, Treasurer and Corocrate Director - Finance Mr. Maurice G. Stark 5764 Satinwood Drive Columbus, Ohio 43221-
r 1.1-2 Vice-President and Corporate' Oirector - Government and International Sponsor Relations Mr. George B. Johnson
-8504 Atwell Road-.
- Potomac, Maryland 20854 Vice-President and Coroorate Director, Communications and Public Affairs Mr. Clyde R. Tipton, Jr.
2155 Cheshire-Columbus, Ohio 43221 Vice-Preside'nt and Corporate Director, Human Resources Mr. Lawrence L. German 2245 0xford Columbus, Ohio 43221 Vice President and Corporate Director, Multi-Component Operations Dr. T. W. Ambrose 505 King Avenue Columbus, Ohio 43221 Director,' Pacific' Northwest Division and Pacific Northwe'st Laboratories Dr. Douglas 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 the applicant by any alien, foreign corporation, or foreign government.
Organization of the License Apolication This total application is divided into Part I and Part II.
Part I contains the criteria and administrative procedures set up to assure the maintenance of high quality health and safety conditions for all Battelle-Northwest work performed under this special nuclear materials license. 'The criteria and administrative procedures in Part I may not be changed without prior approval from the Nuclear Regulatory Commission.
Part II. presents additional descriptive material as evidence of the technical competence, management control procedures and philosophy at Battelle-Northwest. This competence, control, and philosophy assure adequate nuclear health and' safety performance in all of the Laboratories' acitivities.
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1.1-3 Location Where Licensed Material Will be Used The primary work location is the Battelle-Northwest controlled buildings and facilities located on or adjacent to the Department of Energy's Hanford Site at Richland, Washington. These facilities include those of the Pacific Northwest Laboratory (PNL) operated for the Department of Energy (DOE) by Battelle-Northwest (BNW) and those privately owned by BNW. Additional temporary work locations include sponsor's laboratories and facilities except in Agreement States.
Battelle-Northwest has entered into two contracts with DOE 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 laboratory facilities in carrying out assigned DOE _research and development programs, and
- 2) a Use Permit Contract, EY-76-C-06-1831, 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 aiso conducts contract research for its own account in privately owned facili-ties in the BNW Richland Research Complex located immediately south of the Hanford 300 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) which requires a special nuclear materials license.
A map and description of the Hanford Site and environs with plot plans showing the locations of Battelle-Northwest controlled buildingsand facilities, are in Part II of this application.
Special Nuclear Materials to be Handled in Battelle-Northwest Controlled Facilities License coverage is sought for enriched uranium and all isotopes of plutonium. These materials may be handled in any physical and chemical form for all research and development purposes except for administration to humans.
The maximum quantity of licensed materials which will be in inventory under the control of Battelle-Northwest at any time will be less than one effective kilogram, as defined in subparagraph 70.4(t) of 10 CFR Part 70, of uranium 233, uranium 235 and plutonium except that the quantity of plutonium shall be no greater than 200 g.
Since the maximum quantity of licensed material is relatively small com-pared with normal inventories in use by Battelle-Northwest for 00E programs under Operating Contract EY-76-C-06-1830, the potential risks to the health and safety of onsite and offsite_ personnel will not be significantly increased by_ addition of the licensed work.
1.1-4 Radioactive Materials to be Handled Temporarily in~Soonsor's Facilities Except in Agreement States License-coverage is also sought for the temporary use of special nuclear material for research and development purposes in a sponsor's facility ex-cept in Agreement States. Temporary work under the terms of this license will in each case be limited to a quantity less than a minimum critical mass.
The use of the licensed materials in sponsor's facilities will be limited as necessary to assure a high degree of safety using engineered and administrative safeguards which are entirely under control of Battelle-Northwest and therefore do not create a situation of dual responsibility between Battelle-Northwest and sponsor personnel. Alternatively, where 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.
Examples of Work to be Performed Under the License '
Battelle-Northwest will perform contract research and development activities for its own account and for many sponsors, Loch government and industrial, in practically all areas of the physical and life sciences ex-cept human medicine. Much of this contract research work will be nonnuclear in character. However, it is proposed to include the laboratory's broad and competent nuclear research capabilities in the spectrum of research services offered.
Research activities may involve handling quantities approaching one effective kilogram of fissile materials in both nonmetallic and metallic forms. Small amounts of special nuclear materials are used in support of research and development work related to the production and processing of I
nuclear fuels and fuel material.
In addition, special nuclear materials are used in a wide variety of non-fuel research and development programs, includ-ing the following areas:
i Research in radiobiology Development of improved means for the dosimetry of ionizing radiation Measuring, minimizing, and controlling radioactivity released to the environment
1.1-5 Reactor. system development, as well las reactor materials and component development
- Study of irradiation effects
- Development of improved activation analysis techniques Reprocessing of irradiated fuels and neutron target materials for recovery of products and radionuclides OcVelep=ent of radioactive waste processing procedures.
No special nuclear materials will be produced under this license since it does not cover the operation of a nuclear reactor nor insertion of any licensed material into a nuclear reactor.
Financial Oualifications The net worth of the Battelle Memorial Institute (BMI) is approximately
$155 million. The BMI annual business volume for 1973 exceeded $294 million.
Previous License Numbers No-license numbers prior to SNM-942 have been issued to Pacific Northwest Laboratories of the Pacific Northwest Division of Battelle Memorial Institute by the Nuclear Regulatory Commission.
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1.2-1
-1.2 REQUEST FOR APPROVAL OF ALTERNATE METHODS The major portion of the work with radioactive materials performed by Battelle-Northwest -is under the Operating Contract EY-76-C-06-1830 with 00E.
That portion of the work with radioactive materials performed by BNW under the license' represents a small amount both 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, the Westinghouse Hanford Company, and the Hanford Environmental Health Foundation. Because of the close relationship among the Hanford contractors, both geographically and programatically, it is very important that radiation protection standards be maintained uniformly among the various Hanford contractors.
In order to achieve and maintain this uniformity the Richland Operations Office of DOE has issued directives in the -
form of 00E-RL Manual Chapters and the Hanford Services and Facilities Cata-log.
The Hanford Services and Facilities Catalog requires.that all Hanford contractors utilize certain Hanford-wide services provided by a specified con-t.* actor; for example:
All maintenance, repair and calibration of radiation survey instrumen-tation is performed for all contractors by Battelle-Northwest.
All bioassay samples _ and personnel dosimeters for employees of all Hanford contractors, and all samples obtained for the Hanford Environ-mental Survefilance Program are processed by one contractor - U. S.
Testing Company.
' One Battelle-Northwest component makes all in-vivo determinations, evalu-ates the results of all. Dersonnel exposure measurements, compiles the data obtained using one comon data processing program, routinely reports the results to the concerned contractors, maintains the exposure record files, and makes all necessary reports, again for all Hanford centractors to meet the requirements established by 00E-RL.
Another Battelle-Northwest component conducts the Environmental Surveil-lance Program, by scheduling, obtaining (but not processing), evaluating and reporting the results of samples taken and measurements made through-out the Hanford environs.
