ML19350C336
| ML19350C336 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 12/31/1980 |
| From: | WESTERN NUCLEAR, INC., WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | |
| Shared Package | |
| ML19350C329 | List: |
| References | |
| 18190, PROC-801231, NUDOCS 8103310945 | |
| Download: ML19350C336 (17) | |
Text
_
1 l
t:
i I
1 WESTINGHOUSE ELECTRIC CORPORATION j
NUCLEAR ENERGY SYSTEMS l
3 t
i i
l SITE ALARA MANUAL FOR THE NUCLEAR FUEL DIVISION AT THE ALABAMA i'
NUCLEAR FUEL FABRICATION PLANT 1
I.
1, :
i t
f.
December 1980 i
t
' h A
. NUCLEAR FUEL DIVISION F.
18130
[
!8iosaroigal5 i
i
4 l
l
' C I
t l
REVISION RECORD l
l 1
i Revision No.
Date of Revision Pages Revised Reason for Revision f
i l
1 f
I i
l
.l llG E
h J
1 l
1 t
J i
e-----m-- - ----_. - _ _ _ _., -
m-.-
a.,,msm,e.ws-em-w-a wpy y g,g-g
1
)
l l
i I
TABLE OF CONTENTS Section Title Page INTRODUCTION ix
" \\B7 1-MANAGEMENT COMMITMENT 1-1 11 Plant Personnel Awareness 1-1 L
1-2
' Management Audit 1-1
'1-3 Qualifications and Responsibilities of the i
Regulatory Compliance Component Staff 11 f
f 14
. Plant Worker Training 12 L
1 Regulatory Compliance Component Authority 12 1-6 Modification to Procedures, Equipment and Facilities 1-2 i
N..
I
-2 VIGILANCE BY THE REGULATORY COMPLIANCE I
COMPONENT STAFF 2-1 L
2-1 Origins of Radiation Exposures and Radioactivity Releases.
2-1
~
L
~
'2-2 Reduction of Exposures and Releases-2-1
.l l
2 Equipment an'd Supplies for Radiation and Environmental Protection-Work -
2 =
i
-: 3 IMPLEMENTATION ALARA Committee '
, 3-1
, 1 i
12-1 13 2 Reports -
3-2.1 -incident Report-3-2 l 2.2 ; ALARA Report
. 3-2 :
u I
i m
r,
4 l
1 1
g,-
r et v y +y -* w+ e p y-tr y t eesy
-ww + w, gs-eg y4 m e, w, Wynyt*v r vsv re e+ w'=*ireme. -
==+esw sr* - h w*e te = =w -
-'d****'--
I l
LIST OF ILLUSTRATIONS Figure Title Page
)
3-1 Average Dose Equivalent Per Radiation Worker 34 l
l 3-2 Integrated Radiation Worker External Dose Equivalent 3-4 l
3-3 Average Environmental (Site Boundary) External Radiation Dose Equivalent 3-5 3-4 Alpha Radioactivity Collected on Controlled Area Air Samples 35 d
j 3-5 Alpha Radioactivity Collected on Stack Air Samples 36
{
3-6 Alpha Radioactivity Collected in Liquid Effluent Samples 3-6 37 Urinalysis Results 3-7 I
3-8 in-Vivo Coenting Results 37
[
~
i G
l P
t I
L@
Vii
. ~...
)
't J INTRODUCTION
- _x The Westinghouse Nuclear Fuel Division's Alabama Nuclear Fuel Fabrication Plant (ANFFP) is designed to strictly control and prevent hazardous situations and actions under normal
(]
conditions of operation and to present conditions which could lead to accidents. Engineered
('
safeguards and administrative controls provide multiple factors for maintaining releases of radiation, radioactivity, and hazardous materials (to in plant and out-of-plant areas) at levels well below regulatory maximums.
