ML19350C247
| ML19350C247 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 11/14/1980 |
| From: | Pianki F ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 17922, NUDOCS 8103310690 | |
| Download: ML19350C247 (18) | |
Text
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C-E Power Systems Tel. 203/688 1911
// O O Combustion Engineenng. inc.
Telex 99297 1000 Prospect Hdi Road VAndsor, Connecticut o6095 N POWER M SYSTEMS License SNM-1067 November 14, 1980 Docket 70-1100 U. S. Nuclear Regulatory Comission Washington, D. C.
20555 Attention: Mr. R. G. Page, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle & Material Safety
Dear Mr. Page:
It is requested that License SNM-1067 be amended to reflect the recent organiza-tional changes made as a result of the promotion of Mr. Gregg A. Johnstone to t;ie position of Supervisor, Health Physics & Safety and the change of statu: of Mr. George J. Bakevich from Manager, Nuclear Licensing, Safety & Accotntabil.
to Nuclear Licensing Consultant. Mr. Johnstone will be responsible for the i
'9-logical and industrial safety programs of the manufacturing facility, waile Mr Bakevich will continue to perform any criticality safety analysis necessary to suppor' license changes and facility and equipment changes.
The health physics techn.ians will now report to the Health Physics & Safety Supervisor. He will in tu n report directly to the General Manager.
Detailed responsibilities for both positions are described on the proposed license page changes included as part of this amendment request.
It is requested that our previous amendment appli-cation on the above subject, dated October 24, 1980, be withdrawn in its entirety.
The new organizational structure will assure continuity of all safety programs and the licensing process and incorporates comments mada by Mr. N. Ketzlach of your staff during a meeting with C-E representatives held on November 10, 1980.
Pre-paration of our license renewal application is approaching completion and will be submitted for your review within 60 days. At the present time, it is requested that the following page changes be made to the current license:
Delete Pages Add Pages V-2, Rev. 3, dated 2/7/77 V-2, Rev. 4, dated 11/14/80 VIII-5, Rev. 4, dated 3/15/78 VIII-5, Rev 5, dated 11/14/80 VIII-6, Rev. 7, dated 3/15/78 VIII-6, Rev. 8, dated 11/14/80 VIII-7, Rev 6, dated 3/15/78 VIII-7, Rev. 7, dated 11/14/80 VIII-8, Rev. 1, dated 4/16/73 VIII-8, Rev. 2, dated 11/14/80 VIII-9, Rev. 9, dated 3/lE/78 VIII-9, Rev. 10, dated 11/14/80 VIII-12, Rev. 4, dated 3/15/78 VIII-12, Rev. 5, dated 11/14/80 VIII-13, Rev. 1, dated 4/16/73 VIII-13, Rev. 2, dated 11/14/80 VIII-14, Rev. 1, dated 4/16/78 VIII-14, Rev. 2, dated 11/14/80 VIII-16, Rev. E dated 3/15/78 VIII-16, Rev. 4, dated 11/14/80 e n a.,.,
L m mae-. J
- 2 03310 6q o
Delete Paces XV-2, Rev. 3, dated 9/16/7aXV-1, Rev.1, dated Add Pages XV-3, Rev. 1, dated 4/16/73 XV-2, Rev. 4, dated 11/
XV-6, Rev. 4, dated 9/21/79 XV-19,Rev. O, dated 4/16/73 XV-3, Rev; 2, dated 11/14/80 XV-24 Rev. 2, dated 3/15/74 XV-6, Rev. 5, dated 11/14/80 1
XV-19,Rev.
XV-24 Rev. 3, dated 11/14/80 license fee of $150This amendment request is con i License Fee Manageme.00 as required by 10 CFR 170s dered to nt Branch under separate cove has been sent directly to thype chan If you have any questions co r.
on extension 2898 e
Very truly.yours, ncerning this arendment requ est, please contact me
~
F. J//Pidn:ki, Te'n'eral Mana
/,
Nuclbar Fuel Manufacturing ger FJP/GAJ/ssb Enclosures Fire protection, including sprinklers, is designed into all buildings which are subject to fire damage.
A direct emergency telephone line to the Windsor protective agencies (Fire, Police, Ambulance, etc.) is available and controlled by the site security personnel.
5.5 Site Protection - Medical The medical staff, available at Combust 3on's Windsor site, consists of three full-time nurses, and one full-time physician, who is on 24-hour alert.
