Text

To Onsite Radiological Contingency Plan. Six Oversize Charts Encl.Aperture Cards Are Available in PDR
	ML20058B396
Person / Time
Site:	07001100
Issue date:	05/21/1982
From:	; ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	;
Shared Package
ML20058B394	List: ML20058B388; ML20058B396;
References
	PROC-820521, NUDOCS 8207230698
	Download: ML20058B396 (174)
	v • d • e

{{#Wiki_filter:_ f 5 ?,. i l I On-S I fE.4 ADIULUUICAL CUN fli4GdNCY PLAia 1 r i l 0 LI C E.4SE 30. St. 4-1007 Occ ke t 70-1100 1 C0:4 cJ Si[ Jia disd i te sE n l.ej, I.4C. duclear Fuel.4anuf ac turin:; .41ncsor Plant ,linasor, Cf 8207230698 820607 PDR ADOCK 07001100 C PDR k

I i SYAuDAdu F0nMAf A.*U C0JTEaT Fod dADIOLUUICAL CONTINGENCY PLANS FOd FUEL CYCLE AND 14AfEHIALS FACILITIES fadLC UH CONT' CUTS Pace No. lafdOUUCTION 1-0 1.U UEu2HAL DESCdivTION OF fHE PLANT /LICEaSED ACTIVITY l -1 1.1 Licensea Activity Description 1-1 1.2 Site and Facility Description 1 -3 1.3 Process Jescription 1 -l o 2.0 ENUIuEERED /rt0 VISIONS FOR AeNORMAL OPERATIoaS 2-1 2.1 Criteria ror Accommodation of Aonormal Goerations 2-1 2.1.1 Process Systems 2 -1 2.1.2 Alarm Systems and delease Prevention 2-7 ( )

2. l.3 Support Systems 2-3 2.1.4 Control vrocecures 2-30 2.2 Demonstration or Engineerec ?rovisions f or Aonormal Operation 2-30 2.2.1 Process Systems 2 -30 2.2.2 Alarm Systems anc delease erevention Cacacility 2 -30 2.2.J Su: port Systems 2-32 2.2.-

Control Operations 2-37 3.0 v' LASS ES OF n AJIOLuJICAL CunTla3ENCI ES 3-1 J.i Classirication System 3-1 J2 secommencec Classirication Scneme 3-14 3.3 dange or Pos tuiated Accicents 3-23 4.0 u n 3 Ai4 I I. A f i U n FO.I CONTROL OF HADI0 LOGICAL CuaTIuGEaCIES 4 -1 4.1 4crmal Plant Jrganization 4-1 4.2 Un-Si te dac iologic a l Contingency n'esponse Crganiza tion 4 -3'

r i FABLE OF C0;iTEt4TS (Cont'd) vage do. ()4.2.1 Direction anc Coordination 4 -3 4.2.2 elant Start Haciological Contingency Assignments 4 -4 4.3 Ort-Site Assistance to Facility 4-10 4.4 Coorcination witn Participating Uovernment Ag encies 4-11 0.0 HADIOLOGICAL CONTINGEJCY MEASUHES 5-1 c.I Activation or Haciological Contingency desponse Organization 5 -1 3.2 Assessment Actions 5-o c.3 Corrective Actions 5 -o c.4 vrotective Actions 5 -6 c.4.1 versonnel Evacuation from Site & Accountability 5-6 5.4.2 Use of Protective Equipment & Supplies _5-7 o.4.J Contamination Control ;Aeasures 5-13 r.D Exposure Control in Haciological Contingencies 5-10 ( ) 5.5.1 Emergency Exposure Control Program 5-lo 5.5.2 Decontamination of Personnel 5-21 9.o Mecical Transporta tion 5 -22 c.7 Medical freatment 5-23 o.0 dQUIv.A En f Aa0 FACILITIES o-1 0.1 Control Point 0-1 0.2 Communications dculpment o-1 o.3 Facility for Assessment Teams o-1 o.4 Un-Si te Aeo ical Fac ili ties o-2 o.o Emergency,,tonitering douipment o -2 7.0 , TAI nTEnAi4CE OF HADI 0 LOGICAL C0 4 fi tlGE:4CY PHEPAdEDdE55 CAPABILITY 7-1 /.1 ilrittan Procedures 7-1 /.2 fraining 7-l (-} (s/ 7.3 fes ts and Jrills 7-2 E

FAoLE OF CONTEnfd (Cont'd) Page so. ( ) 7.4 Heview anc Up-Dating or the Plan and vrocecures 7-3 /.b .4aintenance and Inventory of Radiological Emergency Eculpment, Instrucentation, anc Supplies 7-3 0.0 HECOHOS AWD HEv0HfS 8-1 1 d.1 secoras of inc idents 8-1 6.2 decords or Preparedness Assurance - a-1 8.3 deporting Arrangements 8-3 9.0 dECOVdHY 9-1 9.1 de-Entry 9-1 9.2 Plant Westoration 9-1 9.3 desumption or Operations 9-1 .O l 4 i i-4 l l -J-i I L-

GV InfdODUCfloa The auclear Fuel Idanuf ac turing anc Fuels Development Laboratory operations or Combustion Engineering. Inc., licensed under NHC laaterials License SWM-loo 7 and located in

Windsor, Cf, submits this Hadiological Contingency Plan as directed by NHC Order dated Feoruary 11, 1981.

fhe plan has been prepared in accorcance with the " Standard Format anc Content For Hadiological Contingency Plan for Fuel Cycle and daterials Facilities," dated January 9, 1981. Ar ter final approval oy the Division of Fuel Cycle and Material Safety of tne USkRC, the plan will become a condition of.4aterials License sam-10o7. l l ( I O 4 devision 2 Date: 6/21/92 eage: 1-0 i Ie

f" O 1.0 Gene-el nescrintion of the Pl=nt/ Licensed activity 1.1 Licansec Activity Oascrietinn fhe dinosor plant of Comoustion Engineering, Inc., where licensed activities will be conduc ted, is locatec at 1000 Prospect nill doad in aindsor, Connecticut. Licensed activities are conductec primarily at the i4u cle ar Fuel Anaufacturing racility (Suilcing #17) anc an adjacent warehouse and shipping dock (Sullding #21). Additional research and development activities are concucted in the 04uclear Laboratory f acilities in Building d5 and

18 (Development Department Lacoratories), buildings #2 and

2A (iiuclear Test buildings), duildings 43 and e3A (Kreisinger Development Laboratory),

Buildings

1 and 1A (Storage Builcings), and duilding do (daste Water Process Suilaing),

and duilding #1o (Testing and Storage of Sealed Sources Am-241 Se, ana U230) at the Windsor Site. 1.1.1 sossession Li-its & Locatian Combustion Engineering, Inc. has authorization to () receive, use,

possess, store and transfer at its dindsor site, the following auantities of racicactive materials:

Isotone d2r2 Cunntity Loc =efaa Uranium en-Uranium 500,000 Kgu .a f g. -61dgs. 17 1 21 & riched to Oxides storage in trailers 14.1% wt. cetween Bldos. 17 & 21 Develocment Department Blogs. I, l A, 2, 2A, 3, ( 3A, 5, lo & 18. t l Uranium en-Any 4800 gas blog. I, lA, 2, 2 A, 3, ricnec to less U-23S 3A, 5, lo, 17, id s 21 than 2u wt.% (Bicg. I7 & 21 limited percent U -2 Jo to 300 ga U-235 eacn ror enrichments exceecing 4.1 l w t. % U -2 35 ). uatural ano/ Any 10,000 Kgu cidg. 1 IA, 2, 2 A, 3, 3A. or Depleted b, o, lo, 17, id s 21 Uranium devision 2 Jate: c/21/82 rage 1 -1 k

{TL () vu-23d Encapsu-5 sources, du11 ding 17 laced ea. con-deutron taining less Sources tnan 2.0 gm Pu-238 vu Any Form 100 micro-Bldg. 1, IA, 2, 2A, 3, 3A, grams as 5, 6, l o, 17, 18 6 21 analytical samples Encapsulated U308 20 sources, Bldg. I, I A, 2, 2A, 3, 3A, heutron ea. con-o, o, 16, 17, 13 & 21 Sources ta ining less tnan 1.7 gm U-23b I.1.2 lutnori7ed Activities The primary activities carried out in buildings at the Mindsor site include, out are not limited to the 3 s/ followings Storage of small quantities of dicg. #1 s 1A racioactive material ( <350 gas U-235) dicg. #2 & 2A - Faorication and decontamination or reactor servicing equipment, storage of archive fuel rods, and relatec activities. Storage of sma ll auantities or 31cg. #3 3A radioac tive ma terial ( < 3bu gms U-2 36 ). desearch anc development activities Bldg. g5 utilizina

Saa, incluaino tne operation of a

i radio-cnemistry labora tory, ceramics lac, and relatec racilities. Source material is used for dAJ work in tne enermal hydraulic testing of reactor fuel anc l comconents. dlog. #o - daste water processing from manuf ac turing and lacoratory activities. l clog. dio - Same as building #5. dicg.

1/

.danuf ac ture of hid ruel assemolies utilizing low enriened uranium (uo to 4.1 wt.M U -235 ) ( in the form of uranium oxice

powder, pellets,

rocs, and in asse nclies.

i devision 2 Date: 3/21/82 Page 1 -2 l L__ 1

() dicg. *18 - Tes ting of reactor fuel assemolies anc components. dicg. #21 - Storage of sam in shipping containers. 1.l.3 gyamations acq Snecial Antherivations Licensed activities in 81dg. 1, lA, 2, 2 A, 3, 3A. 5, 6, lo, anc 18 shall be of an analytical or cevelopment nature and that the material may ultimately oe returned to the nuclear Fuel Aanufacturing facility. These transfers shall not require the issuance of applicaole WWC transfer cocuments, out shall ce transferrec in accordance with the provisions of this

license, ano shall be handlec as a

departmental transfer and.shall be controlled by the Fundamental riuclear Material Control Plan (FdMC). 1.2 S!TF un ;ArILITV 09SCW I PTI3il I.2.1 Loc a t i on of tha Plant Comoustion Engineering's low enriched UO2 tuel () rabrication is part of the C-E Power Systems Group loca ted at the C-d Windsor site. The site is locatec 9 miles north of Hartrord and is snown with respect to the tri-s ta te recion of New York, Massachusetts, and Hhoce Islanc in Figure 1-1. The C-E dindsor site is a 1,000 acre tract located in the township of

Jindsor, C F.

Figure 1-2 illustrates the site location and major transportation links within the town or Mindsor. Figure 1 -9 shows an enlargement of the C -d site councary shown in Figure 1 -2. 1.2.2 eecionai Damecr=cnv ihe area surrouncing the C-6 dindsor site is sparsely populated. East Grancy is the nearest t o.vn to One site. The to wn center is located approximately 3 .ailes north or the site. It has a population of 4,037 persons yielcing a population density or 228 per s cuare :.111e. Jindsor is the nearest town of any size. Its town center is locatec approximately a m iles southeast of the

site, fhe town's population is 25,171 persons yielding a popula tion density of 850 per s qua re mile.

The aoove cata is basec on preliminary 19d0 census data. As shown in Figure 1-3, the five towns or

dindsor,

() Jindsor Locks, dast

Urancy, Grancy, dicoatield anc Simsoury are wholiy or partly within 5 miles of tne devision 2 Dates o/21/92 Page: 1-3 t

e i l () C-E site. Population, population density, town

area, distance ano direction of the towns from the C-E site are given in Table 1 -1 Figure I -3 is a

map illustrating the lo sectors surrouncing the C-E site up to a 5 mile radius _This maa is part of the State of Connecticut's Emercency sesponse Plan for both Comoustion Engineering's low enricned ruel f aorication racility and General Electric's prototype Naval deactor Site. Major roadways, schools anc cnurches have been delineatec. Figure 1-4 is a composite of topographical maps showing the structures surrounding the C-E site. The nearest residents in each or the 16 sectors within i mile are indicated in this figure and summarized in Table I -2. The nearest resident is located in Sector 5, east of Building #17, a distance of 700 meters. Population centers within one mile of the site (with r approximate resicent and or commuter pcpulation of each center) are taculated in Table 1 -2a. Figure I -o is a map of the dindsor site which specifically identifies the coordinates or Suilding

17 to the nearest second, fhese coordinates are d 72 bo" for tne center or

-43' - 08" and a 41 -SI' Building #17. O 1.2.3 Land use la the Fecility cavirons The Town of dindsor covers over 19,000 acres consisting of predominately agricultural anc residential areas. A survey completed at the beginning or 19/9 showed the distribution of land use within the town to ce as follows: 2S% residential, 244 agricultural, 22% vacant

land, 1o%

public facilities, 8% industrial and commercial and c% net wats. ( Tao le 1-3). The areas immediately surrounding the C-E dindsor site consists or a town-owned sanitary lanofill anc tne Farmington diver to the north, and a comoination of heavily wooced areas and agricultural rields primarily for tne growth or broad lear tocacco to the south and west. however, recently to the soutnwest of the site, at the intersection of Prospect Hill doac anc Blue Hills

Avenue, the Griffin Office Center was constructed by Culbro

fobacco, Inc.

This center presently has aoproximately 300 employees from various corporations with plans for adaitional builcings in the near future. To the east of the dincsor site, tne receral government owns land whicn is ceing used oy Knolls Atomic Power Laboratory operated oy General diectric for the 'J. S Department of Defense and j Department of Energy. The laboratory is mainly usec devision 2 Dates o/21/$2 Page 1-4 i t

() for the training of naval personnel in the operation or a prototype suomarine nuclear reactor. Other towns within a o mile radius of tne C-d dindsor site are bloomfield and East Grancy. Eas t Granby's land use consists of 47.8% woodland, 30.74 agriculture and open

space, 8.9%

residential, 7.2% public f acilities and 0.5% industrial and commercial (Tacle 1-4). The town of dloomfield consists of 29% res idential, 11.1% commercial and industrial and 17.3% c ul tiva t ed land (fable 1-o). Figure I -6 descrioes land use within a 5 mile racius or the C-E Windsor site in greater cetail. Three significant industrial comolexes exis t within a 5 mile radius Approx # of dame Location _Canloveas Distance Sactor Hamilton Stand. Winasor Locks 7,000 4 miles n/nE a S/SE Stanadyne, Inc. Plindsor 3,000 o E Emhart Indust. Windsor 720 2 O v 1.2.4 Land Usa On-Site Figure l-7 shows the buildings and facilities presently locatec on the C-E Windsor site. fhere are some 25 struc tures snown, each one iden tif ied as to building number, building name anc site location. Taole I-o lis ts the structures by building

number, builcing name anc present utilization.

Also listec is the total acreage occupied by each ouilding. Total area occupied oy all s tructures on site is 17.45 acres. In addition, some 22 acres of tne site are utilized for access

road, parking lo ts,

walkways between ouildings, etc. Thus, out of tne 1,000 acres availaole on the site 39.45 or, 3.9 percent of tne total is ceing used for ouildings, parking facilities, etc. The remaining 900.55 acres, or 90.1 percent or the total availaole, remain undisturoea anc consist mainly or woodlands, water codies, and ocen spaces. Figure I-d shows an aerial view of the C-d ,linc so r plant site, rhe C-E site is a naturally wooaed area anc is restricted to hunters and the general cuolic to () protect the existing environment. Guards ecuicpea witn two-way racios patrol the site on a 24-nour basis nevision 2 Date D /21/82 Page 1-5 L

O(_) to enforce this restriction. The Great Fond located in the southwest section or the site and the inland wetland located in the southeast end of the site are home for many species of waterfowl anc also a stopover point for migratory birds. Special pumps have been installed, at C-E's expense on the south shore of the Great Pond to agitate the water in the winter montns to prevent ice formation and to provide open water for the waterfowl that permanently reside in the area. 1.2.5 Fuel Fanrication Jacilitv. Buildinn 43 7 The uFA-d Fuel Faorication Facility is 120' wide x 340' long and contains 40,800 square feet of floor space. The snop section of the fuel faorication facility is 120' wide x 300' long and contains 36,000 square feet of floor space. It has concrete flooring, corrugated asbestos s id i ng, and a pourec gypsum root

ceck, approximately 3d' hign.

The 30,J00 square f eet of floor soace is divideo into () two areas the first area b'eing utilizec ror radioactive process work while the seconc area is utilized for nonradioactive process work. Distribution of floor space within each area is listed belows do r < A rg do. Scuare Geet Tyne ?rmeess ilatl Pe lle t Fabrication 5,0]O dadioactive Pellet Encapsulation 7,000 .< ac i oa c t i ve Fuel Hoc Faorication /,000 tionradioactive Fuel mundle Assembly 4,000 f4cnr ad ioac tiv e Machine Snop o,000 tionr adioac t iv e Cleaning, Storage, General vrocess 8.000 - donracioactive rotal Jo,000 fne radioactive area of the snop is air concitioneo and humidity controlled anc is under negative cressure to prevent the escape of airborne uraniu.n Jioxice into the nonradioactive shop areas, rhe ofrice section of tne facility is 40' wice x 12J' long anc contains 4,800 square feet of ricor space. It nas conc re te

riocring, exterior concrete clock walls witn rull windows and a poureo gypsum root deck approximately 11' hign.

gj nevision 2 Cate: o/21/82 Page 1-o m

O i.2.o ""cieer '-ermeer as ec111tv The i4uclear Laboratories facility con ta ins o0,000 square teet of rioor space. It is a multiple level structure that has a main bay at one ~end with three wings located off of the main bay. The wings are identiried as the north, central and south wings of the facility. At the opposite end of the cuilding and a ttached to the central wing is a high bay test facility, 100 feet in height. The main oay and eacn of tne tnree wings of the structure contain office space which occupies a total of 27,000 square r eet of the facility. idechanica l testing and research/ development work occupy areas in the main bay, central wing, incluaing high bay area, and south wing anc take up some 10,500 square teet or rioor space. dork in the areas is evenly divided among activiti es that re cu ire the handling of radioactive materiais anc activities that require the handling of nonradioactive materials. The electrcnics testing laboratory, fabrication of O_, special research test fuel, and chemistry testing or y procuction nuclear fuel for quality control ourcoses occupy the remaining areas in the main oay anc three wings and take up some 1o 500 square feet of floor space. .Tork in the areas is evenly diviced among ac tivities tha t require the handling of radioactive materials and activities that recuire the handling of nonracioactive materials. ( sevision 2 Jate: 5/21/92 vsge 1-7 L

OV LAULu I _; suvulAf!Od AND PO W LATIOa OFNSITY OC TO % S 7f!TH I N 10 '3 ! LC, r< A')I U S O C CU..MUSTION CNGI N CCJ IilG. I J C.. Approximate Distance of General Estimatec Population fown Center Direction Square Population Density E2hn to Si a tro, Sita Milas (1070) sareen/sc fla Martfera............... 9.............S......la.o.....lb8,017....... 8495.o .iindsor................ 5.............SE.... 29.o..... 22,502........ 760.2 d1oomrield..............o.............S..... 20.9......lH,301........ 080.3 dest Hartford...........d............ 3d.... 21.o......o8,J31....... 3149.1 East Ha r t r o rd.......... 9............. S 2..... l a. 2..... 5 7,5 3 3....... 3164. 0 Aa nc hes te r............ 13............. S..... 2 7. o..... 4 7,99 4....... 1738. 9 doutn ainasor.......... 7.............SE.... 29.2..... 15,553........ 532.o f-) dast dinosor............o.............SE.... 25.o...... 8,SI3........ 317.6 v . 41 n d s o r Lo c x s.......... 4............. d...... 9. o..... 1 5. 0 3 0........ l b 2 0. 8 dast G r a n cy............ 3............. u..... 1 7. 8...... 3. 5 3 2........ 1 9 8. 4 S im sou r y................ o............ 5 d.... 3 4. 2..... 1 7,4 2 5........ 51 0. 9 l / 3 A VO n i n C 1. C e n t e r... 6............. Sd..... 7. 4...... 3,0 0 0........ 4 05. 4 Uranoy Center...........o.............d...... 10.0...... 4,500........ 450.0 1/2 Sufrield inc1.......o.............a.....22.0......4,300........195.4 Center 6 d. So r rie la 1/3 dnrield inc1........d.............uE.... 11.0..... 10,000....... 1454.5 fnompsonville 1/2 illington excl.... 12.............E......Il.0...... 3,700........ 229.4 Center 1/J Vernon exc1 Center.lJ.............E.......o. 0...... 7.200....... 1200.0 f3fAL3 333.3 471,481 n ss devision 2 Date: 3/21/82 dage: l-d u-