The international scientific community has recommended, and state and Federal regulatory agencies have adopted as regulations, certain stated levels of radiation exposures to workers and the general population that are never to be exceeded, virtually without regard to circum-stances. Any allowed exposures to, or releases of, radioactive materisis are expected to be associated with some justifying benefit; inequitable distribution of risks among individuals in a given population is expected to be minimized. ANFFP Management fully endorses these
)
basic tenets of radiological protection.
ANFFP Management's interest in radiological protection is primarily directed toward conduct-ing operations such that actual exposures to radiation, and actual releases of radioactive materials, are kept as far below established upper limits as is reasonable to achieve in view of technical, economic, and social considerations.
In accordance with this interest, I and the entire ANFFP Management Staff are fully com-mitted to making every reasonable effort to maintain radiation and radioactivity exposures, and releases of radioactive materials in effluents to uncontrolled areas and environs, as low as is reasonably achievable (ALARA).
(-
(T.B.S.)
ANFFP Plant Manager Date l
ix
Il v
SECTION 1
't)
MANAGEMENT COMMITMENT ANFFP Management's commitment to minimize exposures to radiation and radioactivity, m.
)
and to minimize releases of radioactive materials, provides clearly defined radiation protection
("/
responsibilities and an environment in which the responsible Regulatory Compliance staff can do its job properly. The following paragraphs address the several aspects to this commitment.
1-1.
PLANT PERSONNEL AWARENESS Plant personnel are to be made aware of ANFFP mnagement's commitment to the ALARA principle. The commitment will appear in policy sts.ments, and at initial training and re-fresher training sessions. Initial training sessions will concentrate on assuring that workers are aware of what the management commitment is, what "As Low As Reasonably Achievable 7-(ALARA)" means, why it is recommended, and how they are to implement it on their jobs.
N.]
1 2.
MANAGEMENT AUDIT ANFFP management representatives (the Regulatory Compliance Review Committee) will periodically perform a formal audit to determine how exposures and/or releases might be
' lowered. This will consist of a formal review of the semiannual ALARA Report to the Review
~
Committee, which is to include reviews of operating procedures and past exposure and release records, plar*
spections, and other relevant information assembled by the regulatory com-pliance comi t staff. Committee meeting minutes will document that management has reviewed spec.
rating procedures, has reviewed those locations in which most exposures f) are being receive,
.. reviewed what groups of workers are receiving the highest exposures, V
has carefully weighed comments and recommendations presented by the regulatory compliance component staff. The meeting minutes will document what steps management has taken to reduce exposures to, and releases of, radioactive materials.
(
)
1-3.
QUALIFICATIONS AND RESPONSIBILITIES OF THE
/
REGULATORY COMPLlANCE COMPONENT STAFF Qualifications and responsibilities of the Regulatory Compliance Component staff, including the regulatory compliance manager and the health physics engineering discipline, are documented I
i
\\j 1-1
in Section 4, " Specification S 1-3: Organization and Administration Controls" of the ANFFP License Application. The senior manager of the Regulatory Compliance Component will be responsible for implementing facility regulatory compliance programs, including the radiation protection program. Qualifications for the regulatory compliance manager and the health physics engineering discipline are commensurate with the potential problems anticipated in a low enriched uranium fuel fabrication plant.
1-4.
PLANT WORKER TRAINING Employes at the Alabama Nuclear Fuel Fabrication Plant will participate in orientation and training programs. As part of this training, before and during work at the plant, employes who work with radioactive materials will be carefully instructed in the meanings of radiation and radioactivity exposures, and in techniques for minimizing such exposures. Radiation workers will understand how radiation protection and protection of the environment relate to their jobs. This understanding will be documented via questionnaires completed at initial and annual refresher training sessions. Management, through the Regulatory Compliance Review Committee, will review plant worker training at least once every three years.
1 5.
REGULATORY COMPLIANCE COMPONENT AUTHORITY The Regulatory Compliance Component has been given sufficient authority to enhance safe plant operation. This component has the authority to control unsafe practices and to com-municate promptly with an appropriate level of management about halting an operation deemed unsafe. Operating procedures related to nuclear and radiological safety and.oviron-mental protection are to be reviewed and approved by the Regulatory Compliance Component.