1.2-2 All of these programs are established and performed to meet the specific requirements of 00E-RL. Notwithstanding the fact that Battelle-Northwest may conduct a specific plant-wide' radiation protection service program, Battelle-Northwest cannot unilatarally change that program without the concurrence of all involved contractors and 00E-RL.
The: Richland Operations Office issues supplements to certain DOE Manual Chapters to provide specific guidance for Hanford contractors in interpre-tation of the requirements of the basic DOE Manual Chapters. These Manual Chapters are transmitted to the contractors for compliance; Battelle-Northwest and the other.Hanford contractors have little latitude in the application of the 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 00E under the Operating Contract.
It is neither techni. call" or administratively feasible to apply two different exposure measurement and control programs simultaneously.to the same employees.
The exposure which an employee may receive from licensed materials cannot be distinguished from that which he may receive from materials used under the Operating Contract.
Because the Battelle-Northwest Radiation Protection Program is designed to comply with requirements ir 00E Manual Chapters, certain radiation protec-tion standards cr practices d.fer from those specified in Title 10 Parts 20 and 70 of the Code of Federal Regulations. Those radiation protection stan-dards or practices that differ from particular paragraphs are described here.
Occupational Exposure Limits The annual and long-term exposure limits applied by Battelle-Northwest for work under the Operating Contract are based on those contained in DOE Manual - Chapter 0524. Should changes occur in any of the applicable 00E Manual Chapters which would affect the limits for radiation protection, Battelle-Northwest will-promptly notify the Chief, Uranium Fuel Licensing j.
Branch, USNRC. The current BNW exposure limits are as follows:
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w 1.2-3 Calendar Annual Quarter Whol_e Body, Head and Trunk, 5 rem 3 rem Gonads, Lens of Eye, Red Blood Marrow, Active Blood Forming Organs Unlimited areas of' the skin 15 rem 5 rem Texcept hands, forearms and feet)
Other.oroans, tissues, and organ systems (exceptbone)
Bne, Hands,. Forearms, Feet (a) 30 rem 10 rem (a) All reasonable effort shall be made to keep exposures to forearms and hands to the gener&l limit for the skin.
DOE requires the total dose to include dose received both from external sources and internally deposited radioactive materials.
The 10 CFR 20 quarterly permissible dose limits appear to have been estab-lished as one-fourth of the desired annual exposure in order to eliminate the need for separately stating the appropriate annual limit.
In contrast, the
- DOE. quarterly limits are presented to demonstrate tne degree of nonuni-formity of accumulation of exposure through the year which is permissible as established by the Federal b diation Council (FRC) and the International Connission of Radiolooical Protection (ICRP). Since Battelle-Northwest personnel rarely _ exceed the quarterly limits specified in 10 CFR 20, seldom is it necessary or desirable to expose personnel as nonuniformly as the DOE quarterly limits l
permit. The few cases where such exposure has been necessary have been related j
.to whole body exoosure rather than exposure to the skin or extremity.
In those l~
cases, the-3 rem /q DOE limit is applied [same as permitted by paragraph 20.101 (b)] except that the combined annual whole body exposure from external and internal sources is limited to 5 rem in the year.
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The Battelle-Northwest quarterly exposure limitt described above are submitted as an alternate to the quarterly limits contained in paragraph l-
- 20. l'01 (a ).
The purpose in requesting approval of'the quarterly limits in D ~. Manual Chapter 0524 as an alternate to the 10 CFR 20 quarterly limits is to avoid possible confusion, misunderstanding, or concern on the part of 6
+4, 1.2-4 l
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Battelle-Northwest or other Hanford employees. This could result from the change itself or from the resulting inconsistency between contractors rather than the need for additional _ exposure.
Every new employee is required to canplete an exposure history questionnaire to aid _in the evaluation of internal dose and to assure that the new employee does not exceed a quarterly ~or annual limit as a result of his/her ccmbined exposure for the year (both on'ite and offsite exposure).
In the event that s
the new employee.has been occupationally exposed prior to employment at Battelle-North.sest, a&ninistrative controls will be imposed to restrict exposure for the remainder of the year until such time that the prior 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 prior to employment with Battelle-Northwest. Additionally, if the accrued or assumed exposure exceeds any. quarterly or annual limit, the employee will not be permitted to receive additional exposure while working for Battelle-Northwest until his/her exposure is within the appropriate limits. Any special exposure controls deemed necessary because of either real or assumed exposure will be provided in writing to the employee's supervisor, to Radiation Monitoring and to the employee's exposure records file.
This exposure history satisfied all requirements for NRC Form 4 with the exception of Item 9 (insertion of calculated dose) and Item 13 (permissible dose remaining). Previously, exemptions ware requested for these two items; however, since annual exposure in excess of 5 rem is not permitted, it is not believed necessary to maintain an NRC Form s'.
Pursuant to paragraph 20.501, it is requested that Battelle-Northwest.be granted an exemption' from the numerical values contained in paragraph 20.101(a) and to substitute the Battelle-Northwest occupational exposure limits described on page 1,2-3.
Calendar Quarter The calandar quarter used in the Hanford-wide program is not as defined in paragraph 20.3.
The exposure year at Hanford consists of four quarters ending on the.last Friday.of March, June, September and December. No quarter is less than 12 weeks nor more:than 14 weeks in length in accord with a portion of the definition presented in paragraph 20.3.
However, the remaining days in December, if any, become a part of the new exposure year.
1.2-5 14 change of the calendar quarter to meet one of the definitions presented in paragraph 20.3 vould impact heavily across the plant. The DOE-RL contract with U.S. Testing 01mpany specified that dosimeter change shall be on the last Friday of each month and that the calendar year will end on the ;.'.st Friday of December. The U.S.. Testing Company dosimeter processing schedules and the exposu're records data processing program schedules are based on this definition.
The last Friday of each month was chosen s'ince Friday is the only day of the week that all Hanford contractor employees other than firemen are at work, regardless of shift schedule.
Pursuantto paragraph 20.501, it is requested that the calendar quarter as defined above be accepted in lieu of the definition of calendar quarter con-tained in paragraph 20.3(a)(4).
Reports to prior Employees Exposure reports are provided to prior employees as required by 00E Manual Chapter 0525 and paragraph 20.401(a), within 30 days of the request.
These reports include the accumulated exposures to beta particles, phctons, and neutrons for the' entire period of employment together with information regarding deposition of radioactive material, if appropriate. The reports also include a summary by calendar quarters of the whole body skin, whole body penetrating, and extremity exposures for the current calendar year. Since ex-posures by calendar quarter are not maintained in the data processing file, and in some cases the employee's exposure may span a period in excess of 30 years at the-plant, the normal procedure does not include the reconstruction of data to orovide exposures by. quarters or lesser periods as required by paragraph 20-401(a), other than for the current year. Additionally, if the enoloyee is on a quarterly dosimeter exchange frequency, it is physically impossible to provide exposures for the current year by lesser periods than quarterly. On an individual case, if there is a necessity to recort these data on a quarterly frequency, it would be possible to do this for the entire employment period. This would be accomplished by obtaining data which is cur-rently maintained on microfilm for each employe:.
Pursuant to paragraph 20.501, it is requested that the requirements for
_ prJviding exposure by calendar quarter for other than the surrent calendar year and for lesser periods than quarterly as required in paragraph 20.401(a) be waived.