TAuts 1-2 iiEAdEST 4ESIDEnTS (JITHIN 1 :. TILE HADIUS) (SC WIGUwe I-4) SECTOR 14 0. OlsscTIO a DIST G O RWOA dLDG. 17 (v6TCs9) I (4 2 ti/I4E J (J E 4 E/t1E 990 5 E 700 o E/Sa 1,225 7 SE d S/SE O v S 1.01s 10 $/S.l 1,4c5 1I S.1 1.540 12 J/Sd 1.525 IJ il 730 14 il/u4 lo ad i { lo W/t44 1,430 t i l l Incicates no resicents witnin sector dotes ide ares t site coundary to builcing +11 is coo meters west (5ector 13) i l See Figure 1 -9 i O l i i I j' devision 2 Dates o/21/82 Page 1 -9 I i

rABLE t-2a PuedLAildii Udi.fEHS ;1ITHIl4 i :.i1LE 0F SITE ; LITH AdvH0XIMATE RESIDE:4T Aun424 co'mdT 4 PovutATiota OF c;cH cFnTE> L General Direction _ Pocerlation center _ Erem S h Estimatad Pen,'lation Tvaa Poc"la*4on GE Prototype Heactor N/t4E 300 Commuter Uritrin Otrice Center .l/S i 300 Commuter ilartforo Ins. Printing SW 200 Commuter O C i l i l l l ' O I l sevision 2 Date: s/21/S2 Page: 1-10

IAMLE 1-3 afnD50a LAND US;: SU W A JY Iu ACJCS O tea or << e e ae "et development Change Change Change (4/70) 1/1/77 4/70-1/77 1/1/79 1/77-1/79 1/1/70 1/7A-1/79 Single- .amily 3,43/ 4,185 748 4230 45 4312 82 141 Two-Family 142 141 (1) 141 Chr ee-S ix Family 27 31 4 31 31 apartments 1u9 234 125 238 4 238 Jroup 40 40 uuarters 40 40 1.ixec Mes./ Conm. Io 15 (1) 18 3 13 General Co mmercial 100 107 2 lib 8 115 ottice 2u 29 9 34 5 c5 31 automotive oc o0 4 ou 00 ..ianu f ac-919 o turing 848 91o 08 913 .ino le sa le/ Storage 49 153 104 157 4 1o2 5 33 83 Jtilities 83 83 55 55 tailroacs 50 c5 O clic 341 12 335 (6) Paciliti es 329 329 Semi-Puc.ic 5 32 . acilit: es 528 bJ2 4 332 vuolic Ocen Space 4U4 43/ 33 4bo 18 4o9 14 Semi-Puolic 21/ upen Space 213 21/ 4 217 vuolic aecreation 70 70 70 70 158 158 Oemeteries lod 168 Streets anc soacs 9 /3 1,058 85 10o9 11 1071 4 e locaCCo Land 3,214 3,12o (88) Jill (15) 3097 (14) dtner Agriculture 1,884 1,74o (194) 1701 (3/) loo 8 ( 33 ) totai Ueveloped 12,7o0 13,722 908 13,720 DS 13,813 97 ..e t.ia te r 1,085 cocies 1,06o 1,085 1,085 () cant b,4to 4,454 (934) 4,399 (oS) 4,312 (87) 19,201 iotal Lano 19,201 19,2o1 19,201 ( ) = net Loss l nevision a Dates o/21/82 Paco: 1 -11

{} rAeLE l-4 JAST G4 AidV - Ef ISTING LAUD 'JSE PEHCENT OF _LAan use ,1 c2 cS

Q~dlidiQ desidential Single Family 925 8.3 idul ti-Family 43 4

Commercial 17 .2 Incustrial 33 .3 Quarry 190 1.7 Puolic bradley International Airport 583 5.2 nartrora Gun Cluo du .7 Otner 148 1.3 varks anc Hecreation Copper Hill Country Cluo 78 .9 other 3 X Agriculture and Open Space 3,43/ 30.9 .locci and S 325 47.S doacs Local 144 1.3 S ta te 108 1.0 TOTAL DEV ELO?EJ =*' 2,374 TOTAL LA140 11,13o Acres 100.0% doundec otr to the nearest acre. JevelopeJ land incluces all categories except agriculture, open space and soccianc. I i i 4 nevision 2 Date 5/21/S2 daae 1-12

.q laLc 1 -s k/ MLOO*.t p t a n L A n n U S C SU *.90 4Y Percent of Percent of _Aeros rotal Land Lane in Usa focal Lano 17,21o 100.0 Jater docies (net) 204 1.2 /acan t Land o,990 40.o i Streets and Hoacs 947 5.5 Lanc In Use (9,0o9) (02.7) 100.0 Cultivatec Lanc 1,5co 9.1 17.3 Jacershec anc neservoir odb 3.5 o.7 Puolic Open Space and dec. 910 5.3 10.1 demi-Puolic and drivate Open Space and Hecreation 399 2.3 4.4 Flood Control Land I,i15 o.5 12.3 Developec Land (4,4o8) (25.9) (49.3) desidential (2,o29) (15.3) (29.0) Single Family domes 2,31 8 13.5 25.6 Two Family Homes 3/ .2 4 Convertec Apartments 11 .I 1 Uarcen Apartiaents 7b .5 1.0 i desicential dstates 108 1.0 1.9 Cpmmercial (col) (3.2) (6.2) ..tixec Hesident tal/Comnercial 22 .1 .2 Jeneral Commercial 90 .5 1.0 Au to.notive Commercial 24 .1 .3 artices 28 .2 .3 Lancscacea Enterprise 397 2.3 4.4 Industrial 44U 2.5 4.9 vuolic and Semi-vuolic, Developed (838) (4.9) (9.2) vuolic Facilities 249 1.4 2.7 Cemeteries 137 .8 1.5 i Semi-Puolic 4 Institutional Facilities 129 .7 1.4 Jtilities 323 1.9 3.o v) nevision 2 Date: 3/21/82 Page: 1-13

(Mii 1 -o cuilcings and Support Facilities on tne C-E.iincsor Site Acreage Juildin, ne_ snildin-sagg Present Utilliation occontea i Storage Equipment Storage 0.12 2 Test dicg. Test Lab. anc offices 0.25 3 Kreisinger Fossil Fuel Testing and Offices 2.30 Development Lao 4 Power Systems Admin. Offices 2.40 and En g. b nuclear Lacoratories Laos anc Offices 1.70 o not daste Vault Hadioac tive Was te Storage ano 0.06 Treatment oA Facilities dng. and 4aintenance Shops and Offices 0.17 Services 7 vowerhouse and Central Site Heating / Cooling Source 0.45 O Chilling Plant 7A Central heceiving Material Heceiving 0.06 e Eas t Guarc house Site Security 0.01 7 Cooling rower ,later freatment 0.02 10 Sewage Plant Sanitary Waste Processing 1.50 11 Fire Pump hous e Pumps for Sorinxler System 0.01 12 Huclear Eng, and dfrices 0.57 vnysics 13 dest Guarc house Site Security 3.01 14 Dining Facilities Careteria and vrfices 0.45 la Facility Eng. anc Carpenter Shop and Storage 0.15 Services lo Juclear Lacora tory Laos for Equioment Testin; 0.5o Extension I7 Fuel Fabrication cauclear Fuel Faorication 0.83 f~g b cuilding Hevision 2 Date: o/21/S2 dage 1-14

TABLE l-o (Cont.) () Id .4uclear Lacora tory -. Labs for E;uipment Testing 0.13 Extension 19 Acministrative and Offices-2.30 Engineering 20 Facility Eng. and !4aintenance Eculpment 5torage 0.12 Services 21 auclear.%rg. Warehouse -Nuclear Fuels Storage 0.22 22 Fossil Eng, and Offices anc Test Simulator 0.91 Simulator 2J Fossil Engineering Offices 0.91 24 Acainistrative 6 Offices 0.91 Engin eering Coal Gassification Encineering fest Facility J.34 (P.D.U.) TOTAL 17.45 O i

l 1

l l O. I devision 2 Date: 3/21/82 dage: 1 -l o

IE 1 0 3 %b ~. L*% . ie M Nm

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1.3 +0c958 DEMN!?TICa 1.3.1 Fuel :nnrientina "ac i l f t r. Boiteiac d17 Shipments or uranium dioxide powcer anc pellets are received at tne UFM-d facility in

Mindsor, Connecticut.

The plant contains eculpment to manuracture ruel rod and fuel cuncle

harcware, finished uranium dioxide fuel pellets suitaole for encapsulating in f uel rods, anc completed fuel rods; the comoleted ruel rods are assembled into fuel bundles which are then shicped to the utility's reactor site.

J A detailed description of the process used in the cuilcing

17 facility to convert uraniun dioxide powder into finished fuel bundles is notec in ene rollowing steps.

woraiar at Powder into ?ellet Snen Annex - UO2 powder is received into the pellet shop annex where it is weighed and then stored in the virgin powcer storage area located in the main pellet shop. The average amount and maximum amount of UO2 powder stored in tne pellet shop annex at any one time is 1,500 kas UO2 and 4,000 kgs UO2, respectively. ( entch wakaun - 302 powder cans are movec to the batch mate-up nood where tne cans are opened. The baten makeup hood is under negative pressure at all times so that airflow is into the hood and away from the operator. dewcer Hiendiac fhe baten of UO2 cowder is cischargec into a blender wnere it is mixec to a unirorm consistency. The blended powcer is oischargec onto a crying belt (maximum amount of powcer on belt at any one time would be aoout 100 kgs J02). The criec powcer is cischarged into a granulator in orcer to proauce a f ree flowing ocwder for suosecuent use in the pellet pressing operation. Howcer can only be in tne blender nocc and crying celt at the same time. Howcer cannot ce in tne spreac funnel wnile cowcer is on the crying belt. ihe comoinec amount of powcer in the clender hood and on the drying celt can ce as hign as 150 <as J02. Pall t drasiin - rhe free flowing uranium dioxide powcer is pressec to the desirec "areen" density anc geometrical shace. dellet -0=Na vi a, - The "areen" cellets cischargec from ("T the pellet pressing operation are crocessed througn a (> reducing atmospnere in a cewaxing furnace to remove devision 2 Date: 3/21/S2 Pace: 1-10

the lubricating material introduced into the uranium r^)' (_ dioxide powder prior to the pressing operation to luoricate tne press die cavities. Hellet dinterina - l'he cewaxed pe lle ts are processed through the recucing atmosphere of a sintering furnace where the rinal pellet censity is attainea. Pellets discharged from the Pettet Grinci,, sintering furnace are grounc, inscected for dimensions ano density, and tranterrec to the pellet stacking station. Wellet 5 t a c '< i n a - The pellets are aligned in a linear array, each pellet stack being or a length sufficient to rill one ruel roc. Hel19t orvine - The aligned pellet stacks are placea in a drying oven where resicual moisture is removed from the pellets. He lle t L2dains - The individual pe lle t stacks are weighed for record purposes and the weighed stack is loaded into a fuel tube with one end cap already welded in place. Einal en rfald - The final cao weld is mace anc the O' ' fuel rod is passed through rod inspection to ensure integrity of encapsulation and auality of product. Final inspectec rods are stored subsecuent to oeing assemblec into fuel bunales. Completed fuel reds and Fuel 'dundle Assenblv completec fuel oundle

harcware, conci5 ting of ena rittings and the f uel roc holcing

cage, are broucht togetner in the assemoly room.

Tne ruel rocs are ins e r ted into the rod holding

cage, anc the enc ritting is attached to the end of tne fuel buncle assemoly.

The completed fuel assemnly is

cleaned, inspected, packaged into an aoproved shicping container and shipped to tne utility's reactor site, faole 1-7 summarizes the current operations cerrormec witnin the te FM-d duilding di 7 facility and the generation of effluents associated with those ope ra tions.

Detailed within the table are data on: a) Description or major ano minor processing steps: c) Type of maFor processing ecuipment used c) Type ano quantity of effluents from each major process step classiried as to licuic, gaseous, or solids anc rurtner classifiec as ceing radioactive or nonradioactive ef fluents. (} devision 2 Dates o/21/82 Page: 1-17

1.3.2 nuclear Laboratot es Fecilitv. Muilcinn 45 i {} The Ceramics Lacora tory is involved with the develocment and testing of research fuel materials. fhe ruel materials are received f rom various outside sources and processed using different tes t conditions. The fuel is compacted and sintered in a manner similar to prcduc tion f uel. The comoleted fuels are then tested, loaded in rods, and shipped to incependent test reactors for evaluation. The Chemistry Department receives virgin cowder anc pellets at various stages of production f rom dFM-W for quality control analysis. The pellets are grounc anc separa ted for enemical analyses. This material is then weighed and dissolved or convertec to U308 depending on the analyses to ce performed. The analyses performed are to determine the amounts of impurities and quality of uranium being,usec. The Meta 11ography section of the Nuclear Laboratories receives comoleted U02 pellets from NFA-4 anc the Ceramics Laboratory for evaluation. fhese pellets are sectioned and processed for metallographic examination. 5 ihe Fuels and Materials section conducts research anc evaluation of nonirradiated core materials such as fuel cladcing, neutron poison materials, and fuel rod assembly materials. These materials are s truc tura lly examined by metallograpnic te chn icues, mecnanically and chemically tested for various ohysical and chemical parameters. Table I-d summarizes the current operations cerrormec within the nuclear laboratory racilities anc tne generation of effluents associated witn those operations. Detailed within the taole are cata on: 1) Description of ma jor and minor laboratory operations; 2) Types of major laooratory equipment usect 3) Type anc cuantity of effluents from eaca major laboratory operation classified as to

licuid, gaseous, or solici anc turther classifiec as neing racioactive or nonradioactive effluents, i.3.3 Ivnes of Mediolacical Effluents f-n, duilciac Ncs.

6 acc 17: .t a t h od s of T-ant ont ang_ nisongal ny gocp ifrluents 1.3.3.1 dadinin-ical ch s t e cla r a r Ef'1"aar All licuic wastes in Buildinc

17 vhich Hevision 2 Date: a/21/82 dage: 1-18

p'/ contain UO2 are generated as floor mop water, clean-up water, and water f rom the sinks anc showers in the change rooms. These wastes are generated as a result or powcer handling which is carried out in connection with pelletizing and rod loading operations. Liquid wastes in Suilding e5 which contain UO2 are generated primarily by wet chemical analysis and cleaning of glassware used in the analysis of UO2. Liquid wastes are collected in Builcing Nos. 5 and 17 (1300 gpds refer to Table 1-7) and ciluted to 0.00003 uC1/ml before being released to the building

o liquid waste tanks.

Liquid wastes are crained to any one of ten 2000-gallon retention tanks locatec in the building so liquid waste system. The tanks fill automatically in secuence. .ihen eight tanks become filled to

caoacity, a

blinking warning lignt located on the outside wall of the building is activated. This light signals that two retention tanks remain in reserve to receive radioactive licuid waste before overflow must ce expected. {} Overflow water is civerted to a sump cit. Each licuid tank in Buildina #o is agitated and circulated to provice for representative sampling. A samplinc station is locatea at the base of each tank. A 500 mi sample is withcrawn prior to discnaras, and forwarced to the radiochemistry laboratory for gross alpha anc ceta analysis. If levels are in excess or 10 percent l4/Cw then the waste liquid is circulatea to one of four 5000-gallen cilution tanks where the necessary dilution is achieved. Licuid wastes from Builoing so are.cisenarged to the indus trial waste line. Here tne waste l 11guia is carried to the C-E site creek whicn aisenarges it to the Farmington diver. Tacle 1-9 summarizes 5 years of radioactive licuic effluent data on a semi-annual basis. The six month average for 197o-1980 is 0.00117 uCi. l.J.3.2 diciclocical Airrora= 4=st= Ef'1"aat AirDorne wastes are released from Suilding ({} di 7 as a result or UO2 pellet rabrication processes. As shown in Figure 1-10 tnere are devision 2 Dates o/21/32 Paae: 1-19

4 release points of aircorne r ad ioactive (~} \\- ma'terials f rom duilding dl 7 These systems are described herein: FA-l Powder Preparation and Pressing - This system has a capacity of 12,100 SCFM anc operates with yearly averaged discharge levels of 0.000000000000097 uCi/ cc. It incorocrates orerilters and a double bank of 12 absolute

filters, each 97.77% efficient.

fhe air exhaust from this system which is either returned to or released from the plant is sanpled 100% of the time anc analyzed each cay. F A-2 Furnace H2 Burnotr - This sys tem has a capacity of 1340 SCFM and operates with yearly averaced discharae levels of 0.00000000000027 uC1/cc. It incorporates prefilters and a single bank of 4 aosolute f ilters, each 99.9 7% erricient. The air exnaust from this system is released from the plant and sampled 100% of the time and analyzec each day. () FA -3 vellet Grinding and Hoc Loading - This system has a capacity of 19,422 SCFM and operates with yearly averagec discharge levels of 0.000000000000027 uCi/cc. It incorporates orerilters anc a single canX or 21 aosolute

rilters, each 99.97M efficient.

The air exhaust from this system is released from the plant and sampled 100% or the time and analyzed each day. FA-4 Recycle vowder Area - This system has a capacity of o000 SCFM and coerates with yearly averaaed cischarge levels of 0.000000000000024 uCi/cc. It incorporates pretilters anc a couc le bank or o aosolute tilters, each 99.o 7% efficient. ihe air exhaust from tnis system is released from tne plant anc samp12d 100% of the time ano analyzec each day, rne aoove averaces for tne FA-1, F A -2, FA-3 and FA-4 systems were cerivec rrom the montnly averages f or thes e systems (} tor the year 1977. i Hevision 2 Dates o/21/82 vage: 1 -2 J L

<~w Airborne was tes are releasec f rom duilding #5 (_) as a result of airoorne activity curing nandling and transfer of UO2 powder for chemical analysis

purposes, production of special R&D test

fuel, and metallographic examination of production fuel and special test fuel.

All airoorne waste exhausts from builcing 45 via eicht individual s tacks shown in Figure 1-10.fhe exhaust is continuously monitored whenever operations involving custing or release of radioactive material are in progress. All stacks used for the exhausting of radioactive e f f luen ts are equipped with sampling connections. All cut two of these stacks have absolute filters. The two exceptions are the hydrogen burn-o f f exhaust stack and the environmental test lacoratory stack. The Building

5 exhaust s tacks have the following flows:

1 Stack No. Flow ft1/ min. I o200 2 3100 .3 2000 p/ \\_ 4 1260 o 2610 o 2125 / 2000 3 4500 Air from systems aos. I, 2, 3, 5, o and 7 pass througn single aanks of aosolute filters ( 99.97X ef ficient f or 0.3 micron particles), anc are vented to the atmosphere. Continuous sampling is provided immediately upstream from the discharge point and, over a perioc or a year, the average discharae level has oeen approximately 0.000000000000015 uC1/ cc. System so. 4 accepts effluents from two nydrogen sintering furnaces anc e xnaus ts directly to the atmosohere. The exhaust is continuously sampled i mmed ia te ly upstream from the discnarge point. The average discharge levels f rom tnis Stack f or i vear has been aoproximately 0.0000000000001 uCi/cc. The environmental test lab is connected to m, System oo. 3,

however, the system is not

_/ presently being used to exhaust radioactive effluents. nevision 2 Date: o/21/82 / age 1-21

(3 faole 1-9 summarizes the past 5 years of U airoorne effluents for cidgs. #17 and 45. It should be noted that in 1978 it was found that our ventilation system sampling proces had de te rio rated and were not sampling isokinetically. New stainless steel probes were aesigned in accordance with ANSI 1-13.1-1969 and velocity measurements taken to assure isokinetic samoling of all ventilation systems. The new proces were ins ta ll ed in late 1978 and air velocities adjustea early in 1979. In accition, License sam-10o7 was amended in Decemoer 1979 to allow an increase in the maximum enrichment from 3.5 to 4.1% U235, reflecting the higher enrichments scheduled for the next 10 years. Therefore, the'airoorne releases listed for 197o-1978 are not indicative of normal plant operations. The airborne release cata for 19 79 and 1980 ce tter reflect releases from normal operations. The o months average for these two years was 0.0000191 C1. 1.3.3.3 dadiolacica l Solid fasta Efeluant Solid wastes containing UO2 are generated in duilding #17 in the form of

rags, paper, reject emp ti ed fuel tubes and other miscellaneous materials generated durino normal processino operations.

All waste ma terials are loaced into 55 -ca llon crums which are placed in the culx Assay Counter to cetermine the J235 content. The sealed crums are sent to a waste discosal contractor licensed oy the udC. In

1980, the waste generatea f rom duilding #17 f or disposal was approximately /9 Xg or

uranium, containing approximately 2.3 Kg of U235, all of whicn is containec in some 1700 cuoic feet of solic waste.

