ML19318B074
| ML19318B074 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 05/22/1980 |
| From: | Zeff D BABCOCK & WILCOX CO. |
| To: | |
| References | |
| 16431, NUDOCS 8006250004 | |
| Download: ML19318B074 (35) | |
Text
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&h 7D -/2 of Babcock &WilCOX commercW Nuclear Fuel P ant P.O. Box 800. Lynchburg, Va. 24505 Telephone: (804) 384.5111 May 22, 1980 Mr. L. C. Rou'se, Chief Fuel Processing G Fabrication Branch Office of Nuclear Material Safety and Safeguards Division of Fuel Cycle 6 Material Safety United States Nucicar Regulatory Commission Washington, D. C.
20555
REFERENCES:
(1) SNM-1168, Docket 70-1201 (2) Amendment Application No. 79-3, Dated January 9, 1980
Subject:
AMENDMENT APPLICATION NO. 79-3 Gentlemen:
The Babcock 4 Wilcox Company Commercial Nuclear Fuel Plant requests cmendment of License Number SNM-1168 as previously discussed with members of your staff. The $1400 minor safety amendment licensing fee as required by 10 CFR 170 was submitted with the January 9, 1980 submittal (BGW Check Number 23345).
The areas addressed in the amendment request are as follows:
- Revision of action IcVels for air effluent releases to unrestricted areas.
Revised levels are needed in order to allow for routine localized operations involving pellets outside the controlled area.
A series of detailed controlled experiments were ' performed to deter-mine appropriate controls for maintaining airborne concentrations in such areas as low as reasonably achievable.
During the two calendar quarters that the experiments were performed, extensive surface con-tamination surveys were conducted in the area.
Results of these surveys revealed no new health and safety concerns since existing controls and limits for the uncontrolled area were not exceeded.
Based on these tests and experiments, the most effective air-capture technique was selected for implementation, and we are therefore re-questing a corresponding revision of the action level.
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4 Babcock &Wilcox Mr. L. C. Rouse, Chief Page 2 May 22,1980
- Revision of action levels for liquid effluent releases.
In the past, routine effluent releases from the CNFP retention tank i
had been at levels requiring approval and/or further dilution prior to release. An ultrafilter system was subsequently purchased and' installed at a cost of approximately $30,000 to remove the uranium particulate from certain liquid streams entering the reten-tion tank. The addition of the ultrafilter significantly reduced release icvels, but there are cases where the " cleaned" water from the ultrafilter may not be diluted by the other liquid waste streams (i.e., during periods of plant shutdown, etc.) and therefore would be the only input to the retention t,ank.
This " cleaned" ultrafilter water generally has contamination levels at 20% MPC or below which would exceed the present release levels.
The overall effectiveness of the l
ultrafilter system in removing uranium particulate has been exec 11ent; releases to the environment are approximately one third of the levels experienced prior to using the ultrafiltration system. Therefore, l
the requested 20% action level is not intended to increase radio-activity in effluent releases, but only to reduce the administrative paperwork required during periods of low flow.
i
- Revision of isolation criteria between fuel assembly storage array i
and fuel assembly shipping container loading area. Sections III and V of SNM-1168 presently address the fuel assembly processing and storage area as a single array, with other arrays isolated from it.
Due to limited existing floorspace and the potential need to expand the fuel assembly storage capacity, the fuel assembly shipping container loading area will need to be located closer to the assembly storage rack.
I Section 7.10.3 of Section V of SNM-1168 states that fuel assemblies in adjacent containers will be separated by not less than 18 inches edge to edge.
Pages 184-193 and 196-200 in Section III of SNM-1168 demonstrates the safety of an infinite storage array of fuel assemblies and an infinite array of damaged shipping containers respectively.
l Results show that under all credible conditions the shipping container array is the more reactive of the two.
In addition, it has been determined that the 38" center-to-center distance between two loaded j
containers is equivalent to 18" edge-to-edge separation between i
assemblies in adjacent containers.
Thus, 38" edge-to-edge separation between the storage array and the loading area will provide accepta-ble nuclear interaction control.
Any activity equally or less reactive than the loaded shipping containers'may be conducted at'the same sepa-ration distance away from the fuel assembly storage rack.
l l
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7 Babcock &Wilcox Mr. L. C. Rouse, Chief Page 3 May 22, 1980
- Revised contamination survey frequency.
Presently, we are required to perfonn daily surveys of the lunchroom and locker-room areas even during periods of plant, shutdown and vacation.
Data from previous quarters consistently show that contamination levpis at the lunchroom area during normal powder processing operations have been near zero or at the minimum detectable level as shown below.
Smear Total Survey Average Survey Average 1st quarter 1979 4.3 DPM/100 c
< 100 DPM/50 cm 2nd quarter 1979 2.6 DPM/100 cm
< 100 DPM/50 cm 2
2 3rd quarter 1979
< 1 DPM/100 cm
< 100 DPM/50 cm 2
2 4th quarter 1979 0.0 DPM/100 cm,
< 100 DPM/50 cm2 1st quarter 1980 0.0 DPM/100 cm'
< 100 DPM/50 cm The data summary above clearly shows that such areas do not have a meaningful potential for contamination. The controls placed on persennel and equipment exiting the controlled area effectively precludes contamination spread, and therefore the associated survey frequency could be relaxed without sacrificing employee health and safety.
If you or members of your staff have any questions regarding the above items, please feel free to call me or J. P. Watters at (804) 384-5111.
Sincerely, BABCOCK 4 WILCOX COMPANY C0 ERCIAL NUCLEAR FUEL PLANT
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. N. Zef,f.pger Health-Safety'6 Licensing DWZ:cmm Attachment cc:
J. P. Watters (w/ attachment)
W. F. Heer (w/o attachment)
SNM-1168 DOCKET 70-1201 REVISION INDEX AMENDMENT APPLICATION NO.