Medical, chest x-ray and urinalysis examinations are given to all personnel prior to their first day of employment.
5.6 Site Protection - Health and Safety A full-time Health Physics Technician will be on the site any time powder is being handled. Whenever powder is not being handled, and the Health Physics Technician is not on site, the shift foreman may perform any necessary sampling in accordance with instructions from the Supervisor, Health Physics & Safety.
License No. SNM-1067. Docket 70-1100 Revision:
4 Date: 11/14/80 Page: V-2
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8.2 Nuclear Fuel Manufacturing - Windsor The General Manager reports to the Vice President, Nuclear Fuei Manufacturing and is responsible for the accountability, nuclear criticality safety and radiological safety related to all Special Nuclear and Source Material received by the Nuclear Fuel Manufacturing Facility and used in any manufacturing pro-cess. He assures compliance with the requirements and limitations set forth in the license application during all phases of the manufactaring.
In this position, the General Manager has delegated to the Production Superin-tendent and the Engineering Manager responsibility to assure that all operations involving nuclear materials have been analyzed to establish the required safety limits and controls.
P,efore the cognizant engineering superviscr may initiate equipment changes, or before the Production Control Supervisor may initiate limit changes affecting nuclear fuel handling, they must describe the proposal to the Health Physics and Safety Supervisor. He must review and approve the proposed change or operation and transmit his approval in writing to the cognizant individual. His approval will incorporate the results of criticality safety and radiological safety re-views and will include recommendations to assure that appropriate controls are implemented. The individual who performs the initial criticality safety review shall meet the minimum qualifications for a Criticality Safety Specialist. The individual who performs the independent criticality safety review shall be a per-son designated by the Nuclear Safety Committee and shall meet the minimum quali-fications for a Criticality Safety Specialist and shall not be the initial re-viewer.
All such approvals shall be recorded in a log maintained under the direct super-vision of the Health Physics and Safety Supervisor.
License No. SNM-1067, ~ Docket 70-1100 Revisitn: 5 Date: 11/14/80 Page: VIII-5
Writte'n operating procedures are provided by the cognizant engineering supervisor for all operations, including equipment and floor clean-up.
These include all criticality and radiological safety restrictions and limits.
Signs, including criticality limits an approved by the Manager, Nuclear Licensing, Safety & Account-ability, or the Nuclear Licensing Consultant are posted near the appropriate work station under the direction of the cognizant supervisor and are verified by the Health Physics & Safety Supervisor, i
In addition, all procedures shall provide for the labeling of all mass limited con-l tainers to indicate the enrichment, and the uranium content and shall provide for maintaining the identity of enrichments of all SNM in the facility. All process equip-ment and operating areas shall be labeled to indicate the enrichment and geometry limited containers will be handled as though they are full unless specifically labeled otherwise. Labeling shall be carried out under the direction of the cognizant fore-
- man. The Health Physics and Safety Supervisor is responsible for the surveillance of all Nuclear Fuel Manufacturing activities in which radioactivity is invalved to ensure that the health and safety as well as criticality standards set forth in the license application are met. He has the necessary authority to halt any operation which falls outside those limits and he is responsible for indicating what remedial action is necessary to bring the operation within acceptable limits.
However, if the operation
-is halted because of criticality safety considerations, the Supervisor, Health Physics and Safety will-contact the Manager, NLS&A or the Nuclear Safety Committee who shall
-determine necessary corrective actions to be taken. He reports directly to the General Manager. The organization chi.rt in Figure 8.2 indicates the names of those personnel who presently hold the above described positions and is not a license requirement.
The Manager, NLS&A or the Nuclear Licensing Consultant shall review and approve facility and process changes, equipment rearrangements and additions affecting nuclear criticality safety which fall within the criteria of Section 19 provided that an independent review is performed by the Nuclear Safety Committee or persons designated by that Committee.-
s License No.'. SNM-lD67, Docket.70-1100 Revision: ~8
.Date:
il/14/80 Page: T1?I-6.
l l
NUCLEAR POWER SYSTEP.S J. M. West Division Vice President l
l NUCt. EAR FUEL NUCLEAR PATERIALS MANUFACTURING
& SECURITY H. V. Lichtenberger T. B. Bowie Vice President Manager i
i l QUALITY ASSUP# IC l
l 3
NUCLEAR i
ACCOUNTING.
