ML19332B101

Safety Evaluation Supporting Revised License SNM-1227

ML19332B101
Person / Time
Site:	Framatome ANP Richland
Issue date:	07/31/1980
From:	Crow W, Soong A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML19332B098	List: ML19332B097 ML19332B100 ML19332B101
References
NUDOCS 8009250478
Download: ML19332B101 (45)

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{{#Wiki_filter:. C:1 4 d SAFETY EVALUATION REPORT BY THE DIVISION OF FUEL CYCLE AND MATERIAL SAFETY RELATED TO THE NRC SPECIAL NUCLEAR MATERIAL LICENSE FOR THE EXXON NUCLEAR COMPANY FUEL FABRICATION PLANT RICHLAND, WASHINGTON DOCKET NO. 70-1257 LICENSE NO. SNM-1227 ) JULY 1980 j i 8009250 b7T i-

b a o CONTENTS Page I. INTRODUCTION................................................ 1 A. General................................................ 1 B. Location Description................................... 1 C. License History........................................ 1 II. AUTHORIZED ACTIVITIES....................................... 6 A. General Summary........................................ 6 B. Process Description (UO Building Operations).......... 8 2 Ir'roduction....................................... 8 1. c 2. Conversion Operations.............................. 8 3. Pellet Fabrication................................. L 4. Fuel Cladding and Assembly......................... 9 5. Scrap Recovery..................................... 9 6. Liquid Waste Disposal.............................. 9 7. Solid Waste Disposal............................... 9 8. Waste Uranium Recovery Facility (WUR).............. 9 III. POSSESSION LIMITS........................................... 10 A. Uranium (Material, Form, Quantity)...................... 10 B. Plutonium (Material, Form, Quanti ty).................... 10 IV. FACILITIES.................................................. 11 Building or Facili ty Activities............................. 11 V. LICENSE APPLICATION.......................................... 12 A. R e v i ew H i s t o ry.......................................... 12 B. Compliance History...................................... 12 C. Current Application..................................... 13 VI. ORGANIZATION AND ADMINISTRATIVE PROCEDURES................... 13 A. Organization and Responsibilities....................... 13 NFD Industrial Health and Safety Council................ 13 ALARA Committee......................................... 13 i

CONTENTS (Continued) Page Vice President and Executive-In-Charge, Fuels Manufacturing................................... 15 i Plant Managers.......................................... 15 Supervisor, Radiological Safety......................... 15 Plant Cri ticali ty Safety Engineer....................... 15 Manager, Licensing and Compliance, Operating Facilities. 15 Health Physics Component................................ 15 Criticality Safety Component............................ 16 8. Minimum Technical Qualifications........................ 16 Supervisor, Radiological Safety......................... 16 Health Physics Technicians.............................. 16 Plant Criticality Safety Engineer....................... 16 Manager, Licensing and Compliance, Operating Facilities.................................. 16 Health Physics Component................................ 16 Criticality Safety Component and Second Party Reviewer................................. 17 C. Administrative Procedures............................... 17 D. Audits and Inspections.................................. 17 E. Personnel Training...................................... 19 F. Records................................................. 19 VII. NUCLEAR CRITICALITY SAFETY.................................. 20 A. Introduction............................................ 20 8. Technical Criteria...................................... 20 C. Organization and Administrative Requirements............ 22 D. Conclusion.............................................. 23 VIII. RADIATION SAFETY........................................ 23 A. Radiation Safety Administration................. 23 B. System of Exposure Controls and Exposure Levels Experienced.................................... 25 C. Bioassay Program........................................ 29 D. Use of Respi ratory Protective Equipment................. 29 E. Control of Surface Contamination........................ 29 F. Effluent Contro1........................................ 30 G. Conclusion.............................................. 31 ii

CONTENTS (Continued) Page IX. EMERGENCY PLAN............................................... 32 X. FIRE SAFETY................................. 32 XI. P LANT D ECOMMI SS ION ING........................................ 33 XII. CONCLUSION................................................... 34 APPENDICES Appendix 1-Discussion of License Conditions Appendix 2 - Environmental Protection. (Appendix 2 is to be issued as a supplement to this report following completion of the environmental impact appraisal for the license renewal.) LIST OF FIGURES Figure Number Title Page 1 Area Map Showing Major Geographic and Geologic Features of the Pacific Northwest........................... 2 2 Richland Area and Exxon Nuclear Company Fuels Plant....................................... 3 3 Site Plan, Exxon Nuclear Company, Inc., Horn Rapids UO Fuel Fabrication Plant............ 4 2 4 Local Area Map Showing Major Geographic and Geologic Features Near the Exxon Nuclear Company Fuels Plant Site.......................... 5 5 Safety Related Organization................ 34 6 Approval and Responsibility Matrix................ 18 fii

I. INTRODUCTION A. General The primary function of the Exxon Nuclear Company (EN) plant at Richland, Washington, is the conversion of low enriched (less than or equal to 5 wt% U-235) uranium hexafluoride to uranium dioxide for use in fuel for light-water-moderated power reactors. Until early 1974, mixed uranium dioxide-plutonium dioxide fuel was produced in developmental quantities in the Mixed Oxide & Speciality Fuels (MO&SF) Building. Operations with plutonium have been discontinued since 1974 and nearly all of the plutonium is stored encapsulated in fuel, rods or in sealed NRC-approved containers. Current possession limits include 10,000 kilograms of U-235, of which 300 kilograms may be contained in uranium compounds enriched to a maximum of 7.2 wt% in the U-235 isotope and the balance contained in uranium compounds enriched to a maximum of 5 wt% in the U-235 isotope, and 100 kilograms of plutonium of which at least 90 kilograms is in encapsulated form. From time to time EN has processed limited quantities of uranium fuel enriched up to a maximum 13 wt% in U-235, under amendments to the license which have since terminated. To provide for such operations i.1 the future, EN proposes to allow up to 200 kilograms of the 10,000 kilogram U-235 possession limit as uranium compounds enriched to a maximum of 19.99 wt% in U-235. The distri-bution of the 100-kilogram plutonium possession limit would be changed so that all would be contained in encapsulated fuel rods or NRC-approved containers except for 500 grams as Pu02 contamination on fuel fabrication equipment and one milligram and not more than 1.5 millicuries as contained in sealed sources and standards. B. Location Descriition The Exxon Nuclear fuel fabrication plant is located on a 320 acre site, 0.9 mile west of the inte4section of Stevens Drive, the main route to the DOE Hanford Reservation from the south, and Horn Rapids Road, a secondary highway to the west, within the north boundary of the city of Richland in southeastern Washington State. The site is 370 feet above sea level. Figure 1 shows the site in relation to major nearby geographic and geologic features, Figure 2 shows the Richland area and the plant, and Figure 3 shows the locations of the facilities on the site. Further geographic and geologic features of the site are shown on Figure 4. C License History The license was first issued to Jersey Nuclear Company on December 14, 1970, primarily to authorize possession and storage only of UFs at maximum 5% U-235 enrichment. The license was subsequently revised, on September 14, 1971, to authorize processing operations with low enriched uranium, but was conditioned to expire within 4 months and to require the submittal of supplemental informa-tion to the Environmental Report. The license was extended and amended to permit limited operations with mixed oxide in the Mixed Oxide & Speciality Fuels Building pending the environmental review. The name of the licensee was

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. changed from Jersey Nuclear Company to Exxon Nuclear Company, Inc., in an amendment issued March 22, 1973. The license was revised and issued for a full 5 year term on July 18, 1974, following issuance of the Final-Environ-mental Statements for the Uranium 0xide Plant and Mixed Oxide Fabrication Plants, in March and June 1974, respectively. Exxon Nuclear filed an application for renewal transmitted by letter dated May 31, 1979, and since July 31, 1979, the license has remained in effect in accordance with the timely renewal provisions of Subsection 70.33(b) of 10 CFR Part 70. The renewal application consists of two sections. Section I, including the appendices, contains the proposed license conditions and Section II is the safety demonstration. The Section II information is primarily a listing of the applicable demonstration i'nformation as given to support past amendment applications and, hence, previously reviewed by the NRC. II. AUTHORIZED ACTIVITIES A. General Summary The revised license would authorize Exxon Nuclear to perform the following activities at the Richland site: Location Material Activities UO2 Bldg. Uranium Compounds All operational steps of fuel (up to 5 w/o U-235) manufacturing from UFs - UO2 conversion to packaging finished fuel elements, scrap recycling and reprocessing, process tests, associated quality control activities. U0 (5 to 19.99 w/o All operational steps of fuel 2 U-235) manufacturing involving U0, 2 associated quality control activities, no operations involving gas or liquid forms. M0&SF Bldr Pu & Pu0 -UO Vault storage, repackaging, fuel 2 2 rod down-loading, contaminated process equipment storage. UO (up to 19.99 Storage, blending, pressing, sintering, 2 w/o U-235) fuel rod loading and down-loading, fuel rod welding, fuel rod autoclaving, fuel element assembly, process tests, associated quality control activities.