79-3 PAGE 1 of 2 INDEX DATE:
5-22-80 Section Remove Add Reason Page Revision Date Page Revision Date III 5
0 4/30/75 5
1 5-22-80 Change to Health-Safety and Licensing III 114 0'
4/30/75' 114 1
5-22-80 Change to Health-Safety and Licensing III 123 0
9/19/75 123 1
5-22-80 Change to Health-Safety and Licensing III 194 - 195 0
4/30/75 194 - 195 1
5-22-80 Revised Interaction IV 13 - 14 0
4/30/75 13 - 14 1
5-22-80 Change to Health-Safety and Licensing IV 38 0
4/30/75 38 1
5-22-80 Change to Health-Safety and Licensing IV 40 0
9/19/75 40 1
5-22-80 Change to Health-Safety and Licensing V
2 1
8/11/78 2
2 5-22-80 Change UO t Uranium 2
0 x ide V
11 - 12 0
4/30/75 11 - 12 1
5-22-80 Change to Health-Safety and Licensing V
13 0
9/19/75 13 1
5-22-80 Change to Health-Safety and Licensing V
14 0
12/01/75 14 1
5-22-80 Change to Health-Safety and Licensing V
17 0
4/30/75 17 1
5-22-80 Change to Health-Safety and Licensing V
24 - 25 0
4/30/75 24 - 25 1
5-22-80 Change to Health-Safety and Licensing V
26 1
10/13/78 26 2
5-22-80 Change to Health-Safety 4
and Licensing V
27 0
9/19/75 27 1
5-22-80 Change to Health-Safety and Licensing V
32 0
4/30/75 32 1
5-22-80 Change to Health-Safety l
and Licensing l
V 34 - 35 0
12/01/75 34 - 35 1
5-22-80 Change to Health-Safety and Licensing V
36 0
9/19/75 36 1
5-22-80 Change to Health-Safety and Licensing
)
V 40 0
12/01/75 40 1
5-22-80 Change UO to Uranium l
2 Oxide
SNM-ll68 DOCKET 70-1201 REVISION INDEX AENDMENT APPLICATION NO.
79-3 j
INDEX DATE:
5-22-80 PAGE 2 of 2 Section Remove Add Reason Page Revision Date Page Revision Date V
69 0
12/01/75 69 1
5-22-80 Revised interaction V
70 0,
12/01/75 70 1
5-22-80 Revised interaction V
76 0
4/30/75 76 1
5-22-80 Air action level change
. V 77 0
4/30/75 77 1
5-22-80 Water action level Change V
84 0
4/30/75 d4 1
5-22-80 Change to Health-Safety and Licensing V
94 4
5/25/79 94 5
5-22-80 Add "*" for clarity 7
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BABOXX & WILCDX OPPANY, CutERCIAL NUQfAR REL PLM USNRC LICENSE SN't-ll68 DOCKET M-1201 III NUCLEAR SAFETY ANALYSIS SECTIm 7.T' General Requirements 7.1.4 Continued modifications to product specificatio'ns or design when re-lating to nuclear safety must be reviewed and approved by the Manager, Health-Safety and Lic$nsing and the Safety Board, prior to initiation.
In those cases where proposed modifications may involve a change in the bases on which nuclear criticality safety was originally assessed, a technical evaluation by the nuclear criticality safety function will be initiated by the Manager, Health-Safety and Licensing.
The nuclear criticality safety function noted above is a separate component within the corporate structure and thus is organizationally independent of the CNFP, with no interest in plant operations, other than the nuclear criticality safety aspects.
By established procedure, analyses performe.1 by the nuclear criticality safety function involving potential changes in the bases upon which plant safety was originally assessed are reviewed for appropriateness of method, validity of assumption, and accuracy of the results prior to application l
in the plant by a qualified individual not involved in the ori,-.,
L ginal evaluation.
Qualifications of the evaluator and re-viewers are given in Section V.
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DATE 5-22-80 REVISION NO.
1 PAGE 5
CLRRENT REVISION:
t l
l SUPERSEDES: PAGE 5
LENRC APPROVAL REFERENCE DATE 4/30/75 REVISIm 0
'BABQXX & WIL(DX C&PANY, CatERCIAL NUCdAR REL PIET USNRC LI NSE SNM-ll68 DOCKET 70-1201
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SECTICN
- 7. 4' Pelletizing 7.4.4 Moderation Control 7.4.4.2 Unit Moderation Control Criteria ADMINISTRATIVE CONTROLS (cont'd) 1.
accuracy, by a second, individual at least as well qualified as the one per-forming the initial evaluation.
Further processing of the SNM is prohibited until the above approval is obtained.
The following points are typical of those in the. process which require dual signature:
- Initial moisture analysis of as-received powder
- Prior to addition of powder lubricant to blender or transport container
- Prior to addition of re-cycle material to a moderation controlled unit, if the ma-terial has been exposed to an uncontrolled environment.
Adherence to the above procedure will be audited by the Health-Safety Supervisor or the. Manager, Health-Safety and Licensing at least monthly.
2.
The addition of powder lubricants to the blender or transport container has been shown to be safe i
under credible accident conditions.
However, in DATE 5-22-80 REVISION NO, 1
PAGE 114 CURRENT REVISION:
SUPERSEMS: PAGE 114 USNRC APPROVAL REFERENCE DATE 4/30/75 REVISION 0
1 BABQXX & WILG)X C&PANY, CTPERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET 70-3201 SECTION III NUCLEAR SAFETY ANALYSIS - PELLETIZING 7.4' Pelletizing 7.4.4 Moderation Control 7.4.4.3 Unit Area Moderation Control'(continued) over moderation controlled units or arrays, the overhead shielding essentially serves as a technique for providing "second order" protection. The shield-ing is not required to protect the array from accidental moderation due to pipe rupture since that contingency has been provided for through baffling and double containment.
PERIODIC EVALUATION OF MODERATION CONTROL EQUIPMENT The routine calibration and standards analysis pro-gram for moderation control instcunentation has b
been described previously. While safety within an operational area is the responsibility of the area supervisor, Health-Safety conducts routine system au'dits to verify that all activities are conducted safely and in accord with license conditions.
Additional nuclear safety and health physics audits are conducted by qualified B&W personnel, from outside the CNFP, at least quarterly.
At least monthly, a detailed inspection will be con-ducted by the Manager, Health-Safety and Licensing, or his qualified designee.
Inspection scope, DATE 5-22-80 REVISION NO.