The usec sesolute filters from the Suilcing j al / stack systems are noncestructively assayed to determine t.i e amount or U235 contained in each filter, dased on tne assay values, the filter is either sent to curial or disassembled to recover the uranium. The uranium removec f rom the filter is mixec with other uranium which has been removed from l other tilters. A representative sample of this nixture is taken for uranium analysis for recycle purposes. () All usec filters from Suilcing #17 containing i xevision 2 Date: 5/21/82 Pace: 1-22 L

rg racioactive resicues are placed in plastic (_/ cags wnich are then placec in ooxes. Boxec filters are then placed in wooden shipping crates which are sealec for shipment. The sealed crates are then shioped to an authorized ourial site. Hacioactive solic waste is generatec in building #5 in the f orm or paper, rags, poly bags and waste cearing precipitated uranium f rom chemical, rocesses and analyses in solic rora. Hadioactive solid waste is also generated in the form of scracced unuseable UO2 powcer in small cuantities. Solid waste is disposed of in 55-ga llon drums. Each drun has an inventory sheet ano all waste emptied into the drum is sealed in plastic and logged on the inventory sheet. 'ecome

full, the inventory When the drums o

sheet is reviewed and filed and the drum is transported to the waste storage area and ultimately. transf errec to an authorized waste disposal contractor for burial. rhe highest amount of uranium disposed of in any one year was aaproximately IS Kgs of O uranium which contained approximately 500 grams or U23a. The total volume or waste cisposeo of in a sample year was approximately 350 cubic feet. The filters removec from the aosciute filter systems in duilding #5 are removed from the filter banks and wrappec in plastic coverings and then placed in cardboard boxes anc sealed. The.se boxes are taen olaced in woccen shipping containers and transcortec to the waste storage area for ultimate shipment to an authorized waste disoosal contractor for burial. Historically, tnese filters retain airborne uranium fines in nonceasuraole cuantities anc a reasonaole es tima te of their con tents is mace using an air concentration and volume flow ra te calculation. 1.3.4 ignas cf NonradiclocigaL_Lianid Cffluents Cr2; dailainas di ana al7 arc Mathcas of T-eat ent anc 211gcul_of Such Effluents Sources of nonradioactive liquid sanitary wastes are

snowers, toilets,

sinks, lavatories anc crinking

{)' fountains. Sources of nonradioactive liauid caenical s nevision 2 Date: u/21/82 Page: 1-23

C/) wastas are solvents used to clean components and assemblies, acic solutions used to clean components and re:no ve residual oxide

scale, and degreasing chemicals to remove grease and films trom components and assemolies.

1. 3. 4 '. I Li cuid Chacic a l.la s t a sfeluants fran railcines *, and dl7 Acaton

- approximately 000 gallons are usec per

year, all of which is lost to the atmosphere through evaporation.

The material is used for cleaning purposes and is contained within I gallon discenser cans which are located throughou t the facilities. acproximately 1100 Alcohol (Isocroov1) gallons used per year, all of which is lost to tne atmosphere through evaporation. The material is used for cleaning purcoses anc is contained within I gallon dispenser cans and I quart clastic bottles whicn are locatec througnout the facilities. Erdrocnloric Acid - aoproximately S000 pounds used per year. aixed with dNO3 acid anc water to form a. pickling solution which is O' used in component cleaning and preoaration. Spent acid solution is routed to an outside storage tank f or pickuo and discosal by a licensed co amercial service. acproximately 1800 pounds dgOH (Caustic) usec per year in reqeneration at demineralized resins. fhe material is ( diluted with process water and neutralized during regenerative operation and crained I through the industrial waste line where it is discharged to the C-E site creek whien e ul tima t el y discharges into the Farmington utver. di d e bi - approximately 300 gallons useo per year. Mixed witn HF acid and water to form a picklino solution which is usec in component cleaning and creparation. Spent acid solution is routed to an outside s torage tant for pic4uo ano disposal oy a licensed commercial service. Dater, ant Snlutinn - approximately 700 councs used per year. .41xec with process water ano usec as a cleaning solution for c omoon e n ts and assemolies. Spent cetergent solution is nevision 2 Date: 5/21/82 Page: 1-24

ciluted with process water and crained (s3/ through the industrial waste line where it is discharged to the C-d site creek which-ultimately discharges in to the Farmington Hiver. accroximately 11,200 dacchl2rethylene pounds used per year, all of which is lost to the atmosohere through evaporation. The ma terial is used for degreasing raw materials prior to their introduction into the production process. Fraon - aoproximately 110 gallons used per year, all of which is lost to tne atmosphere througn evapora tion, fhe material is used ror degreasing materials prior to their introduc tion into the precuction process. Aacnine coot =n ts - acoroximately 110 gallons used per year. l41xed with process water anc used as a coolina solution curing machining operations. Spent solution is routed to ou tside s torage containers where they are picked up for disposal by a commercial service. 12conm Pomo 011 - aoproximately 200 gallons useo per year. Used in vacuum cumps to achieve low pressure in operational process equipment. Spent oil is routec to outsice storage containers where they are cicked up for cisposal oy a commercial service, accroximately o000 volvvinzl Alcoholv pounds per year utilizec in UO2 powcer preparation crocess for preparing cowaer of the correct flow quality for the powcer pressing operation. Burnec o f f during pellet dewaxing cperation. 7inc steanales - aoproximately 1300 counos useo per year. Usec in J02 ne lle t pressure process for luorication of pellet cie cavities. durnec off during cewaxinc operation. Egent Picklinc Solutico - accroximately 1000 gallons useo per year. The solution is mace up of HF acid. HdO3 acid and eater. This solution is used to pickle zircaloy components prior to their introcuction into the production process. The most orocaole O-chemical reaction is: i heviy:.on 2 Dates o/21/82 dage: 1-25 L

\\ 3 Zr + 4 Hi403 + 15 HF --> 3 HZr F5 + 8 H2O + 4 :10 which generates zirconium in solution in a fluoride complex ion form with traces of other zircaloy ingredients - tin and iron. This spent pickling acid solution is mixed with the spent aluminum nitrate stop bath solution in a storage tank outside the building ror pickup and disposal oy an EPA-licensed commercial service, fhese are radiological waste streams and w are listed here because they are the only two chemical effluents that fall in this ca tegory. 1.3.4.2 fvnes nf Noaradiolocical Gasenos Offinents Ltom Huildinos =5 and 41 7 and

.i e t h ec s of Iteatmeal Airborne nonradioactive chemical effluents arise during pickling operations, during cleaning operations with volatile

solvents, and from residual inert gases usec in produc tion welding operations.

O %/ Acatone. Alechol and Froon Fumes from acetone, isopropyl alcohol and freon will be liberatec due to evaooration during solvent cleaning operations. These. solvents are not specifically covered by Federal Air Quality S t ana rd s, but the State of Connecticut Department of Environmental Protection identifies them as photochemically unreactive and limits discharges to 100 counds in any I hour anc S00 pounds in any one day. Average yearly use of these materials at 0-E is such that C-E will be discharging less than the amount currently permitted by the S ta te of Connecticut for photochemically unreactive solvents. Fumes from earchlorethylan perchlorethylene will ce liberated cue to evaooration durinc component and assemoly cegreasing operations. This material is not specifically covered by Federal Air Quality Standards, out the State or Connecticut Department of Environnental Protection identifies it as photochemically reactive anc limits cisenarges to 6 pounds in any one hour /~3 anc 40 pounds in any one day. Average yearly k/ use of tnis aaterial at C-d is such tnat C-E devision 2 Date: c/21/82 dage: 1-26

(' will be discharging less than the amount currently permitted by the State of Connecticut for photocnemically reactive solvents. Halium. Atmen and nitroman - These gases are used in various processing and on-going operaticns. These gases are inert ano are properly dispersed during discharge. The volumes involved are routinely small with cally discharges of aoproximately 3000 cubic feet. Discharge through properly located roof exnausts is considered a suf f ic ient means of dispersal in tne present facilities. Hydrofluoric and Witric Acid - Acid cickling in duilding #17 is cerformec in one ocen tank whicn contains a solution of 30 percent nitric acid, 3.5 percent nycrofluoric

acid, and oo.D percent water, dickling temperature in the tank ranges f rom dS - 110 F.

Fumes f rom the tank are vented into a local exhaust system operating at 5,000 cfn. It should oe noted that fumes from the aluminum nitrate stop batch are also dischargec into the same exhaust system. About S hours of oicklinc (~ ' are performed each day, consisting of about 20 temperature cycles. The average concentration of nitrogen oxides in the stack f rom the pickling operation is 9 cpm anc the concentration of hydrofluoric fumes is essentially unde tec table, decause of the low concentration, the stack is not monitored and the exhausts are not treated prior to discharge to the atmospnere, decause of the small volume of oickling performed and since the concentrations of both H0x and hydrofluoric fumes are so small, no a ttemot has been made to cetermine actual concentration of t;Gx at tne site boundary or away frca the C-E site. It is felt that actual concentrations, either on or of f site, are much less than the national crimary anc seconcary amoient air cuality stancarcs for nitrogen dioxide as sat forth by tne Environmental Protection Agency. 1.3.4.3 Igpas nf nonradic16-4-=1 9614-c*eluents re-e luildina d' ann #17 anc darnocs of -==r-aar and Discosal The bulk of the nonractoactive solid wastes O' are collected and ciscosad of oy licensed devisicn 2 Date: a/21/82 Page: 1-27 i t

l i e I 1 co;;r.a rcia l f i rms. Thus, no on or oft site - O environmental effects can ce cetermined for Chese Wastes. l Scrap metals are segregated by type, verified as concaining no radioactivity, collectec and returnec to the manufacturer for j reprocessing, or are sold to scrap dealers i for eventual recyclina. Old fixtures, tools, equipment are disposed of to commercial scrap dealers. .j l t i l i t i 4 i k !O 4 l i E P O -y nevision 2 Dates c/21/82 vage 1 -2 d

O DOCU ENT/ PAG,:- = PU_LE Ai\\O. -- t NO. OF PAGES W REASON D PAGE DLLEGIB1 C HARD COPV FidD AT. PDR CF I OTHER 1 3_ D BET 1ER COP ( REQUESTED ON _ \\ d PAGE 100 LARGE 10 rlLM. l tg wocor<ruDat coR @ owr - NILMED ON APERTURE CARD NO %M13 %ue SAD %%%CAoSS'Ob

TABLE 1-9 s

SUMMARY

OF WADI 0 ACTIVE EFOLUENTS (HinGS. 17 4 Q1 Bgrind Covered Airborne Heleasa (01) I_imrid Qeleas e (ci) -o -3 July 1, 197o - Dec. 31, 19.76 5.53 x 10 1.64 x 10 -6 -3 Jan. 1, 19 77 - June 30, 1977 2.69 x 10 1.47 x 10 -6 -3 July 1, 19 77 - Dec. 31, 1977 4.90 x 10 1.09 x 10 -6 -4 Jan. I, 19 78 - June 30, 1978 2.85 x 10 7.91 x 10 -6 -4 July 1, 19 78 - Dec. 31, 1978 2.82 x 10 7.09 x 10 -5 -4 Jan. I, 19 79 - June 30, 1979 2.31 x 10 5.86 x 10 -6 -3 July 1, 19 79 - Dec. 31, 1979 9.95 x 10 2.68 x 10 f"3 -5 -4 (#37Jan. I, 1980 - June 30, 1980 3.03 x 10 8.38 x 10 -5 -4 July 1, 1980 - Dec. 31, 1980 1.30.x 10 7.50.x 10 -5 -3 6 Months Average 1.0o x 10 1.17 x 10 l i\\\\ N

e. ehe-emMe h tim-me e + .h 4-e- ea mme e--ee m a= e=* <e 4 1 m+4M*MM&4m 6 i 52 g 4" 7a3 e a k 8 + ' l = f $N sg jf 35 u ...gs = We, IiI] o 5, se $33 Eh. - 5 3 I al il = ) H. i tkk CO b n. I s v.. bfb \\ =_ _

\\ 2.0 Encinaerad Provisions for Abnormal ocarations 2.1 critaria f or Accommnda t i on of Abner al Onorations - 2.1.1 Process Svstoms Administrativa Requiramants Doubla contingency Poliev - Process designs shall, in

general, incorporate sufficient factors of safety to require at least two

unlikely, independent, and concurrent changes in p ro ce ss conditions before a

criticality accident is possible. All Written Precaduras and Annroval Authoritv process operations involving SNM shall be covered by a shop traveler and/or an operation sheet which shall be followed. Precautions and limits regarding criticality and radiological safety shall be included in these procedures. In addition, all procedures shall p rov.id e for the labeling of mass limited containers to indicate the enrichment and the uranium content. All process equipment and operating areas shall be /"3 labeled to indicate the enrichment and geometry h/ 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 foreman. These procedures shall be approved by the Health Physics and Safety Supervisor.

However, 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.

Each foreman shall instruct his people to assure their understanding of the operations and their safety limits and restrictions. The adequate performance of individuals is continually ascertained by the foreman. It shall be the responsibility of the foreman to assure that each work station is properly

posted, and tha t operations' are performed in compliance with posted limits and written instructions.

Recuest for chanogs and criticality Analvsis - A ll proposed changes in

process, equipment, and/or facilities that could affect nuclear criticality, r^%

radiological or industrial safety shall ce (~) approved in accordance with written recuirements. Revision 2 Date: 5/21/82 Page: 2-1

okJ The necessary critical:.ty analysis and resultant \\~' safety limits shall be estaolished by a person having the minimum qualifications of a Criticality Safety Specialist. Procedures have been established for requesting changes and all request f orms, approval f orms, and associated documentation shall be maintained under the supervision of the Supervisor, dealth Physics & Safety. Posting of Limits - All work stations and storage areas shall be posted with a nuclear safety limit approved by the Manager NLS&A or the Nuclear Licensing Consultant. The Supervisor, Health Physics & Saf ety maintains records of the review and approval of each posted safe nuclear criticality safety limit, All intarnal Review Renoirem nts process / equipment / facility changes whicn affect nuclear criticality safety shall be reviewed and approved in writing by the Manager, NLS&A or the Nuclear Licensing Consultant. An independent review shall be performed by an individual T designated by the Nuclear Safety Co mm i tt ee. He ('/ h; shall meet the minimum qualifications for a Criticality Saf ety Specialist and shall not be the initial reviewer. All approvals sha ll be recorded in a log maint3ined under the supervision of the Supervisor, health Physics & Saf ety. All ma ss-l imit ed Markina and iahalinc of StJM containers shall ce labeled as to enrichment and content. All geometry limited containers and processes are safe up to the maximum allowaole enrichment of 4.1 % U-235. Audits i mboratorv Onarations - Nuclear criticality safety for all laboratory operations snall be limited to quantities smaller than a minimum critical mass wi~th the exception of one slab limited storage area in Building #2. Each such mass limited area shall be isolated f rom all other fissile materal by at least 12 feet. Criticality control by any other means (volume, slao, geometry, etc.) shall not be permi tted. Thus, the nuclear criticality D safety program in the laboratories consists of s/ simple mass limits. The monthly radiological Revision 2 Date: S/21/82 Page: 2-2

safety audits of laboratory operations shall (_/f-)s include verifications to assure that all nuclear saf ety limits are being adhered to. An annual w management audit of the Nuclear Laboratories shall be conducted and shall include an overall review of the criticality safety program. Nuclear Coel Manufacturinc Oneratiani - Operations at the Nuclear Fuel Manufacturing facility shall be formally audited for nuclear criticality safety. as required by the audit schedule. All training and Training aad Rotrainiac retraining with respect to nuclear criticality safety shall be conducted in accordance with written requirements. Technical Recnirements Preferred Annrnach to nesicn - It is the intent of Combustion Engineering to use physical controls and permanently engineered safeguards on processes and equipment in the establishment of nuclear safety limits wherever practical. Basic Assumntions and Analvtical Methnds - Written health and saf ety restrictions for all operations (_w) on radioactive materials shall be provided in the form of approved Radiation Work Permits or approved detailed procedures, and appropriate operational. limits shall be' posted in the vicinity of work stations. Each operation on fissile material in the Nuclear Laboratories shall be limited to 350 gm U-235 for uranium enriched to more than 5% U-235, and to 740 gms U-235 for uranium enriched to 55% U -2 35, and shall be separated from any other fissile material by 12 feet. Hods conta ining sinterea UC2 pellets enriched to a maximum of 4.1% U-2 35 shall be stored in Building #2. Storage of material in this area shall be limited to a single slab less than 3.7 inches thick. No other fissile materials shall be used or stored in Building #2. I A continuous log shall be maintained for each mass i limited work station or storage area in the Nuclear Laboratories to assure that the limit is maintained and that the enrichment of all material is recorded. No other criticality controls are required for the lacoratories. Criticality safety of the less complex manuf ac turing operations is based' en the use of a gs() limiting parameters which are applied to simple i l l Revision 2 Date: 5/21/82 Page: 2-3

(~N geometries. Safe Individual Units (SIU) shall be selected on tne basis of optimum moderation and sg' full reflection using published nuclear criticality safety data. These units shall be spaced using the surface density method. The remaining manufacturing operations are evaluated using two dimentional transport and/or 3 dimensional Monte Carlo. Codes. The sixteen group Hansen-Roach cross section library is used for homogeneous systems while the CEPAK Code is used to generate multigroup cross sections' for heterogeneous systems. All~ calculational methods involving computer codes shall be validated in accordance with the criteria established in Regulatory Guide 3.41 " Validation of Calculational Methods for Nuclear Criticality Safety". Safetv Marcins - Individual Units - Safety margins applied to units calculated to be critical (with up to 2% uncertainty), and incorporated in the SIUs shall be as follows: Mass 2.3 Volume 1.3 /~ Cylinder dia. 1.1 h,>) Slab Thickness 1.2 These values shall be further reduced where necessary to assure maximum fraction critical values of 0.4 for geometrically limited units, and 0.3 f or mass limited units (based on ootimum water moderation). An additional r edu ctio'n has been applied to several mass and volume limi ts to assure that spacing requirements remain constant for all enrichments. For validated computer calculations, the highest kett for a single unit or an array shall be 0.95 including all applicable uncertainties and b ias. Consideration shall be given to greater safety f actors where there are large uncertainties. The basic assumptions used in establishing safe parameters f or single units and arrays shall be as follows: The poss ib ility of accumulation of fissile materials in inaccessible locations sha ll be minimized. (d - Nuclear safety shall be independent of the ~5 degree of moderation within the process unit Revision 2 Date: 5/21/82 Page 2-4

when addition of moderating materials' is considereo to be credible. Nuclear safety shall be independen t of the degree of moderation between units up to the maximum credible mist density. Criteria used in the choice of fire protection in areas of potential criticality accidents (when moderators are present) shall be justified. fluclear saf ety shall be independent of neutron reflector thickness for the reflector of interest. Optimum conditions (limiting case) of water moderation and heterogeneity credible for the system shall be determined in all calculations. The analytical method (s) used for criticality saf ety analysis and the source of validation of the me thod(s) shall be specified. Saf ety margins for individual units and arrays shall be based on accident conditions such as flooding, multiple batching, and fire. The method of deriving applicable multiplication factors shall be specified. I.imits for Safa Individeral Units (SIUs) Safe individual un.it limits f or 14.1 % enriched UO2 at optimum moderation. All Mass and Volume limits have been adjus ted to provide constant spacing areas for the enrichment shown. Heterogeneous limits have been developed with optimum rod sizes (up to 0.4" diameter) taken to allow for pellet chips, etc. HOMOGENEOUS HETEROGEN EOUS __ gass (Kn 0021 Limit f* Limit f* s 2.5% U235 54 .19 50 .26 > 2.5% 5 3.0% U235 41 .23 38 .29 > 3.0% 5 3.2% U235 36 .23 36 .29 > 3.2% 5 3.4% U235 35 .25 33 .29 > 3.4% S 3.0% U235 32 .26 30 .30 > 3.0% 1 3.8% U235 28 .20 27 .29 > 3.8% 1 4.1% U235 24 .25 24 .27 Hevision 2 Date: 9/21/82 Page: 2 -5

s.... ' O, s OT k-)' \\ HOMOGFNEOUS sETEROGEN E0f3S Volume (liters) ** Limit f* Limit f* < 3.5% U235 31\\,,.39 22 40 3.5 % - 4.1 % U235 25 i.38 18 ,. 38 rm.,,. Cvl. Dia. (inches) < 3.5% U235 .10.7. 34 9.5 N.36, 3 ~.5% - 4.1 %~ U235 9.8 .33 8.9 '34 Slan Thick. (in.)

< 3.5% U235 5.1

.36 4.1 .22

3.5 % - 4.1 % U235 4.6

.32 3.7 .20 Fraction of the equivalent unreflected critical' spherical volume or mass.

- Includes all available. container volumes.