This authority has been documented in Section 4 of the ANFFP License Application.
16.
MODIFICATIONS TO PROCEDURES, EQUIPMENT AND FACILITIES Modifications to operating and maintenance procedures, and to plant equipment and facilities, will be made where they can be shown to substantially reduce exposures and releases at a reasonable cost. Through the ALARA Report, management will document that improvements have been sought, that modifications have been considered, and that they have been im-plemented where practicable.
O O
1-2
OC SECTION 2 o
(v) -
VIGILANCE BY THE REGULATORY COMPLIANCE COMPONENT STAFF lt is a licensed responsibility of the Regulatory Compliance Component staff to conduct sur-
'(N
(
)
veillance programs and investigations to determine that occupational exposures and environ-mental releases are as far below the specified limits as is reasonably achievable. Additionally, the Regulatory Compliance Component staff is instructed to be continually vigilant in search-ing out new and better ways to perform all radioactive material handling jobs with less exposure to, and/or release of, these materials. The following paragraphs address the several aspects to these responsibilities.
2, ORIGINS OF RADIATION EXPOSURES AND RADIOACTIVITY RELEASES The Regulatory Compliance Component, especially the health physics engineering discipline and
{)
staff, will document the origins of radiation exposures in, and radioactivity releases from, the plant. They wi!! document these by location, operation, and/or job category and they will graph trends m exposures and releases. When Radiation Work Permits (RWP) are used, ex-posures and/or releases will be recorded on the permits. In the semiannual ALAR A Reports to the Regulatory Compliance Review Committee, the Regulatory Compliance Component staff will describe which locations, operations, and jobs are associated with the relatively highest exposures and releases, and why exposures and releases are increasing or decreasing.
2-2.
REDUCTION OF EXPOSURES AND RELEASES
(]
The Regulatory Compliance Component, especially the health physics engineering discipline and O
staff, will evaluate methods to reduce radiation exposures and releases of radioactivity. If significant, unusual exposures and/or releases should occur, the Regulatory Compliance Com-ponent will participate in an investigation of the circumstances of such exposures and/or releases, to determine the causes and to take steps to reduce the likelihood of similar future
(
)
occurrences. For each such occurrence, an incident Report will be prepared and the semi-annual ALARA Reports will document that such an investigation has been carried out, that conclusions were reached as a result of the investigation, and that appropriate corrective action was taken, p
2-1
The Regulatory Compliance Component will perform an annual review of operating procedures which are significant to radiation and environmental protection. The health physics engineer-ing discipline staf f will survey plant operations (at a minimum frequency described in Section 5, " Specification S 1-5: Health and Safety Engineered Control and Technical Specifications" of the ANFFP License Application) to identify situations in which exposures and/or releases might be reduced.
The Regulatory Compliance Component will receive and evaluate suggestions relating to radia-tion and environmental protection from plant employees. At initial and annual refresher train-ino sessions, radiation workers will be instructed in the procedure for making suggestions on radiation and environmental protection.
23.
EQUIPMENT AND SUPPLIES FOR RADIATION AND ENVIRONMENTAL PROTECTION WORK Adequate equipment and supplies for radiation and environmental protection work will be provided. The Regulatory Compliance Component will be responsible for determining that proper equipment and supplies are made available, are maintained in good working order, and are properly used in accordance with available written procedures.
O I
O O
O 2-2
- - =
l i:
SECTION 3
- O imeteuewrarion Key elements - implementation of the program of affirmative action toward ANFFP management's commitment of making every reasonable effort to maintain radiation and radioactivity exposures, and releases of radioactive materials in effluents to uncontrolled areas and environs as low as is reasonably achievable are the ALARA Committee and incident and ALARA Reports. The following paragraphs describe this committee and these
- reports.