. Location Material Activities ELO Bldg. Uranium Compounds All operational steps of fuel (up to 19.99 manufacturing involving uranium w/o U-235) compounds, process tests, no operations involving UFs gas, no operations involving liquid forms of uranium of enrichments above 5 w/o U-235. ET Bldg. U0 (up to 5 w/o Hydraulic flow tests involving 2 U-235) single fuel elements. WUR Bldg. Uranium Compounds Mechanical operations involved in (Up to 5 w/o U-235) recovering uranium from solid wastes. Packaged Radio-Uranium Compounds Storage of closed containers of active Materials (up to 5 w/o U-235) product, scrap and waste materials Storage Bldg. which are free of significant external contamination. Materials U0 (up to 5 w/o Storage of closed and sealed containers 2 Warehouse U-235) of UO powder, pellets, and fuel rods. 2 Special Enriched U0 (5 to 19.99 Storage of closed containers of UO 2 2 Uranium Storage w/o U-235) powder which are externally free of Trailer significant contamination. Laundry Uranium Compounds Dry-cleaning of contaminated Facility (up to 5 w/o U-235) protective clothing and equipment. UFe Cylinder UFs (up to 5 w/o Outside storage of UFs cylinders Storage Areas U-235) (full and empty). SNM Accountability Uranium Compounds Transfer, mixing, and sampling of Measurement (up to 5 w/o contaminated liquid wastes. Station U-235) Process Chemical Uranium Compounds Storage and solar evaporation of Waste Storage (up to 5 w/o U-235) contaminated liquid wastes. Lagoon System Retention Tanks Uranium Compounds Interim storage of potentially (up to 5 w/o U-235 contaminated liquid wastes. Packaged Fuel U0 (up to 19.99 Outside storage of fuel packed for 2 Storage Areas w/o U-235) shipment; the transport containers are closed, sealed, and properly labeled for shipment.

. Location Materia Activities Packaged Waste Uranium Compounds Outside storage of packaged Storage Areas (up to 19.99 w/o contaminated materials; the outer U-235) containers are DOT Specification containers, and they are closed, and adequately sealed and labeled. B. Process Description (U0 _ Building Operations) 2 1. Introduction - The main process cperations are described under the headings of (a) conversion operations, (b) pellet fabrication, (c) fuel cladding, assembly and test, (d) scrap recovery, (e) liquid waste disposal, and (g) solid waste disposal. 2. Conversion Operations - The process of chemically converting the uranium fluoride raw material to uranium dioxide is car"ied out in a system of parallel process lines which use the conventional ammonium diuranate (ADU) process. These operations are carried out in closed equipment, generally cylindrical vessels of limited diameter or volume, designed to ensure nuclear criticality safety. The UFs is received in standard 2-1/2-ton cylinders in NRC-and 00T-apprcved shipping packages. Prior to process use, UFs cylinders are stored in areas where they are protected from physical damage. As required, a UFs cylinder is removed from the storage area and connected to one of the conversion lines. The UFs is vaporized by heating the cylinder using steam or electrically heated air in the chests in the UFs vaporization areas near the conversion lines. The vaporized UFs is hydrolyzed to uranyl fluoride (UO F ) and hydrofluoric 2 2 acid (HF) by mixture with water. The uranyl fluoride is subsequently converted to an ADV slurry by addition of ammonium hydroxide. The ADU slurry is dewatered by centrifugation and drying and fed to an externally gas-fired cylindrical calciner. In the calciner, the ADU is converted to the solid UO 2 by heat and the introduction of hydrogen. The ammor,ia and steam in the calciner off gases are water scrubbed, dried, and double filtered through HEPA f'.lters prior to discharge to the atmosphere. The U0 powder from the reduction furnace is 2 either vacuum transferred to powder blending hoppers for subsequent processing or collected in storage containers, sampled and stored. 3. Pellet Fabrication - Dry powder from storage is blended, milled, slugged and granulated. Following any one of these steps the powder may be placed cans for storage. Following the addition of a lubricant and blending in the cans, the oxide powder is pelletized and the pellets sintered in a reducing atmosphere. The sintered pellets are ground to size, washed, dried, and inspected.

_g. 4. Fuel Cladding and Assembly - Fuel p'ellets are loaded into empty fuel capsules (tubes) which are then plugged and seal welded. The sealed rods are inspected, cleaned, autoclaved, and leak tested. The tested rods are assembled into fuel assemblies. Some of the fuel assemblies are hydraulically tested in the Engineering Test Facility (ET). The nuclear criticality safety of the pellet fabrication and :ubsequent operatia s is based primarily on the use of favorable slab geometry. 5. Scrap Recovery - The basic process for the purification-recovery of contaminated scrap involves mechanical treatment, nitric acid dissolution, a cycle of solvent extraction for purification of the uranium, precipitation of the uranium as ammonium diuranate, and calcination-reduction of the ADU. The scrap recovery operations use favorable geometry equipment or safe mass limits to ensure nuclear criticality safety. 6. Liquid Waste Disposal - All uranium contaminated liquid wastes and high level chemical liquid wastes are discharged to the onsite Process Chemical Waste Storage Lagoon System. The ultimate disposition of sludges and solids removed from the lagoons will be as solid radioactive waste buried at a licensed facility. Sanitary wastes, including drains from showers in the change rooms, discharge to a sanitary sewer system leading directly to to EN-City Lift Station (i.e., discharge to Richland sewer system). Procers cooling waters, which are isolated from the actual process atmospheres by double physical barriers, are handled separately from. sanitary and process chemical wastes. Cooling water may be discharged to the municipal sewerage system, used to irrigate the EN property, or discharged to the Process Chemical Waste Storage Lagoon System. 7. Solid Waste Disposal - Solids contamine.a0 with radioactive materials are stored within the exclusion area in NRC-approved containers awaiting treatnent and/or shipment. Uranium-contaminated solid wastes which contain amounts of uranium larger than desirable to discard are held for uranium recovery. Radio-active solid wastes are disposed of by a private waste disposal contractor who is licensed and equipped to manage such wastes. The continued integrity of the containers of waste in long term outside storage is confirmed by quarterly inspections.

8. Waste Uranium Recovery Facility (WUR) - Exxon Nuclear plans to recover the uranium from the stored contaminated solids in a new building to be known as the Waste Uranium Recovery Facility (WUR).