Interaction crit ria - Activities involving SNM may be conducted in s ingle or two level areas of the facility. The surface density method shall be used to evaluate arrays of SIUs where each mass-limit has a (~ fraction critical of 50.3,;and each geometry-limit has 6-v) a fraction critical of 50.4 All SIUs shall have .a separation of at least one foot, edge to edge. Spacing for mass limited activities carried out in the single level portions of the facility shall be such that the contained UO2 and mod e ra to r, if " smeared" over the allowed spacing areas would not exceed 50% of the critical water-reflected infinite slao surface density assuming optimum water moderation. For cylinder and volume limited activities, a spacing limit based on 25% of the cr itic al water-reflected infinite slab surface density assuming optimum water moderation sha ll a pply. Slabs require no additional spacing, and may border the spacing boundary of any other array unit. Pertions of the f acility contain two levels, each of which may be used for SNl4. In all ca'S es, the floor deck of the second level consists of 'a 3/8" steel plate Eminimum),_ which is at least 10 ft. above the ground floor. Mass limits on 'each level. shall b e ~ spaced such that the contained UO2 and moderator, if " smeared" over the allo ~ed. spacing-areas would. not w exceed 25% of the critical wa ter-re f lec ted infinite slab surface density assuming optimum _ water {'} mcderation. Cylinder or volume limited units shall be devision 2 Date: 5/21/82 Page: 2-6

~ limited to 16% of the critical water-reflected g(m infinite slab suctace density assuming optimum water '/ mode ra tion. All array calculations have been performed assuming a 'd oubly inttnite planar

system, based on the consideration that components of subcritical infinite arrays can be combined where the unit size and cell spacing is preserved.

Array reflection consists of a 16" thic2 concrete floor, and 4" thick concrete roof 2b ft. above the floor. Spacing requirements for

mass, volume, or cylinder SIUs are shown below.

Spacing areas shall be established to provide equal distances from the edges of the uni ts to the spacing bouncary in all directions. Limit Snacina Araas Mass .3.5 ft2 Volume 9.0 ft2 Cylinders (per f t. of length) 5.0 ft2 Cylinders 25 ft2 (lla x 4 0"- Ig., 3.5% U-235 only) ) 2.1.2 Alarm Svstems and Releasa Pravention A criticality alarm system which meets the requirements of 10 CFR 70.24(a) (1), Regulatory Guice 8.12, " Criticality Accident Alarm System", January 1981, and ANSI /ANS 8.3-1979, " Criticality Accident ' Alarm System" shall be maintained in the laboratory areas and the manufacturing facility. The detectors operate in the range of 1-10,000 mR/hr. The locations of the detectors within the manufacturing facility are shown in Figure 2.1 and the laboratories in Figure 2.2. The radiation intensity is shown on a central panel located in the Health' l Physics & Safety office for the manufacturing facility l (Bldg. #17) and in the main hallway in~ Building e5 for the laboratories. There is an alarm which serves as a l local and general audible radiation evacuation alarm. When -the alarm is

sounded, the Emergency Plan is I

i mmedia te ly put into effect. The monitors are connected to the emergency power

system, which is supplied to all emergency lights and alarms in the event of a general power failure within the facility.

This electrical system renders the system operative at all times. This system is tested for operability l [.3 quarterly. Operation is further enhanced by visual l s> observation by Health Physics personnel. Alarm Revision 2 Date: 5/21/82 Page: 2-7 I

N, operational tes ts of the radiation monitors are p('# performed monthly by Health Physics personnel. A / radioactive source is used. to perform these tests. The entire system is calibrated quarterly and following any repair that affects the accuracy of the measurement. 2.1.3 Sunnort Svstems 2.1.3.1 Structural Performance vs Site Fnvirnnnental Factors Severe Natural Phennnena The consequences of all credible acc id en ts were examined. In all cases, the probability of a major accident was found to be extremely low. This low probability is derived from the fact that: 1) all process equioment is designed to incorporate permaneltly engineered safeguardst 2) strict administrative control of production processes is maintained: 3) the double contingency principle ~ is adhered to in the preparation of safety evaluations: and 4) ("') generous safety factors are included in all v,.. facility limits. The spectrum of accidents discussed is shown below Accident classirication Off-Site imnact Injured. Employee Notif ication of None l Unusual Event ~ Contaminated None Employee Process Leak or Alert None Spill a None Fire Helease of 25 uCi Site Area 50% of MPC for of Airborne Hadio-Emergency insoluole U-235 active Particu-at site coundary lates into C-E Site Environs Criticality Site Area Ahole body dose T Accident Emergency 1.184 RAD Thyroic {/ Dose 2.93 RAD Hevision 2 Date: 5/21/82 Page: 2-8

r~s (_) Emergency Alert General Alert None (off-site im-pact from General Alerts.which are reclassified into Alert or Site Area Emergencies are described above) Analysis of Postulated incidents Havina Off-site Imoact Criticality Accident Since the amount of U-235 on site is greater than the minimum mass necessary to achieve criticality, it is necessary to consider the possibility of a criticality incident. While such an accident is theoretically

possible, it is highly unlikely because of the administrative and.

cperational controls established by C-E over the receipt, use and storage of enriched uranium. In the history of the low enricheo fuel fabrication industry, there never has been a criticality accident associated with f uel praparation or (~} . fabrication. There have been four \\.y criticality accidents in high enriched scrap . recovery operations, but all of these involved wet enemical processing. The operations performed on the Windsor site do not involve wet chemical processing. Fortunately, criticality accidents have occurred so rarely that no statistical analysis of the probability. of such an accident has been a t temp ted. Criticality even ts that have occurred have had no significant environmental impact. Radiation injuries were restricted to individuals directly involved. Fission products were effectively confined to the processing j l building in which the event occurred. Promot evacuation of employees upon a criticality alarm would assure no more than minor radiation doses to all except those in the immediate vicinity of the accident. In es timating the intensity of a criticality

accident, it has been assumed that 1,000,000,000.000,000,000 fissions o ccur prooucing approximately 8,000,000 calories of heat.

The rollowing type of accident (s'N) conditions would be necessary to cause a l l t devision 2 Date: b/21/82 Page: 2 -9

nuclear excursion. {} \\- Moderated Uranium Ovida - Encansulated A sufficient quantity of production assemblias, to sustain a nuclear chain reaction when covered with

water, could th eore ticall y, but inadvertently be a ccumula ted.

In the above case, the first spike of the nuclear chain res: tion could exceed 10,000,000,000,000,000 fissions, ejecting the moderating water as s team in a sufficient quantity to render the system subcritical. The release of fission products is not expected because the enriched uranium is encapsulated in zirconium tubing which is designated to withstand a reactor environment. Moderated Uranium Ovide - Unenc9nsulated Unencapsulated enriched uranium such as fuel powder, fuel pellets or fuel sludges could be accumulated, through inadequate administrative con tro ls, in sufficient ) quantities for a criticality accident. x Similar accidents have occurred in the past with high enriched uranium solutions as previously noted. From 1,000,000,000,000,000 fissions could be expected from a single burst releasing fission procucts. The fission products which could be released l would combine to yield maximum of f-site doses of Whole Body Dose 1.184 RAD Thyroid Dose 2.93 RAD (Calculated in accordance with NRC Regulatory Guide 3.34) Major Airborne Particulate Releases A major airborne radioactive particulate release is again highly improbable because of the High Ef f iciency Particulate Air (HEPA) Filters utilized at C-E NFM-d (99.97% efficient). All air released to the environs (~/g is sampled continuously by in-line stack samples which are analysed daily to cetermine s-Revision 2 Date: 5/21/82 Page: 2-10

(3 any release. Any release that would result n_/ in a concentration of airborne

UO2, greater

'i than 50% of MPCa for insoluble U-235 in a twenty-four period at the site boundary will be considered significant and the State of Connecticut, Office of Civil Preparedness shall then be notified. A person standing at the site boundary continuously (24 hr/ day in a concentration equal to 1.0 MPCa (General Population) after i year will receive a dose of approximately 0.50 rem. This notification level used by C-E NFM-W is a f actor of 1000 less than the NHC notification level recuired by 10 CFR Part 20. However, because of C-E NFM-d's continued low annual airborne effluent release

rates, airborne levels exceeding 50% of MPCa at the site boundary would indicate a significant increase above normal operating conditions and notification of state egencies is viewed to be appropriate.

A release of this magnitude is insignificant f rom a radiological safety s tandpoin t, but is used to mitigate the consequences of a potentially large release. Worst Case Scenario rS Jn) The emergency plan scenario chosen was an accidental criticality excursion. This scenario was chosen because it is the only accident that could occur at C-E NFM-4 that has a potential for any significant off-site impact. The emergency plan scenario is based on the following: The postulated accident occurs in the powder processing area of the nuclear f uel manuf acturing facility, the area in which low enriched U02 in powder form is pressed into pellets (UO2 in powder form has the greatest potential of being brought to the conditions required for an accicental criticali ty to occur). The following conditions would have to occur simultaneously: 1) A violation of criticality mass limits by a factor of 2.3 (a safety factor of 2.3 is incorporated in all mass limits). 2) The accidental introduction of a large quantity of water to the aoove mass of UO2 powder to bring it to optimum moderation conditions. , () 3) The assembly of the powder and water Revision 2 Date: 5/21/82 Page 2-11

mixture into an optimum ' geometrical (} configuration. A burst of s" 1,000,000,000,000,000,000 fissions is 1 then assumed to occur. This is equivalent to a release of about 32 megawa tt. seconds, which is a much larger excursion than could be expected in any system in a low. enriched fuel fabrication facility. To cause an excursion of this magnitude, a very rapid increase in reactivity would be required, which is not credible in the systems in this facility. Radiation injuries would be restricted to individuals directly involved and personnel within a 10-20 foot radius of the accident. Prompt evacuation of employees by an automatic criticality alarm system would result in minor radiation doses to all except those in the immediate vicinity of the accident. Whole Rody cloud Oose The distance. to the nearest resident (~ bordering the C-E Windsor site is o40. meters. A-} The atmospheric conditions assumed for this r accident were very conservatively chosen to be Pasquill Type F with a windspeed of I meter per second blowing directly toward the home of the nearest resident. If 50% atmospheric condition information was available for the site, the calculated dose would be decreased by at le as t. an order of magnitude. The dose was calculated assuming a semi-infinite . cloud surrounding the individual with a radioisotope concentration equivalent to the center line of the plume. Since the Pasquill Type F atmospheric stability condition produces a very sma ll l plume, the dose is over-es timated by about a factor of 8 as a resul.t of the semi-infinite cloud assumption. In the calculation of the cloud gamma anc beta dose, credit was taken for the celay time between the time of criticality and the arrival of the cloud at the nearest site boundary. This delay is c ompos ed of two ("] components. One is the delay in the Fuel N' Fabrication Building and the other is the Revision 2 D.a t e 5/21/82 Page: 2-12

transit time from the building to the nearest r') (-3 residence. The delay in the building was done assuming the volatile fission products were instantly mixed within the pellet shop volume of 291.000 ft3. It was assumed that 19,331 ft3 of the building

volume, which is equivalent to 30 seconds flow through the ventilation system, was discharged with no

_ delay of the fission products. The doses at the site boundary were. calculated for this release. The next 19,331 ft3 volume was delayed for 30 seconds and the doses at the site boundary calculated. This same procedure was followed until the entire building volume was released. The doses from each 30 second release was added to determine the total dose from the cloud. This method of calculating has two conservative assumptions - 1) no delay is assumed during each 30 second release, and 2) no further dilu. tion of the fission products in the building is assumed for each release. The other areas of the Fuel Fabrication Building have no forced external ventilation so the delay time would be substantially longer. The delay af ter release is 9.3 minutes based (") on the transit time of the cloud moving at I (/ meter per second for 560 meters. The only other credit taken was the wake effect of the building. which is only 1.5 This is based on the minimum external area of the Fuel Fabrication Building which is 334 square me.ters. The resulting whole body and body surface dose from the cloud as well as the prompt gamma and neutron dose are shown in the table 3-1. Brgnt Gemn and Nootron Oose The prompt gamma and neutron dose was calculated f or the nearest residence using the method shown in Regulatory Guide 3.34 dated July 1979. 1,000,000,000,000,000,000 fissions were assumed for the criticality accident and the distances were 560 and 700 meters for the nearest site boundary and resident, respectively. No credit was taken for structural attenuation. Thyroid Oose (~) The doses to the thyroid f rom the inhalation of radioactive iodine were calculated for the Revision 2 Date: 5/21/82 Page: 2-13

r-} n'eares t site boundary and resident to the

(s Fuel _ Fabrication Facility.

The results are '~' shown in the table 3.1. This source assumes 50% release from the fuel and 50% p l a te-ou t inside the Fuel Fabrication Facility. The same atmospheric conditions were used to calculate the concentration of iodine as used in the whole body dose calculations. It was assumed that the breathing rate was 0.0000000000000347 cubic meters per second which is the breathing rate characteristic of the active portion of the normal work day. No decay was assumed for the transit time from Building

17 to the nearest site boundary or resident.

The thyroid dose per iodine curie inhaled was taken f rom Table II in TID-14844. OFC-S ITE DOSES CROM NORST CASE C9 fTTCALITY ACCIDFNT Tvoe of Dose Whole Body Dose 1.184 RAD

Thyroid 2.93 RAD
Calculated using a breathing rate of r")

.000347 cu. meters /sec. The methods (,/ used in the assessment of this accident are consistent with those used by the USNHC. Naturally Occurrinc Phenomana Accidents of this type are the. naturally occurring events such as f looding, wind damage, tornados and earthquakes. Flooding is not considered credible because the high water level for the area's worst flood l (August 1955) was approximately 110 feet above mean sea level. Since the Windsor site is located approximately 180 feet above mean sea level, the probability of direct damage resulting from local flood is very low. The average hourly wind speed for 1979 was 3.8 mile s per hour. The prevailing wind direction for o months, May to October is l south and for the 6 mo n ths, November to

April, is northwest.

The average wind velocity at the Windsor site is 11.2 miles per hour. The highest recorded velocity was 70 miles per hour in November 1950. The buildings on the Wincsor plant site are ("} designed to withstand steady wind levels on ks the order of 100 miles per hour. The tornado I Revision 2 Date 5/21/82 Page: 2-14

hazard probability for this region is () 0.000001 for a tornado with winds ranging k from 140 MPH to 239 MPH. This means that in any one year there is a.1 in I,000,000 chance of a tornado of this size affecting the C-E Windsor site. The Windsor plant site lies in a region classified as Zone I, corresponding to Intensity VI on the modif ied Mercalli . scale of 1931. The plant is s tructurally adequate f or Zone 2 earthquake loads which are more severe than Zone 1. It is evident from the above that there is a very low probability of release of radioactivity from the facility by Class 6 accidents. Accidents at Neichenrinc Activities A neighboring activity, the General Electric Co., Knolls Atomic Power Laboratory, located Ln Sector 2, Figure 1-4, could have an accident tha.t would impact on the Windsor site. In the event of such an accident, the Windsor Site Emergency Plan would be activated. () 2.1.3.2 confinement Barriors and Svstams .This section contains detailed descriptions of all operations in the manufacturing facility dealing with confinement barriers and systems ( Buildings

17 and
21).

Sufficient detail is provided to permit an independent verification of the adequacy of i the controls for the purpose of assuring safe operations. In certain operations, the intricacies of the equipment require further analysis, which is provided herein. Details of specific calculations used to support various aspects of the analysis are discussed in this section. UO2 Powder Procassinc Vircin Powdar Storana Araa The virgin powder storage area is isolated from the remainder of the plant on all sides by concrete block walls, a double steel roof, f), and a metal fire door. This door is normally ( in the open position, and is automatically Revision 2 Date: 5 /21 /82 Paget 2-15

1 t'S closed upon activation of the fire alarm, and \\_/ on failure of electrical power. The automatic closing f eature of this door shall be verified quarterly and records of its performance shall be maintained. These engineered safety features are considered adequate to prevent the Lntroduction of water in the event of a fire. This area will be kept free of combustibles, and is located such that there are no potentially hazardous items such as boilers in the vicinity of the area. An ammonia cracker is housed in a concrete block building which is located some 25 feet northwest of Building #17. In view of its many redundant safety

features, it is not

/ viewed as a potentially hazardous item. Criticality Safety Analvsis The following conservative assumptions were incorporated into the calculational model of the virgin powder storage area: 1) All steel structural materials were neglected. p(j g 2) The fuel was assumed to be a homogeneous mixture of UO2 containing 7.0 wt% H20, 3) All storage positions were filled and each individual can was assumed to be full. 4) Effects of interspersed water moderation and flooding were not addressed. l The K ENO-I V Code with sixteen group Hansen-Hoach cross sections was used to determine the reactivity of the virgin powder storage area under the conditions noted above. A keff of 0.9338 1 0.0077 was obtainec for an infinite system in the horizontal direction. Powder Preoaration and Blendino UO2 powder f rom one sealed batch container (moderation control assured) is transferred to a blender where it is mixed with a binder. Two separate blenders feed a common powder spread funnel by means of incividual powcer transfer pipes entering at a 45 degree angle. An identical powder preparation line runs parallel to this one at a centerline distance O. 5 of 13 feet. Hevision 2 Date: 5/21/82 Page 2-16

() The blending operation is enclosed in a ventilated hood. Sufficient negative pressure is provided to assure a minimum f ace velocity of 100 fpm. Drvino Agglomerated UO2 powder is spread onto the dryer belt from the powder spread f unnel to a controlled depth of 1/2". A complete enclosure is provided around the dryer belt assembly and this enclosure is maintained at a slight negative pressure. The discharge end of the dryer belt utilizes a wiper blade to prevent the flow of significant amounts of material to the plenum under the belt. Nevertheless, the wiper blade and plenum shall be inspected once per week to assure that the wiper blade,is f unctioning properly and no fuel is accumulating in the plenum below the belt. Records of these inspections are maintained. The belt dryer operates on a 1/2" slab limit. (The criticality safety analysis also assumed an accidental accumulation of up to 1/2" of powder under fS the dryer belt in the event of malfunction of (m/ the wiper blade). The safety of the dryer assembly is assured by this restricted slab thickness. The dryer heater controls are wired to the motor control such that the dryer belt cannot be activated unless the heaters are turned on, and to stop the belt under conditions of high heat (high heat automatically shuts off the heating elements). Granulation Dried oxide is gravity-f ed into a granulator where it is sized for subsecuent pressing. The granulated powder is then g ravi ty-f ed through a discharge funnel ending in a 2 inch square opening. A short adapter of a 2 inch circular cross section is welded to the funnel to allow connection of 2" diameter hose which is then connected to a portaole hopper below. A complete enclosure is proviced around the granulator. It is maintained at a negative pressure to preclude dusting. ) Revision 2 Date: 5/21/82 Page: 2-17

l criticality Safatv Analvsis The powder blending, drying, and granulation stations were divided into two parts for calculational purposes: the back end of the station included the

blenders, the powder transfer pipes leading to the powder spread f unnel, and the first 10 feet of the 30" wide dryer belt.

The spread funnel is fixed in position to restrict the powder discharge from it to a 24" wide by 1/2" deep layer of U02. The following conservative assumptions were incorporated. into the calculational model of the bac k end. 1) The blender hoods are restricted to 35 Kg UO2 per station. It was assumed that this mass of UO2 was located at the base of each blender hood directly above each powder transfer pipe. 2) It was assumed that the above masses were hemis phe ri cal in

shape, and were at optimum moderation and maximum enrichment (4.1 wt.% U-235).

The rad ii of these hemispheres varies as a function of the (,'; assumed concentration of UO2 in water in i ' order to maintain a fixed mass of 35 Kg UO2 in each. 3) Although the belt dryer is limited to 1/2" of UO2 powder, the model allows for an accidental accumulation of 1/2" under the dryer belt in the event of malfunction of the wiper olade. l 4) The powder transfer pipes anc powcer i spread funnel were assumea to ce fi lled to capacity with UO2 at optimum moderation and maximum enrichment (4.1 wt.% U-235). 1 5) An infinite array of stations was analyzed although there are only - 2 parallel stations. 1 Sixteen group Hansen-doa ch cross sections were used in K E.NO -I V to determine tne reactivity of the system under various conditions. Optimum moceration (assuming no external mist) occurred at a fuel concentration of 0.8 gm u/cc in water (very l [,) undermecerated system initially). Variable l density external water mist was then l Hevision 2 Date 6/21/92 Page 2-18

introduced.to determine peak reactivity of p/ the system. The. highest keff of 0.8698 2 g s. O.0103 occurred for the full' flood case although a secondary peak of 0.7565 0.0077 was found at 0.025 gm/cc interspersed water moderation. As this system was initially undermoderated, it was difficult to determine whether the large amount of water necessary to bring the system to peak reactivity was a result of the large amount in troduc ed into the fuel directly (0.8 gm U/cc in water) or the result of full density external water introduced in the flooded case. As a final check, the fuel concentration in water (gm U/cc) was varied while holding the external . moderation condition at f ull flood. A peak reactivity of 0.8684 k 0.0101 was obtained at a fuel concentration of 1.2 gm u/cc in water, although the reactivities of the other cases resulted in statistical

overlap, and were therefore essentially of the same magnitude.