I PAGE 123 CLERENT REVISION:
l SUPERSEDES: PAGE 123 IENRC APPROVAL REFERENCE DATE 9/19/75 0
REVISION t
BABC00( a WILG)X C00i#, CORERCIAL NtJCIEAR FLEL PLAK 1
USNRC LICENSE SNt+-ll68 DOCKET 70-1201 SECTIO 4 III NUCLEAR SAFETY ANALYSIS 7.'10 Fuel Assembly Storage 7.10.1 Continued Interaction:
The 21 x 38 inch c/c array is the more reactive. Since it has been assumed infinite in the x-y plane, its calculated k-effective is
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higher than that of the combination of the two arrays. The separa-tion between the two arrays is greater than 38 inches so that no third type of array is created.
Therefore, values obtained for the infinite 38 x 21 inch c/c array may be conservatively used for the actual combination. For the maximum credible degree of interspersed moderation, k-effective is less than 0.4.
Similarly, all other arrays not isolated from the assembly storage array are also free draining and cannot accumulate low density moderator. Since they are also low enriched uranium
(<_ 4 weight %) the same principle applies--the actual combination of arrays is less reactive than the infinite array of 38 x 21 inch c/c assemblies.
7.10.2 Section III, Part 7.10.1 discusses the nuclear safety of an infinite array of parallel fuel assemblies stored in 21 inch by 38 inch or 36 inch center-to-center spacing in a vertical con-figuration.
Part 7.9 validates the nuclear safety of fuel as-sembly processing.
Nuclear interaction between fuel assembly processing and assembly storage is limited to less than the in-teraction within the storage array alone due to geometric relation-ship. Nuclear interaction between assembly storage and assembly shipping container loading is limited to the interaction associ-ated with an array of damaged loaded shipping containers as described on Pages 196-200 of Section III of this part..Since a planar array of assemblies on 21 inch centers is subcritical for credible interspersed moderation conditions (Part 7.10.1)
(Part 7.10.1), the planar array in the assembly f
l94 IMTE 5-22-80 REVISIOl NO, 1
PAGE CLERENT REVISION:
SUPERSEDES: PAGE l94 LENRC APPROVAL REFERENCE l
IRTE 4/30/75 REVISIO4 0
BABQXX & WIL(DX C&PM, CatERCIAL NUGEAR REL PLM USNRC UCENSE SNPt-ll68 DOCKER 70-1201 SECTIm III NUCLEAR SAFETY ANALYSIS
-7.10 Fuel Assembly Storage 7.10.2 Continued processing area, where four foot separation is maintained, is likewise subcritical. Two or more planar arrays have been i
shown to be subcritical in combination when center-to-center distance is not less than 38 inches, and with major faces opposed, the situation resulting from consideration of an l
infinite storage array.
Rotation of one planar array 90 degrees from the vertical to l
present its edge to the face of the opposing array, while main-taining the specified separative distances, significantly reduces interaction probabilities by presenting less " effective" surface area for interaction thus,.in effect, extending the effective separation distance. This demonstration accurately reflects. conditions at the junction of the fuel assembly pro-cessing and storage area, and also at the junction of the assem-bly storage and shipping container loading area.
Under normal operating conditions the activities will be con-ducted in the absence of any significant moderation; under i
such conditions, fuel of 4 wt.% enrichment and less cannot be made critical.
DATE 5-22-80 REVISION NO.
1 PAGE 195 CLRRENT REVISION:
SUPERSEDES: PAGE 195 USNRC APPROVAL REFERENCE l
DATE 4/30/75 REVISIm 0
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BABQXX & WIL(DX C&PANY, UNERCIAL NlX1 EAR REL PLM USNRC UCENSE SNM-ll68 DOCKET 70.1201 SECTIO 4 IV HEALTH PHYSICS 8.2' Cont'd limited to the following (10 CFR 20.101)
- Whole body, trunk and head, active blood forming organs, lens of eyes, and gonads 1.25 Rem / cal. qtr.
- Hands and forearms, feet and ankles 18.75 Rem / cal. qtr.
- Skin of whole body 7.50 Rem / cal. qtr.
However, AEC Form 4 documentation is provided for each permanent employee and in specific cases the Manager, Health-Safety and Licensing and the Plant Manager may authorize exposures greater than the above provided 10 CFR 20.~101 (b) and 20.102 requirements are satisfied.
In these cases, the " maximum permissible exposure" is taken to be:
- 3 rem per calendar quarter to the whole body,
- 5 rem per calendar year to tne whole body,
- And, accumulated dose is < 5(N-18) rem where N is the individual's age at last birthday.
8.3 Exposure of employees to airborne contaminants is limited by the concentrations set forth in 10 CFR 20, Appendix B, Table 1 averaged over 40 working hours in any 7 consecutive days.
DATE 5-22-80 REVISION NO.
I PAGE 13 CURRENT REVISION:
SUPERSEDES: PAGE 13-USNRC APPROVAL REFERENCE I
DATE 4/30/75 0
REVISION
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BABUXX & WILU)X OWANY, CTPERCIAL NinEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET M-E l
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SECTIm 8.3 Cont'd Permissible exposure levels are adjusted based on the actual time the individual is present in the area. Additionally, respirators may be used and exposure results adjusted according to the protection factors defined in Parag'raph,12 of this section, and in Section V.
In actual practice exposure to airborne act ity is maintained as low as practicable by engineered or other controls and a design / operational criteria of < 25% of Appendix B concentration
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levels is applied.
8.4 Minors (persons under 18 years of age) are limited to doses not greater than 10% of those pecified in 8.2.
Exposure of minors to airborne contaminants will not exceed the levels contained in Appendix B, Table II of 10 CFR 20.
Minors are not employed at CNFP as a matter of policy.
8.5 Exposure of visitors in all cases is limited to 10% of the levels specified for occupational exposure in 10 CFR 20, unless documen-tation of the radiation exposure history is available.
8.6 Eating and smoking are prohibited in controlled areas.
Smoking l
may be permitted in change rooms if assurance of adequate radiological hygiene practices are maintained. At the discre-tion of the Manager, Health-Safety and Licensing drinking fountains may be located within controlled areas where non-transportable
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materials are being processed.
Drinking facilities are provided in change areas.
DATE 5-22-80 REVISI m NO.