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1.2-6 l Reports of Exposure ~on Termination ~
00E Manual Chapter 0525 requires the reporting of exposure for termina-ted employees to the System Safety Development Center (SSOC) in Idaho Falls, Idaho within 30' days'after the terminated employee's exposure has been de-termined or_ within 30 ' ays after the ; individual's termination date, whichever d
is later. A copy is also provided to the_ employee upon request. This report contains' the same 'information which -is to be submitted to the Director of Management and Program Analysis, USNRC, as required in paragraph 20.408. The
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past organization of the Federal Agencies dealing with nuclear energy pre-sented the situation in which two identical reports could have 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-organization 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 paragraph 20.501, it is requested the requirements of DOE Manual Chapter 0525 be deemed to satisy the parallel of requirements of
-paragraph 20.408 and that the requirements of paragraph 20.408 continue to be waived.
Exposure Records and Reports for Current Exposure Year All Hanford contractor employee's exposure records are compiled using automatic data processing methods. Each month, reports reflecting any action in-the employee's exposure data file are reported in the form of computer printout ~ reports. For employees who are monitored persuant to paragraph 20.202 or 00E Manual Chapters, a summary report provides the 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 Radiation Monitoring.
The thermoluminescent multipurpose dosimeter uses LiF chips to measure beta, photon and neutron radiation. The dosimeter is constructed to provide a measure of the skin dose and a one centimeter-tissue depth dose to the
]
whole body. Q(ality factors of 10 and 3 are used to determine dose equivalents to. body organs for fast and thermal neutrons, respectively.
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1.2-7 For employees who are provided extremity dosimeters, another-data process-ing report is also provided on a monthly frequency. ~ne sum of the employee's
- accumulated derma dose plus any special measure.:nts c'ade for the extremity
.is considered the employee's extremity exposure.
Annual summations are provided for each employee's exposure record file, and.in the form of an annual exposure report card to the employee.
The exposure records and reports for the current exposure year include all of the information required on Fonn NRC 5 with the exception of Item 13 (running total for calendar quarter) and Item 18 [ additional exposure allowable under 5(N-18) rems] as required in paragraph 20.401. The various data on the monthly exposure reports have permitted management to effectively maintain BNW employees' exposure below 3 rem per quarter. The aooition of the quarterly total to these reports would not change the exposure control program but would increase the cost of the Hanford plant expo:ure records program since any change would necessarily affect the entire plant. No accounting is made of the amount of exposure remaining within the formula since an employee's annual exposure is limited to 5 rem.
Pursuant to paragraph 20.501, it is requested that exemption to the require-ments of paragraph 20.401(a) be granted to the extent that Items 13 and 18 of Form NRC 5 need not be completed.
Caution Signs, Labels and Signals The methods used by Battelle-Northwest in identifying those locations where radiation protection controls are required, differ in detail from those specified in paragraph 20.203. All locations where significant radiation exposure can be received, whether externally or internally, are posted with signs bearing the standard radiation symbol together with the words " Radiation Zone". Radiation Zones are established to limit casual (non-Radiation Zone) exposure to less than one-tenth of the occupational radiation exposure limits.
All areas which would be required to be posted by paragraph 20.203 (as a radiation area, high radiation area, airborne radioactivity area or radioactive material area) are included within the Battelle-Northwest requirement for posting as a Radiation Zone. All significant quantities of radioactive mate-rials or radiation generating machines are stored and used in Radiation Zones in conformance with established Radiation Protection Procedure:.
The placement of signs denoting Radiation Zones is such that at least one sign.is visible from any avenue of approach. These signs normally make no
1.2-8
- reference to either the nature of existing radiation conditions or the radia-tion protection measures required within the Radiation Zone. 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 outside of the exclusion area and by security patrol for buildings or areas within the Hanford Site exclusion area. Visitors are not permitted to enter any Radiation Zone unless escorted by an employee thoroughly familiar with the radiological status and radiation protection requirements.
Radiation Work Procedures detail the requirements for protective clothing, personnel monitoring devices, surveillance of work by Radiation Monitoring, the locking out of process equipment, and other such requirements which can best be defined b,y the local groups actually performing the work. Although normally prepared for use over an extended period, occasionally a Radiation Work Procedure will authorize work for only a short period.
Radiation Work Procedures require approvals of operating management, tuilding management and Radiation Monitoring supervision.
t 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 protection records.
This practice of 1) uniformly posting all areas-where -ignificant exposure may be received as " Radiation Zones" and 2) specifying the existent radiological conditions and radiation protection requirements on the Radiation Work Procedure required to be prepared for every Radiation Zone has been used for many years within the laboratories and is consistent with the procedures of other Hanford contractors.
The COE facilities operated by Battelle-Northwest are designed in accor-dance with Radiological Design Criteria (currently documented as BNWL-MA-3) which have been in effect for a number of years. These criteria include a requirement to provide locks or interlocks for areas where dose rates in excess of 1 rem /hr or airborne concentrations in excess of 1000 MPCs may be encountered.
Since much of the work for DOE involves kilocurie or megacurie quantities of fission products, transuranium elements, etc., it is not practical to provide
1.2-9 physical access controls below these levels. As described earlier, all work in Radiation Zones, including areas where high dose rates or airborne concentra-tions may be encountered, is controlled by RWP provisions.
Pursuant 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 Radioactive Area"), 20.203(d) (use of the words -' " Caution Airborne 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 asso-ciated Radiation Work Procedure. All areas that would be required to be posted by paragraph 20.203 will be included within areas posted as Radiation Zones.
Additionally, it is requested that the level of 1 rem /hr be accepted as the dose rate at which physical safeguards including locks or interlocks shall be required rather than the levels specified in paragraph 20.203(c)(2).
Records of Liouid Waste Ofsposals 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 Development Laboratory (HEDL) contractor.
It is not possible to distinguish liquid wastes generated in licensed activities from those wastes generated in 00E contract activities, and in some cases, it is not possible to identify the contributions to the system from a given building or those arising from the activities of a given contractor. Measurements are made and records are kept by the HEDL contractor of the total radioactivity disposed to these systems.
Pursuant to paragraph 20.501 it is requested that an exemption be granted relative to the requirement in paragraph 20.401(b) for maintaining records of disposal of licensed materials to the 300 area Liquid Waste systems.
' Criticality Detection System Paragraph 70.24(a)(1) of 10 CFR 70 requires that a criticality detector system be maintained "...in each area in which special nuclear material subject to such license is handled, used or stored"...
In those buildings where BNW
~ orks with substantial quantities of fissil e ma:erials (e.g., 306-W, 325, w
308) and the fissile material storage building (303-C), criticality detector systems are provided. Those buildings where lesser quantities of fissile materials are used are established as isolated facilities as described in BNWL-MA-25,
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1.2-10
" Criticality. Safety Procedures", Procedure 1, part III.B. An isolated facility is any facility _ where the inventory of fissile material is limited to less than 45% of a minimum critical mass (MCM). An exception to this 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 established as isolated facilities in which work with licensed materials may be performed include the 3720, 3708, and Life 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 varicus chemical and physical analyses and measurements on samples or speci-mens and studies of the deposition, uptake or biological effects of these materials on animals and plants.