(See Figure 3, page 5, for the i location of the WUR on the site.) The construction of the WUR and dry opera-tions, such as sorting, have been authorized by a recent amendment to the existing license. The WUR is to be licensed and built in two stages. The initial WUR Building will have a ground floor area of 2,400 square feet. The exhaust gases from the WUR will be double HEPA filtered, and continuously monitored and controlled to meet the concentration limits applicable to the i 00 plant. Criticality safety for the dry end of the WUR will be assured on a 2 safe batch basis. All storage areas associated with the dry end of the WUR

' will be controlled on a safe batch basis. (The wet operations will be the subject of a separate amendment application.). The building was designed to meet a variety of national-and local codes and standards including the Uniform Fire Code. III. POSSESSION LIMITS Material Form Quantity A. URANIUM (Maximum of 10,000 kg of contaiaed U-235) a. Uranium of any a. any 1 35 grams for enrichment analytical purposes b. Uranium compounds with b. any solid, but subject to 1 200 kilograms of uranium of over 5 wt% special process require-contained U-235. but not greater than ments in Appendix I, 19.99 wt% U-235 Section 1 c. Uranium of 1 5 wt% c. Any covered by authorized Up to a maximum U-235 enrichment activities of 10,000 kilo-g rat '. of contained U-235, including a and b above. B. PLUT0NIUM (Maximum of 100 kilograms) a. sources and standards a. sealed a. < 1 milligram and 51.5 millicuries b. Pu0 b. contamination on b. 1 SQQ grams 2 internal surfaces of fuel fabrication equipment. c. Pu02 or c. encapsulated in fuel c. Up to a maximum Pu0 -UO rods or in sealed 100 kilograms of 2 2 NRC-approved containers plutonium including a and b above. i

, IV. FACILITIES Building or Facility Activities UO2 Building UFa conversion, pelletizing, ceramic processing, encapsulation, assembly of fuel rods into assemblies, laboratory operation, scrap recovery, loading of finished assemblies into shipping containers. Mixed 0xide & Speciality Plutonium may only be stored except that plutonium Fuels Building (M0 & SF) may be removed from storage for repackaging or downloading of fuel rods. The main activity is fabrication of poison fuel (Gd 0 -UO ) rods and 23 2 speciality fuel fabrication operations including welding of thermocouples to fuel rods and assembly of speciality elements. Packaged Radioactive Storage of closed containers of product, scrap, Materials Storage and waste materials (free of significant external Building contamination). Engineering Laboratory U0 fuel development on a pilot scale, including 2 (EL0) chemical and mechanical processing and testing. Engineering Test (ET) Hydraulic flow and mechanical testing of single Building completed fuel assemblies. Waste Uranium Recovery Recovery of uranium from solid wastes by Facility mechanical treatment. UFs rylinder Storage Areas Outside storage of UFs cylinders - full or empty. Process Chemical Waste Storage and solar evaporation of contaminated liquid Storage Lagoon System wastes. Special Enrichment Storage of closed containers of U02 powder which Uranium Storage Buildings are externally free of s'gnificant contamination. Laundry Dry cleaning of contaminated protective clothing and equipment (uranium operations only). l Packaged Waste Storage Outside storage of packaged contaminated materials - l Areas the outer containers are DOT specification containers, closed, sealed, and labeled. l 1 I

. V. LICENSE APPLICATION A. History of Regulatory Review The safety review of Exxon Nuclear's renewal application included an evaluation of the application transmitted by letter dated May 31, 1979, the superseding application transmitted by letter dated February 22, 1980, and supplements transmitted by letters dated March 13, April 29, June 5, June 19 and June 27, 1980, a review of the compliance history, and a detailed review of the organization, administration, radiation protection, and nuclear criticality safety programs. Receipt of the renewal application and the intent to prepare an assessment and take licensing action were noted in the Federal Register on September 25, 1979 (44 FR 55254). During the period of initial safety review, A L. Soong and R. L. Stevenson spent November 27 through 30, 1979, at the Uf plant accompanying Mr. W. Cooley of Region V, Office of Inspection and Enforcement (IE) on an inspection. Mr. Cooley is the principal safety inspectcr of the Exxon Nuclear plant from IE. Draft questions (covering all aspects of safety and including comments from the IE inspector) resulting from the initial licensing staff reviews of the renewal application were discussed and explained to Exxon Nuclear personnel by Soong and Stevenson during the visit, and were formally sent Exxon a.. clear by letter dated December 10, 1979. A copy of the report of the visit by Soong and Stevenson, dated December 7, 1979, is in Docket File 70-1257. The report (No. 70-1257/79-08) of Cooley's inspection of the Exxon Nuclear plant was issued January 22, 1980. No items of noncompliance with NRC requirements were identified within the scope of the inspection. Answers to the NRC questions cn the license renewal application were given with the Exxon Nuclear letter of February 22, 1980, and reflected in changed pages in the superseding application. B. Compliance History A review was made of the licensee's recent health and safety compliance history using reports of inspections made by Region V, Office of Inspection and Enforcement personnel. The period examined was August 1, 1974, through December 1979. For the period reviewed, there wcre 15 inspections pertaining to healtn and safety, effluent control and emergency procedures. Items of noncompliance were identified in 4 of the 15 bispections. These non-compliance items concerned proper posting of criticality anu. 3diation areas, inadvertent transfer of SNM in excess of consignee's license limit, incorrect storage of SNM, failure to maintain frequency of internal audits, and failure to maintain written procedures for opening packages. None of the noncompliance items identified in the over-5 year period reflected basic weakness in the program or resulted in adverse effects to the health of the employees, or to the health and safety of the public. Exxon Nuclear responded to the noncompliance items with prompt corrective actions that were reported to the Region V Office of Inspection and Enforcement.

. C. Curred Application in the application, Exxon Nuclear Company has demonstrated that it has the necessary technical staff with the proper qualifications to administer effective :.uclear criticality and radiation safety programs. The following sections contain a description of the principal aspects of the Exxon Nuclear organization, administrative procedures, and nuclear and radiation safety programs, as proposed by Exxon Nuclear, and the additional license conditions developed by the staff of the Uranium."uel Licensing Branch, Division of Fuel Cycle and Material Safety, Office of Nuclear Material Safety and Safeguards. VI. ORGANIZATION AND ADMINISTRATIVE PROCEDURES A. Organization and Responsibilities Operations at the Exxon Nuclear Richland site are administered by a staff organized according to Figure 5. The organization provides separate, independent and parallel lines of authority and reporting for the production and safety functions. Thus, within the Fuels Manufacturing Department, the plant safety and security staff report to the Manager, Auxiliary Ope ations, who has a position of authority comparable to the facility managers. Furthermore, the basic safety criteria are established by specialists within the Corporate Licensing and Compliance Department, which reports to the company president through a different chain of command than that of the operations groups. Exxon Nuclear has committed to a policy of safe operation without detrimental effects to the environs, and the responsibility for establishing and assuring adherence to the policy rests with the President, Exxon Nuclear Company. The Preradent has implemented the policy through delegation to department managers responsible for radioactive material processing. Fuels Manufacturing Department (FMD) Industrial Health and Safety Council The Council meets monthly to review practices and trends in all areas of safety and to recommend changes to prevent recurrence of unusual incidents. Council membership includes the Vice President and Executive-in-Charge, FMD (Chairman); the Industrial Safety Engineer; the Manager, Auxiliary Operations; key safety engineers and specialists; and section and appropricte subsection managers of the Fuels Manufacturing and Corporate Licensing and Compliance Departments. Designated members of the Council make monthly inspections of housekeeping and safety practices and report the findings to the Council. ALARA Committee An ALARA Committee of the FMD Industrial Health and Safety Council maintains awareness of trends in employee radiation exposures and radioactivity releases. The membership of the Committee includes the Manager, Licensing and Compliance, Operating Facilities ' chairman), the Health Physics Specialist, the Supervisor of Radiological Safety, and the Managers of Manufacturing Engineering,

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L3 FIED L _ _.J m 2 Safety Relate,l Organfration C 3 t-- w $) d r - - - - -- - - - - M,M's,'M' --------- g I l l President & Chief l [ l Emecutive Officer l p I l I s i I I Vice President & faccutive-in-Charge Vice President & Esecutive-In-Charge Ilce President & faecutive-in-Charge futt5 FWdifACTURING [NGINEERING & TECalN0 LOGY pgojtcys E thnager flanager m nager Hanager a h ufacturing Purchasing & Logistics suclear fuels Engineering Corporate Licensing & Compilance Department A ri I l f I .I Plant l D e'r a"t i o nsA'III*'Il l fuelsDevelooment& Testing (ET) C "'9*# "*9'I m nager Nuclear Criticality g N r., UO2 Do toaistfes Lgg,,,,,g g g,,pyg,,C, tar,N sn.ni g_ m Operating facilities -PIir. IX) & Speciality Hgr., Plant Nuclear flaterials __LuclLflant Security 2 W" A ** Health Physics Component IF)r.,Ibnufacturing Industrial Safetyl IftS}DCtrina Comronent _ Criticality'54fety s Comoonent lbjr., fac. & (quip- {_ Plant Criticality ment Engineering (flDs Safety Engineer I The Plant. Criticality Safety Enginee-also performs the duties of ngr., rrocess & mini Supervisor, Radio-the Industrial Safety Engineer. Ioaicai Saf'tr .cnndettnceria-2The Manager, Licensing and Compliance, Operating Facilities, is currently performing the duties of the Health Physics Component. tunager llealth Physics _jigjp tenan_cg_. Technicians m-