I PAGE 14~
1 CLERENT REVISION:
SLPERSEDES: PAGE I4 USNRC APPROVAL REFERENCE 0
DATE 4/30/75 REVISION
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BABC00( & WIL(DX C&PANY, C0WERCIAL NtX1 EAR REL PUNT USNRC' LICENSE SNM-ll68 DOCKET M-1201 SECTICN IV HEALTH PHYSICS 16.' Cont'd 16.2 In addition to the above, logs are established and maintained to document all routine monitoring activities including:
- Air sampling
- Radioactive Material shipments
' - Bioassay and Environmental samples
- Source control and leak tests
- Smear and penetrating radiation surveys
- Equipment history, use and calibration
- Pre-operational and operational evaluations
- First aid (per OSHA requirements)
- Contaminated air handling system inspections
- Health physics, Nuclear safety, and industrial safety inspections and audits.
16.3 In-plant records, and reports submitted to regulatory bodies, are reviewed periodically by the Manager, Health-Safety and Licensing ***
and in the course of routine audits prodived by other B&W components.
il Record retention requirements are in accord with 10 CFR 20.
16.4 Where applicable, all records are maintained using terminology l
equivalent to 10 CFR 20. Where because of type of sample or l
the analytical technique employed, other units are more descriptive or useful, Health-Safety may maintain records in the units most appropriate. Typically, unit terminology will be as noted below:
i 38 DATE 5-22-80 REVISION NO.
1 PAGE CLERENT REVISION:
SUPERSEDES: PAGE 38 USNRC APPROVAL REFERENCE 4/30/75 MTE REVISION g-
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BIBQXX & WIL(DX C&PANY, COMBCIAL NtX1 EAR REL PUNT f
USNRC UCENSE SNWll68 DOCKER A1201 IV HEALTH PHYSICS SECTION 17.' Continued posting plant entrances with signs incorporating the radiation symbol and the following warning:
CAUTION RADI0 ACTIVE MATERIALS ANY AREA OR CONTAINER WITHIN THIS PLANT MAY CONTAIN RADI0 ACTIVE MATERIAL.
4 This sytem has been applied effectively at the CNFP for the past four years.
17.1 Personnel access to the plant, and supporting buildings is con-trolled through a guard station which is constantly manned. The plant area is surrounded by a chainlink fence, and all access points, other than the main gate, are locked when not in use.
Key control is the responsibility of the plant engineer.
For purposes of plant and personnel protection and access control, the CNFP " restricted area" is considered to consist of all areas within the perimeter fence.
In specific instances, the Manager, Health-Safety and Licensing may modify the restricted area as defined above in order to accommodate unusual or temporary conditions.
17.2
" Controlled areas" within the CNFP are established as neces-sary to assist in the protection of personnel or in the control of contamination spread.
Criteria specified in 10 CFR 20.202 and 20.203 are applied to i.he determination for the necessity d
of establishing controlled areas.
i i
DATE 5-22-80 REVISION NO.
1 PAGE 40 CURRENT REVISION:
SUPERSEmS: PAGE 40 USNRC APPROVAL REFERENCE DATE 9/19/75 REVISION 0
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BABC00( & WILCDX C(PP#f(, COMERCIAL NUCLEAR REL PLM USNRC LI NSE SNPt-ll68 DOCKET 70-1201 SECTICN V CONDITIONS 2.0 Authorized Activities are as follows:
2.1 Fabrication of nuclear power fuel assemblies using Uranium 0xide powder ***
or pellets as starting material, through pellet prodaction, fuel i
assembly fabrication, packaging and delivery of fuel assemblies j
to a carrier for transport.
2.2 Disposal of various solid, liquid, and airborne wastes resulting from the authorized activities, excluding on-site burial.
2.3 Laboratory operations such as but not limited to chemical analysis, metallographic analysis and testing.
2.4 Storage of nuclear materials in various forms and facilities appropriate to safety.
2.5 Activities of a process and product development nature for those technologies authorized by SNM 1168.
2.6 Maintenance of the facilities and equipment under adequate control to assure safety.
2.7 Possession of authorized by-product, source, and special nuclear materials in packages approved pursuant to 10 CFR 71 for the purpose of delivery to a carrier for transport, and in private carriage between NRC licensed facilities within the United States.
1 DATE 5-22-80 REVISION NO.
2 PAGE 2
l CURRENT REVISION:
SLPERSEDES: PAGE 2.
USNRC APPROVAL REFERENCE DATE 8/11/78 I
REVISION
BABQXX & WILCDX C&P#O UMERCIAL NtX1 EAR REL PLM USNRC UCENSE SNM-ll68 DOCKER M-1201 SECTICN V CONDITIONS 6.0' General Specifications - Implementation of the technical specifications will be accomplished through application of the following general specifications.
6.1 Control Program Specifications and design criteria for purchased or locally fabrication equipment where nuclear and radiological safety i
considerations are involved are approved by a knowledgeable representative of Health-Safety and Licensing.
Before being released for production operation, new equipment is tested j
to assure that safety specifications are satisfied.
Safe
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geometry equipment will be measured by a knowledgeable person to ascertain that it is of proper dimensions before it is put into service. Where operational safety is based wholly er in part on the use of electrical or mecnanical interlocks, the proper functioning of interlocks shall be verified upon installa-tion and on an annual basis thereafter.
Sintering furnace safety.
interlocks will be tested prior to each startup.
Routine plant inspections place added emphasis on new operations.
No equipment is used after being removed from service until an
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equipment check'ouf f$r continued effectiveness of safety related parameters is performed.
i DATE 5-22-80 REVISION NO.
1 PAGE 11 CLERENT REVISION:
SUPERSEDES: PAGE 11 USNRC APPROVAL REFERENCE DATE 4 / 30/ 75 REVISION 0
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BABOXX & WILCDX 00WANY, C0tERCIAL NtGEAR REL PLWT WNRC UCENSE SNft-ll68 DOCKET M-1201 SECTim V CONDITIONS 6.0' General Specifications 6.1 Radiation instruments are calibrated at the frequency indicated in Section V, Part 8.3.4.
Calibration is performed by Health-Safety personnel.
Ventilation, containment, aiid air cleaning equipment is routinely inspected by Health-Safety personnel to assure continued effectiveness and compliance with license specifications.
These inspections are recorded and a periodic review is per-formed by the Health-Safety Supervisor, and Manager, Health-Safety and Licensing.
The Health-Safety Supervisor or qualified designee is responsible for control of the air sampling and contamination survey pro-gram, and evaluates sample results on a daily basis. Sample and survey records are periodically reviewed by the Manager, Health-Safety and Licensing.