Pursuant to paragraph 70.14 it is requested that conditions of installing 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).
1.3-1 1.3 MINIMUM TECHNICAL SPECIFICATIONS AND CAPABILITIES Organization and Personnel Competence (A) Battelle-Northwest will maintain a unique department
- responsible for the establishment and conduct of all radiation protection and nuclear safety programs. This' department will be separate from the operating depart-
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ments of Battelle-Northwest. This department for radiation protection and nuclear safety will serve as the Battelle-Northwest official contact with the Nuclear Regulatory Commission for all matters concerning radiation protection and nuclear safety ** as they pertain to this license renewal application.
In-dividuals with.in this department that are designated as Senior Engineers, Nuclear Safety, are responsible for conducting criticality safety reviews, audits and appraisals of the nuclear facilities. Specific responsibilities of the department will include:
Establishing the policies, standards and limits to be applied through-out Battelle-Northwest in Nuclear Safety and Radiation Protection.
Providing review and approval on 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 Modification Permits, Safety Analysis Reports, Safety Assessment Documents, Radiation Work Procedures, and Criticalrity Safety. Specifications.
Performing inspections, audits, and reviews of facilities and proced-ures and initiating changes necessary to assure a high level of criti-cality prevention measures and personnel rc.diation protection and com-pliance with all Battelle-Northwest and State and Federal recuirements.
Evaluating, recording, and reporting radiation exposure received by personnel within Battelle-Northwest controlled facilities and by all Battelle-Northwest employees.
Measuring and recording radiological conditions in all work locations i
where sources of radiation are present and prescribing the protection methods to be employed in perfoming the work.
Currently named the Occupational & Environmental Protection Department Nuclear safety encompasses both reactor selety and criticality safety l
where criticality safety deals with preveation of an accidental criti-cality in a nonreactor environment.
O 1.3-2 Conducting a surveillance program to define the geographical and bio-logical distribution of radioactive materials in the plant environs, determining the status of the plant environs with respect to applicable limits and guides, and establishing appropriate guides for the controlled release of radioactive materials from Battelle-Northwest-controlled facilities.
Establishing procedures and maintaining records of the shipment of radioactive materials from Battelle-Northwest to other locatic'ns either on or off the Hanford Site.
Reviewing nuclear safety analyses for reactors, critical facilities, and laboratories containing fissile materials or large inventories of radionuclides.
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 above.
(1) The manager of the _organi:ation responsible for administering the radiation protection and nuclear safety programs will be a college graduate (preferably.also a Certified Health physicist) with recognized substantial experience in the field of radiation protection and nuclear safety. A mini-mum-of seven years experience, including at least three years in the 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 col-lectively excerienced-in nuclear safety and radiation protection.
(2) The Technical' Leader, Nuclear Safety, will be a college graduate with a minimum' of seven years experience including at least five years in criticality safety work.
l' i-
1.3-3 (3) ' A Senior Engineer, Nuclear Safety, will be _ a college graduate with at least five years of technical experience and three years in criti-cality safety work.
(B) In addition to the nuclear safety responsibilities assigned in the previous section, Battelle-Northwest will maintain a research organization *
.(descriptively denoted as " Criticality Safety") that is independent of
" Nuclear-Safety" that:
- 1) provide technical criteria on matters pertaining to criticality safety; 2) establish technical bases for criticality safety specifications; 3) approve technical adequacy of criticality safety specifi-cations; 4) perfonn technical reviews of Battelle-Northwest facilities and operations from a criticality safety standpoint; 5) participate along with
" Nuclear Safety" in the conduct of annual criticality safety appraisals of the operation of nuclear facilities.
Individuals within the Criticality Safety organization are designated as Specialist and Senior Specialist for approving criticality safety specifications and technical bases for criti-cality safety specifications.
(1) The manager of the organization responsible for approve Criticality Safety Specifications for technical adequacy and for performing technical reviews of Battelle-Northwest facilities and operations from a criticality safety standpoint will be a college graduate with a minimum of seven years experience including at least five years in criticality safety work.
(2) A Senior Specialist, Criticality Safety, will be a college graduate with at least five years of technical experience and at least three years in criticality safety analysis work.
(3) A Specialist, Criticality Safety, will be a college graduate with at least one year in criticality safety analysis work.
- Currently the Criticality Analysis Unit of the Nuclear Technology Section of the Energy Systems Department l
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1.3-4 (C)' Battelle-Northwest will maintain a unique department
- responsible for security and safeguards for nuclear materials. This department will be separate.from the operating departments of Battelle-Northwest. This depart-ment 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. Responsibilities of the department will include:
Establishing the policies, standards and limits for security and nuclear material safeguards to' be applied throughout Battelle-Northwest.
Maintaining a system of control and management of nuclear materials which will optimize procurement cost, use and recovery.
Providing the custodial care and special procedures to prevent diver-sion.or unauthorized use.
Providing audits to assure compliance with appropriate security and safeguards procedures.
- Establishing and maintaining an inventory, material transfer and fore-cast system for special nuclear materials.
(1) The manager of the organization responsible for security and safe-guards will be an individual with substantial experience in the field of security, safeguards and/or nuclear material management. This organization will be staffed with a number of people sufficient to fulfill the organization's responsibilities.
(D) Research Departments (1) The manager of each Battelle-Northwest program will be technically trained in the field of endeavor (or an associated field of endeavor) which is the basis of the work to be performed. He/she will have experience re-quired to operate in accordance with Battelle-Northwest policy and the con-tractual obligations established by DOE /RL that may affect the program. He/she will be responsible for operating safety and insuring that personnel follow established rules.
l.
- Currently named Safeguards & Security Department l
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1.3-5 (2) A Criticality Safety Representative is appointed for each facility by operations management. The representative reports to the operating manager and is responsible for the facilities internal auditing, approved Criticality Safety Specifications and providing liaison with Nuclear Safety. He is trained by either Nuclear Safety or Criticality Safety in the instruction and procedures on criticality safety that are pertinent to his assignment as criticality safety representative. His appointment is subject to the concurrence'of the Technical Leader, Nuclear Safety.
(E) Battelle-Northwest will maintain a Safety Review Council as estab-lished in Management Guide 12.7 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 consideration by any Department Manager, higher authority, or a member of-the Safety Review Council. The Safety Review Council or council chairman can determine whether 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 Counc11 as a group is held if requested by any member. The Council has access to all information and facilities required in the discharge of its responsibilities.
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Review by this 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 likelihood and consequences of a serious accider.t. Results of reviews per-formed by the Council are reported to the Director, Battelle-Northwest.
Examples of important matters to be considered for review by the Safety Review Council include:
Nuclear safety criteria for the design and operation of facilities and equipment.
Proposals for conducting safety analyses or research programs involving significant risks for sponsors.
Safety Analysis Reports or Operating Safety Analysis Reports.
Plans for implementing operating safety limits, audit and inspection programs, and operator training programs.
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1.3-6 Departmental plans for response and recovery from major accidents in facilities requiring Safety Analysis Reports.