, Maintenance, UO2 Plant, and MO&SF Plant. The Committee makes a formal annual report to the FMD Industrial Health and Safety Council evaluating the employee exposures, release data, controls, and practicality of further improvement. Vice President and Executive-In-Charge, Fuels Manufacturing The Vice President and Executive-In-Charge, FMD, is the senior site representative. He is responsible for the overall management of the engineering, design, development and fabrication of nuclear fuel. Plant Managers The Plant Managers direct the operations of the fuel manufacturing facilities and are responsible for the safety and environmental effects of those operations. Their specific responsibilities include preparation of operating procedures, training of employees, compliance with license conditions, and membership in the Emergency Cadre and the ALARA Committee. Supervisor, Radiological Safety The Radiological Safety Supervisor directs the activities of the Health Physics Technicians. The radiological safety programs for which he is responsible are established in accordance with criteria provided by the Hea; % Physics Component of Licensing and Compliance. The programs include air 3ampling, contamination and radiation surveys, bioassay, in vivo examination, and records. The Radiological Safety Supervisor has authority commensurate to Plant Managers and can shut down any operation he deems unsafe or not in compliance with license conditions. Plant Criticality Safety Engineer The responsibilities of the Plant Criticality Safety Engineer include prepar-ation of criticality safei.v specifications based on criteria and analyses provided by Licensing and Compliance, auditing shop operations, and assisting in criticality safety training of personnel. Manager, Licensing and Compliance, Operating Facilities The Manager, Licensing and Compliance, Operating Facilities, is responsible for developing, administering and auditing the licensing, health physics, criticality safety and environmental surveillance programs for all Exxon Nuclear facilities at Richland. He has the authority to shut down any operation he deems unsafe, detrimental to the environment, or not in compliance with the license. Health Physics Component The Health Physics Component is part of the Licensing and Compliance, Operating Facilities Section of the Corporate Licensing and Compliance Department. The i responsibilities of the Health Physics Component include providing technical l i

. bases, criteria, and methods related to health physics, compliance inspections, assistance in employee training, membership on the ALARA Committee, and establishing frequencies for bioassay, radiation surveys, and contamination surveys. This position is currently being filled by the Manager, Licensing and Compliance, Operating Facilities. Criticality Safety Component The Criticality Safety Component is part of the Licensing and Compliance, Operating Facilities Section of the Corporate Licensing and Compliance Department. The responsibilities of the Criticality Safety Component include providing technical bases, criteria, and methods related to nuclear criticality safety. The component also provides criticality safety analyses, assists in employee training, performs compliance inspections, and approves criticality safety specifications. B. Minimum Technical Qualifications Minimum technical qualifications have been established for the safety related staff positions, as follows: Supervisor, Radiological Safety - The minimum qualifications of the Radiological Safety Supervisor will be a B.S. degree in a technical field with 5 years' experience in "adiation safety, or, in the absence of a degree, 10 years' experience will be required. Health Physics Technicians - The minimum qualifications of Health Physics Technicians will be a high school diploma with 2 years of radiation monitoring experience or an additional 2 years of radiation monitoring experience in lieu of a high school diploma. Plant Criticality Safety Engineer - The minimum qualifications will be a B.S. degree in a technical field with 3 years' experience in nuclear activities, or an additional 6 years of similar experience in lieu of a B.S. In either case, at least one year of this experience will be in criticality safety. Manager, Licensing and Compliance, Operating Facilities - The minimum qualifica-tions of the Manager, Licensing and Compliance, Operating Facilities will be a B.S. degree in a technical field wit 10 yea. s' experience in the nuclear energy field, of which 4 will have been in positions with nuclear safety responsibility. Health Physics Component - At least one member of the component will have a B.S. degree in science or engineering with 5 years experience in radiation protection, including at least 2 years of radiation protection experience allied with nuclear fuel fabrication.

s . Criticality Safety Component and Second Party Reviewer - At least one member of the Criticality Safety Component and each second party reviewer of nuclear criticality safety analyses will have a B.S. degree in science or engineering with at least 3 years of experience in nuclear criticality safety, including 2 years of criticality safety analysis. C. Administrative Procedures Organizational responsibilities and authorities are defined by upper Exxon Nuclear management through policies, job descriptions and procedures. The respective department managers approve written personnel qualifications for key positions below the department manager level. The hiring of managers and key specialists in plant operations, health physics, nuclear criticality safety and nuclear materials management is subject to approval by the cognizant vice presidents of the company. Exxon Nuclear management is committed to assure that procedures important to plant operations are properly prepared and reviewed, are kept current and are followed by operating personnel. The information in Figure 6 illustrates, among other things, the responsibilities of the various management personnel and organizational components in the preparation, review and approval of written criteria and procedures important to plant operation. Figure 6 thus summarizes in readily comprehensitie form certain administrative requirements defined in the text of the Conditions section of the license application. The figure helps make it clear that there is appropriate expertise and depth in the development and review of criteria and procedures at least equivalent to the corresponding requirements in the existing licenses for similar fuel processing operations. To assure that long-term procedures such as manuals and operating procedures are kept current, they will be reviewed for updating at least annually. To assure that procedures are followed, any observed failure to follow procedures will be promptly corrected and any procedure found to be incorrect or which fails to describe actual operating practice will be promptly revised. D. Audits and Inspections Personnel responsible for safety audits are generally identified in Figure 6. As noted in the description of responsibilities, monthly inspections of house-keeping and safety practices are made by designated members of the Fuels Manufacturing Department Industrial Health and Safety Council and results reported to the Council. The Health Physics Component of Licensing and Compliance, Operating Facilities Section, makes monthly inspections of radiation protection practices and

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. exposure controls. Results of these inspections are documented, including any recommended corrective actions, and distributed to appropriate managers in the Fuels Manufacturing and Corporate Licensing and Compliance Departments. As part of their normal activities, the Radiological Safety Supervisor and Health Physics Technicians make periodic inspections of all areas of the plant where radioactive materials are stored, processed or handled. Detected infrac-tions are corrected on the spot. Serious infractions and noncompliance with license conditions are documented and distributed to appropriate managers. The Criticality Safety Component of Licensing and Compliance, Operating Facilities, and/or the Plant Criticality Safety Engineer make at least monthly inspections of criticality safety practices at the plant. Results of these inspections are documented, including any recommended corrective actions, and distributed to appropriate managers in the Fuels Manufacturing and Corporate Licensing and Compliance Departments. While performing their daily dut'es, Health Physics Technicians are alert for infractions of criticality safety specifications. Detected infractions are communicated to the Plant Criticality Safety Engineer. E. Personnel Training New employees are given initial instruction by knowledgeable personnel adequate to allow safe beginning of on-the-job training, with complete instruction accomplished within 2 weeks after starting work. In addition to the normal on-the-job-training, employees are instructed in radiation protection and criticality safety requirements and procedures, industrial safety, fire protec-tion, and emergency procedures. The degree of training is commensurate with the employee's responsibilities and the extent of his contact with radioactive and fissionable materials. Affected employees are notified and instructed when changes are made in radiation protection or criticality safety controls, or in emergency procedures. Safety topics are routinely discussed in monthly safety meetings. Each employee routinely working with special nuclear material receives annual refresher training in radiation protection and criticality safety. Exxon Nuclear has committed to the maintenance of records of employee indoctrination and training for a minimum period of 5 years. F. Records In the Conditions section of the license application, Exxon Nuclear has committed to the mainterance of records of various required actions (such as the records of criticality analyses, internal audits, FMD Industrial Health and Safety Council meeting reports, and routine surveys) for a minimum period of 5 years except where NRC specifies longer retention times for specific records. l l