Instances of inadequate control of contamination or air effluent levels, and of equipment operation not in accordance
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with established nuclear and radiation safety and license l
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l DATE 5-22-80 REVISICN NO.
I PAGE 12 CURRENT REVISION:
SUPERSEDES: PAGE 12 USNRC APPROVAL REFERENCE DATE 4/30/75 REVISION 0
BEXX & WILGX COPPN#, COMERCIAL NIX 1 EAR REL PIET USNRC LICENSE Snit-ll68 DOCKET 70-1201 V CONDITIONS SECTICN 6.0' General Specifications 6.1 Control Program (continued) parameters are reviewed by either the Health-Safety Supervisor or the Manager, Health-Safety and Licensing who may order the operation suspended if timdly compliance cannot b'e assured.
Disciplinary action can be recommended if warranted.
SAFETY REVIEW BOARD A Safety Review Board shall be established to consider the effect of new or revised facilities, to analyze equipment and processes involving radioactive materials and to evaluate the continuing effectiveness of established controls and safeguards, including maintenance of "as low as practicable" criteria.
In the case of minor procedural changes and where existing safety practice remains unchanged, the Manager, Health-Safety and Licensing may determine that Board review is not necessary. The Board shall be chaired by the Manager, Health-Safety and Licensing, and the permanent membership shall consist of representatives of CNFP operational and technical management. Technical representatives of consulting organi-zation shall be included as necessary (LRC, Nuclear Criticality Safety Group).
The Manager, Health-Safety and Licensing reviews all requests for changes in process and equipment which involve radioactive material and determines if Board DATE 5-22-80 REVISION NO.
1 PAGE 13 CtRRENT REVISION: ***
SUPERSEDES: PAGE 13 USNRC APPROVAL REFERENCE DATE 9/19/75 REVISION 0
a BANDO( & WILG)X C&PANY, CatERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTION 6.0' General Specifications 6.1 SAFETY REVIEW BOARD (continued) review is necessary.
The Board will not approve any new or revised facility, equipment, or process until it has received written determination (from the Manager, Health-Safety and Licensing) for the necessity of a nuclear safety evaluation and/or license amendment, and has reviewed where required, a properly documented nuclear safety evalua-tion or approved license amendment.
Board meetings may be convened at the discretion of the Manager, Health-Safety and Licensing, but shall be held at least quarterly.
Records of Safety Review Board proceedings, including support-ing calculations and approvals, will be retained for at least six months after the completion or termination of the subject activity.
RECORDS Operating logs and records of reviews, tests, inspections, personnel qualifications, and audits shall be maintained on file for review by B&W management and regulatory agencies.
Duration of record retention is based on existing federal regulations, license specifications, customer requirements and pr~ dad management practices.
6.2 EMEF rLAN An emergency plan and implementing procedures for coping with radiation emergencies shall be maintained.
Emergency pro-cedure content shall include:
a.
An organization for coping with radiation emergencies, including
- definition and assignment of authorities, responsibilities, duties, qualification, and training requirements.
Notification steps for "in-house" personnel and federal, state, and local authorities shall be included.
b.
A list of employees and other individuals, in addition to those assigned to the emergency organization, who have special qualifications for coping with emergency conditions.
c.
The actions planned to protect the health and safety of individuals and to prevent damage to property both within and outside the site boundary in the event of credible emergencies, including the means for determining the mag-nitude of the release of radioactive materials, guidelines for evaluating the need for notification of local, state, and Federal agencies, and the type and extent of protec-tive action to be taken within and outside the site boundary.
DATE 5-22-80 REVISION NO.
I PAGE I4 CURRENT REVISION:
SUPERSEDES: PAGE I4 USNRC APPROVAL REFERENCE 12/1/75 0
REVISION DATE
BABQXX & WIL(DX OPP ##, CutERCIAL NUCLEAR REL PIM USNRC LICENSE SN?t-ll68 DOCKET E1201 SECT!ct V CONDITIONS 6.0 General Specifications 6.3 Personnel Training (continued) is maintained by Health-Safety.
The training of personnel assigned to'the Health-Safety func-tion is the responsibility of the Manager, Health-Safety and Licensing.
The extent and depth of the training is based on the specific job assignment involved.
Heal th-Safety monitoring personnel shall reveive a combination of formal and "on-the-job" training such that they can successfully 1
demonstrate their proficiency in basic nuclear and radiation physics monitoring and control techniques and reguP, tor, re-quirements. The degree of proficiency will be detannined on l
an individual basis by practigd and written examinations, the results of which will be maintained on file ty Health-M fety.
Member of thd CNFP emergency monitoring team shall be trained l
by Health-Safety in the proper technique of accident control.
Training program content shall be as outlined i: 6.3.1 through 6.3.3.
c DATE 3-22 80 REVISION NO.
I PAGE 17 CURRENT REVISION:
SIFERSEDtiS: PAGE 17 USNRC APPROVAL REFERENCE DATE 4/30/75 REVISIm 0
MKDO( & WILCDX CufM., C0ffERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET k.1201 SECTim V CONDITIONS 6.0' General Specifications G.5 Enrichment Control (continued) re-establishment of the identity.
6.6 Procedure Control, Written procedures for the conduct of specific operations in-cluding maintenance and development work within the plant are prepared by the functional component responsible for that activity and are reviewed and approved by appropriate respresentatives of plant management. Where the activity under consideration involves SNM or radioactive materials, specific written approval by the Manager, Health-Safety and Licensing or his designee is required prior to implementa-tion of the procedure. Adherence to procedure is required of all personnel.
Procedures for operations where nuclear and radiological safety are involved shall include specific reference to, applicable safety requirements.
Procedure and format shall be such that operations are clearly detailed and specific directions are provided for operation under both normal and abnormal conditions.
Deviation from written pro-cedures for the handling of SNM shall be approved by the Manager, Health-Safety and Licensing, or his qualified alternate.
Procedural control of activities at the CNFP are categorized as follows:
DATE 5-22-80 REVISION NO.
1 PAGE 24 CURRENT REVISION:
SUPERSEDES: PAGE 24 USNRC APPROVAL REFERENCE DATE 4/30/75 REVISION O'
MEKDO( & WILCDX C&PANY, CutERCIAL NU0fA REL Pl#T USNRC LI NSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECT!W 6.0' G_eperal Specifications 6.6 Procedure Control (continued)
- Procedures developed by Health-Safety specifying the method by which safety related functions are to be accom-plished.