Proposed changes in the mode of operation of facilities modification that increase either the probability or consequences of a significant accident.
Evaluations of potentially significant safety interactions within Battelle facilities or with other Hanford contractors.
Proposed nuclear safety policies and programs and other selected policies and programs of the Pacific Northwest Laboratories.
Any activity not covered above that could have substantial safety implications.
Members of the Council are selected by the Director of Battelle-Northwest from persons recognized as authorities in specific fields such as atmospheric dispersion, biological effects of radiation, chemistry, containment, critical mass physics, fluid flow, heat transfer, legal liabilities, metallurgy, pres-sure vessels, reactor physics, operation and engineering, risk evaluation, and industrial safety. The Council may be supplemented by other resources or specialists within Battelle.
Procedures Radiation protection Formal administrative procedures for radiation protection are maintained by Battelle-Northwest.
Periodic reviews are made of these procedures by trained health physicists to assure their adequacy. These procedures are changed only with the approval of the manager, radiation protection department, or qualified higher authority. Radiation Protection Procedures and specific Radiation Work-Procedures are reviewed periodically with employees and are kept readily available to them.
Comprehensive dosimeter, monitoring, survey, bioassay, and whole body counting programs are maintained by Battelle-Northwest. The evaluating, recording, and reporting of radiation exposure, as detennined by these pro-grams for all Battelle-Northwest emoloyees and visitors, meet high professional standards and will continue to reflect the contractual requirements. Any changes-in the programs or the exposure evaluation and recording procedures will require the review and approval of the manager responsible for radiation protection.
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1.3-7 A high quality environmental surveillance program is maintained for DOE /RL to permit a continuing evaluation of the status of the environs with respect to applicable limits and the impact of environmental contamination
.on the surrounding population.
Radiatior, protection training is a continuing program under Battelle-Northwest. The formal training programs range from those for the professional in radiation protection to programs for individuals whose knowledge of radiation is incidental to their work. An initial general radiation protection orientation is presented to new employees of Battelle-Northwest.
This program is supple-mented throughout the service of the employee to assure sufficient knowledge of radiation protection practices and procedures and changes in these practices and procedures. Soecific training is presented to radiation monitoring person-nel, and others who reouire special skills in the conduct of safe work. This program of training will be continued at a level to assure that radiation pro-tection requirements are met and that work with radiation or radioactive materials is conducted safely.
Criticality Safety For work that involves fissionable materials, Battelle-Northwest follows the Two-Contingency Policy. A sufficient number of limits and controls are exercised to assure that before a criticality accident is possible, at least two unlikely, independent and concurrent errors or accidents must occur in one or more of the conditions specified as essential to nuclear safety. To implement this Two-Contingency Policy, formal procedures for the control of fissionable materials is maintained.
The principal procedure for control of fissionable materials is the Criti-cality Safety Specification (CSS). Criticality Safety Specifications are l
written procedures which give limits that, when followed, will ensure criti-l cality safety in facilities processing, storing, or otherwise handling significttt quantities of fissionable material. Any work involving more than 45". of the l
minimum critical mass of fissionable materials is conducted in a nuclear
1.3-8 rac111ty under an approved Criticality Safety Specification. An approved Criticality Safety Specification is required for any work involving fission-able materials, with the following exceptions:
Natural and depleted uranium and thorium.
Work in a facility where only exempt quantities, less than about 3%
of the minimum critical mass assuming spherical geometry and optimum water reflection and moderation, are present.
Work in an isolated facilit.y where the amount of fissionable material does not exceed one of the limits in Table 1.3-1 or Table 1.3-2.
If more than one type of controlled materials are involved in an isolated facility, the sum of the fractions of the allowed masses shall not exceed one. Also, fissionable material in the fonn of encapsulated sources containing more than Table 1.3-1 or Table 1.3-2 values may be handled under isolation control upon written agreement with DOE /RL.
An isolated facility is defined as one which may contain more than 3% but less than 45% of the minimum critical mass, assuming sphetical geometry and optimum water reflection and moderation. Fissionable material in the form of encapsulated sources containing more than 45". of a minimum critical mass may be harned under isolation control upon agreement between Battelle-Northwest and 00E/RL. An isolated facility shall be physically separated by at least 6 feet from any other work involving fissionable materials. Each isolated facility is estaolished 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 fissionable material. The analysis will be made by a competent criticality safety specialist 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 maintained in a permanent fiel by the nuclear safety group.
Facility Criticality Safety Representatives or their appointed delegates will be responsible for obtaining new or revised Criticality Safety Specifi-cations. Assistance of the Senior Specialist, Criticality Safety is available 4
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1.3-9 TABLE 1.3-1 Weight Percent Allowable Weight 235 235 0
ko U q
g 1.0-900 9000 1.5 168.8 2532
' 1. 7 121.4 2065 2.0 81.1 1622 2.5 49.1 1228 3.0 35.1 1053 3.5 27.9 977 4.0 22.0 880 4.5 18.3 823 5.0 15.6 783 8.0 7.9 632 10.0 5.85 585 20.0 2.48 496 25.0 1.88 472 30.0 1.5 450 40.0-1.07 428 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 Isotope Limit Np-237 18,900 g Am-241 32,400 g Cm-244 6,345 g Pu(Fuel)
- Less than 50% Pu-238 230 g (total Pu)
- More than 50% Pu-238 1957 g (total Pu)
Uranium (any enrichinent)
(see Table 1.3-1)
U-233 256 g Cm-243-67 g Cm-247-67 g Am-242 9g
.Cm-245 99
~Cf-249 99
4 1.3-10 to provide technical bases for establishing criticality safety limits. The nuclear safety group will provide assistance in preparing and distributing the Criticality Safety Specifications.
Each Criticality Safety Specification shall be approved or concurred to by the following or their autorized representative:
Criticality Safety Specialist
. Senior Specialist, Criticality Safety Senior Engineer, Nuclear Safety Technical Leader, Nuclear Safety Building Manager of the building in which the CSS will be used Criticality Safety Representative of the building Manager of the Operating Component in the affected facility.
Approval by the responsible manager formally establishes the specification as a written instruction to all members of the organization. Approval by the manager of the nuclear safety group shows that the specification is consistent with DOE and Battelle-Northwest policies and regulations and will good safety practices. The signature of the Senior Specialist, Criticality Safety, estab-lishes that the technical bases for the specification are correct. The steps to be followed in obtaining a CSS are outlined in Table 1.3-3.
In establishing Criticality Safety Specifications, fissionable material is defined as material which will support a neutron chain reaction with fast 243 239Pu, 241Pu, 233, 235g, 242g Cm, and/or thermal neutrons. This includes U
245Cm, 247,,.249Cf, and Cf in any form (metal, alloy, solution or compound).
251 c
241 238Pu, 240Pu, 242Pu, 237Np, 244Cm and Am are fissionable but can support a chain reaction only with fast neutrons. Criticality is not possible with these nuclides in aqueous solution. Any other fissionable transuranium nuclides will be considered that may be specifically identified in the future. Natural uranium, although fissionable, is excluded due to its large minimum critical mass.