31.
ALARA COMMITTEE The ANFFP Regulatory _ Compliance Review Committee will function as the facility ALARA
- Committee.. As described in Section 4_of the License Application, when functioning in -this capacity the committee will determine that appropriate action is taken, as required, to main-V
' tain and demonstrate compliance with ALARA regulatory requirements.
.The committee will be specifically responsible for conducting reviews and providing assess-
.ments of occupational radiation exposures (internal and external), radioactive ~ materials releases j
to unrestricted areas, and related abnormal occurrences.
The committee will be chaired by a designee of the ANFFP Site Manager and membership will_ include operations (Production Discipline Manager), 'manufac'turing engineering (Engineer-ing Discipline Manager) and regulatory compliance (Safety and Compliance Discipline Manager).
~
- The committee will convene at least semiannually, following any major ANFFP radiation
~
incident, and at the request of the ANFFP Site Manager (or at the request of any committee
- member).'
. The committee will' submit a semiannual written summary to the ANFFP Site Manager which
" reviews employe exposures and effluent release data to determine:
f%
2
))
. If' there are any: upward trends developing in personnel exposures for identifiable:
e
- categories of workers or' types of ope.;' ions, effluents,( or_ concentrations 'of effluents in environmental samples.-
L-Q,
3-1 ^
<<e
, -i-
If exposures and effluents might be lowered under the concept of "As Low As
=
Reasonably Achievable" if equipment for ef fluent and exposure control is being properly used, maintained, e
and inspected.
Further, the coramittee's summary will include review of other required inspections performed during the past six months and review of the data from the following areas: employe ex-posures, bioassay results, unusual occurrences, in plant airborne radioactivity, effluent releases, and environmental monitoring.
3 2.
REPORTS Two key reports with ALARA significance are the incident Report and the ALARA Report.
3-2.1.
Incident Report Following any unusual occurrence in which an individual is exposed, and/or radioactive materials are released, in excess of any limit in the facility license and/or the regulations, the Regulatory Compliance Component will participate in a detailed incident investigation. As part of an incident investigation, an Incident Report will be prepared. The incident Report will document the following information (as applicable):
e-The area involved Equipment failures that contributed to the exposure and/or release a
Procedures relating to operations which contribute to the exposure ond/or release a
Corrective actions, including actions taken to prevent recurrence.
a Incident Reports will be prepared by the cognizant operations management personnel and will be reviewed and approved by the Regulatory Compliance Manager. These reports will be summarized in the semiannual ALAR A Report to the Regulatory Compliance Review (ALARA)
Committee by the regulatory compliance component staff.
3 2.2.
ALARA Report Summary a
External Personnel Exposures
=
internal Personnel Exposures e
Airborne Radioactivity Concentrations a
Effluent and Environmental Monitoring a
a Unusual incidents e
Audits 32 L
I.
1-p, s
ij.'e -
e
-Uses of Equipment I
e _ Appendix
[
~ The purpose of this report will be to summanze current operatmg conditions in the Alabama j
^ Nuclear Fuel Fabrication Plant relative to radiation and environmental protection, to identify c !..
any trends developing, and to inform management of the results of actions being taken to i
l
' reduce personnel and environmental exposures.
]
i "The Appendix will elaborate o'n significant topied issues and will graphically depict informa-tion relating to:
Average dose equivalent per radiation worker (figure 31).
l s
~
a.
--Integrated radiation worker external-dose equivalent (figure 3 2).
a Average environmental _(site boundary) external radiation dose equivalent
_ figure 3-3).-
l
(
e Alpha radioactivity collected on contro!!ed area air samples-(figure 3-4).
a-
- Alpha radioactivity collected on stack air samples (figure 3 5).
fy~
s Alpha radioactivity collected in. liquid effluent ' samples (figure 3 6).
-i l-L j
l e
' Urinalysis results (figure 3-7).-
l
~
l
's:
In Vivo counting results (figure 3-8).
l l[!