The conclusion drawn from the above analysis is tha t peak reactivity for this system occurred as a result of external flooding and reflection rather than by optimization of the fuel concentration in the various individual <~ f uel-bearing components of the sys tem, h'T The front end of the station included the last 10 feet of the 30" wide dryer belt, the granulator, the discharge funnel and

hose, and a cylindrical press ' f eed hooper.

Two different hoppers are available for use depending on the enrichment being processed. For 53.5 wt.% U-235, an 11"

diameter, 40" long cylindrical hopper with a conical top is used.

For enrichments up to 4.1 wt.% U-235, a 10.5", 17.7" long cylindrical hopper (safe volume) with a flat top is used. The longer hoppers will be stored under lock and key prior to the start of processing of any enrichment greater than 3.5 wt.% U-235. Reactivity calculations were performed at the maximum allowable enrichment for each case. The following conservative assumptions were incorporated into the calculational models of the front ends I) All system components except for the dryer belt were assumed to be filled to capacity with UO2 at optimum moderation and maximum enrichment (3.5 or 4.1 wt.% U-235). [} 1 Revision 2 Dates 5/21/82 Page 2-19

2) Although the belt dryer is limited to r-)x 1/2" of UO2 powder, the model allows for (_ an accidental accumulation of 1/2" under the dryer belt in the event of malfunction of the wiper blade. 3) An infinite array of stations was analyzed although there are only 2 parallel stations. Sixteen group Hans en-Hoach cross sections were used in KENO-I V to determine the reactivity of the system under various conditions. For the first case, the system was analyzed at 4.1 wt.% U-235 with the 10.5"

diameter, 17.7" long press feed hopper.

Optimum moderation (assuming no external mi.s t ) occurred at a fuel concentration of 1.8 gm U/cc in water. Variable density external water mist was then introduced to determine peak ' reactivity of the system with the 10.5" hopper. The highest keff of 0.9386 0.0075 occurred for the full flood case. For the second case, the system was analyzed at 3.5 wt.% U-235 with the 11" diameter, 40" long press feed hopper. The maximum keff in S (f the absence of external water mist occurred at 2.2 gm U/cc in water. This result was derived from calculations at 2.0, 2.2, and 2.4 gm U/cc with associated keff values of 0.800 0.010, 0.833 0.014 r es pec tively. Variable density external water mist was then Lntroduced to' determine peak reactivity of the system with the 11" hopper. The highest keff of 0.934 0.17 occurred for the full flood case.. This result was derived from calculations at 0.001, 0.05, 0.10, anc 1.0 gm/cc of H2O with associated kett values of 0.825 1 0.016, 0.821 2 0.020, 0.805 1 0.012, 0.850 2 0.014, and 0.934 2 0.017 respectively. Pressina The press is provided with enclo sures which assure adequate ventilation at the opening , face, and at the junction of the portable hopper with the press. Air flow rates are sufficient to assure face velocities of at least 100 fpm. i O Revision 2 Date 3/21/82 Pages 2-20

rs Dewaring and si n ta ri na A& Furnace boats containing green pellets are charged in a single line to a dewaxing furnace and then to a sintering

furnace, where under controlled conditions, the pellets attain the desired properties.

Because the UO2 is in a compacted

form, dusting is minimal, and ventilation is not required.

Hydrogen burn-of f exhaust is vented from the building, and is filtered and monitored. Final Si7ina A complete enclosure is provided around the grinder to preclude the dusting of UO2. The enclosure is maintained at a negative pressure with respect to the room. Scran Reevele All clean scrap is accumulated for reproce ssing and recycle with the feed material. Scrap may be milled to yield (~s desired particle size best suited for the ww) processing, oxidized and reduced to assure removal of volatile additives and to achieve the desired ceramic properties of the resulting recycle UO2, and blended to assure uniformity. The following equipment is included in the pellet shop annext a) Oxidation and Reduction Furnace b) Milling Equipment c) Boildown equipment d) General Purpose dood e) Filter Knockdown Hood f) Stor. age Facilities g) Blender h) Micronizer The furnace is similar in its operation to the furnaces previously described. Although the feed and exit zones of the furnace are not ventilated, sufficient reserve ventilation (approximately 1800 SCFM) exis ts to provide such ventilation if surveys indicate the need. The remaining operations except blending, are r^g all carried out in hooos with sufficient (_) ventilation to assure a face velocity of 100 fpm. Revision 2 Date 5 /21 /82 Page: 2-21

(~%. h' Concrete Block Storace Area for Reevele Materials '~ A concrete block storage area is provided for recycle materials. This storage area is intended for volume limited SIUs and has a maximum height of 7 feet. The blocks are of solid 10" thick concrete, having a minimum density of 125 lb/ft3. Mortar. is used to ' Join the blocks and to secure the structure to the building wall. Steel shelves, of at least 10 ga. thickness are built into the struc.ture with a vertical spacing of at least 16 inches. Each storage position measures 16" wide x 14" deep, and is lined on three sides with 1/4" thick mild steel. The criticality saf ety analysis demonstrates that the spacing boundary can be located 48 inches from the front of the shelves. All pellets are contained in 3-l/2 gallon or smaller containers 1 homogeneous UO2 is contained in 5 gallon or smaller containers. Criticality Safety Analysis (} The following conservative assumptions were h, incorporated into the calculational model of the concrete block storage area: 1) Each storage position was assumed to contain a 5-gallon poly bucket tilled with UO2 at optimum moderation and maximum enrichment (4.1 wt.% U-235). 2) The system was assumed to be infinite in the horizontal plane. 3) Variable density external water mist was introduced to determine peak reactivity of the system. The KENO-IV Code with 16 group Hansen-Roach cross sections was used to determine the reactivity of the concrete block storage area under various conditions of moderation. Optimum moderation of the fuel occurred at a concentration of 2.5 gm U/cc in water assuming no external water mist. The peak reactivity of the system, keff 0.9207 3 = 0.0081, occurred at an external water mist density of 0.7S gm/cc. Dimensional details (~) of the calculational model are shown in \\- Figure 2-3. Hevision 2 Date: 5/21/82 Page: 2-22

Hod Loading and Assambiv Cabricatinn Pellet Stackino Pellets from the pellet. f abrication f acility, or from outside vendors are placed on a downdraft table where they are aligned for rod loading. On the

table, the pellet configuration is limited to a 3.7 inch slab thic kne ss.

The UO2 pellets are placed on troughs before being loaded into rods. Rod Loading and Puel Rod Transnort Parts Pellets are. transf erred from the stacking troughs into rods. The loaded rods are placed into carts each of which can hold up to 250 fuel rods in parallel sleeves which are spaced on four rings in an annular fixture with an I.D. of a pproximately 10 inches and an 0.D. of approximately 22 inches. Guard rails prevent the carts from coming any closer than three feet center to center. The carts are used in normally dry areas to transfer the rods to operations which include end plug. welding, weld and (~/) .deflashing. These operations are performed g ( on one rod at a time. Rods are immediate ly returned to the cart after each step is completed. Finished rods are fluoroscoped and are checked for enrichment with a slab limit of 3.7 inches. Cr i t ic a l i ty Safety Analysis The following conservative assumptions were incorporated into the calculational model of the fuel rod carts: 1) Only the 1/4 inch thick, 4" 0.0. inner steel cylindrical annulus was accounted for in the model. All other steel construction material was neglected. 2) The carts were assumed to be infinitely long and spaced 36

inches, center-to-center to form an infinite array in the horizontal plane.

3) The fuel rods are contained in 1/2

inch, Sch 40 P VC tubes, each 134 inches long.

fi, There are 250 tubes arranged in 4 concentric rings with an avera e pitch of s-j Hevision 2 Date: 5/21/82 Page: 2-23 l l

-s I.18361 inches. The fuel tube region of () the cart is thus a cylindrical annulus beginning at 4" from the centerline of the cart and extending to a radius of 7.312 inches. In the calculational

model, it was assumed that all 250 positions were occupied by the largest diame ter rods (.3765-a 0.D. UO2 pellets at 10.03 gm/cc stacked density with a

Zr-4 cladding thickness of.028 inch) at the maximum enrichment (4.1 wt. % U-235). Fuel Dod Storace Area The multi-level storage area for boxes for fuel rods consists of up to 10 tiers of 32 loca tions each. The steel fuel rod boxes have a maximum length of 14'14 and an inside width and depth of 8 inches and 5-3/8 inches respectively. A vertical spacing of 12-1/2 inches oetween boxes is maintained, the first tier being 18-inches above the concrete floor. Lateral spacing is restricted by physical barriers to a minimum of 4 inches. The rod ooxes rest on roller conveyors to facilitate. movement in and out of the storage array and are held in place by a fixed brace fs(j at the back end. The roof of the storage rack consists of corrugated fiberglass on a 3% pitch to assure adequate drainage to the floor. Water fire fighting is not permitted in this area and is controlled by the 24-hour security personnel stationed in the Building

17 guard house.

Moderation control is thus assured under all cond itions. Water accumulation in the vicinity of the storage rack is not considered credible in view of the close proximity of an open eculpment pit in the floor which is 30 f eet x 60 f eet x 18 feet deep. A 3 foot deep sump at the bottom of the pit is equipped with a level detector which ac tiva tes a pump to transfer any accumulated water to the industrial sewer system. Criticality Safetv Analvsis The following conservative assumotions were incorporated into the calculational model of the f uel rod storage areas (f I) 'The fuel rods, if in a tightly packed Revision 2 Date 5/21/82 Page: 2-24 l t

hexagonal array, would result in over 300 73( ) rods in each box. An infinite array of boxes in the horizontal plane was assumed. The fuel was homogenized over the volumelof the box and was assumed to be dry. 2) All rod boxes were assumed to be filled to capacity at maximum enrichment ( 4.1 wt.% U-235). The smallest diameter rods (0.382. inch) were used to obtain maximum fuel loading. The Zr-4 cladding (0.025 inch thickness) was homogenized with the fuel. 3) A lateral separation dis tanc e of 3.5 inches between rod boxes was assumed. Interspersed moderation was not considered credible since moderation control is assured by the design of the storag e area. 4) All steel construction material was neglected. Si A 15 tier array was analyzed although a maximum of 10 shall be permitted. The lo group Hansen-Roach cross sections were used in KENO-IV to determine reactivity of the system under the conditions noted above. A keff of 0.7994. 1 0.0050 was obtained for a 15 tier infinite array. A second calculation of a finite 15 tier array with 16 inch concrete reflectors on all sides yielded a keff of 0.7372 1 0.0045. Double Shelf Red Storaca Racks The double shelf storage racks for fuel rods hold a maximum of 12 steel boxed identical in all respects to those in the multi-tier array described above. Each box is equipped with a tight-fitting aluminum cover which overlaps the outside edge of the box by a minimum of one inch. One box may remain uncovereo for short periods of time to allow for the addition or removal of rods for inspection purposes provided that personnel are in attendance. Spacing between boxes in both a vertical and horizontal direction is a minimum of 6 inches. Minimum c en te r-to-c en t er spacing between storage 7-g (/ racks is ob inches and the racks are Hevision 2 Dates D/21/82 Page: 2-25

considered to be present in an infinite array h(/ s in the horizontal plane. The following conservative assumptions were incorporated into the calculational model of the double shelf fuel rod storage racks: 1 )- The f uel rods, if in a tightly packed hexagonal array, would result in over 300 rods Ln each box., The rac ks permit storage of 12 boxes each (6 in the vertical direction) and an infinite array of storage racks was assumed in the horizontal plane. The fuel was homogenized over the volume of the box and was assumed to be dry. 2) All rod boxes were assumed to be filled to capacity at maximum enrichment (4.1 w t. % U-2 35 ). The smallest diameter rods (0.382 inch) were used to obtain maximum fuel loading. The Zr-4 cladding (0.025 inch thickness) was homogenized with the fuel. 3) All steel cons truc. tion material was neglected, -} v 4) Variable density external water mist was introduced to determine peak reactivity of the system under optimum conditions. The sixteen group Hansen-Roach cross sections were used in KENO-IV to determine reactivity of the system under the conditions noted above. The highest keff of 0.8886 0.0070 was obtained at an external mist density of 0.06 gm H20/cc. Fuel Assembly Fabrication Fuel rods are loaded into the assembly l skeleton in a fixture which provides a j lubricating water spray. These fixtures are designed to assure that water ca nnot be re tained. .Nevertheless, safety for this operation has been established with full moderation and re fle ct ion. Criticality safety calculations for a 16 x 16 flooded l i fuel assembly with a 12 inch water ref le ctor l were performed using the K ENO-I V computer l code with 4 group CEPAK cross sections for the fuel region, water

holes, and external C_4

/ wa ter ref lection. All stainless steel was Revision 2 Dates 5/21/82 Page 2-26

conservatively omitted. A maximum keff of f-) ((_j 0.8817 2 0.0049 was obtained. In-Plant Storane of Cuel Assemolies Fuel assemolies are stored in a vertical position using racks of adequate strength to preclude loss of the design spacing. The assemblies in the. storage positions only shall be wrapped with polyethylene with the bottom ends open to assure free drainage. Within the same

room, (but at greater separation distances) there are two horizontal loading tables where the fuel rods are initially loaded into the assembly skeletons, a vertical wash tan k where the assemblies receive a

final. demineralized water rinse, two fixed vertical inspection stands equipped with elevator platforms to allow final 0.C. dimensional

checks, and a

marked floor area where the assemblies are loaded into shipping containers prior to outdoor storage. Each of these stations is physically limited to one fuel assembly except the shipping container which holds two. () 1) A,19 x 34 array of assemblies was modeled at a 10 inch center-to-center spacing of fuel assemblies within the double rows. The distance between tags of fuel assemblies within any given double rack is 35 inches center-to-center while the aisle between the double racks is 37 inches ( c e n t e r-to-c en te r ). This calculational array effectively brings the 25 additional assemblies closer together and provides greater interaction with the 440 assemblies in the storage area than is actually possible. 2) All steel construction material was neglec ted. 3) Variable density water mist was introduced within and between the assemblies to determine the reactivity of the system under various degrees of water moderation. 4) Four group cross sections were generated using the CEPAK Coce f or the 3 regions of the assemblies: fuel

region, water 7-)i

(_ holes, and external' water mis t between Revision 2 Date 5/21/82 Page: 2-27

assemblies. These 3 regions were then p). smeared over the entire array using the p ', DOT code to obtain one set of four group flux-weighted la ttice cross sections. 5) Four group cross sections were also generated using the CEPAK Code for the 8" concrete walls, 10" concrete

floor, and the external water mist between the fuel assembly array and the ceiling and walls.

The ceiling was considered to be 8 inch thick

concrete, though 4

inches is usually assumed. The 4 group cross section sse ts described above were then used in KENO-IV to determine the reactivity of.the fuel assembly storage area under the above noted conditions for the most reactive assemblies (the 10 x 16 type). The analysis indicates that the margin of criticality safety is acceptacle for water mist densities up to.03 gm/cc, (keff <0.95) which is far greater than tha t attainable from the assembly room sprinkler system. As a final check in demonstrating that one (_,g3 set of four group flux-weighted lattice cross sections represented the entire fuel region in a. conservative

manner, the following calculations were performed 2 A 16 x 12 array of f uel assemblies with 0.035 gm H20/cc mist was modeled at the design spacing with a

tight-fitting 16" concrete reflector (infinitely high assemblies) us ing cross sections for both a heterogeneous case (discrete fuel assembly and mist regions) and a homogeneous case (all assemblies and mist smeared" over the entire array between them a of assemblies as was done for all previous calculations). The homogeneous case (keff = 0.9507 .0032) was shown to be conservative by 3% (the heterogeneous case yielded a keff of 0.9208 0042).

Thus, the conservatism in using the flux-weighted la ttice cross sections is demonstrated.

The local fire departments have been instructed to use only dry chemical extinguishing methods in the fuel assemoly storage room and the pellet shop. Signs restricting fire fighting in this area to cry f~y chemical methods only have been posted at \\_/ each entrance to the assembly storage room. Revision 2 Date: 5/21/82 Page 2-28

There is only one vehicle access gate to the () fuel f abrication f acility which is controlled by_a security guard 24 hours a day. He has instructions to prohibit firemen from using fire hoses in the above described restricted areas. Thus, criticality safety is assured under all credible conditions of moderation. 2.1.'3.3 Access and cerass of Oneratino oersonnel and Emercency Resnonse Teams See Sections 3.0 and 4.0 for details. In addition, it should be noted that the longest distance personnel have to walk to leave the Building 17/21 complex is ISO feet.

Also, vehicular tra f f ic into and out of the Building 17/21 complex is controlled by security personnel who are on duty around the clock, seven days a week.

Fire, police, and other emergency vehicles have direct access to tne C-E Windsor site by way of well paved highways and s ec onda ry roads. Emergency vehicles do not have to cross a bridge to gain access to the W1.ndsor site. 2.1.3.4 Fire and Cynlosion Resistance and Suceression () A full time Fire Marshal is on the site during normal working hours. He is on 24 hour alert. His duties include routine inspections of the buildings and routine checks 'of all fire extinguishment equipment. He is also responsible for training and equipping an active Fire Brigade. This Fire Brigade is comprised of Combustion employees, several of whom are also members of local community fire depar tments. Fire protection, including spr in kle rs, is designed into all buildings which are subject to fire damage. I A direct emergency telephone line to the Windsor Fire & Safety Complex (Fire,

Police, Ambulance, e tc. ) is controlled by the site security personnel.

A copy of the Certificate of Insurability from American Nuclear Insurers is available. The manufacturing and laboratory facilities are constructed and operated consistent with requirements of the a pplicable fire safety a codes. gs () Revision 2 Date* o/21/82 Pages 2-29 i L

2.1.3.5 Shieldinc 3 ~! Shielding as such 'is not used.

However, TLD personal dosimeters are worn by employees to determine actual exposure.

2.1.4 Centrol Procedures The criteria for maintaining the response capabilities of plant engineered systems is to reduce employee and environmental exposure levels to as low as reasonably achievable. 2.2 Demonstration of Encinaerad Provisions for Abnormal Onerations 2.2.1 Process Svstems Capabilities of radiation detection and measurement instrumentation shall be as f ollows: Alpha Counting System 10 - 100,000 dpm Alpha Survey Meters 0 - 50,000 counts per minute Beta-Gamma Survey Instruments .05 mH/hr - 200 mH/hr Neutron Survey Instruments .5 - 5,000 mrem /hr A sufficient number of the ins truments,

meters, and

() systems listed above shall be mainta ined operational to adequately conduct our Health Physics program. The detectors for the criticality alarm system are calibrated quarterly and following any repair that affects the accuracy of the measurements. All other instruments are calibra ted twice per year and f ollowing ariy repair that af f ects the accuracy of the measurements. The calibration of the survey instruments shall meet the specifications described in Section 1.11 of Regulatory Guide 8.24 " Health Physics Survey During Enriched Uranium-235 Processing and Fuel Fabrication". The alpha counting equipment is checked - daily to verify background and efficiency. l 2.2.2 Alarm System and Release Prevention carability All routine operations involving nuclear fuel handling are covered by a shop traveler and/or varicis operation sheets (0.S.) which are issued by Manufacturing Engineering or Quality Control. These. procedures include the necessary precautions j which must be observed to assure that the operation is conducted in a safe manner. The Health Physics Safety Supervisor will review these precautions (sk_) regarding all aspects of safety and indicate his l l Revision 2 Date: 5/21/82 Page: 2-30

approval in writing. However, 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 Consul tan t.

Each f oreman shall instruct his people to assure their understanding of the operations and their safety limits and res tric tions. The adequate performance of individuals is continually ascertained 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.

Pestina and Labelina All work stations involving nuclear fuel handling will be posted with a Nuclear Safety Limit. All mass limited containers will be labeled as to contents and enrichment Radiological posting of areas will be in accordance with 10 CFR 20,203. Personnel Monitorina All personnel must. wash their hands before exiting the contaminated area and monitor their

hands, exposed

,(, areas of the body and personal clothing with the alpha personnel monitor located at the change line. Any person having suspected contamination on his body must thoroughly wash the area and recheck for c on tamina tion. If contamination persists, a member of the health physics staff will assist in decontamination. Survevs Removable contamination levels in plant areas and on items to be released to an unrestricted area are established by smearing an area of 100 cm2 (4' x 4") with a two inch diameter smear paper. Pellet Shop and Cold Shop floor smears are taken on a weekly basis as a minimum. Direct radiation surveys of plant

environs, sealed

sources, and of f -s i t e shipments of radioactive materials shall be made as necessary to comply with the regulations in 10 CFR 20.201.