Suchproceduresmaybef$rinternalHealth-Safety use or may be intended for general distribution to affected individuals within other components.
Health-Safety proce-dures shall be appreted in writing by the Plant Manager, the Manager, Health-Sant, and Licensing, and other members of plant management / supervision if it is determined by Health-Safety that their area of responsibility is affected by the procedure.
- Safeguards procedures provide tech-niques for the accountability and measurement of SNM. Such procedures will be approved in writing by the Manager, Health ***
Safety and Licensing and by affected plant management.
- Manufacturing, Quality Control, and selected Maintenance /
Engineering procedures, where nuclear or radiological safety,
~
license conditions, or regulatory requirements are involved require prior approval by the Manager, Health-Safaty and Licensing, as well as approval by affected members of plant management.
i 1
I DATE 5-22-80 REVISION NO.
PAGE 25 l
CURRENT REVISION:
f SUPERSEDES: PAGE 25 USNRC APPROVAL REFERENCE DATE 4/30/75 REVISION 0
^
BABCDO( & WIL(DX COPANY, CatERCIAL NUCLEAR REL PIET USNRC LICENSE SNtt-ll68 DOCKET 70-3201 SECTim V CONDITIONS 6.0 General Specifications 6.6 Procedure Control (continued)
Revised procedures shall be subject to approval in the same manner as new procedures.
Health-Safety procedures will be reviewed at least annually for technical correctness and applicability.
Procedure distribution and control is the responsibility of plant supervision.
6.7 Audits and Quality Assurance An internal audit and quality assurance program shall be maintained to provide assurance that plant activities are conducted safely and in accord with license specifications.
The audit program shall be the responsibility of the Manager, Health-Safety and Licensing.
Health-Safety supervision shall conduct, at least weekly, a formal audit of plant status relative to nuclear and radio-logical safety.
At the discretion of Health-Safety, the audit may consist of an in depth evaluation of a specific area or may be of a generalized nature providing an overview of total plant activities. Audit results shall be documented, reported to plant management and supervision as appropriate, and will be maintained on file by Health-Safety for at least 6 months.
Health-Safety audits shall be conducted by personnel technically qualified in operational nuclear and radiological safety and in the application of license specifications.
DATE 5-22-80 REVISION NO. 2 PAGE 26 CURRENT REVISION: ***
SUPERSEDES: PAGE 26 USNRC APPROVAL REFERENCE DATE 10/13/78 REVISION I
LGi3 met 5hWLWEEbtiM e USNRC LICENSE SNM-3168 DOCKET 70.1201
,SECTICt1 V CONDITIONS
- 6. 'O General Specifications J'
6.7 Audits and Quality Assurance (continued)
Health-Safety personnel shall, as part of their routine duties, conduct informal daily audits of plant ' activities.
Independent auditors shall conduct inspections as follows:
- Nuclear safety
- quarterly
- Health physics quarterly The audit program shall include physical inspections and records review for the industrial, nuclear, and radiological safety elements of plant activities including:
- Effectiveness of procedural controls impacting on operational safety parameters
- Review of equipment design, layout, and operation for continued compliance with safety design criteria
- Audit of operating records, where such records provide a means of verifying procedural compliance with safety specifications
- Periodic review and evaluation of contamination survey data Independent auditors' reports shall be submitted to the Plant Manager. The Manager, Realth-Safety and Licensing shall review audit findings for the satisfactory completion of any necessary remedial actions.
Audit findings are reviewed by the Safety Review Board.
DATE 5.-22-80 I
27 REVISION NO.
PAGE CURRENT REVISICN:
SUPERSEDES: PAGE 27 USNRC APPROVAL REFERENCE DATE 9/19/75 REVISION 0
1
BABOXX & WILCDX CRP#f/, UNERCIAL NU(1 EAR REL PIM
^
USNRC LICENSE St&t-ll68 DOCKET 70-1201 NDITIONS SECTIO 4 7.'0 Nuclear Safety - Technical Specifications 7.1 General Requirements (continued) 7.1.2.1 The Manager, Health-Safety and Licensing, l
with the concurrence of the LRC Nuclear Cri-ticality Safety Group, will detennine which arrays are more reactive than those used as a basis for a, b, and c or are best represented as slabs for nuclear interaction purposes.
In these cases, the interaction acceptance cri-teria will be evaluated on an individual basis by the LRC Nuclear Criticality Safety Group or it will be the equivalent of eight inches (20.3 cm) of water or as defined in 7.1.2(d)or(e).
7.1.3 Isotopic enrichment of SNM will be verified by shipper's certifications with added assurance by Quality Control sfatistical overchecks.
l DATE 5-22-80 I
REVISION NO.
PAGE 32 CURREffT REVIS10ri:
SUPERSEDES: PAGE _
32 USNRC APPROVAL REFERENCE DATE 4/30/75 RFViSIm 0
BABC00( & WILOR C&PM/, CatERCIAL NUCEAR REL PLAW USNRCLICENSESNM-ll68 DOCKET D 1201 SECTIO 4 V CONDITIONS 7.d Nuclear Safety - Technical Specifications 7.1 General Requirements (continued) 7.1.4.2 Proposed modifications shall be demonstrated to satisfy the following criteria to approval:
a.
The license condition specified in this part are not modified.-
b.
Nuclear safei;y calculations are performed in a manner equivalent to those originally utilized to demonstrate safety for the area and type of operation under consideration.
Calculations shall consider both individual unit and interaction safety and shall apply the basic assumptions and input parameters used in the original calculations.
c.
Calculated reactivity levels do not increase based on the assumptions and input parameters described below.
7.1.4.3 The review and approval procedure shall be as follows:
A written request shall be submitted to the Manager, a.
, Health-Safety and Licensing describing the proposed change.
b.