FUEL FABRICATION LICENSING J. E. Wahler R. F. Brunette 'i F. J. Pianki CONSULTANT Controller General Manager G. J. M evid',
i M nager I
i I
i l
l PRODUCTION PRODUCTION PANAGER, N'JCLEAR ENGINEERING MANAGER t
SUPERINTENDENT MANAGER LICENSING, SAFETY E^
II P. W.-Hubert A. R. Neumann G. C. Kersteen l
l
-(VACANT)
I L
SUPERVISOR, HEALTH ~
SUPERVISOR SECURITY PHYSICS & SAFETY '
NUCLEAR PATERIAL,
-SUPERVISOR l ACCOUNTABILITY G. A. J hnstone R. E. Sheeran 1
Figure 8.2 l
' License' No'. SNM-1067,: Docket 70-1100
-Revision:.
7.
Date:
11/14/80
.Page: VIII-7
All processes and procedures issued by a cognizant supervisor and approved by the Health Physics & Safety Supervisor are transmitted to the cognizant foreman by Pro-
- duction Control or Quality Control.
Procedures involving a change in the criticality safety controls used for that particular process in the past shall be approved by the Manager, NLS&A or the Nuclear Licensing Consultant.
In their absence, a member des-ignated by the Nuclear Safety Committee sha'l approve the change.
Each foreman shall instruct his people to assure their understar.iing of the operations and their safety limits and restrictions. The adequate performc,ce of individuals is continually as-certained by the foreman.
It is the responsibility of the foreman to assure that each work station is properly posted, and that operations are performed in compliance with posted limits and written instructions.
f Licenst No. SNM-1067 Docket 70-1100 Revision: 2 Date: 11/14/80 Page: VIII-8
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8.3 Audits 8.3.1 Laboratory Operations Laboratory operations will be audited once per month by the Health Physics and Safety Supervisor. He will verify that all designated operating procedures are being followed and will report his findings to the Director of Nuclear Laboratories.
8.3.2 Nuclear Fuel Manufacturing Operations Operations at Nuclear Fuel Manufacturing-Windsor will be formally audited as follows:
a) Once each working day by a Health Physics Technician for Health Physics compliance and criticality compliance. These audits will be transmitted to the Health Physics and Safety Supervisor.
b) Once each month for nuclear criticality safety by an individual who meets the minimum qualifications of a Nuclear Criticality Specialist. He shall audit for compliance with all regulations and operating procedures, and shall assess the adequacy of the criticality safety program.
His findings will be documented and submitted to the General Manager.
c) Once each month for radiological safety by an individual who meets the minimum qualifications of a Radiological Safety Officer or Radiation Specialist. He shall audit for compliance with all regu-1ations and operating procedures and shall assess the adequacy of the radiological safety program. His findings will be documented and submitted to the General Manager.
d) Once each year by the Nuclear Safety Committee. The Committee will review al' aspects of the criticality and radiological safety programs and will transmit their report in writing to the General Manager for followup on recommendstions.-
O License No. SNM-1067. Docket 70-1100 Revision: 10 Date:
11/14/80 Page:.VIII-9 9
e
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8.5.2 Production or Engineering Supervisors - Laboratory Managers and Manager, Quality Control The minimum qualifications for these positions are a bachelor's degree in one of the sciences or engineering and three years experience in nuclear fuel fabrication facilities. He must have an understanding of the criti-cality and health physics aspects of fuel handling and a knowledge of administrative controls imposed on fuel handling operations.
0 8.5.3 Manager, Nuclear Licensing, Safety & Accountability (NLS&A) or Nuclear Licensing Consultant The minimum qualifications for the position of Manager, NLS&A or Nuclear Licensing Consultant shall be a bachelor's degree in one of the sciences, engineering or equivalent and a minimum of three years experience in posi-tions which demonstrate sufficient judgement and analytical capability to establish and maintain a technically sound and effective nuclear criticality and radiation safety program. He must meet the minimum qualifications for a Nuclear Criticality Specialist.
o 8.5.4 Health Physics and Safety Supervisor The minimum qualifications shall be a bachelor's degree in one of the sciences, engineering or equivalent and a minimum of two years experience in Radiation Safety Protection in positions which demonstrate sufficient judgement and capa-bility to establish and maintain an effective nuclear criticality and radiation safety program.
8.5.5 Radiological Safety Officer or Radiation Specialist The minimum qualifications shall be a bachelor's degree in one of the sciences, engineering or equivalent and a minimum of two years experience in Radiation Safety Protection.