All survey results shall be documented. Protective Clothina Protective clothing is used for all personnel entering 7-)s the unclad fuel handling area. ( Hevision 2 Date: 5/21/S2 Page: 2-31

( nosimetrv - TLD Badoes Each individual who enters a restricted area under sucn circumstances that he is likely to receive a dose in any calendar quarter in excess of 25 percent of the applicable value specified in 10 CFR 20.101(a) shall be supplied with a TLD badge and indium foil for purposes of personnel dosimetry. Badges will be processed monthly. When a high exposure is suspected, the individual's badge will be immedia tely processed. All visitors will be supplied with indium foil badges. Area TLD badges and neutron foils are also strategically placed throughout the facility for the purpose of recording background radiation levels as well as radiation resulting from a criticality accident. These badges will also be processed monthly during normal operations and immediately following a criticality accident. Procedures to determine high radiation doses immedia tely following a criticality accident are described in the Emergency Procedures Manual. Breathinc Zone Mcnitorinn (,2 Breathing zone monitoring of personnel will be j conducted as necessary to insure compliance with regulatory. requirements. 2.2.3 Sunnart Systems Ventilation in the manuf ac'tur ing facility (Suilding

17) is provided by four separate exhaust systems as described herein:

This system FA-1 Powder Precaration and Pressinc has a capacity of 12,100 CFM and incorporates prefilters and a double tank of 12 absolute filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system which is either returned to the unclad fuel area or released from the plant is sampled 100% of the time and analyzed each day. FA -2 Furnace H2 Rurnoff - This system has a capacity of 1340 CFM and incorporates prefilters and a single bank of 4 absolute filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day. ( This system FA-3 Egliet Grindim7 and Rnd Loadian Revision 2 Date 5/21/82 Page 2-32

has a capacity of 19,422 CFM and incorporates (( ) prefilters and a single bank of 21 absolute J filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system is released from the plant and sampled.100% of the time and analyzed each day. FA-4 Reevele powder Area - This system has a capacity of 0000 CFM and incorporates prefilters and a double bank of 6 absolute filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day. The capacity of the ventilation systems have been _ matched to provide a negative pressure differential between the Pellet Processing Facility and all surrounding work areas. The direction of the air flow shall be checked monthly and documented. If airborne radioactivity

results, averaged over a

two week period, exceed 25% of the applicable concentration listed in Table II, Column I of.10 CFR 20 Appendix B for air being discharged to an unrestricted area (from manufacturing or laboratory operations), an investigation will be conducted and corrective action taken. n (_) In addition, to assure our releases. remain as low as resonably achievable, a quarterly limit of 50 uCi in gross alpha activity of total uranium in plant gaseous effluents shall be maintained. If the rad ioactivity in plant gaseous effluents exceeds 50

uC1, a

report which identifies the cause for exceeding the limit and the corrective actions to be taken to reduce release rates shall be submitted to the Commission within 30 days. Also, if the parameters important to a dose assessment change, a report shall be submitted within 30 days which describes the changes in parameters a nd includes an estimate of the resultant change in dose commitment. The 50 uCi/qtr. limLt would result in a lung dose to 'a critical individual at the nearest residence of conservatively less than 0.10% of the 25 mrem / year standard as specified in 40 CFR 190. Ventilation system filters and/or prefilters will be changed, rotated, or knocked down whenever a pressure drop of 4 inches of water is measured across the comoina tion of the prefilter and first bank of absolute filters. The pressure drop for all 4 systems shall be chec ked weekly and documented. When the face velocity at a ventilated hood drops below 100 fpm, the hood filters or ventilation system filters will be F1 changed, brushed, or knocked down to incrrease the air flow to 100 fpm minimum or the hood.will not be used s, Hevision 2 Date: 5/21/82 Pages 2 -33

to handle radioactive material. Face velocities will [ ') be checked weekly in the manuf ac tur ing facility and monthly in the laboratories. Any work on filter change involving any of the four fixed air systems shall be performed under an HWd. Following all filter, char.ge s or other movement of filters, both the foremen and H.P. Technicians shall inspect the placement of the absolute filters for proper sealing. In

addition, air samples will be taken and counted immediately after 1/2, 2,

and 8 hours of operation to assure the absolute filters are adequately filtering the. exhaust air. The. adequacy of the samplihg techniques to obtain representative samples will be verified quarterly in the manufacturing facility and-annually in the laboratories, neveinnment n123rtment (Nuclear Laboratories) Airborne wastes are released from the Nuclear Laboratories as a result of airborne activity during handling and transfer of UO2 powder for chemical analysis purposes.- production of special R&D test f uel, and me ta llographic examination of production fuel and special tes t fuel. All airborne waste f-(_) exhausts from the Nuclear Laboratories (Building

5) via eight individual s tac ks.

The exhaust is continuously monitored whenever operations involving dusting or release got radioactive material are in progress. All stacks used for the exhausting of radioactive effluencs are equipped with sampling connections. 'All but two of these stacks have absolute filters. The two exceptions are the hydrogen burn-off exhaust stack (stack

4) and the environmental test laboratory stac k (stac k #7).

The Nuclear Laboratories (Building a5) exhaust s tac ks typically have the following flows: Stack No. __jltga_ Monitored Flow (ft1/ min) 1 Chemistry (No longer in use) 6200 2 Hot Chenistry Lab 3100 3 Emission ~ Spectroscopy Lab 2000 4 Sintering Furnaces (Ceramic Lab) 1260 5 Radiochemistry Lab, Environmental Labs & Vault 2610 0 Ceramics Lab (Rm.222), Me ta llo-graphic Lab 2125 7 Environmental Test Labs (no "( longer in use) 2000 8 Ceramics Lab (Ras. 224A & B) 4500 Revision 2 Dates o/21/82 Page: 2-34

Air f rom systems Nos.1, 2, 3, 5, 6 and 8 pass through (#,) single banks of absolute filters (99.97%) efficient for 20.3 micron particles), and are vented to the atmosphere. Continuous sampling is provided immediately upstream f rom the discharge point. System No.4 accepts effluents from two hydrogen sintering f urnaces and exhausts directly to the atmosphere. The exhaust is continuously sampled immediately upstream from the discharge point. The environmental test lab is connected to System No. 7 However, the system is not presently being used. Ventilation system filters and/or prefilters will be changed, rotated, or knocked down whenever a pressure drop of 4 inches of water is measured across the combination of the prefilter and first bank of absolute filters. The pressure drop for all systems shall be checked monthly and documented. When the f ace velocity at a ventilated hood drops below 100 fpm, the hood filters or ven tila tion system filters will be changed, brushed, or knocked down to increase the air flow to 100 f pm minimum or the hood will not be used to handle radioactive material. Face velocities will be chec ked monthly in the laboratories. The filters in these stacks shall be tested af ter all filter changes or movement of the filters to assure they are ade quately filtering the ([) exhaust air. The results of thes e tests shall be documented. In s trumenta li20 Capabilities of radiation detection and measurement Lnstrumentation shall be as f ollows : Alpha Counting System 10 - 100,000 dpm Alpha Survey Meters 0 - 50,000 counts per minute Beta-Gamma Survey Instruments .05 mR/hr - 200 mR/hr Neutron Survey Instruments .5 - 5,000 mrem /hr A sufficient number of the instruments,

meters, and systems listed above shall be maintaineo operational to adequately concuct our Health Physics program.

l The detectors for the criticality ala rm system are calibrated quarterly and following any repair that affects the accuracy of the measurements. All other instruments are calibrated twice per year and f ollowing any repair that af f ects the accuracy of the measurements. The calibration of the survey instruments shall meet the specifications described in l Section 1.11 of Regulatory Guide 8.24, " Health Physics Survey During Enriched Uranium-235 Processing and Fuel s s_) ibrication". The alpha counting equipment is checked l Revision 2 Dates 5/21/82 Page: 2-35 l

daily to verify background and efficiency. Q4Cu2at ion a l R ad i a tion cynosures Due to the extremely low levels of penetrating radiation which exist at Combustion Engineering's fuel f abrication f acility (<5 mr/hr), the greatest emphasis in exposure control has. been directed towards minimizing inges tion of airborne uranium particulates. To this end,- C-E has always maintained internal exposures as low as reasonably achievable through the use of ventilated hoods and process containment and an extensive breathing zone (BZ) air sampling program. General air samplers are strategically placed through .the facility to provide ind ications of airborne activity levels and are analyzed three times per day. A bica'ssay program which includes periodic urinalysis and in-vivo counting has been providing information regarding internal deposition of radioactive materials for over 10 . years and confirms Combustion Engineering's long standing commitment to the ALARA Concept. External Radiation Evrosures There has not been a single instance throughout the history of license SNM 1067 which has resulted in any O-individual exceeding the 10 CFR 20 quarterly limit of 1.25 rem. Internal R ad i a t ion Cynosures The most accurate results concerning actual internal deposition of radio-nuclides are found in bioassay results. The accuracy of these results far exceeds the accuracy obtained from personnel breathing zone air samples (BZ's), since BZ samples serve only as an immediate aid in assessing internal exposure potential and do not conclusively indica te that the material was actually ingested. During the past 3 years, all urinalysis results were less than I microgram U/ liter (the lower limit of detection for our fluorimetric method of analysis) with 3 exceptions in 1978 where 3 individuals' results were 2, 3, and 4 micrograms U/ liter respectively. In-vivo lung counting results over the past 10 years clearly indicate that no individual has ever received a maximum permissible lung burden MPLB) which is about 200ugm U-235 for low enriched uranium. Due to the extreme sensitivity required to detect such low fg amounts of U-235, mos t results are reported as zero u (_) with a statistical accuracy associated with them. Revision 2 Date: 5/21/82 Page: 2-36

i / 2.2.4 cnntrol ocerations Internal Fynosura (Parsonnel Breathinc Zone Air Samnling and Fixed Location Ganaral Air Samni f nc ) Nuclear Foal Manufacturino The room air in all areas where unclad licensed material is handled, processed, or where operations could result in worker exposure to the intake of quantities of uranium exceeding those specified in 10 CFR 20.103, shall be continuously sampled and analyzed on every shif t f or radioactivity. Air sampling shall be accomplished using fixed-location (general air) samplers and personnel breathing zone (BZ) samplers for basic evaluation of the internal exposure of workers, for supportive measurements, and for special studies. During the normal operations period, if a single air sampling station indicates the airborne concentration of radioactivity for that area exceeds one MPC level as specif ied in Table I Column I of 10 CFR 20, Appendix B, an investigation as to the cause shall be conducted. Any necessary corrective actions to 7e (_)j) prevent its recurrence shall be taken and documented. The fixed location general air samplers shall have a minimum flow of 10 liters / minute and the personnel breathing zone samplers shall have a minimum flow of 1400 cc/ min. The personnel breathing zone samplers shall be the primary means of determining radioactive airborne concentrations of particulates in the workers breathing zone. Breathing zone (BZ) samples will be taken for the first two weeks of a new operation or significant change in operation, involving unclad

UO2, with sampling carried out 100% of the time during which the operation is carried out.

Thereafter, process operations involving UO2 powder will be surveyed with BZ samplers at least 75% of the time. Operations involving U02 pellets shall be samoled at least 25% of the time. The fixed location samplers are located throughout the shop and run continuously during cperations. These samplers provide air samoles which are representative of working areas in order to verify adequate ventilation and contamination control. All samples will be analyzed for each working shift (after I a 24-hour decay to estaolish a radon-f ree count). If any problems arise, the minimum (BZ) sampling times shall be increased accordingly. 1 Revision 2 Date: 5/21/82 Page: 2-37 i I l

It is reccgnized that the behavior of individual () operators can be a significant contributing f actor to an individual's exposures, and that this may not be amendable to the desired degree of improvement. Where the individual operator is found to contribute significantly to higher exposures, closer personnel surveillance shall be maintained. Thus, an individual whose 40 hr exposure exceeds 2.5 MPC days shall be continuously monitored with a BZ sampler. If his 40 hr exposure exceeds 4 MPC days, he is removed from exposure to airborne contamination. It is the respons ibility of the licensee to evaluate these situations to determine the relative contributions of individuals and equipment. The pellet shop is the only place in the manuf ac turing facility that handles unclad U02. This portion of the facility is kept at a negative pressure. Therefore, continuous air sampling shall be conducted in this area only. novelonment Decartment (Nuclear Lahnratories) All operations in the laboratories which involve UO2 powder or the potential for worker exposure to airborne uranium exceeding the limits specified in 10 CFR 20.103, shall be sampled with breathing zone 0 samplers 100% of the time. A one MPC action level and a minimum of 1400 cc/ min flow shall be used for laboratory operations. Frternal Execsure (Oosimetrv Pecuirements) Each individual who enters a res tric ted area under such circumstances that he is likely to receive a cose in any calendar quarter in excess of 25 percent of the applicable value specified in 10 CFR 101(a) shall be supplied with a TLD badge and indium foil for purposes of. personnel dosimetry. Badges will be processed monthly. When a high exposure is suspected, the individual's badge will be immediately processed. All visitors will be supplied with indium foil badges. Area TLD badges and neutron foils are also strategically placed throughout the facility for the purpose of recording background radiation levels as well as radiation resulting from a criticality accident. These badges will also be processed monthly during normal operations and immediately following a criticality accident. Procedures to determine high radiation doses immediately following a criticality accident are described in the Emergency Procedures Manual. Revision 2 Date: 5/21 /82 Page: 2-38

Bicassav Program Urinalysis and in-vivo lung counting shall be conducted annually. If the most recent quarterly average of the airborne uranium concentration for any work area exceeds 25% of the respective DAC the f re quency of sampling and the type of bioassay measurements for workers in that work area shall be modified to that given in Table 3 of Regulatory Guide 8.11, " Application of Bioassay for Uranium", June 1974. The following tables outline the action levels which will be utilized for both urinalysis and in-vivo counting: URINALYSIS ACTION ?EVCIS Urinalvsis Result Action I) Sample >25ugU/11ter

1) Confirm result (if unexpected)

2) If result is confirmed:

--Impose work restrictions -Collect & evaluate dianostic (,s) urine samples --Conduct investigation to ident-ify probable cause -Perform in-vivo count IN-VIVO ACTION !EVCIS In-vivo Result Action

1) Lung Burden >l75ug

1) Confirm result (if unexpected)

U-235

2) If result is confirmed:

-Impose (or continue) work limitations. l -Conduct job investigation to identify probable cause, de-I termine if others were ex-l posed, and evaluate ade quacy l of air sampling. -Initiate corrective actions

2) Lung Burden >200uq Ta ke the aoove action, and in U-2 35 addition, remove the individual from further exposure to air-borne radioactivity.

O) t Hevision 2 Date: 5/21/82 Page: 2-39 r

Contamination Surveys x Contaminated Areas (Pallet Shon Rufidinc dl 7 4 + Snecified Lacoratories Stifidinc d6) Removable Aloha Contaminatinn Actinn to be Taken 10,000 dpm/100 cm2 Immedia te Clean-Up 5,000 dpm/100 cm2 24-hr Clean-Up Contaminated areas shall be surveyed on a weekly basis. Material on processing equipment or fixed on surfaces shall be limited as required to control airborne radioactivity and external radiation exposures. Clann Armas (Othar Plant Areas. Offica Araas. Lunch Areas) Removablo Alnha Cnntamination Action to ba Taggn .100 dpm/100 cm2 Immediate Clean-Up 50 dpm/100 cm2 24-hr Clean-Up

10 dpm/100 cm2 Immediate Clean-Up
(lunch rooms only)

Other manufacturing

areas, office

areas, warehouse (Bldg. 21) shall be surveyed on a monthly basis.

The lunchrooms shall be surveyed daily, as a minimum. Matarials & Couinmant Relaasad for Untastricted Use (does not include the anandonnant of ouildinns) _ The release of materials and equipment for unrestricted use shall be in accordance with " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or i Ternination of Licenses for By-Product.

Source, or Special Nuclear Material", USNRC, Novemoer 1976.

Rasniratorv Protection The Respiratory Protection Program shall be conducted in accordance with the USNRC Regulatory Guide 8.15. Audits All audits shall be performed in accordance with a written plan, n nevelonmant Decartment (Nuclaar Labanngriaal 's_J Operations in the Nuclear Laboratories will ce Revision 2 Date: 5/21/82 Page 2-40

I formally audited as follows: \\s Laboratory operations will be audited once per month by an indivicual who meets the minimum cualif ications of the Health Physics & Safety Supervisor. He will verify the ade quacy of the Radiation Protection Program and that all designated limits and controls are being followed. The findings of the monthly audits shall be documented and copies submitted to operational supervision and to the Vice President, Development. The reports shall include items for correction (if necessary) and the actions taken on items from previous audits. A management audit of the Nuclear Laboratory operations is made annually, with no more than 13 months be tween audits. The audit shall be performed by an individual independent of Nuclear Labs who meets the minimum qualifications of the

Manager, Health Physics.

The audit will be an overall review for compliance with all regulations and license requirements. Records will be reviewed for trends and abnormalities to assure the appropriate corrective actions have been implem'ented to assure all exoosures are as low as reasonably achievable ( ALARA). An overall review of the radiation and criticality saf ety program shall be a major portion of this audit. ) Nuclear Euel Manufacturinn Onerations - Operations at the Nuclear Fuel Manufacturing Facility will be formally audited as follows: Once each working day by a Health Physics Technician for Heal th Physics compliance and criticality compliance. He shall submit his findings in writing to the Supervisor, Health Physics & Saf ety. Once each month f or nuclear criticality saf ety by an indivicual 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 reported to the General

Manager, Nuclear Fuel Manufacturing.

Once each month for radiological safety by an individual who meets the minimum qualifications of a Radiation Specialist. He shall audit for compliance with all regulations. and operating procedures and shall assess the adequacy of the radiological safety program. His findings will be documented and submitted to the General

lAanager, Nuclear Fuel

(_4y ) Manufacturing. Revision 2 Date: S/21/82 Page: 2-41

y /: Once each. year by the Nuclear Saf ety Commi ttee. This committee will review all aspects of the criticality and radiological safety programs and will transmit their report in writing to the Vice President, Nuclear . Fuel with copies to the Vice President, Nuclear Power Systems and operational supervision. Follow-up actions on audi ts of the Nuclear Laboratories will be the respons ibility of the

Manager, Health Physics and for audits of the manuf acturing f acility, will be the responsibility of the General Manager, Nuclear Fuel Manufacturing.

A ll audits shall include a section for previously identified items for correction to assure the appropriate corrective action has been taken. Investications and Recortinc of Off-Normal Occurrancas Any unusual events that.could lead to radiation health and safety problems shall be reported to the General

Manager, Fuel. Fabrication, or the Vice President Development as appropriate.

The NHC shall be notified of such occur.rences. It is the in tent of Combustion Engineering, Inc., to be in compliance with the reporting requirements of 10 CFR Part 21 for reporting of defects and noncompliance and 10 CFR 73.71 for (s3/ events that significantly threaten or lessen the effectiveness of safeguards. Hecords Recorcs relating to health and safety shall be retained indefinitely. Such records shall include plant alterations or additions,

aonormal, and of f -normal occurrences and events associated with radioactivity releases, criticality

analyses, audits and inspections, ins trument calibration, ALARA findings, employee training and retraining, personnel exposures, routine r ad iation

surveys, and environmental surveys.

s_-e i Hevision 2 Date: 5/21/82 Page: 2-42

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( 3.0 cla sses of Radiological contincancias 3.1 Cla ssi f ica tt en Svstem The NHC has issued guidelines for the consideration of accidents in the NEPA reviews of nuclear power reactors. Nine categories of postulated accidents, ranked in order of severity from trivial to very serious, have been identified. In general, accidents in the high potential conse cuenc e end of the ranking have a low probability of occurrence. The NRC has not published guidelines for the consideration of accidents in fuel fabrication plants or related facilities such as the nuclear laboratories. A spectrum of accidents which is possible in connection with the operation of the Windsor f acility has been pos tulated and classified into six categories ranging from minor (Class I) to catastrophic (Class 6). Class I - Minor accidents with no radioactive release within the facililty. Class 2 - Accidents which could release some radioactivity inside the plant but with no release to the environs. () Class 3 - Accidents which could release small amounts of radioactivity outside the plant. Class 4 - Accidents which could release radioactivity. offsite. Class 5 - Radioactive material shipping accident. Class o - Natural Phenomenom Class 1 Accidents Class I accidents may be expected to occur several times in the plant lif etime but the consequences are small. Accidents in this class originate f rom: outage of plant utilities, l eouipment failure and chemical accidents. 1 Facility Pager Outace C-E receives electric power from the Hartf ord Electric Light Company (HELCO) and backup power. is provided for critical services automatically, by means of an onsite diesel power-dr ived alternator. Complete power outages are inf re que n t. Voltage fluctuations of a few cycles duration are fairly frequent and require the use of isolation transformers and buf f ers of various kinds for power supplies, (s^s_) computers, delicate instruments, etc. Fluctuations of longer Revision 2 Date: 5/21/82 Pages 3-1

(~ duration, such as low voltage lasting long enough to result s_f in loading and cause circuit breakers supplying motors to

~'

open, or f requency fluctuations to af f ect ordinary e quipment rarely occur. In the unlikely event that HELCO power suff ered an outage and the emergency alternator f ailed to pick up its lo ad, all ventilation exhaust systems would 'stop operating. Air pressure in the buildings would equalize with the atmospheric pressure, and any backflow through the exhaust system would be so low that airborne uranium-bearing material would not escape from process hoods. The UO2 processing sections of both Buildings #5 and

17 are designed to have low air infiltration rates and the HEPA ventilation filters prevent any spills of contamination to the environs through the exhaust system.