a . VII. NUCLEAR CRITICALITY SAFETY A. Introduction The Exxon Nuclear system of nuclear criticality safety at the Richland site is based on: 1. Technical criteria using established policies, analytical methods, data and safety margins. 2. Qualified nuclear criticality safety staff with specified responsibility and authority. 3. Administrative requirements for written operating procedures, review of criticality safety analyses, audits of operations, posting of limits ar.d training. An important element, listed in item 3 foregoing, is that the criticality safety criteria provide for reviews by two different qualified reviewers of changes that involve criticality safety considerations. It is also relevant that there is a depth of criticality safety experience in the Corporate Licensing and Compliance Department, beyond that required to meet the stated license requirements. B. Technical Criteria The technical criteria that Exxon Nuclear uses to establish the criticality safety of a proposed, revised or new operation are provided in the License Conditions section of the renewal application. The important criteria are as follows: 1. The basic policy is the double contingency policy enunciated as follows, " Process and equipment designs and operating procedures incorporate sufficient factors of safety to require at least two unlikely, indepen-dent, and concurrent errors, accidents, equipment malfunctions, or changes in process conditions before a criticality accident is possible." This policy accords with accepted practice throughout the U.S. nuclear industry and is endorsed by Regulatory Guide 3.4, Revision 1, " Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors." 2. Where double batching is possible, mass limits are held to no more than 0.45 of the minimum critical mass. Where double batching is not possible, the mass is limited to no greater than 0.80 of the critical mass. Mass limits have been based on data and calculations reported in Documents TID-7028, DP-1014, ARH-600 and other standard references such as the Handbook of Criticality Data (UK Authority Health and Safety Branch) as well as a validated calculation using the KEN 0 IV Code with Knight-modified Hansen-Roach cross sections.

. 3. Cylinder diameters, slab thicknesses, and unit volumes are limited to 90 percent, 85 percent, and 75 percent, respectively, of the critical values. These margins and those given in paragraph 2 above are compar-able to those used in the Nuclear Safety Guide, TID-7016, Rev. 1, and are widely used throughout the nuclear industry. 4. The optimum (limiting case) conditions of water moderation credible for the system are assumed in setting limits. 5. Unit limits are based on full wall reflection unless less than full reflection can be assured under both normal and credible abnormal conditions. 6. The licensee spaces the process equipment and stored units to meet the following general criteria: The spacing between units within an array is limited by mechanical a. i means. i b. For single units and multi unit arrays that have been experimentally measured or for which calculational methods accurately or conservatively reproduce experimental values, the multiplication factor does not exceed 0.95 at a 95 percent confidence level. When the indicator of the reactivity of the array is the critical c. number of units in the array, the allowable number of units does not exceed 0.50 of the calculated critical number. d. The mechanical integrity of equipment or storage arrays is adequate, for both normal and credible abnormal conditions, to prevent deformations or rearre.ngements so extensive as to constitute a contingency. i 7. The licensee analyzes the spacing of the process equipment and stored units using one of the followino methods: Calculations using validated Monte Carlo type computer code-cross a. section combinations such as KENO and the Hansen-Roach cross sections. b. The solid angle method in TID-7016, Rev. 1, with the additional constraints that the method not be applied to arrays susceptible to interspersed moderation or reflected by reflectors more effective than water at the outer cell boundaries. 8. The licensee controls the movement of special nuclear material, e.g., no ) more that one safe batch may be moved at a time when introducing or j removfr material from a work station.

. 9. The licensee categorizes and externally posts facilities and plant areas as to permissible firefighting techniques, to help minimize the probability of criticality from such activities. C. Organization and Administrative Requirements The organization charts, general responsibilities and qualifications of the safety-related positions, including those for nuclear criticality safety, are given in Section VI, Organization and Administrative Procedures. The first level nuclear criticality safety supervisor for this facility is the Plant Criticality Safety Engineer, who reports to the Manager, Auxiliary Operations. The Plant Criticality Safety Engineer receives technical guidance from the Criticality Safety Component in the Corporate Licensing and Compliance Department. The responsibilities of the Plant Criticality Safety Engineer are summarized in VI.A. In addition to the requirements for qualified staff and the established tech-nical criteria, the licensee's criticality safety requirements involve several important administrative requirements: 1. All changes involving nuclear criticality safety considerations must be analyzed by a qualified analyst and reviewed by a qualified reviewer. Preoperational audits of the new equipment or process changes that require a nuclear safety analysis are made by the Manager, Maintenance, the Plant Criticality Safety Engineer, the Criticality Safety Component, and the Supervisor of Radiological Safety. All new or modified facility and process equipment is subjected to acceptance testing before release for routine operation. 2. In addition to the preoperational audits, there is an indepth system of audits of operations at stated intervals by: a. the Plant Criticality Safety Engineer, b. the Criticality Safety Component of Licensing and Compliance, Operating Facilities, and c. representatives of the FMD Industrial Health and Safety Council. 3. Requirements to ensure incorporation of the criticality safety limits in criticality safety specifications and maintenance of these specifications in the work or storage areas to which they apply, l 4. Requirements for the posting of nuclear criticality safety limits. 5. Requirements for training of operations personnel (see Section VI.E for additional details).

, 6. Safety policies and abnormal events or problems are reviewed by a permanent Fuel Manufacturing Department Industrial Health and Safety Council consist-ing of senior management and key safety personnel at the site. D. Conclus,on The nuclear criticality safety review and our conclusion that the controls are acceptable are based on the following: 1. The license conditions as revised to improve clarity, correct discrepincies and ensure continued compliance with accepted practice. The basic policy underlying these conditions is in accordance with Regulatory Guide 3.4, " Nuclear Criticality Safety in Operations with Fissionable Material Outside Reactors." 2. The demonstrated qualifications of the nuclear criticality safet/ personnel and the depth of expertise available in the Exxon Nuclear organizar. ion for the solution of problems, including personnel competent in the use of accepted computer codes, and far auditing. 3. The conformance of the technica, criteria for nuclear criticality safety with established U.S. practice. 4. The validity of the nuclear criticality safety analyses made under the license, incitdir.g the demonstration sections. 5. The history of safe plant operation with respect to nuclear criticality safety since the original license was issued. VIII. RADIATION SAFETY A. Radiation Safety Administration The Radiological Safety Supervisor reportt to the Manager, Auxiliary Operations, and is responsible for maintaining a radiation safety program which is established in accordance with criteria provided by the Health Physics Component of the Corporate Licensing and Compliance Department. He is also responsible'for the protection of plant employees and the public and for inspecting plant operation for compliance with the license and radiological regulations. He is authorized to suspend any operation which he believes threatens the health and safety of the employees or the public. Any change in radiological safety operating procedures is prepared by the Radioligical Safety Supervisor, and reviewed and accepted by the Health Physics Component of the Corporate Licensing and Compliance Department. This approval procedure ensures proper health and safety review of all standard requirements affecting radiological safety. In detail, the responsibilities of the component headed by the Supervisor, Radiological Safety, include:

1. Review and approval of health physics aspects of changes to operating procedures associated with the processing, handling or storage of SNM, 2. Approval of radiatics work permits, 3. Routine surveillance of operations, and 4. Conducting training courses in health physics. Overall objectives of the program are to ensure adequate containment of radio-active material and to reduce the levels of radiation exposure to meet the ALARA goal. The positions of Supervisor of Radiological Safety and Mr.aager, Licensing and Complianca, Operating Facilities, are filled by individuals who must meet the minimum qualifications stated in Part VI of this report. These minimum technical qualifications assure that these individuals have an academic background, or equivalent, complete with special training in health physics and professional experience. Two special features of the radiation safety administration, the radiation 1 work procedure and the ALARA Committee, are described in detail below. Radiation Work Procedure For any operation or maintenance work involving work or entry into a system containing SNM, not already covered by an effective operating procedure or where there is a potential for release of contamination, a radiation work procedure is prepared by the Supervisor, Radiological Safety, and approved by the Manager, Licensing and Compliance. Operating Facilities, and the manager (s) of the affected operation. ALARA Committee The ALARA Co aittee is responsible for assuring implementation of the ALARA regulatory requirement pertaining to radiation workers. The Committee membership consists of the Manager of Licensing and Compliance, Operating Facilities, the Health Physh3 Specialist, the Supervisor of Radiological Safety, Manager of Manufacturmg Engineering, Manager of Maintenance, Manager of the UO 2 Plant, and Manager of the MO&SF plant. The Committee is specifically responsible for conducting periodic reviews and assessments of occupational radiation exposures (internal and external), radioactive material releases to unrestricted areas and any related abnormal occurrences. The Committee meets semiannually and prepares an annual report to the FMD Industrial Health and Safety Council that summarizes the status of the ALARA program and makes recommendations on how to achieve the ALARA goal. The activities of the ALARA Committee, the monthly plant inspections of radiation protection safety and nuclear criticality safety, the employee training program, and the administrative procedures for reviewing pertinent cnanges by the health and safety organization demonstrate Exxon management's commitment to comply with the ALARA concept. i