-Before a building can be designated as a nuclear facility in which greater than 45% of a minimum critical mass of fissionable material mey be handled, a Safety Analysis Report (SAR) is recuired. Also, any significant modification
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.V' 1.3-11 CRITICALITY SAFETY SPECIFICATIONS TABLE-1.3-3 Steo 0herating Organization Criticality Safety Nucl ear -Sa fety Determines that'a new or revised CSS is needed.
'l
, Inform Nuclear Safety of need.
Submits request.
for a Basis Letter to Criticality Saf.ety.
Reviews operation, eval-uates criticality poten-tial and contingencies.
2 Prepares technical basis in form c.f a Basis Letter to Operating Organization with copy to Nucl. ear Sa fety.'
Prepares CSS on standard Places Basis Letter master forms.
in " Basis Letter File" kept b.v Nuclear i
3 Safety.' Assists in preparation of CSS as requested by origin-ator.
Reviews and approves CSS.
Signatures:
Senior 4
Specialist, Criticality Sa fety.
Reviews a'nd approves CSS.
5 Signatures:
Sr. Eng..
and Technical Leader, Nuclear Safety, Reviews and approves CSS.
Signatures:
Bldg.
S' Manager; Criticality Safety Representative; Operating Manager.
vates, duplicates,
'7 and distributes approved CSS.
1
r 1.3-12 or additional work not previously covered in an SAR requires a safety analysis in a supplemental SAR. A Safety Analysis Report is the result of a thorough study and analy.is that is perfomed to assure that potential major nuclear
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hazards have been incorporated to reduce the probability of major accidents and to minimize the consequences in the unlikely event of their occurrence.
The safety analysis considers foreseeable nuclear accidents that would sub-
)
stantially threaten 1) the safety of personnel or the public, 2) the use of or damage to property, and 3) the continuity of operation of facilities.
Each SAR, and each revision, requires the approval of the responsible Department Manager and the Safety Review Council. Additionally, review by tne Richland Operations Office of 00E is required by Manual Chapter 0530 if the facility is allowed to contain more than one minimum critical mass of fissionable materials.
Safety Factors and Assumptions. Criticality safety limits used in es-tablishing Criticality Safety Specifications will be based on data from experimental measurements or, if direct experimental data'are not available, on limits obtained from a calculational method that can be shown to be accurate or conservative when compared to experimental measurements. Safe limits will be obtained by reducing the critical value of a safe margin commensurate with interpolations and extrapolations to measurements and calcu-lations. The maximum fractions that independently satisfy the two contingency criteria for criticality safety are:
0.45 of critical mass 0.75 of critical volume 0.75 of critical mass per unit area O.85 of critical slab thickness 0.85 of critical cylinder diameter O.95 k,ff Neutron Reflection. Safe limits will be based on full water reflection except when less reflection can be assured by the Two-Contingency Policy.
Instances in which less than full water reflection may be assumed are:
1.3-13 Fixed, unreflected process vessels in a sealed hood or cell into which access is controlled.
Unreflected containers of vessels wrapped with sufficient cadmium of other nuclear poison sheeting to assure nominal reflection.
Individual storage units in a storage array (less than full water reflection may be assumed for some arrays in the interaction calculations).
Neutron Moderation. Safe limits will be based on optimum water moder-ation, unless other than optimum moderation can be assured by the Two-Contingency Policy.
Instances in which non-optimum water moderation may be assumed are:
Fissionable material in watertight containers.
Fissionable material in watertight gloveboxes in which the amount of moderating material introduced into the glovebox is limited and con-trolled.
(Automatic overhead room fire sprinklers are permitted if the gloveboxes are critically safe by geometry under-flood conditions.
Under the situation where a glove box is not safe by geometry under flooded conditions, the mass limit is reduced such that criticality would not be possible.)
Fissionable material stored in a vault or room which specifically excludes water flooding or significant moderation by other materials.
Fuel rods securely bundled (close packed).
Systems in which the moderator is solid, thus fixing a H/X ratio to a certain value or range of values as in the case of fissionable materials in polystyrene or other compact substance.
Fuel rods or groups of fuel reds 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 contributes to reactivity, allowance factors to obtain safety margins depends on the
s 1.3-14 method used to calculate the critical number of units in the array and on how well the method predicts criticality for arrays that have been measured experimentally. For those arrays that can be accurately computed, the maxi-mum allowable k,ff will be 0.95 at a 95% confidence level; and for arrays that compare less favorably with experimental measurements, k,ff for the array will be less than 0.95, depending on comparisons to measurements.
Soecial Reflectors and Moderators. The above limits are based on reflec-tion and moderation of light water. For instances where fissionable material processing or handling involves special reflectors or moderators, such as 0 0, 2
carbon, beryllium or heavy metal reflectors, criticality safety will be assessed on an individual basis.
Emphasis is placed on moderation control in gloveboxes in which unr,;,ier-ated special nuclear material is processed. Controls employed are as follows:
Whenever the supply of water or oil is unlimited, potential flooding due to the rupture of a water or oil line is controll.ed by means of continuous operator surveillance, quick-acting shutoff valves, or water detectors located on the floor of the glovebox.
A limited quantity of hydrogenous liquid is permitted in a glovebox for cleaning purposes, provided that the liquid is not mixed with the special nuclear material. As an added 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 n.aterial is the preferred means of criticality safety control and is used wherever feasible. When processing fuel elements of more than one plu-tonium or uranium enrichment, at least two positive means of identifying each enrichment are required (e.g., fuel dimensions, color coding, labeling, etc.).
2 witn U0, criticality safety is based entirely on Prior to blending Pu0 2
the critical parameters for Pu0, with no credit for reduced reactivity due 2
to U0. After blending, allowance in the limits may be given for UO2 content 2
if the correctness of the blend is confirmed by a sample analysis.
a s'
1.3-15 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 dimensions are attributed to spherical geometry, unless equipment design assures a geometry less favorable to criticality than spherical (e.g., cylinder or slab).
Safe cylinder and slab dimansions for process vessels are based on the most reactive form of the fissionable material that can reach the vessels.
The structural integrity of safety related items such as shelving for fissile material storage is'at least three times the load capacity pennitted by Criticality Safety Specifications.
Sumps are required to be safe in the event of a credible leakage and accidental spillage from vessels and piping linked to the sump.
Vacuum headers, vent headers, and similar header systems are reviewed in detail for potential criticality hazards.
Pipe connections are not permitted between a fissionable solution system controlled by safe geometry and a system controlled by safe mass.
1.3-16
'In processes conducted behind massive shielding, soluble and fixed neutron poisons such as' boron in solution, pyrex Raschig rings, and steel plates containing boron or gadolinium may be used as a primary means of criticality safety' control.. When a soluble 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, double 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 DOS 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.
Internal audits are performed monthly by a member of the facility operating staff to assure that the operation of a facility complies with the appropriate procedures
-and Criticality Safety Specifications.
Independent audits will be conducted by Nuclear Safety to assure that a facility is being operated within the proper category of criticality safety control; that the handling of. fissionable material is adequately coverad by a CSS; that the limits and controls of applicable CSS are being met; and that
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good safety practices are in effect. BNW nuclear facilities are audited by Nuclear Safety at least twice annually and isolated facilities at least once each year.