Loss of Water Sucolv Water supply to the Windsor site comes f rom a 12" main fed by the Metropolitan District Commission (MDC). In the event of a complete failure of the fire protection supply line a 425,000 gallon supply of water, in two pumped storage

tanks, is maintained at all times for fire fighting purposes.

j In the. event of total water supply failure from some unforesen occurrence, damage .to some of the water-cooled process equipment could occur. There is no water-cooled equipment in the UO2 facilities in which a coolant loss would result in a. release of uranium into working areas or, for that matter, into the environs. Chemica l Accidenis Anhydrous Ammonin - Anhydrous ammonia is stored in two tan ks (8000 gal. & 6000 gal.). The tanks were pressure tested at 250 psi and equipped with dual pressure relief valves. The tanks are mounted on reinforced concrate piers and are located within a fenced area to preclude accidental damage by trucks, f ork lif ts, etc. The exposure of the tanks to an intense fire would result in operation of the relief

valves, designed to bleed overpressure.

The release would cease as the fire was extinguished.. Ammonia vapors could reach high concentrations, but it is felt that the vapors would oe rapidly dispersed and have no permanent effect on personnel or the immediate environment. Liould Nitronen - Liquid nitrogen is stored in a 5000 ga llon insulated tank permanently located on a reinforced concrete pad. The tank is equipped witn dual pressure relief valves which automatically dump nitrogen gas to the atmosphere when the tank pressure reaches 245 psi. The likelihood of a 's significant tank leak is extremely remote. In any

case, nitrogen is nontoxic and nonflammable.

Liquid nitrogen Hevision 2 Date 5/21/82 Pages 3-2

s evaporates.upon exposure to the atmosphere and is quickly ,_) dissipated into the environment.

s..e Linuid Prenana - Liquid propane is stored in a

1500 gallon tank. The tank is designed for a safe working pressure of 250 psi, and is equipped with a saf ety relief valve set at 250 psi. The tank is located on reinforced concrete piers designed for that purpose and is located inside a

paved, fenced area to preclude the possibility of damage by

trucks, fork lifts, etc.

The chance of a significant leak o ccu rring is extremely low. Liquid propane is readily volatilized to a gas upon exposure to ambient conditions and is dissipated into the atmosphere. Propane is highly flammable and this would present a fire hazard should a large leak occur. The fire, however, would be restric ted to the immediate vicinity of the tank and no significant environmental effect would be caused. Scent Acid - Spent acid solution is stored in a 2000 gallon stainless steel tank. The tank sits on a concrete pad and is located away from the general traf fic flow of the building to prevent accidental damage by a truck or fork lif t. The tank is emptied periodically by a licensed trucking concern and transported to an EPA-approved disposal f acility. Nitric Acid - Liquid nitric acid is stored in a 5000 gallon stainless steel tank. The tank sits on a concrete pad and is m ) located away f rom the general traffic flow of the building to prevent accidental damage by a truck or fork lif t. In the 10 years that the tank has been in use it has not suff ered damage of any type nor has there been any leakage of nitric acid to the environment. Changes in fuel rod production processes have reduced use of the material to a point where a large storage capacity is no longer required. In the near future, this tank will be removed and all future shipments of nitric acid will be received in 3 0-ga llo n stainless steel l casks. The acid will be stored in these casks until the l material is to be introduced into the production process. Class 2 Accidents Accidents in Class 2 have lower probabilities of occurrences, l are less frequent than Class I accidents and result in the release of radioactive materials to secondary confinement with no release to the environment. The consequences of a Class 2 event might require operational downtime to make repairs or to replace damaged equipment anc effect decontamination within plant structures. The risk is acceptably sma ll because of design considerations which provide engineered safety features such as the multiple high efficiency particulate filters and redundant plant s erv ic es to achieve reliaoility. I Revision 2 Date: 5/21/82 Page: 3-3

Accidents in this class originate f rom a detected spills of 3 g_<) uranium-bea ring ma te rials, undetected spills of uranium-bearing materials, and minor tires involving fuel. Detected Scills of Uranibm-Bearinc Vaterials Spills of uranium-bearing materials are considered readily handled incidents. The main requirement would be detection, containment and immediate cleanup. In all such

cases, the gross quantity of material would be cleaned up and the area surveyed to be sure cleanup was complete.

Standard health physics procedures would be followed to prevent and/or evaluate any personnel exposures. These procedures include notification of Health

Physics, immediate monitoring, issuance of respiratory protection, if required, removal and analysis of air samples taken in breathing zones curing cleanup operations, followed by completion of the decontamination and personnel decontamination as needed.

Spills of uranium would release small amounts of uranium to the working area but should not result in a significant release of uranium to the environs since the HEPA filtration system would filter out all but 0.1 percent of the uranium. Spills in this class which are defined as immedia tely detected and cleaned up, have only small potential for even minor injury to employees or damage to the environment. Undetected Snills of Uranium-Bearinc vatarials -) ,J For undetected solid or li quid spills of ur an ium-be aring materials, a maximum of 8 hours would elapse before such a spill would be detected. This time period is based on the frequency of the surveys conducted in the facilities. Prior to the end of each work day (or shift change) a survey of. a ll control areas is conducted. Contamination could spread to uncontrolled areas of the building, but would be detected before it could be spread to the outside environment. It should be noted tha t this is a worst case incident and assumes that the personnel involved in the incident ignored the monitoring devices installed at the exits of a ll controlled

areas, and in

addition, failed to obs erve protective clothing re qui remen ts.

Because personnel practices require clothing change and personal cleaning .before leaving the control area, none or the contamination is expected to be tracked out to the environs. Minor Fire Involvino Uranium-Bearina Materials Minor fires involving uranium-bearing materials could release airborne uranium inside the building, but release of uranium to the environs is improbable because of the HEPA filtration

system, the size or the

building, the availability of portable fire extinguishing equipment, the extensive (S

sprinkler system, and the training of personnel in fire s_) protection. Airborne uranium released within the building as Revision 2 Date: 5/21/82 Pages 3-4

... ~. (3 a result of a fire would be handled in the manner indicated (;! for detected spills. Class 3 Accidents Class 3 accidents ' include a fire or explosion. Accidents of this type have a very low probability of o ccurring, but may result in the release of some radioactivity to the immediate vicinity of the plant environs. The probability of a fire with release of radioactivity from either Building

5 or
17 has been minimized through carefully engineered safeguards, strict control of combustible materials, and protective measures to control a

fire it it does occur. The safeguards that will protect against fire include extensive sprinkler systems, f ed through an 8" loop and augmented by a 425,000 gallon storage tank with bac kup pumping capability. External fire hydrants are provided as backup for properly located portable fire extinguishers within the buildings. In addition, a constant liaison is maintai.ned with the local fire departments. Potential Sources of Cire or Fynlosien Flammable Solvents - Acetone and alcohol are contained in I gallon safety cans equipped with flame arrestors. Solvents are stored in grounded drums located outside the buildings. 71rennium Fines - Zirconium used for fuel encapsulation is machined, forming.. chips and fines. Administratiive controls limit the accumulation of chips and other fines to 5 pounds or less at a machine location. The chips are covered with water at all times while they are stored at each machine lo ca' tion. The chip material is collected periodically and placed in 55 gallon drums which are sealed and shipped,to a zirconium supplier where they are recycled into product. Nitric Acid - Nitric Acid is used in pickling operations. The combination of nitric acid and organic materials forms l highly comoustible substances such as nitrocellulose. Organic materials are kept well separated f rom nitric acid. Hydrogen is used as a reducing e alosion Mvdrocen v l atmospnere in the sintering furnaces. In case of power l failure, loss of exhaust f ans, or excessive temperatures, the l flow of hydrogen gas is cut off. Past experience has oemonstrated that sintering furnace explosions may occur due to the presence of oxygen during furnace startup as a result of incomplete air purge. Preven ta tive measures include burnoff of waste hydrogen gas, au toma tic sprinkler

system, continuous personnel training, and a.vailability of cortable fire fighting equipment.

() Revision 2 Date: 5/21/82 Page: 3-5

Erninsinn in Sinterinn Fornaca An explosion of the magnitude postulated for this analysis is considered incredible, but has been analyzed to show

that, even for extreme conditions, the derived safety standards are not exc eedec.

For purposes of this analysis, it is hypothesized that all precautionary steps f ail and an. explosion occurs in one of the furnaces. It is assumed tha t the furnace contains a maximum of 280 kilograms of uranium oxide in the form of pellets. It is assumed that all of this uranium oxide is olown into the pellet shop. With a filter efficiency of 99.9 percent, the calculated release from the building to the external environment is 280 gr,ams of uranium oxide (56o uCi if enrched to the maximum 4..I wt% U -2 35 ). This is an extremely conservative estimate of the UO2 reaching the external atmosphere, since much of the UO2 released would be in the form of pellets. The dose to the nearest

resident, which is 700 meters from Building

17 in Sector 5,

was calculated assuming that the atmospheric stability condition was Pasquill Type F and the wind speed was I meter per second. The dose equivalent was calculated to be 8.8 mrem to the lung and.013 mrem to the bone assuming a breathing rate of U.0005 cu. meters per second with a retention factor of 25% for this insoluble (Class Y) material. These doses are (,) only 0.001% and 0.000009% of the derived standards for lung and cone, respectively. Fira in Cual Rod Storana Araa In spite of the above precautions, a fire in the fuel rod storage area has been evaluated. Tests of fuel rod integrity versus temperature have been done which sncv that the maximum loss of uranium is about 60 mg per rod *. ed on this, if a fire occurs in a fuel rod storage area, th e activity released would oe 0.12uCi per rod (if enriched to the maximum 4.1 wt% U-235). Assuming a fire does occur, it is estimated that the maximum number of rods which could rupture would be 300 (maximum number of rods in a fuel rod storage container). This could result in the release of 36.0 uC1. Since the rod storage area has no hEPA

filters, it is conservatively assumed that the total 30.0 uCi of uranium is released from the building.

It is further assumed that the atmospheric stability conditions is Pasquill Type F and the wind speed was I meter per second. The wind direction was assumed blowing toward the nearest resident which is 700 meters from the edge of Building #17 in Sector 5. The dose equivalent was calculated to be 1.14 mrem to the lung and.0162 to the bone using a breathing rate of 0.0005 cu. meters per second with a retention factor of 25% for this insoluole (Class Y) (~) material. These doses are only 0.0015% and 0.000012% of tne (_ i devision 2 Date: 5/21/82 Page: 3-6 i I

derived standards for lung and bone, respe ctively. e~bg

nef erence s (VI-7)

Environmental

Heport, Alabama Nuclear Fuel Faorication Plant,- Pg. 5-4, Docket No. 70-2909, December 1979.

Class 4 Accidents This category may be described as accidents that occur onsite that subsequently release radioactivity of f site,. including a criticality accident without a fatality, or a major fire or explosion which. destroys an entire building. MaIce Pire or Ovelosion A major fire or explosion that would destroy the entire building, including the building exhaust filtration system and HEPA filters,. could release uranium oxide to the atmosphere. However, a major fire / explosion which involved an entire building is considered to have an exceedingly small probabili.ty by virtue of extensive engineered safeguards against fire and control of fire if it occurs. The safeguards that will provide against fire include extensive sprinkler systems, f ed through an 8" loop augmented by a 425,000 gallon storage tank with backup pumping capability, rs Engineered safeguards are incorporated to minimize the (,) probability of. fire such as use of noncombustible and fire resistant materials; strict control of solvent and flammable liquid inventoriest strict control of combustible materials fire resistant filters, and use of covered metal containers for comoustible waste. All special nuclear materials are stored in a manner that allows complete flooding in the event of a fire so that a criticality accident will not result from fire fighting techniques. The combined safeguards for both prevention and control of fires makes the probability of an unchec ked fire remote. critien11tv Since the amount of U-235 onsite is greater than the minimum mass necessary to achieve criticality, it is necessary to l consider the possibility of a criticality incident. While l such an accident is theoretically

possible, it is highly unlikely because of the administrative and operational controls established by C-E over the receipt, use and storage of the enriched uranium.

In the history of the fuel f abrication indus try, there never has b een a criticality accident associated with fuel preparation or fabrication. There have been f our criticality accidents in scrap recovery operations, but all of these involved wet chemical processing. The operations performed on the Windsor site do not involve wet chemical processing. O Revision 2 Date: 5/21/82 Page: 3-7

Fortunately, criticality accidents have occurred so rarely 3 (j that no statistical analysis of the probability of such an ~ accident has been a ttemp ted. Critical even ts that have occurred have, had no significant environmental impact. Radiation injuries were restricted to individuals directly involved. Fission products were effectively confined to the processing building in which the event

occurred, Prompt evacuation of employees upon a criticality alarm would assure no more than minor radiation doses to all except those in the immediate. vicinity of the accidents.

Encaosulated Uranium Ovida - Vederatgd A sufficient quantity of production assemblies, to sustain a nuclear chain reac tion when covered with

water, could theoretically but inadvertently be accumulated.

This could occur in the assembly washing operation where administrative controls are required or in a special zone where exclusion of water is required to maintain the system subcritical. In the above case, the first spike of the nuclear chain reaction could exceed 10,000,000,000,000,000

fissions, ejecting the moderating water as steam in a

sufficient quantity to render the system subcritical. The release of ftssion prcducts is not expected because the enriched uranium is encapsulated in zirconium tubing which is designed to withstand a reactor environment. Moderated Uranium Ovide - Unencansulated Unencapsulated enriched uranium such as fuel

powder, fuel pellets or fuel sludges could be accumulated, through inadequate administrative controls, in suf ficient quantities for a criticality accident.

Similar accidents have occurred in the past with uranium solutions as previously noted. From 1,000,000,000,000,000 to 1,000,000,000,000,000,000 fissions could be expected from a single burs t releasing fission products. Resultinc Doses to the Envirens - Cloud Desa The whole body and the surface body doses were calculated assuming a criticality accident that produced 1,000,000,000,000,000,000 fissions. This is ecuivalent to the. release of about 32 megawa tt-seconds, which is a much larger excursion than could be expected in any system in the Fuel. Fabrication Facility. To a ttain an excursion of this magnitude, a very rapid increase in reactivity would be required which is not credible in the systems in this facility. The fission product isotopic release and the average energy used in this analysis were taken from Regulatory Guide 3.34, dated July 1979. The distances to the nearest. site boundary and resident are 560 and 700

meters,

( respectively. The atmospheric conditions assumed for the Hevision 2 Dates o/21/82 Pages 3-8

dose calculations were very conservatively chosen to be G'1 .Pasquill Type F with a wind speed of I meter per second anc the wind blowing directly at the nearest site boundary or resident. The gamma and beta dose was calculated assuming a semi-inf inite cloud surrounding the individual with a radioisotopic concentration e cuivalent to the center line of the plume. Since the Pasquill Type F atmospheric stability condition produces a very small

plume, the gamma dose is over-estimated by about a f actor of 8 as a

result of the semi-infinite cloud assumption. In the calculation of the cloud gamma and beta

dose, credit was taken for the delay time between the time of criticality and the arrival of the cloud at the nearest site boundary.

This delay is composed of two components. One is the delay in the Fuel Fabrication Building and the other is the transit time from the building to the nearest residence. The delay in the building was done assuming the volatile fission products were ins tantly mixed within the pellet shop volume of 291,000 ft3. It was assumed that 19,331 ft3 of the building

volume, which is equivalent to 30 seconds flow through the ventilation system, was discharged with no delay of the fission products.

The doses at the site boundary were calculated f or this release. The next 19.331 ft3 volume was N delayed for 30. seconds and the doses at the site boundary {~gh ca lcula ted. _This same procedure was followed until the e entire building volume was released. The doses from each 30 second release was added to determine the total dose from the cloud. This method of calculating has two conservative assumptions - 1 ) no delay is assumed during each 30 second release, and 2) no further dilution of the fission products in the building is assumed for each release. The other areas of the Fuel Fabrication Building have no forced external ventilation so the delay time would be sucstantially longer. The delay after release is 9.3 minutes baseo on the transit time of the cloud moving at I meter per second for 560 meters. The only other credit taken was the wake effect of the building which is only 1.5 This is cased on the minimum external area of the Fuel Fabrication Building which is 334 square meters. The resulting whole body and body surface oose from the cloud as well as the prompt gamma and neutron dose are shown in Table 3-1. Promnt Gamma and_Meutron Oose The prompt gamma and neutron dose was calculated for the nearest residence using the method shown in Regulatory Guide 3.34 datec July 1979 1,000,000,000,000,000,000 fissions were O assumed for the criticality accident and the distances were 500 and 700 meters for th e nearest site boundary and Revision 2 Date: 5/21/82 Page: 3-9

(x resident, respectively. No credit was taken for structural (_) attenuation. s.- Thyroid nesg The doses to.the thyroid from the inhalation of radioactive iodine were calculated for the nearest site boundary and res ident to the Fuel Fabrication Facility. The results are shown in Table 3.1. This source assumes 50% release from the f uel and 50% plate-out inside the Fuel Fabrication Facility. The same atmospheric conditions were used to calculate the concentration of iodine as used in the whole body dose calculations. It was assumed that the breathing rate was 0.0000000000000347 cubic meters per second which is the breathing rate characteristic of the active portion of the normal work day. No decay was assumed for the transit time f rom Building #17 to the nearest site boundary or resident. The thyroid dose per iodine curie inhaled was taken from Table II in TID-14844 Canclusions The doses shown in Table 3.1 were calculated using extremely conservative assumptions. Even using these conservative assumptions, the resulting doses at the site boundary are 1.0 percent, and 7.4 percent of the derived standard values of 3 300 rem (thyroid), and 25 rem (whole body). Class 5 Accidents This category is described as accidents that occur offsite that suosequently release radioactivity offsite. An accident type falling into this classification is a radioactive shipping accident. Transportation of radioactive materials takes place both to and from the Windsor plant site. The uranium shipped to the Windsor site is principally UO2 powder and pellets in Model Ut4 C-2901 and CE 250-2 shipping containers. Shipments from the Windsor site will be principally unirradiated fuel assemblies, of rods made of sintered UO2 pellets encapsulated in zircaloy

tubes, in Model 927Al and 927Cl shipping containers.