B. System of Exposure Controls and Exposure Levels Experienced External Exposure Because of the radioactive decay characteristics of uranium, external exposure has generally not been a problem in uranium fuel fabrication plants and Exxon's Richland plant is fairly typical. (The operations with plutonium in the Exxon plant were discontinued in 1974. The radiation exposure contributed by the stored plutonium will be limited). External exposure is evaluated and controlled on the basis of the data from personnel dosimeters as well as by beta gamma dose-rate surveys. The dosimeters are read and evaluated on a quarterly basis. Exposure trends are analyzed at least every 6 months by the ALARA Committee to ensure that ALARA goals are being met. An administrative investigation will be conducted when a dosimeter result exceeds 500 mrem. The external exposure data submitted by Exxon Nuclear for the period from 1977 through 1979, as indicated by Table 1, show that annual personnel external exposures are typically less than 0.4 rem, or approximately 10 percent of the allowable exposm e limit. Internal Exposui Introduction In a fuel fabrication facility, radioactive material may enter the body by breathing contaminated air or by ingestion as a consequence of poor personal hygiene and failure to self monitor. Once in the body, the subsequent distribu-tion and excretion of the uranium is a function of the physical and chemical characteristics of the specific material. In the Exxon plant at Richland, protection of the operating personnel from excessive internal exposure is provided by the use of: 1. Plant ventilation systems designed ta limit the concentrations of radio-active material in breathing air in tiic plant working areas. 2. An air sampling and analysis program for monitoring the concentration of radioactivity in working areas to confirm proper functioning of the ventilation-filtration system and detect the presence of elevated concentrations. 3. A bioassay program to monitor and detect any significant deposition of radioactive material in the body. 4. Protective clothing, shoes and gloves to minimize direct contact with the radioactive material. 5. Respiratory protective equipment to limit the inhalation of airborne radioactive material.

o -26. Table 1 Annual External Radiation Exposure Data (rems) Exxon Nuclear Company Group 1977 1978 1979 Av. Max. Av. Max. Av. Max. UFs Conversion &. Scrap 0.18(2) 0.40 0.22(2) 1.01(I) 0.37 0.67 Recovery Areas 00 Pellet Area 0.23 0.50 0.25 1.30(I) 0.40 1.12 2 UO2 Fuel Rod Handling 0.11 0.18 0.11 0.32 0.29 0.88 Areas Mixed 0xide & Specialty 0.13 0.28 0.14 0.28 0.24 0.45 4 Fuels Plant ELO Facility 0.07 0.11 0.09 0.17 0.16 0.23 Quality Control 0.07 0.34 0.15 0.35 0.21 0.74 (Including Analytical Laboratories) Maintenance 0.04 0.25 0.08 0.23 0.12 0.26 4 i I (1) 00simeter (or holder) contaminated. (2) Includes data recorded frota con +aminateri dosimeter (or holder). 6. Surveys to detect the presence and extent of radioactive contamination. 4 7. Procedures, including action levels, for investigation, control and { decontamination of contaminated surfaces. 8. Arrangements for emergency evacuation of the building, based on installed alarms, procedures, personnel instruction and practice alerts. Description of Room Air and Equipment Ventilation Systems i The ventilation ' system in the Exxon Nuclear plant consists of air supply and i exhaust systems. Outside air is brought into various plant areas by the air conditioning equipment through inlet filters and all exhausted air from process areas is filtered through a HEPA filter before discharge through the stack. l The stack blower is connected to an emergency backup power system for use in l l

the event of an AC power failure. Exhaust air is continuously monitored prior to release. In the fuel fabrication building, room air is recirculated and continuously monitored. If the recirculated air exceeds a specified concentra-tion level, it is diverted to the facility exhaust air system without recirculation. The corrosive exhausts generated by the etch, UFs-UO2 conversion and uranium scrap reprocessing processes are passed through a scrubber, a dryer and double HEPA filters and released through the stack. The ventilation system at Exxon Nuclear is designed and maintained to limit the spread of airborne contamination by maintaining air pressure gradients so that airflow is directed from the working area into the process equipment, glove boxes and hoods. Monitoring of Air Concentration Levels The ventilation system was designed and is operated to move air from areas of low contamination potential to areas of higher contamination potential. The concentration of radioactivity in the room air is monitored using fixed sampling heads mounted at work locations where the potential for airborne contamination exists. The filters from these samples in the process areas are changed and counted on a daily basis. Internal exposures from airborne radio-activity may be estimated from the hours an individual works at each assigned location and the corresponding air concentrations. The proper location of the sampling head to provide representative air samples is evaluated at least once every year and whenever any significant process or equipment changes are made. The action levels for airborne radioactivity in the plant are set so as to comply with 10 CFR Part 20 limits. The air quality in the plant is also maintained through tests and maintenance of the ventilation system and filters. For example, tests will be performed periodically to determine that air flows are from uncontaminated areas to contaminated areas. HEPA filters are replaced when the differential pressure across the filter exceeds 3 inches of water, and hood face velocities are maintained at a minimum of 125 linear feet per minute. The minimum frequency for checking the pressure drop across the filters and the average facc velocity into ventilated enclosures is monthly. In-Plant Airborne Activity levels The concentrations of airborne radioactivity in various working areas for the past 3 years are shown in the following table:

Average Airborne Concentration Levels in Exxon Nuclear Plants, Expressed as % of MPC Area 1977 1978 1979 UFs-UO2 Conversion and Scrap Recovery 20 20 25 UO Pellet <10.0 <10.0 12 2 UO Fuel Rod s10.0 <10.0 <10 2 Analytical Lab <10.0 <10.0 <10 Pu0 Process Equip. 2 and Storage Area <0.1 <0.1 <0.1 As the table indicates, the average airborne concentration level in the work areas in the main facility is less than 25 percent of the MPC level specified in 10 CFR Part 20. Program of Engineered Improvements As can be seen in the preceding section, except for the UFa-UO2 conversion and scrap recovery area and the 002 pellet production area, which average 25 percent and 12 percent respectively of the airborne radioactivity concen-tration specified in 10 CFR Part 20, the average air concentration of radio-activity in work areas is consistently less than 10 percent of MPC. The higher concentrations of radioactivity in air in the UFs-UO2 conversion area and U02 pellet areas are attributable to increasing production rates and to frequent cleanouts between processing of different enrichments. In order to further improve the levels of room air contamination in the conversion and pellet areas, Exxon management has committed to a program intended to reduce these levels to as low as reasonably achievable. The program has the following main elements: 1. Equipment and Facility Modifications (1978-1979) Installed heaters on the offgas plenum assemblies of the UFs-UO a. 2 calciners and installed 6 secondary off gas system to minimize plugging of the offgas ducts, b. Installed steam control valves and heaters on UFs gas lines to minimize plugging of these lines and reduce the frequency of gas line cleanout. c. Installed utility hoods in the UFs-UO2 conversion areas to accommodate the cleanup of equipment within the hood rather than at unenclosed workbenches. 1