8.5.6 Nuclear Criticality Specialist The minimum qualifications for the position of Nuclear Criticality Specialist shall be a bachelor's degree in one of the sciences, engineering or equivalent License No. SfM-1067. Docket 70-1100 Revision:
5 Date: 11/14/80 Page: VIII-12
and two years experience in outside-of-reactor nuclear criticality safety or two years experience in nuclear reactor physics and one year experience in outside-of-reactor nuclear criticality safety.
8.5.7 Nuclear Materials Manager The minimum qualifications for this position is a bachelor's degree in one of the sciences or engineering, and two years experience in nuclear materials management.
8.5.8 General Foremen and Foremen The minimum qualifications for all foremen are a High School diploma and two years experience. The General Foreman will have at least two years experience in radioactive materials handling.
8.5.9 Manager, Industrial Hygiene and Safety The minimum qualifications for this position are a bachelor's degree in one of the sciences or engineering, and two years in a position responsible for industrial and fire safety.
1
- License No. SNM-1067 Docket 70-1100 Revision:
2 Date: 11/14/80 Page: VIII-13
8.6 Industrial Safety Fire and explosion hazards of all laboratory operations are evaluated by the Manager of Industrial Hygiene and Safety. The Health Physics
& Safety Supervisor provides these evaluations for the manufacturing operations.
t' All buildings are provided with sprinklers. Metal fire hazards are minimal as uranium will be in the oxide form, and machining operations on zirconium are not routinely carried out. Whenever rirconium is machined or cut, the chips will be stored under water.
' License: No. SNM-1067. Docket 70-1100
-Revision:
2 Date: 11/14/80 Page: VIII-14 A.
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The functions of the Comittee are to:
1.
Assure a second review of all Nuclear Safety aspects of any changes which the Manager, NLS&A or the Nuclear Licensing Consultant is requested to re-view and approve. This review will be performed by a qualified person designated by the Chairman of the Committee, and acting in behalf of the Comittee.
2.
Audit all manufacturing operations involving SNM at least once a year. This audit must include as a minimum, a review of the nuclear criticality and radio-logical safety programs and their application and to assure that management policies are consistent with the objective of maintaining occupational radi-ation exposures as low as reasonably achievable. The Committee member who reviews the criticality safety program shall be a person other than the one who perfonns the monthly criticality safety audit. The Comnittee member who reviews the radiological safety program shall be a person other than the one who performs the monthly radiological safety audit.
License No. S M-1067. Docket 70-1100 Revision: 4 Date:
11/14/80 Page:
.VIII-16 L--
.15.0 Nuclear Health and Safety-Facilities, Equipment, and Procedures Compliance with all applicable Federal, State and Local health and safety regulations by Nuclear Products Manufacturing is assured by the Health Physics and Safety Supervisor. For operations carried out by the Nuclear Laboratories, this responsibility is carried out by the Radiologcial Safety Officer.
The Radiation Protection Program for all nuclear operations emphasizes the prevention of ingestion, inhalation, interstitial or other modes of entry into the body of radiation, since there are a minimum of ex-ternal radiation problems.
The safety groups act in a staff capacity, providing services to the production and engineering groups, as described in Section 8.
A more detailed listing of duties are pro 4d in this section.
o
'15.1 Responsibilities of Nuclear Licensing & Radiation Safety Supervisory Personnel 15.1.1 Responsibilities of the Manager, Nuclear Licensing, Safety, and Account-ability:
a) Prepare and submit license applications, amendments, and renewal applications to the NRC for, approval.
b) Perform criticality safety analysis using computer codes and surface density method in support of license changes.
c) Overall responsibility for all safety programs including radiological safety, nuclear criticality safety, and industrial safety.
d) Responsible for nuclear material control in manufacturing facility.
e) Emergency Planning including interface with State of Connecticut Office of Civil Preparedness f) Assess the adequacy of the radiological safety program to maintain management's comitment to ALARA.
. License No. SIM-1067,. Docket 70-1100 Revision:
2 Date: 11/14/80 Page: XV-1 l' _
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g) Provide the initial review and approval of proposed facility and equipment changes which affect nuclear criticality safety.