The Chairman of the Safety Review Council will be provided a copy of each audit report. A sumary report of these audit activities will be made to the Battelle-Northwest Director at monthly intervals.
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t 1.3-17 Criticality Safety Training 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 the basic Battelle-Northwest criti-cality safety. rules. Periodic training (minimum annual frequency) in emergency action required 'for ari accidental nuclear criticality shall' be con-ducted for. all nonreactor nuclear ' facility personnel.
The' minimum training krogram requirements for all personnel involved in working with fissionable materials at nonreactor nuclear facilities (those performing work and those providirrg supervisory guidance) consist of:
. (' ) Three of four quarterly training sessions which may be primarily 1
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 au'dit and appraisal results.
The following topics shall be covered in at
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least one training meeting each 24 month period:
Aasic criticali.ty principles; methods of criticality safety control; and compa'ny policy and procedures for maintaining cri,ticality safety.
'(2)
Each individual shall demonstrate a satisfactory knowledge of the' requirements an'd procedures pertinent to the individual job assignment. The
.dconstration may be oral, written, operational, or all three.
Reexamination is required:
at least annually on emergency procadures; 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 training, including an auditable record of the-
~ testing, shall'be maintained for each individual.
The training records shall be maintained for' a minimum of two years. - Records shall be sufficient to show the following:
I D
I 9
g.
m 2
1.3-18 T_ raining material covere'd an'd 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 knowledge of the subjects and procedures pertinent to his job assignment.
Criticality Detection System A cr;iticality detection and alarm system is required in any facility containing greater than emot 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' alanns,' power-loss annunciator, a central annunciator and the necessary wiring and controls. ' Audit and trip signals are fed to an annunciator and comparator unit which provides 2-out-of-n coir 3cidence operation and signals any 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 build.ig, are activated. A detailed description of the system design criteria, performance tests, detector placement, calibration and maintenance instructions, and operating experience is availab.le in Criticality Detectio'n and Alann ' System, edited by C. R. Richey and T. W. Jeffs, Bat'.elle, Pacific Northwest Laboratories. December 1977.
A ' description of.the system follows.
Detector
' Neutron sansitive detectors are loc 3ted where at least two datectors
- will' trip with a minimum foreseeable-criticality burst frcm either a liquid or metal system.
This burst produces 20 rads in soft tissue of combined neutron and gamma radiation at an unshielded distance of two meters from the reacting material within-one minute.
The neutron to gamma rat'io 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 shall be'used to compensate for intervening shielding and to ensure the alarm
' system will trip foll'odng the minimum foreseeable burst.
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1.3.
Comoarator LThe comparat,or panel annunciates both visually and audibly any failure or alarm condition ~ of any detector in the building,.
The ccmparator will activate the alarm when two-out-of-n (ng3) detectors trip the alarm circuit.
Redundant " trip circuits shall be included in the comparator.
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4 All circuiuy and controls ass'ociated with the comparator unit shall be protected against unauthorized tampering by the use of key lock doors and switches or key lock switches.
Howler Control Circuit The-howler control circuit shall be fail-safe.
The' fail-safe solid-state electronic timing device should be-used for the howler timer.
Calibration and Testing 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 critical'ity detectors, the detectors shall be re'placed annually with others newly tested and calibrated by personnel of the plant radiation instrument calibration and repair faci;lity.
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'pewer The criticality alarm system in all buildings will be connected to emergency pcwe,r if it is available.
For those buildings, where emergency power is not avail-able, in the event of.an emergency or planned power outage, all work with 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 power supplied to all portions of the' criticality alarm system.
An. annunciator of signal power loss to the criticality alarm system will te' installed in each building at a.locatien which is cccupied during norm 01
-building use.
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1.3-20 Criticality Alarm Sicnal The criticality alarm signal (ah-oo-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 location along the outside of the building.
Radiation Emeroencies Battelle-Northwest emer,gency procedures are maintained in conformance with DOE-RL directives which. require that each separate facility emergency procedure conform to the-plan for that plant area in which the facility is located regardless of which of the'several Hanford contractois may operate
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the facility.
The objectives of these procedures are to minimize the risk' to employees and members of the public in the vicinity of the Hanford Site, and secondarily
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to minim,1ze damage to or loss to use of valuable facilitie,s and equipment in the event of an acci~ dental criticality, fire, explosion, or release of radio-active materi,als.
.Prodedures applying to Battelle-Northwest and Pacific Northwest Laboratory
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(PNL) facilities are review ~ed periodically by' trained radiation protection and safety personnel to assure both their adequacy and their conform'ance to 00E-RL directives.
These precedures contain specific information'regarding the sound
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of the various emergency signal,s, their meaning, the appropriate action to be taken, the location of the staging area to which employees are to evacuate, and the specific plan of accountability for personnel.
The criticality. alarm signals and the appropriate personnel response l
to these signals will-remain uniform in accordance with the established i
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. However, the signals in Battelle-Northwest owned facilities may' be different from those in the DOE owned faciliti.es. The fire alarm system for the Battelle-Northwest facilities is c:mected to the
- Richland fire department; the fire alarm system for DOE faci' es is.cennected to the'00E fire department.
The criticality alarm signals
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terly, and the fire alarm signals will b'. tested semiannually.
Facility emergency procedures will be reviewed annually with the invalved personnel.- Evacuation drills'will be performed in all Battelle-Northwest
- facilities at least annually 'to assure that employees know the meaning of energency ' signals, and know the immediate action response appropriate to each.
The_ systems established by DOE-RL, whereby 00E-RL, management of Hanford contractors and members of established emergency'and technical su'pport teams are-riotified, will be used jn emergency situations.
The authorities and responsbilities of the emergency director and the members of the radiological emergency staff are defined in writing.
Specialized plans for Battelle-Northwest groups who have special responsi-bilities in emergencies (viz., environmental monitoring, radiation monitoring, and the radiological emergency staff) are mai,ntained together with special train-ing programs by Battelle-Northwest.
These plans will be reviewed at least j
annually.
hedical, firefighting, and access control personnel are employees of contractgrs other than Battelle-Northwest.
Emergency plans and training p,cograms for these, groups are established by management of the centractor organizations involved to meet DOE-RL requirements.
Kits centa,ining instruments capable of measuring dose rates that might be encountered during rescue entries"folicwing a nuclear excursion or similarly serious accident and self-reading pocket ionization dosimeters capable of mea-suring gamma doses up to 600 R are maintained at locatiens near but not in Battelle-Northwest or PNL facilities where radioactive and/or fissionable materials are used.
These kits also contain respiratory protective equipment and pro-tective. clothing necessary for building re-entr/.
Facilities and Ecuiement Plans for new facilities or significa'nt modification of existing facilities will be reviewed.by radiation protection, safety, and operating. organization persenrel for adequacy of shielding, interlocks, alarms, ventilation, centainment, and Radiation Zone posting.
In addition, new facilities, major modifications of 9
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l.3-22 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 psrformance of licensed work will be judged by the same 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 those encountered in the performance of work under the Operating Contract with 00E.
Gaseous effluent treatment systems are installed on the exhaust system of any building where a potential exists for the evolution of airborne radioactive.
contamination.