The proposal will be reviewed by the Manager, Health-Safety and Licensing for content, completeness, and compliance with license DATE 5-22-80 REVISIQ1 NO, I
PAGE 34 CURRENT REVISIGl:
SUPERSEDES: PAGE 34
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USNRC APPROVAL REFERENG DATE 12/1/75 REVISIQ4 0
BABC00( & WILOX C0FPM, C0FERCIAL NUCLEAR REL PLAW lENRC LICENSE SNtt-ll68 DOCKET 70.1201 SECTIQ1 V CONDITIONS 7.D Nuclear Safety - Technical Specifications 7.1 General Requirements (continued) 7.1.4.3 Continued b.
specifications and, where nuclear safety evalua-tion is required, forwarded to the Nuclear Criticality Safety Function (NCSF).
c.
The NCSF performs necessary calculations in accord
?-.,
with 7.1.4.2 b and forwards the results in writing to the Manager, Health-Safety and Licensing.
Evaluations performed by the NCSF are reviewed as specified in Part 5.5 of this section.
d.
The results of the nuclear safety calculations and the recommendations of the NCSF and Manager, Health-Safety and Licensing are reviewed by the Plant Safety Board and the permissibility of the change determined and documented.
e.
Appropriate personnel are notified in writing of the result of the review by the Manager, Health-Safety and Licensing.
f.
The proposed change will not be implemented until a pre-operational audit (Ref.Section V, Part 6) has been satisfactorily completed.
g.
Correspondence calculations and other ritaterial will be maintained on file by Health-Safety 35 DATE 5-22-80 REVISION NO.
1 PAGE CURREtR REVISION:
SUPERSEDES:
Pace 35 uSNRC APPROVAL REFERENCE DATE 12 N 75 REVISION _ 0
BAB000( & WILODX C0FPMY, CORERCIAL NUCLEAR REL PLANT USNRC LICENSE SNti-ll68 DOCKET 70.1201
~
V CONDITIONS SECTIO 4 7.0 Nuclear Safety - Technical Specifications 7.1 General Requirements (continued) 7.1.4.3 Continued g.
for at least 6 months following termination of the operation.
7.1.4.4 Nuclear safety evaluation is not required where the anticipated change does not affect existing nuclear safety controls or bases.
The Manager, Health-Safety and Licensing or his qualified designee determines when a change in product, process, or equipment requires a nucle.sr criticality evaluation or license amendment.
I I
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I DATE 5-22-80 REVISICH NO.
1 PAGE 36 CURREllT REVISIG1:
SUPERSEDES: PAGE 36 USNRC APPROVAL REFERENCE DATE -. 9/19/75 REVISICN 0
BABC00( & WILODX CDP #iY, CORERCIAL NUCLEAR FLEL PLAff
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USNRC LICEllSE Stittll68 DOCKET 70.1201 SECTIQ1 V C0flDITI0flS 7.0 Nuclear Safety - Technical Specifications 7.2 Materials Specifications - The following specifications for materials are based on the various criticality control evaluations discussed in Section III and may be considered typical of material processed.
7'. 2.1 Fuel Pellets Composition:
Uranium 0xide Size:
.300" diameter
.600 235 Enrichment:
to 4.05%
0 fl0TE: An increase from A.00 to 4.05 w/o does no+ signi-ficantly affect nuclear safety calculations based on 4 w/o mater?al.
I DATE 5-22-80 REVISION tJ0, PAGE 40 CURRENT REVISION:
SUPERSEDES:
PAGE 40 USNRC APPROVAL REFERENCE DATF 12/1/75 ppyrgim 0
BABC00( a WILGX C& PAW, C&PERCIAL NUCLEAR REL PUNT USNRC LICENSE SNft-ll68 DOCKET 70.1201 SECTim V CONDITIONS 7.0 Nuclear Safety - Technical Specifications 7.9 Fuel Assembly Processing (cont'd) 7.9.1 Continued accumulation of fuel rods once the fuel rods have been removed from the geometric safe 4.0" slab.
A mirimum separation of 4 feet will be maintained be-tween bundle assembly stations, and the equipment will be such that liquids cannot be retained in and around the in-process operation.
7.9.2 Assembly processing operations once the fuel rods are restrained in the fuel assembly configuration may be performed without moderation control.
The assemblies will be separated by at least 36" center-to-center.
i' 7.9.3 For the purposes of nuclear interaction control, the fuel assembly processing and fuel assembly storage arrays are considered as a single array with adjacent arrays being no more reactive than an array of fuel assemblies loaded in adjacent containers as described in Part 7.10.3 of Section V.
7.10 Fuel Assembly Storage and Packaging
}
7.10.1 Fuel assembly dust wrappers, if used, will be arranged to permit drainage of water from within. Moderation, I
such as polyethylene, etc., will not be permitted
{
within the assemblies.
I DATE 5-22-an REVISICN N0.
I 69 PAGE CURRENT REVISION:
SUPERSEDES: PAGE 69 USNRC APPROVAL REFERENCE DATE 12/1/75 REVISION 0
),
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BAB000( & WILWX C& PAIN, C&itRCIAL NUCLEAR FLEL PLAK USNRC LICENSE SNM-ll68 DOCKER 70-1201 SECTIO 4 V C0ilDITIONS
- 7. '0 Nuclear Safety - Technical Specifications 7.10 Fuel Assembly Sterage and Packaging (continued) 7.10.2 Fuel assemblies may be stored in racks meeting the following spacing criteria:
a.
Fuel assemblies in linear arrays will have mini-mum 21" center-to-center spacing.
b.
Fuel assemblies in planar arrays will be arranged on minimum-36" x 36" center-to-center spacing.
c.
A minimum of 38" center-to-center spacing will be maintained between the nearest assemblies of adjacent planar of linear storage arrays.
The following restrictions shall be imposed on fire fighting within the assembly storage array:
a.
The use of hoselines shall be prohibited unless authorization has been received from a management representative of the plant emergency response organization.
b.
Area postings will be maintained at the array perimeter specifying limitations on fire fight-ing techniques.
c.
Simultaneous application of more than one hoseline is not authorized.
7.10.3 Fuel assembly packaging and unpackaging operations involving licensed tiodel B shipping containers will be performed within the following limitations:
a.
Fuel assembly packaging will be in accord with the requirements of the cont.iner certificate.
b.
Fuel assemblies in adjacent containers will be separated by not less than 18 inches edge-to-edge.
c.
The edge-to-edge seperation betwaen fuel assemblies *"*
in the storage rack and assemblies in shipping containers shall be greater than or equal to the minimum center-to-center distance between loaded shipping containers (38 inches).
l l
l l
DATE 5-22-80 REVISIO1 NO.