. d. Replaced the U02 powder blending station with a closed system to control the dispersion of airborne contamination. 2. Additional Administrative Controls Increased emphasis by Exxon Nuclear management in training e n sicm a. on contamination control and cleanup. b. Improved incal air monitoring program to provide air intake measure-ments representative of the air actually breathed by the operators. 3. New Facility Modifications In its 1980 capital equipment budget, Exxon Nuclear has committed 5750,000 to improve the existing ventilation system in UFs-UO conversion and UO 2 2 powder / pellet production areas. The improvement includes the installation of new exhaust systems and a scrubber in the UFs-002 Conversion Line No. 2 process exhaust. C. Bioassay Program Internal exposure for both uranium and plutonium is evaluated and controlled by a bioassay program. The bioassay program fo6' uranium is conducted in accordance with detailed provisions similar to those in Regulatory Guide 8.11. The pertinent parts of the license application include the definition of sampling frequencies, types of analyses to be used, action levels and action to be taken. The Exxon Nuclear bioassay program for plutonium is a minieal program that is adequate for the storage of plutonium at the Exxon plant. At the present time, no guides have been developed by the NRC for plutonium biossay. Ex~on's program for plutonium bioassay, however, is eciuivalent to the program of other NRC licensees and is deemed adequate for the inactive storage and form of plutonium authorized by this revised license. D. Use of Respiratory Protective Equipment 4 The conditions for use of respiratory protective equipment defined in Regulatory Guide 8.15 are required by 10 CFR 20.103(c) and will apply to the revised license. The Office of Inspection and Enforcement inspected the licensee's program for use of respiratory protective equipment against Regulatory Guide 8.15 and found the program in compliance. E. Control of Surface Contamination The restricted areas of the Exxon Nuclear Richland Plant are zoned contamination control areas, intermediate areas and general areas. Each defined area is surveyed routinely for any undesirable surface contamination. The frequency of this survey and action levels for cleanup are based on the use to which the areas are committed and on the potential hazard presented by the presence of surface contamination.

. The specifications for the control of surface contamination used by Exxon Nuclear are within the limits used at other nuclear facilities with similar types of material and potential for contamination. They are summarized as follows: Guide to Surface Contamination Control Levels Action Levels dpm Areas Removable, Alpha 100cm' Survey Frequency U Pu U Pu Contamination Control 10,000 500 weekly daily Intermediate 500 200 daily daily General

• 200 background weekly weekly
• General areas where food is allowed will be surveyed daily.

When contamination levels in any area exceed the appropriate action level, decontamination action will be taken immediately. To ensure that the radiation detecting instruments function properly, the instruments are calibrated every 6 months. Release of equipment and packages from the plant site is in accordance with Annex C guidanLe. (A copy of Annex C is included in Section XII of this report following the license conditions.) F. Effluent Control Exxon is committed to a program to maintain releases of radioactive materials to levels as low as reasonably achievable (ALARA). Important aspects of this program include: Establishment of action levels for radioactive concentrations in effluents so tbst any abnormal operation will be promptly corrected and the radio-active concentration in the effluent held below the limit specified in 1 10 CFR Part 20. Use of written procedures, reviewed and approved by Radiological Safety, for processes that discharge radioactive material to the environs. At the Exxon Nuclear facilities, potentially contaminated exhaust air is exhausted through at least one set of absolute filters and discharged through stacks which are continuously monitored for particulate and gaseous activity. Data reported by the licensee show that the annual average airborne uranium release from the Exxon Nuclear UO2 Plant (1976-1978) is less than 1 percent of 1

, the MPC limit specified in 10 CFR Part 20. Therefore, the environmental impact of the air % rne releases from facility operation is very small. All uranium *-contaminated liquid wastes and high level chemical waste solutions are discharged to the onsite process chemical waste storage lagoon system for storage and solar evaporation. The lagoons are lined with two layers of an impervious plastic liner to prevent the contents from seeping into the groundwater. Furthermore, there is a leak detecting system, including underground wells and sampling tubes, under the liner to provide leakage detection capability for the lagoons. Exe n is investigating methods (such as centrifugation, filtration, and ion exchange) for possible uranium recovery from the contents of these lagoons. However, the ultimate disposition of sludge and solids removed from these lagoons will be as solid radioactive waste buried at an approved site. Sanitary wastes generated by the plant employees, and process cooling water are not expected to contain significant quantities of uranium. These ~ Quid wastes are discharged through the separate sewer system to the EN-City Lift Station where the total combined liquid effluent is then pumped to the Richlard municipal sewerage system. The liquid effluent is continuously sampled as it is pumped to the municipal sewerage system, and the composited samples are analyzed daily for pertit.cnt radioactive materials and chemicals. Any increase in the radioactive material content of the samples above background is cause to take appropriate corrective action. Effluent releases from the Exxon facility are and have been within all license conditions and regulatory requirements for discharge of radioactivity to unrestricted areas. A detailed description of the effluent releases from the Exxon Nuclear facilities and the impact resulting from the overall plant operation will be published in the Environmental Impact Appraisal related to the license renewal. G. Conclusion Upon completion of the radiation safety review of the licensee's application and compliance history, the staff has concluded that the Exxon Nuclear Company has the necessary technical staff at the Richland facility to administer an effective radiological safety program. Conformance by Exxon Nuclear to their proposed conditions as well as to those developed by the staff of the Uranium Fuel Licensing Branch should ensure a safe operation and the quick detection of unfavorable trends or effects by Exxon Nuclear or IE with prompt corrective action. The ongoing program of engineered improvements to reduce radiation levels should result in a gradual reduction in airborne activity. )There are no sources of plutonium-contaminated liquid waste at the Exxon Nuclear plant.

. IX. EMERGENCY PLAN Exxon Nuclear has submitted an emergency plan in accordance with Regulatory Guide 3.42 which meets the requirements of 10 CFR 70.22(i). The plan was reviewed by the staff using the elements listed in Section IV of 10 CFR Part 50, Appendix E, to juCe the adequacy of the plan. The staff finds that the emergency planning for tne Richland site meets the requirements of 10 CFR Part 50, Appendix E, and provides a basis for an acceptable state of emergency preparedness. The Exxon Nuclear emergency plan is incorporated in the license by reference in Appendix III in the license condition section of the renewal application. X. FIRE SAFETY Fire safety at the Exxon Nuclear site is based primarily on: 1. A low inventory of combustible material. 2. The use of burning devices, gas detection equipment, and asbestos curtains where necessary to prevent explosions and fires around sintering furnaces and ovens. 3. The use of chemical fire extinguishers. 4. Plant personnel trained in the use of fire extinguishers. 5. Fire detection instruments and automatic alarms. 6. Preplanned emergency response procedures which include assistance, if required, from local fire departments. The Richland site is periodically inspected for fire safety by inspectors acting for the insurance underwriter. The mcst recent relevant inspection was performed on June 27, 1978, and the results o' the inspection are summarized in the letter from American Nuclear Insurers to Mr. Robert Purcell shown in Part 5 of Attachment A of the renewal application. The report of an inspec-tion by the Richland City Fire Department on February 13, 1980, of fire protection features and practices in the plant is also given in Attachment A, Part 6. In the section on the effects of postulated accidents given in the Environmental Statement for the Uranium 0xide Plant, it was concluded that no release of radioactive material to the environs was likely to occur as the consec;uence of a sintering furnace explosion or autoclave explosion. In the Environmental Statement for the Mixed 0xide and Speciality Fuels Plant, the postulated accidents involving fires or explosions were analyzed as to possible resulting individual doses. Based on an assumed evacuation within 2 l hours after accident initiation, maximum (lung) doses to an individual at the site boundary were calculated to be 0.5 mrem and 7 mrem for a hydrogen

. explosion and glovebox solvent explosion, respectively. These analyses were based on the assumption that the facility would be in full operation when the accidents occurred. The staff concludes that the impact of a fire at one of the Richland facilities would be quite limited and that existing fire safety provisions for the site provide safety protection adequate for the Exxon Nuclear facilities. XI. PLANT DECOMMISSIONING General Decommissioning Plan Exxon Nuclear, by letter dated June 16, 1978, and supplements transmitted by letters dated December 12, 1978, and January 9, 1979, submitted a general decommissioning plan for the Richland site including the builaings and the lagoons. The objective of the plan is to take residual contamination levels to the values of Table I of the NRC guidelines, " Guidelines For Decontamina-tion of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material," November 1976. The Table I values are acceptable levels for release of facilities and equipment for unrestricted use. The decommissioning plan also includes a discussion of the general considera-tions for decontamination of the plants and site, the procedures to be followed during decontamination and an estimate of the costs for decontaminating the Richland plants and site. The Exxon Nuclear decommissioning plan for the Richland site was reviewed by the staff and appears to be adequate in that the objective complies with NRC Guidelines, the procedures proposed are reasonable, acceptable to the staff and should allow the objective to be attained, and the estimated costs appet.r to be realistic. Financial Plan The staff has evaluated the Exxon Nuclear financial commitment and finds that, although it does not contain a financial security arrangement that would guarantee decommissioning funds, it offers the assurance of an officer of the parent corporation (Exxon Corporation) that the parent corporation will provide the necessary funds (three million dollars) for decommissioning. The staff finds that the Exxon Corporation commitment is a very small fraction of the worth of the corporation. Accordingly, the staff accepts the letter commitment from the Corporate Senior Vice President as adequate assurance that the facilities will be decontaminated at the end of plant life so that they can be released for unrestricted use. The Exxon Nuclear commitments for decammissioning are incorporated in the license by reference in Appendix II oi "le license condition section of the renewal application.