The gaseous effluent systems are designed to maintain effluent releases as far below the limits specified in 10 CFR 20 as practicable.
5.*xce pt 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 filt'ers are tested upon installation to assure that they meet design objective of 99.9M efficiency test for c,old' DOP smoke with particle sizes betwe'en 0.3 and 0.8 um.
All HEPA filters, with the exception 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 practicab.le.
If Jcontinued gene ~ ration of effluents prior to replacement is deemed unadvisable, the operation is terminated pending replacement of the treatment system.
Protective clothing, respiratory protective equipment, radiation detection l-I and measurement instruments, and dose rate measurement systems and equipment are intanded to be uniform for license and Operating Contract work.
The services, equipment, and procedures used will be in accordance with COE contractual requirements established by 00E-RL.
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1.3-23 Materials
-Special nuclear materials used in Battelle-Northwest controlled facilities
.under this license will be identified as such and maintained separately from materials used under the Operating Contract.
Special nuclear materials handled temporarily in a sponsor's facility, except in Agreement States, un' der the terms of this license, will be retained in Battelle-Northwest custody at all times while in the sponsor's facility and will b'e identified and mdintained 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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2.3-15 Activities involving the handling of radioactive material in 3720 Build-ing are conducted in HEPA filtered fume hoods or glove boxes. Three exhaust systems serve the building. Two small systems serve two individual labora-tories. The balance of the building is served by a third system recently installed to replace seven previously individual systems. With this up-grading, all building systems provide two stages of HEPA filtration, and meet current standards.
3708 The _3708 or Radiation Measuremr.nt Laboratory serves as a laboratory for several research and development g'.oups. The structure is one-story concrete 2
block on grade with a concrete fcundation and slab floor. Of 3868 ft total 2
2 area, 3196 ft is used for storage with 672 ft utilized as a common area.
The building is equipped for work with small quantities of highly radio-active materials including plutonium. Air is supplied to the laboratory rcoms through overhead diffusers. Room air is exhausted through a roughing filter and a HEPA filter; glove box air, after undergoing the same process, combines with room air and passes through an additional HEPA filter bank before being released from the building.
Provisions are made to sample the air in the room and stack and to mea-sure the airborne contamination released from or spread within the facility.
A separate building vacuum system is provided which meets the operational requirements of the sampling equipment.
Potentially contaminated liquid wastes are transferred to a r aceiver tank and taken tome 300 Area retention waste system or to the 300 Area
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contaminated waste system, depending on sample results.
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.The Alpha Radiation Facility'is a room in 3708 occupied soley by the Nuclear Waste Technology Programs Department. The personnel of the Process Demonstration section NWT Department control access tothe facility.
The Alpha Radiation Facility and its attendant safety requirements are the responsibility of the Manager of Nuclear Waste Process Demonstration section. The facility is classified as an Isolated Facility,~which administra-tively' limits the amount of fissionable material in the facility to 0.45 of a minimum critical mass. Radiation work procedure is reviewed annually.
No criticality audits are required; however, the facility is surveyed daily during use; and if 'it is operating on a standby status, the facility is surveyed weekly by radiation monitoring, t.
A fire, temperature and smoke detector alarm system has been installed in the 3708 Building. Rooms are protected by combustion particle detectors.
Glove boxes are equipped with quick-disconnect fittings and distribution piping to permit application of dry chemical fire extinguishing materials.
Fire extinguishers are in accessible positions for use by personnel.
331 i
l The 331 Building or Life Sciences Laboratory I, located in the 300 Area, is suited for the performance of a wide variety of biological and ecological research studies. The laboratory provides facilities in which to conduct research in radiation biology relevant to the needs of the expanding use of f
nuclear energy.
It contains quarters for housing and caring of colonies of I
l large and small animals. Special facilities are provic -d for perfoming inhalation toxicology, large animal radionuclide metabolism and toxicity, physiology, pathology, ecology, and aquatic studies primarily related to the effects of specific radionuclides and radiation in living systems.
The laboratory consists of three basic elements molded together into a single building.
The primary element is a three-story structure with a projected area of 2
-67,000 ft consisting of two laboratory floors with a mechanical-electrical services floor. sandwiched in between.
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A.13 has directed and managed the activities of the Radiological Department
.and Calibrations Section of the Radiation Protection Department, served as a technical staff consultant to the Director of the Environmental and Life Sciences Division and is presently Manager of the Occupational and Environmental Safety Department at Battelle-Northwest. As Manager of the O&ES Department he is responsible for the overall Battelle-Northwest radiation protection program. Various technical papers were presented at meetings such as the Health Physics Society, the American Nuclear Society, IAEA symposia and to educational groups. Mr. Unruh is a charter member and current President of the Health Physics Society and is certified by the American Board of Health Physics.
R. A. Libby, Senior Specialist Criticality Safety, Nuclear Technology Section, Energy Systems Department Mr. Libby received his B.S. Degree in Engineering Physics from Oregon State University in 1971 and his M.S. Degree in Nuclear Engine-ering from the University of Washington in 1972. From 1972 to 1973 he sorked as a physicist at Lawrence Livermore Laboratory while taking additional courses in Applied Science at the University of California /
Davis. From 1974 to the present he has been enployed by Battelle-Northwest, first as a shielding specialist then as a criticality safety specialist. As a Senior Criticality Safety Specialist he writes or reviews the technical basis letters for all Battelle-Northwest Nuclear Criticality Safety Specifications and is invoived with plant audits and inspections of Battelle laboratories. He ha: presented papers at several i
ANS national meetings and has attended the Taos, New Mexico short course on criticality safety.
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.c ew A.14-S. M. Durst, Criticality Safety Specialist, Nuclear Technology Section, Energy Systems Department Mr. Durst received his B.S. Degree in Physics from the University of Washington in 1970 and his M.S. Degree. in Nuclear Engineering from Louisiana State University in 1974. After working at the EBR-II facility at Argonne National Laboratory for one year, he joined Battelle-Northwest
- in 1974.
From 1974 to the present he has contributed to a variety or research studies and experimental programs related to criticality safety.
He became-a qualified Senior Experimenter at the Critical Mass Laboratory in l979. Mr. Ourst is the author or co-author of numerous papers in the i
criticality safety field.
D. E. Friar, Senior Engineer, Nuclear Safety, Ra'diation Standards and Engineering i
.Section, Occupational and Environmental Protection Department Ms. Friar received her B.S. Degree in Physics from California State University at Long Beach in 1973. From 1973 to 1974, she was employed by the l
Westinghouse Hanford Company, Hanford Engineering Development Laboratory, as a Criticality Safety Representative for.the Plutonium Fuels Laboratory. Frcm 1974 to the present, she has been employed by Battelle-Northwest, first as a research scientist for the Criticality Safety Analysis Section, and then as a senior engineer'for Nuclear Safety with the Safety and Nuclear Materials 4
Management and the Radiation Standards and Engineering Sections. During this period she performed technical analyses for criticality safety, audited operations for conformance with established criticality safety limits, wrote the criticality safety specifications, and provided criticality safety training on request from operations. Ms. Friar is currently a member of the American Nuclear Society, the Society of Women Engineers, and an Executive Comittee member of the ANS Technical Group for Human Factors Systems.
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