15.1.2 Responsibilities of the Radiological Safety Officer for the Nuclear Laboratories and the Supervisor, Health Physics & Safety for Nuclear Products Manufacturing.
a) Furnish consulting service on all aspects of health physics.
b) Audit all activities involving radiological problems. All audits will be documented, and transmitted to the General Manager.
c) Distribute and process personnel monitoring equipment, including maintenance of personnel exposure records.
d) Supervise and coordinate the radioactive waste disposal records, e) Provide an environmental monitoring program.
f) Supervise decontamination of equipment, areas, and personnel.
g) Schedule necessary physical examinations, and bioassay of personnel working with radioactive materials.
h) Maintain records concerning the use and disposition of all radio-active materials.
- 1). Issue Industrial Hygiene and Safety regulations as required.
j) Review and approval of operating procedures which do not involve any changes in the criticality safety controls used for that particular process in the past.
k) Training and periodic retraining in criticality, radiological, and industrial safety.
C' 15.1.3 Responsibilities of the Nuclear Licensing Consultant a) Furnish consulting service on all aspects of nuclear criticality safety involved in license applications, amendments, and renewal applications.
l b) Audit the manufacturing facility for criticality safety. Audit schedules are set forth on Page VIII-9.
.c) Provide the initial,t w and approval of proposed facility and equipment chane c vic'. affect nuclear criticality safety.
l License No. SNM-1067, Docket 70-1100 Revision:
4 Date: 11/14/80
(
Page: XV-2
}. :
d) Review and approve those operating procedures and revisions which
' involve.a change in criticality safety controls.
In his absence, a member designated by the Nuclear Safety Comittee may perform the review. Operating procedures which do not involve any changes in the criticality. safety controls used for that particular process in the past may be reviewed and approved by the Health Physics & Safety
' Supervisor.
l
. License Noi 521-1067,' Docket 70-1100.
Revision:
2 Date: 11/14/80 Page: XV-3 h;L
15.3.4 Health Physics Restric2ed Areas A Health Physics. Restricted Area is an area in which more than 235 350 grams of U as unclad UO may be processed, and/or in 2
which the radiation level exceeds 2.5 mr/hr. A removable alr'.s 2
level of 5000 dpm/100 cm requires clean-up within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 2
a level of 10,000 dpm/100 cm requires immediate clean-up.
15.3.5 A Clean' Area is an area which is free of radioactive contamination or ionizing radiation levels significantly greater than background.
No radioactive contaminated equipment or clothing will be brought into a Clean Area unless authorized by the Radiological Safety Officer or the Health Physics and Safety Supervisor.
2 A maximum removable alpha level of 100 dpm/100 cm is permitted.
m License No.I NM-1067, Docket 70-1100 Revision: 5 Date:
11/14/80 S
Page:. XV-6
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15.13 Training Program 15.13.1 Operating Personnel All persons who are to handle radioactive materials in Buildings
- 17 and #21 will receive training in the health and safety require-ments and the emergency plan under the direction of the Health Physics and Safety Supervisor.
In the laboratories, thin training will be given under the direction of the Radiological Safety Offi-cer.
This will cover criticality safety, the precautions required for UO2 powder handling, including limiting exposure to external radiation, prevention of internal exposures, use of protective clothing and personnel monitoring devices, fundamental radiation safety rules (10 CFR 20) and policies, and plant emergency procedures are discussed.
Annual retraining is conducted under the direction of the Health Physics and Safety Supervisor. As the need arises, changes in regula-tions, operating conditions and procedures, and administrative policies are covered. To demonstrate that all employees are familiar with the Emergency Procedure, drills are conducted at least twice per year. After each drill is evaluated,' the cognizant Manager is informed of any short-comings, and shall.take corrective action.
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License No. SNM-1067. Docket 70-1100 Revision:
1 Date: 11/14/80 Page: XV-19
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-15.13.2 Health and Safety Technicians, Supervisors, and Accountability Auditing Personnel Health Physics Technicians for Nuclear Manufacturing, or the Nuclear Laboratories will receive the above training and annual retraining and will be instructed by the Health Physics and Safety Supervisor, or the Radiological Safety Officer, as appropriate, in the use of instruments, the evaluation of contamination, the emergency plan, environmental sampling, and other aspects relevant to their assign-ments. The Accountability and Health Physics Technicians will also receive sufficient training in criticality control to enable them to carry out their auditing functions.
License No.lSNM-1067. Docket 70-1100 Revision:~
3 Date: 11/14/80 Page: XV-20 r, n.,,
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