l l XII. CONCLUSION Upon completion of the safety review of the licensee's application and compliance history, the staff has concluded that the activities authorized by issuance of a revised license to Exxon Nuclear Company, subject to the conditions developed by the staff of the Uranium Fuel Licensing Branch, will not constitute an undue risk to the health and safety of the public. Further-more, the staff has determined that the application fulfills the requirements of 10 CFR 70.23(a) subject, however, to the imposition of whatever additional license requirements may be determined necessary as a consequence of the environmental impact appraisal now being made. The issuance of a full, 5 year term renewal license should be held in abeyance until the additional require-ments have been determined. The staff, therefore, recommends that the Exxon Nuclear Company license be revised it in its entirety, in accordance with the statements, representations ar.d conditions contained in Part I and the appendices to Part I of the~ licensee's application transmitted by letter dated May 31, 1979, and supple-ments, subject to the following conditions and continued on a timely renewal basis until completion of the environmental appraisal: 9. Authorized Use: For use in accordance with statements, represen-tations and conditions contained in " License Conditions," Part I and the Appendices to Part I (Special Conditions, Decommissioning Plan, Emergency Plan) of the licensee's application transmitted by letter dated May 31, 1979, and supplements transmitted by letters dated February 22, March 13, April 29, June 5, June 19, and June 27, 1980.

10. Authorized Place of Use: The licensee's existing facilities near Richland, Washington, as described in the referenced application, Table 1.3-1.

11. All areas in which radioactive materials are stored, handled, or used shall be posted with caution signs meeting the requirements of Title 10, CFR Part 20.203, except that of 20.203(f). In lieu of 20.203(f) requirements, a sign bearing the legend "Every container or vessel in this area, unless otherwise identified, may contain radioactive material," shall be posted at entrances to each building in which radioactive materials are used, stored, or handled.

12. Notwithstanding the evaluation of training effectiveness as described in the last paragraph under 3.10 on page 3.59 of the License Conditions section of the application, the effectiveness of refresher training shall be evaluated using written tests conducted for such purpose and signed by the individual being tested.

13. The licensee is exempted from the monitor alarm requirements of Section 70.24, 10 CFR Part 70, in the areas specified below: a. SNM Accountability Measurement Station, and

. b. waste lagoons. 14. Release of equipment and packages from the plant site or to clean areas onsite shall be in accordance with the attached Annex C, dated November 1976. vcnwu A. L. Soong R. L. Stevenson Radiation Safety / Project Manager /; / // /./ r Approved by ~ Z n..- v W. T. Crow, Section Leader Uranium Process Licensing Section a I l i [

1 (Relevant to Condition 14'.. ANNEX C GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL U. S. Nuclear Regulatory Commission Division of Fuel Cycle and Material Safety j Washington, D.C. 20555 November 1976 i 1

e 0 1 The instruction in this guide in conjunction with Table I specify the radioactivity and radiation exposure rate limits which should be used in accomplishing the decontamination and survey of surfaces or prei::ises and eqt.jpment prior to abandonment or release for unrestricted use. The limits in Table I do not apply to premises, equipment, or scrap containing induced radioactivi.ty for which the radiological considera-tions pertinent to their use may be different. The release of such facilities or items from regulatory control will be considered on a case-by-case basis. 1. The licensee shall make a reasonable effort to eliminate residual contamination. 2. Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contaminatico levels, as determined by a survey an.d documented, are below the limits specified in Table I prior to applying the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering. 3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement shall be presumed to bc contaminated in excess of the limits. 4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having surfaces contaminated with materials in excess of the limits specified. This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organization continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must: a. Prov'de detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination. l b. Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment or scrap, are unlikely to result in an unreasonable risk to the health and safety of the public.

O 2 5. Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishs that contamin-ation is within the limits specified in Table I. A copy of the survey report shall be filed with the Division of Fuel Cycle and Material Safety, USNRC, Washington, D.C. 20555, and also the Director of the Regional Office of the Office of Inspection and Enforcement, USNRC, having jurisdiction. The report should be filed at least 30 days prior to the planned date of abandonment. The survey report shall: a. Identify the premises, b. Show ', hat reasonable effort has been made to eliminate residual contamination. Describe the scope of the survey and general procedures followed. c. d. State the findings of the survey in units specified in the instruction. Following review o the report, the NRC will consider visiting the facilities to confirm the survey. I i l I t 1 ._._m

3 TABLE I ACCEPTABLE SURFACE CONTAMINATION LEVELS bcf DdI bef NUCLIDES' AVERAGE MAXIMUM REMOVABLE U nat, U-235, U-238, and 5,000 dpm n/100 cm2 15,000 dpm n/100 cm2 2 1,000 dpm a/100 cm associated decay products Transuranics, Ra-226, Ra-228, 100 dpm/100 cm2 300 dpm/100 cm2 20 dpm/100 cm2 Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 Th-nat, Th-232, Sr-90, 1,000 dpm/100 cm2 3,000 dpm/100 cm2 200 dpm/100 cm2 Ra-223, Ra-224, U-232, I-126, I-131, I-133 Beta gamma emitters (nuclides 5,000 dpm py, 100 cm2 15,000 dpm py, 100 cm2 2 1,000 dpm py, 100 cm with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above. aWhere surface contamination by both alpha-and beta gamma-emitting muclides exists, the limits established for alpha-and beta gamma-emitting nuclides should apply independently. bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as de-termined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geo-metric factors associated with the instrumentation. CMeasurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derivid for each such object. dthe maximum contamination level applies to an area of not more than 100 cm, 2 4

4 TABLE I 'The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination of objects on less surface area is oetermined, the pertinent levels should be reduced proportionally and the entire surface should be wiped, fThe average and maximum radiation levels associated with surface contamination resulting from beta gamma emitters should not exceed 0.2 mrad /hr at 1 cm and 1.0 mrad /hr at 1 cm, respectively, measured through not more than 7 milli-grams per square centimeter of total absorber. O

a o APPENDIX I Bases for Numbered License Conditions There are fewer numbered license conditions (14) recommended in this action than has been typical in similar licensing actions taken during the past 3 years. The apparent reduction is a result of the licensee's incorporating essentially all requirements in the proposed license condition section of his renewal application, which is incorporated into the license by reference in Condition 9. Typical of the items for which specific conditions were thus rendered unnecessary are the emergency plan, decommissioning plan, overall gaseous radioactive release limit and requirements for Radiation Work Procedures. The numbered license conditions (other than the nine standard items such as name, address, and possession limits, and Item 9 referred to above) are listed in the preceding section. The additional conditions arise from requirements in the regulations that call for specific authorization, and the staff's judgment that certain procedures deemed important to safety or to monitoring should be more specifically defined. The conditions are explained below. Condition 11. This. condition provides for an alternative posting arrangement (exemption to 20.203(f)(1) and (2)) which is justified by access limitation meeting 20.?03(f)(3)(vi). Condition 12. (Evaluation of refresher training effectiveness). It is intended that this condition require written testing of operators (at a maximum 2 year interval) as a measure of refresher training effectiveness. The staff considers written testing to be a worthwhile measure of training effectiveness when coupled with other measures, such as the supervisor's observation of individual worker job practices. Coadition 13, which exempts certain areas from the criticality alarm require-ments, is based on the essential incredibility of accidental criticality in the identified areas. Condition 14, concerning release of equipment and packages from the plant site, imposes requirements for such release that have become standard. -}}