1 PAGE 70 CURRENT REVISIO4:
SUPERSEDES: PAGE 70 USNRC APPROVAL REFERENCE DATE 12/1/75 REVISIg; 0
a
,.1
BMK00( & WILCDX COPPAf(, CCHERCI/L NUClfAR REL PUNT
.r USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTIQ4 8.0 Technical Specifications - Radiation Safety 8.1 Effluents to Unrestricted Areas 8.1.1 Continued c.
The following program shall be instituted to assure that airborne releases to uncontrolled areas are main-tained as low as practicable:
Quarterly Avera'ge - % of 10 CFR 20
- u*
Appendix B, Table 2 LIMIT ACTIO14 1 10% of "MPC" None required.
11 - 20%
Conduct investigation of system and correct if possible.*
21 - 75%
Visually inspect system. As soon as practicable, conduct efficiency test. Detemine and correct cause.**
> 75%
Conduct immediate investigation to determine and correct problem in ventilation system. Maintain addi-tional Health-SOfety surveillance of system to monitor contamination levels until problem is corrected.
,,end weld operation area - None required end weld operation area - None required at 1 0% MPC 5
- x*
Health-Safety shall maintain records of investiga-tions and actions resulting therefrom.
d.
Pre-filters serving equipment in the pelletizing area wil,1 be instrumented and monitored as speci-fied in 8.1.la above.
8.1.2 Potentially contaminated liquid effluents will be controlled through a retention tank system with dilution and mixing capabilities and shall be evaluated i
DATE 5-22-30 REVISION NO.
1 PAGE 76 CURRENT REVISION:
SUPERSEDES: PAGE 76 USNRC APPROVAL iEFERENCE DATE 4/30/75 REVISION 0
J
r BABUXX & WILCDX C&PANY, COMERCIAL NUClfAR REL PLANT USNRC LI NSESNM-ll68 DOCKET M-1201 V CONDITIONS SECTICN 8.'O Technical Specifications - Radiation Safety 8.1 Effluents to Unrestricted Areas 8.1.2 Continued for compliance with 10 CFR,20, Appendix B limits prior to release to unrestricted areas. The following actions, at the contamination levels indicated, will be undertaken in order to maintain contaminated liquid effluent re-leases as low as practicable:
% 10 CFR 20 App. B. "MpC" Action
< 20%
No action required.
21 - 75%
Individual releases authorized by Plant Manager or his alter-nate.
> 75%
Discharge prohibited. Waste routed for further treatment or disposal by burial.
Health-Safety shall maintain records of investigations and actions resulting therefrom.
a.
Retention tanks will be inspected monthly for sludge accumulation.
l DATE 5-22-80 REVISION NO.
I PAGE 77 CURRENT REVISION:
SUPERSEDES: PAGE 77 USNRC APPROVAL REFERENCE DATE 4/30/75 REVIS!0N 0
i
BABC00( & WILCDX C&P##, C0ffERCIAL NUCLEAR REL PLAR
\\
U3HRC LICENSE SNtt-ll68 DOCKET 70.1201 V CONDITIONS SECTION 8.'0 Technical Specifications. Radiation Safety i
8.2 Ventilation, Containment, and Airborne Activity Control (cont'd) 8.2.3 Air Sampling (continued)
The following action points shall apply to the routine air sampling program:
Exposure - % MPC (Time Weighed Average)
Ac' tion
< 25%
No action required.
> 25%, < 50%
Report to Manager, Health-Safety and Licensing or designee.
Evaluate operation and contain-ment.
Increase air sample frequency if indicated.
> 50%, < 75%
Report to Manager, Health-Safety and Licensing. ***
Take steps necessary to lower airborne activity to acceptable range.
> 75%
Notify Plant Manager.
Terminate operation if > 100% MPC.
[1odify or Tnstall air capture devices.
Increase air sample frequency.
Health-Safety shall maintain records of investigations and corrective actions taken.
The dove action levels do not apply to non-routine operations conducted with the cognizance of l
l t
l DATE 5-22-80 REVISION No.
I PAGE 84 CURRENT REVISION:
SUPERSEDES: PAGE 84 USNRC APPROVAL REFERENCE
] ATE.
4/30/75 REVISION 0
F BABCDOC & WILODX C0FP#ff, CORERCIAL NUCifAR REL PUNT USNRC LICENSE SitM-ll68 DOCKET 70-1201 SECTIG1 V CONDITIONS 8.
Technical Specifications - Radiation Safety 8.4 Personnel Monitoring and Contamination Control 8.4.4 Personnel Contamination 8.4.4.1
- a. - Survey anti-contamination clothing, if con-tamination levels are more than 350 but less than 3500 DPM/50 cm2, or equivalent, don clean protective clothing over the contami-nated garments. ' Anti-contamination clothing with contamination levels greater than 3500 DPM/50 cm2, or equivalent, shall be removed.
Remove shoe covers worn in controlled areas, or place clean shoe covers over contaminated shoes.
b.
Other than as noted above, use of anti-contami-nated clothing for temporary or non-routine activities shall be as stated in Paragraph 8.4.6 of this section.
8.4.5 Surface Contamination Control The following criteria shall be applied to monitoring and control of surface contamination.
The levels shown below represent contamination levels which, when exceeded, will cause clean-up activities of the affected area to be initiated.
^jf%DiVV.
Area Actfon tevel Survey Frecuency 2
- 1. Coetrolled tellet Perovable:
5.000 DPrV103 cm L'eekly f' *.
Total 50.cou r/iV 53 cm ecco (hot area) rt te)
Tota 2
OF When po.rder processing c;erations (not includit;d::.;11 were ros, tine ci 'ity control activities) are being conducted. In r.o be core than c,ne week be* ten surveys.
200CP.M/100c-j Flonthly 3.
Clean Kerovable:
(Re.alader of Total 500 CPty 50 cm plant and office area)
The lunchroom and locker rooms shall be surveyed daily when in use and removable contamination kept as low as reasonably l
achievable.
t l
DATE 5-22-80 REVISION NO.
5 PAGE 94
- ^dd*d l
CurnENT nEvlsica:
16431 SUPERSEDES: PAGE 94
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USNRC APPROVAL REFERENCE DATF 5/25/79 REVISift1 4