~
j l
-fALARA reports will be prepared by cognizant disciplines within the Regulatory: Compliance l'
' Component' staff, and will. be pr'esented to the committee by the Regula' tory Compliance
]
Manager?
j
.i i
l
_i
- Y
~
i a.
~.-l
-l y
33 s>
l
O 17696-1 1
O, 0.5 RESTRICTED AREA -TOTAL BODY ACTION LEVEL 2<
0.4 -------------------------
E c
Lu o-0.3 O
m y
0.2
<c 0.1 4
0.0 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd YR YR YR Figure 31. Average Dose Equivalent Per Radiation Worker (By Quarter) 250 ACTION LEVEL FOR 500 RADIATION WORKERS 200 - - - - - - - - - - - - - - - - - - - - - - - -
E tu 9
150 z<2 i
J 100 O
1 50 ACTION LEVEL FOR 100 RADIATION WORKERS 0
{
1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd YR YR YR O
1 Figure 3-2. Integrated Radiation Worker External Dose Equivalent (By Quarter) 34
.~.. - _-
.. ~..
-~_. -..-.-
t 4
17696-2 1
[
4 1
i j-0.2 i
r
.t
- I l
i.
E t
W PRE OPERATIONAL BACKGROUND LEVEL 4
cc w
0.1 xw
- i.
i f
0.0 19
- 19 19 19 19 19 1
3 2 -
Figure 3-3. Average Environmental (Site Boundary) External Radiation Dose Equivalent (Annual) t I' >.s u-500 a.
vI w u.
.JO.
. 400 I$
t
<N 300 Q<
i u.- 3E ~
O $2!
200 Co w
- i Z
s coEo aw.
100-
.zwO
'N
-0 1st
- 2nd 3rd
- 4th 1st 2nd 3rd 4th 1st-2nd l
YR YR YR
[h A Figure.3 4._ Alpha Radioactivity Collected on Controlled Area Air Samples (By Quarter)
L -
~
'3-5 g
,o 4
-+- g w v* a-.-w 9 v e, W e, m v. w-w r-+ w 'e w.. w.
w-w w p-e.ee..r e-se e
e
.mp-e es.-..+-...w.-ime+s--*==+.em
...rde.e.
+----6.w"e.e--.....--*-%--- =., -- - =
-.-es.+--, =
17696-3 200 0
AVERAGE MICROCURIES PREDICTED BY ENVIRONMCNTAL EB De REPORT Uz o<
100 C I 8
lE -
sO
<>0&
l l
l l
l l
l l
l 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd YR YR YR Figure 3-5. Alpha Radioactivity Collected on Stack Air Samples (By Quarter)
O 8000
$a 6000 oW OO AVERAGE MICROCURIES PREDICTED BY ENVIRONMENTAL 04 4000
- - - - - - - - - - - - - ~ ~ ~ - - - - - - - - - -
56 REPORT a m 45 2000 l
l l
l l
l l
l l
0 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd YR YR YR O
Figure 3-6. Alpha Radioactivity Collected in Liquid Effluent Samples (By Quarter) 3-6
17696-4 i
i 1
0 50 2-m Ow ww w-40 i
o i
Xz ww Mw3 30 i
uQ. mE
,^
E<
<m 20
+
m
- u. C
- l 0 0 m
zu 10 w2 4
m i.
go 0
1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd YR YR YR 4
1~
Figure 3-7. Urinalysis Results (By Quarter) i t
l.
20
.o 2-tn Om w N.
w s:
- o X u.
i wo MM wE i-z<
i om 10 i
Oc Uo
- u. c Ou CE l
W o.
m m E--
i 0-1:t 2nd 3rd
-4th.
1st
.2nd 3rd 4th 1st. 2nd i
~
l YR YR YR 1
1 I
i l
l
(
- Figure 3-8..in-Vivo Counting Results (By Quarter)
L 1b130
.37 l -
..