Fuel shipments from the Windsor site are made using exclusive use trucks, t All such raoicactive shipments are regulated by the U.S. Department or Transportation and the Nuclear Regulatory Commission, and are in f ull compliance with state and f ederal regulations governing the safe shipment of hazardous materials. Shirments to the Windsor Site /'} (/ The majority of the material shipped to the Windsor site will l Hevision 2 Dates o/21/82 Page: 3-10

. _. _ _.. ~ (1 consist essentially of uranium oxide (UO2) in the form of v powder and pellets. This material will be shipped in CE 250-2 shipping containers under USNRC Certificate of Compliance #9022. An average of 260,000 Kg of UO2 in the form of powder and pellets is received each year at the Windsor site. This material is shipped in exclusive use trucks and approximately 45 shipments are received annually. Shipments, on receipt, are completely surveyed for damage and radioactive contamination and the truck is surveyed before it is allowed to leave the plant site. Shinments from the Windsor Site The majority of the radioactive material shipped from the Windsor plant site consists of finished fuel assemblies. The assemblies, consisting of fuel rods containing fully encapsulated UO2 pe lle ts, will be shipped in specia lly designed and tested Type 937Al or 927Cl shipping containers under USNRC Certificate of Compliance #0078. An average of 200,000 Kg of UO2 in the form of encapsulated UO2 pellets in fuel assemblies is shipped each year from the Mindsor s ite. The assemblies are shipped in the containsers in exclusive use trucks and approximately 35 shipments are made annually. In addition to fuel shipments, quantities of radioactive materials in the form of papers, rags,

filters, and metals

") are also shipped f rom the Windsor site to an NHC-licensed (1 9 burial site. Approximately ten such truckloads of material 7 are removed from the Windsor site to the approved burial ground location each year. The increased numoer of shipments for burial is because of recent burial site allocation requirements. The actual volume of waste has decreased significantly over the past 2 years. All such shipments are made using approved steel drums on exclusive use trucks. All containers and the transport vehicles will be completely surveyed for proper loading, absence of defects that colld effect container integrity, and for levels of radioactive contamination before off-site shipment. Environmental Imnact of Shinments All shipments of radioactive material to and from the C-E dindsor plant site will be made in accordance with the stringent regulations of the DOT and NRC. These re ulations specify container integrity under severe conditions. The CE 250-2, UNC-2901, 927Al and 927C1 containers are

designed, l

manuf actured, and maintained to provide containment of their contents and remain subcritical when subjected to the ( following hypothetical accident conditions. A 30' drop onto an unyielding surface in the most damaging orientation, followed by, A 40' drop onto a 6" diame ter steel rod, striking in the most Revision 2 Date: 5/21/82 Page: 3-11

l vulnerable spot on the container, f ollowed cy, f~sd A Ju-:ainute fire at 147b degrees F, rollowec by, Suomersion in water to a depth of 3' for a hours. In adcition to the stringent performance standarcs for shipping containers, C-E imposes acministrative control over the exclusive-use truck transport vehicles. The

number, type, and contents of the containers loaded on each truck will be controlled to ensure that all vehicles will remain nucle ar-saf e under normal transoort and accident conditions, wo transportation accident resulting in a

criticality has ever occurrec. In addition, container performance standaras and vehicle loading controls are providea to ensure that a venicle will remain nuclear-sare even curing tne hypotnetical accident conditions. For tnis

reason, it is extremely u n 11.<e l y that a

nuclear criticality could r es ult from shipments to or troo the dindsor site. Shoulo a shipping package be breached, the impact on the environment would be low because tne nuclear materials would be in solid form and woulo not be readily dispersible. Due to the low radiation levels or the uranium involved, the radiological imoact on tne environment from a transportation accident would not be significant. () Class o Accidants Accidents of this type are the naturally o ccu rr ing events such as flooding, wind

damage, tornacos ano earthauakes.

Flooding is not considered credible because tne hign water level ror the area's worst flood (August 1955) was acproximately 110 feet aoove mean sea level. Since the aincsor site is loca ted aoproximately 180 feet acove mean sea level, tne probability of direct camace resultinc f rom lo cal flood is very low. The average hourly wind speed for 1979 was 8.8 miles per hour. The revailing wind cirection ror 6 nonths, May to Oc tobe r is south and for the 6

nontns, aoveaner to April, is northwest.

The average wind velocity at the aindsor site is 11.2 miles cer

hour, fhe hichest recorded velocity was 70 miles per hour in dovemoer

1950, ihe ouilcings on the aindsor plant site are desioned to withstanc steady winc levels cn the order of 100 miles per hour.

The tornaco hazara procecility for tnis region is U.003001 ror a tornado with winds ranging from 140 MPH to 239 ta en. inis means tnat in any one year there is a 1 in 1,000,0u0 chance or a tornado of this size affecting the C-E Mincsor site. The ilincsor plant site lies in a region classiriea as Zone 1, correspondina to Intensity VI on the modified Mercalli scale of 1931 The olant is s truc tura lly acecuate f or Zone 2 earthcuake loacs whicn are more severe than Zone 1. It is evicent from the above that there is a g-)s (_ very low procacility of release of racioactivity from tne facility oy Class o accidents, sevision 2 Date: o/21/S2 Page: 3-12 ~. -

TABLE 3.1 OF: SIT 00SES CROY CJITICaiITV ACC I 9hT Site Bouncary idearest desident 33 __ Dose (HAO) Oese N AO) ilhole dody I.842 1.I87 Surrace 4.06 2.145 Thyroic 2.93 I.90 0 O devision d Date: D/21/c2 dage: 3-13

(} 3.2 classirientien Schame Section 3.1 or this plan evaluates tne conse cuences of all creciole accidents. In all cases examined, the probability or a major accident was round to be extremely low. This low probacility is cerived from tne fact that: 1) all process .ermanently engineerec equip.nent is designed to incorporate c safeguarcs; 2) strict acministrative control of production processes is maintained; 3) the doucle contingency princiale is adhered to in the preparation of safety evaluations; anc 4) genercus safety factors are includec in all facility limits. A classification system has been

employed, however, which covers the entire spectrum or possible emergency situations l

regardless or the probability of their occurrence. This section of the plan describes how the spectrum of postulatea accidents are encompassed within the emergency cnaracterization classes. Each class defined is associatec with a particular set or immediate actions to ce taken to cope with the situation. It should be noted that various classes of accidents require a graded scale of responses, which form the casis for the classification scheme. Also, a small

proolem, such as a

Os fire, may increase in severity and therefore move un trom one class of accicent to another. r actification of dausual svent (1) Dascrintion fnis class involves accicents anc occurrences on-site in which emergency tr ea tme n t of one or more individuals is r e qu i rec. It includes those situations that nave no potential ror escalation to more severe emergency concitions, fhere ;aay oe no ettect on the

facility, and immeciate operator action to alter f acility status is not necessarily re cu ired.

A personnel emergency does not activate the entire emergency organization, but may ac tiva te tea.ns sucn as tne rirst alc team. It may also recuire spe cial lo cal services such as amoulance and medical. Energencies in this class can reasonaoly be expe c ted to occur curing the life of tne plant. Recognition of this class of emergency is primarily a jucgement ma tte r for facility supervisory or management personnel. Its importance as part or tne classification scheme rests to some extent on its " negative" information content, vis, tnat tne incicent giving rise to tne emergency is res tric tec in its scope of involvenent. (]} Examples or personnel emergencies are: Hevision 2 Date: o/21/82 Page: 3-14

C' - Injuries recuiring rirst aid treatment oy trained plant g personnel or oy C-d's on-site medical f acility. Injuries recuiring transportation to o f f -s it e mecical facilities ror treatment. - Actual or possible internal exposure to racicactive .aaterials re cuiring healen physics evaluation and r o ll ow-up. External contamination re quiring cecontamination and assessment by Health Physics. Action This class or emergency is declared by the affected indivicual or nearoy personnel. (It coes not involve sounding of an alarm). An assessment of the situation is made by a representative of the Manufacturing or Laboratory Health ehysics stafr to determine whether meaical treatment and/or personnel decontamination is necessary. ilh en applicable, corrective actions will ce promotly taKen to preclude further injury to tne individual involved or nearby personnel. These corrective actions may incluces a) Shutting of f electrical power, to f aulty equionent. o) Isolation and containment of minor crocess leaks. ]/~ destricting personnel access to are'as of possiole high c) concentrations of airoorne radioactive material, c) Any otner action necessary to correct or miticate the situation at or near the source of the prcolem. Noraially, protective action other than. the possicle use of respiratory protec tion in the immediate area, is not reouired for a personnel emergency. Use of resoiratory protection is determined av a trainec i l member of the Aanufacturing or Laboratory or nealth Physics stafr. versonnel cecontamination will oe performec by or l uncer the supervision of a qualified Mealtn Physics l representative. 14otification of otr-site mecical : =cilities, if necessary, is made by the Emergency Jirectcr while transportation is proviced oy on-site security venicles. act!ricatien ot_"nusual svant ( :> > pescriction This class involves specific situations tnat can ce recognized as crea ting a hazard potential that was oreviously l no ne.< i s te n t or latent. The situation may not yet nave causeo camage to the facility or harm to personnel anc does not ] necessarily require an immeciate cnange in f acility operatinc status. Inherently, however, tnis is a situation in which sevision 2 Date 3/21/92 Page: 3-15

time is availaole to take precautionary and constructive (]) steps to prevent an accicent and to mitigate the consequences should it occur. An Emergency Alert situation may te the result of either manmade or natural phenomena and can reasonaoly be expectec to occur curing the life of the plant. Emergency Alert. conditions imply a racic transition to a state of readiness by the f acility personnel and oossioly oy off-site emergency support organizations, the possible cessation of certain routine functions or activities within the facility that are not immediately essential, and possible precautionary actions that a speciric situation may recuire. Examples of situations which fall in the emergency alert classification are: domo rhreats Civil Dis turbances Tornado Warning or Sighting Ear thcua ke fremor or aarning of Seismic Activity Forest Fire Threat or i4uclear Attack Although anyone can report a situation requiring an Emergency Alert, the Emergency Director is responsible for classifying and declar'ing the Emergency Alert. ao situation associatec with in-plant events involving radioactive materials has been () identiriec as celonging in tne Emergency Alert classification. j Ac-ion The responsipility for ceclaring an emergency alert rests with the Emergency Director. rhe general criteria for declaring an emeraency alert are as follows: 1) domo Threa ts 2) Actual or warning of impending civil aisturoance i J) Eartnquake tremor or warning or seismic activity 4) Forest rire warning or signting 3) Sighting or report of release of toxic or noxious gas nearby unich could affect the site o) Tornaco warning or sichting l 7) .iarning of possiole nuclear a ttack The daergency Director then assesses the situation anc makes a decision as to wne tner to evacuate to the E.nergency Control Center or dmergency Assemoly Areas, oy manually activating l the non-nuclear alarm, or to instruct oersonnel to remain insice plant buildings by tne emergency intercom anc paging system. At this time, the plant will be

securea, processes l

and equipment shut down, and utilities snut off as ceemed necessary oy tne Energency Director. Contact woulc be mace c). with ort-site agencies as necessary. ts 1 devision 2 Date: 3/21/82 Pace: 3-16 l

/ The emergency alert is terminatec oy the Emergency Director wnen the threatening. situation has passed. Alert (3) neserietion This class includes ace.idents within the manufacturing areas (Buildings 17 ano 21). or the Develop men t Laboratories (Building 6) requiring staff emercency organization resconse. The initial assessment of situations in this class should incicate that it is unlikely that otner facilities at tne dindsor site would be affected.

However, substantial-modification of plant operating status is a highly probable correc tive action if it has not already taken olace oy-auto:aatic protective systems.

This, class is associated witn-a judgement that tne emergency situation can ce correctec and con tro lled by the facility ' staff anc on-site emergency response teams. Protective evacuations or isolation of certain areas may ce necessary. This class or e:aergency can also reasonaoly oe expectec to occur curing the life of the plant. Accidents whicn rall into this class are those acc icen ts analyzec in the Environmental Impact Information as events p/ that are predic ted to have insuf ficient consecuences outsice s. the plant to warrant taking protective measures. Criteria for declaring plant emergencies is based on (1) the recognition of an immediate need to implement in-plant emergency.neasures to protect or provice aid to affectec persons in the f ac ility or to mitigate the consequences of damage to plant eouipmenti (2) a positive coservation that radiation monitors d, not indicate the possibility of a

a. d; (3) the recognition oy oersonnel in criticality accident the area involved that the situation is beyond their capabilit/ to resolve.

The non-nuclear alarm may oe sounced by any person cognizant of the situation. Declaring and classifying the emergency is the responsibility of tne 'nergency Director. d Examples of ac*,cr levels for plant emergencies are: '3?. or soill ( toxic or racioactive) 14ajor p o : 3 Fire (nc. c u,- 711able oy personnel in the immediate

vicinity, Explosion contained within ouilaing The daergency Director may request that o f f -s i te agencies wnica may oe required to respond to a

particular emergency assume an alert concition until the emergency is terminated. C>T For example, tne Mincsor Fire Depsctment would ce recuestec devision 2 Dates o/21/82 Page: J-17

f-to stand by in case of a fire that is not easily \\ extinguishaole. Action A plant emergency is declared by automatic or manual activation of the non-nuclear alarm by any personnel cognizant or the emergency situation. Upon soulding of the alarm, personnel immediately evacuate to the designatec emergency assembly areas. The following on-site emergency teams are then called upon as aooropriate by the Emergency Director First Aid Team Fire brigade Survey Team Security Facilities Engineering 6 Services (.4 a in t e nanc e ) The Emergency Di re c.to r, in accordance with emergency. procedures issues cirections for care of any injured personnel, comoating the specific preolem anc preventing unauthorized entry to the affected area. ne then Oetermines the need for additional assistance from ofr-site support groups and in i tia tes call-in (e.g., fire department) oy (~} ' telegnone. In addition, co.amunication for calling in outside assis tance consists or an independent hot line in tne l4ain s-Guard House to the Windsor Police Dispatcher. Use of respiratory protection is determinea by a trained member of the.4anuf acturing or Laboratory n. d. staff. Personnel aecontamination will be performed oy or uncer the supervision of a trained Health Physics respresentative, notiric ation of ^ and transportation to off-site medical facilities, if necessary, is also under the direction of the Emergency Director. A Health Physics representative will accompany potentially contaminated victims to any o f f -s i t e treatment racility. fhe aindsor Site Emergency droceaures contain instructions for the speciric emergency teams during tne emergency. Wnen tne emergency has been controlled, dealth Physics will survey tne arrected area and release it for clean-uo or return to normal operations. Sito tr+a 9mernency (d) Descriotion Emergency situations more severe than plant ener;encies are not expecteu to occur curing the life or the plant oecause of design features anc otner measures taken to guard against /~s their occurrence. f.evertneless, it is necessary and prudent k_) to make provisions f or a class that involves an uncontrollac nevisian 2 Date: a/21/92 Page 3-18

/~l release or radioactive materials into the C-E 41ndsor site \\~# environs, outside the duilding #17 manuracturing or Building

S laooratory areas.

An " uncontrolled release" is defined as any release of 25uci or greater of airborne radioactive particulates averaged over a 24-hour ceriod into the dincsor site environs. Notification af o f f -s i t e emarcancv oruanizations will ha maco for all sita emercancies. 75 a Stata or ConngtLLcut's Offica of Civil Pranarennass is the main o f * -s i n g_12anc y that will be antifiac. Thav hava acread to enordia n g_a,11 am e rc anc y rasconsa affer*s ro wirac hv narticinatinn a,varn-entn1 and local acancias as necassarv *, coom with env anarnancy involvinn off_ sit,

imnace, Protective actions include evacuation or personnel trom the affected building to the designated emergency assembly areas and/or warning of site employees to remain inside other site ouildings until the emergency condition is terminated.

These communications will be handled througn the emergency intercom and paging system. This system is activated by the Security Guard wnen the 3559 call (the dinasor Site Emergency Telephone dumber) is received, ihere are nine emergency telephones loca ted throughout the ~41ncsor site that can be activatea f rom a central con trol panel at the guardhouse oy the guard. The guarc will con tac t all nine of these locations by simply pre ssing one outton that keys in the energency intercom system. Picking up the hancset rings a ll (~)/ nine telephones simultaneously and a llows the guard to describe the emergency to all nine ceoole at the same time. This provides notification to key emergency personnel. One of these nine loca tions is the Vice President Nuclear Fuel (Emer gency Director). The Emergency Director is tnen aole to communicate with all of the other key emergency personnel at the same time via this conf erence call and recuest assistance from the appropriate services. The guarc also can contact the dindsor volice Disaatener via the eaergency not line in ne guarchouse. This is a cirect line to the aindsor Fire and Safety Complex where assistance from botn the rire and oolice depar tments of surrounding townships is ootainec. No dialing is needed oicking up the hanaset ac tiva tes the system anc outs the Quard in contact with the aindsor Police Dispatener. inese communications are on emergency power. Associacea assessment actions include radiological monitoring and provisions for monitoring tne environment. A site emercency is ceciered by (1) automatic sounding of the nuclear (criticality) alarm wnen levels exceed a mr/nr at tne criticality detector or (2) sounding of the non-nuclear alarm, initiated eutomatically or by any person cognizant or the emergency situation. (These alarms initiate i mmec ia t e f^) evacuation) or (3) a release averaged over a 24-hour perioc tnat is equal to or greater than 25 uCi of airecrne xevision 2 Date: 3/21/82 / ace: 3-19

racioactive particulates (determined oy analysis of stack O_/ samples). Declaring anc classif ying the emergency is tne s responsi'ility of tne Emergency Director. o Examples of site emergencies are: Confirmed criticality accident Ma.Jor fire or explosion wnicn is not easily controllable by on-site emergency response organizations Helease of 25 uCi of airborne radioactive carticulates into tne C-E Windsor site environs averaged over a 24-hr period. Two ammonia tangs locatec within the cuilding

17 fenced manuracturing area have oeen analyzed for all credible accidents.

A large ammonia release is considered to oe incredible based on the rollowing: All lines into the ammonia tanks are equipped with excess riow valves. These valves are protective devices that provide a means of protecting personnel and croperty from accidents caused by excessive ammonia loss cue to hose rupture or breakage of pipelines. Excess riow valves are designed to close at flows in excess of their normal ratec riows. Any rupture or break in a line that increases the riow aoove the racec flow rate of the valve will close the valve. These valves are also recessed witnin the ammonia O-tanks so that even if the line is sheared off at the

tank, une valve will still f orm a seal and stop the release.

Also, the tanks are design-tested at 325 psi (vapor pressure or und at 100 degrees F is 200 psi) and supported oy two solid concrete suoports (one at eacn end of the tank). These concrete supports have concave shaped tops so the tants rest within the supports. The tanks are also locatec within tne duilding al 7 controlleJ access area wnere tnere is minimal. ir any, trartic flow. Finally, the tanks are surroundec by a 12 foot high reinrorced cnain link fence. Action A site area emergency can ce initiated in several ways: a) Souncing or tne nuclear alarm (continuously souncing norn), automatically sounded when levels of a cr/hr or greater are present at tne criticality cetector. o) Sounding of the non-nuclear alarm ( con t inuous ly rincing ce ll), automatically sounded or sounced by any oersonnel cognizant of an actual or imoendinc emergency tnat may nave impact outside or Juilding #17 or duilcing #5. c) Je tec tion of an airoorne radioactive particulate release (_ or 2cuCi or creater averaged over a 24-hour cericd.

l 1

nevision 2 Dates c/21/82 dage: 3-20

qk/ Examples of site area emergencies are: Criticality accident Major fire or explosion delease of 25uCi or greater or airoorne r ac ioac tive particulates into C-E Windsor site environs averaged over. a 24-hour period. The non-nuclear alarm is usually sounaec to cesignate a plant emergency. At the discretion of the Emergency

Director, a

site emergency may be declared. At this time, personnel are ins truc ted to further evacuate to the designated emergency assembly areas. The emercency actions are then directec and any necessary of f-site notifications made f rom the Emergency Control Center. In the case of activation of the nuclear alarm, all personnel evacuate immedia tely to the designated Emergency Assembly Areas. Upon assemoly at the buildings, supervisors cetermine that all personnel under their cognizance have been evacuated and are accounted tor, including their visitors and outside 5 contractors. rhose present in the assembly area are que s tionec to d e t e r.aine ir any unusual occurrences were coservec anc a survey team, consisting of at least two persons knowledaeable O' in tne use of ractological survey instruments, are instructed to prepare for re-entry. The Emergency Procecures laanual contains appropriate instructions anc criteria for re-entry. First aic is provided for any indivicuals injured during tne evacuation and all identification bacges are checked for indium f oil activa tion. When tne report or the re-entry team is

receivec, the in cid en t is considered confirmed if radiation levels in excess or o ar/nr are encountered anc indium rails on TLD area Josime ters are activated.

At this point, a Health Physics representative is dispatened 4 to the site councary downwind of the olant to monitor tne exposure rate. fhe maximum off-site thyroid dose is es timatec rrom these readings as specified in tne detailed procedures. The Emergency Direc tor assures that the following actions are initiatec: aJ Arrange ror trea tment of injured or exposed personnel, b) Arrange for decontamination of cersonnel, c) Determine radiation level in assemoly area and relocate O-personnel if necessary. c) Collect TLD cacges and record indium foil reacings. kevision 2 Cates o/21 /82 dage: 3-21

i (3 e) Start action to obtain assistance ir necessary from: .dindsor anc State Police Departments. \\_) St. Francis Hospital C-E Management State of Connecticut, Office of Civil Preparedness f) Direct survey team to estaolisn 100 mr/hr coundary line. g) dased on inf orma tion f rom survey team, initiate action to shut down the plant. h) Obtain other assistance and make notifications of other off-site agencies as necessary. Exposures during subsequent re-entry operations will be limited. Spec if ic instructions, based on actual equioment or process involved, will be issued to minimize tne po ss ibili ty of causing adaitional criticality excursions. Allowed exposure for any individual will be kept as low as reasonaoly achievable. However, doses in excess of tne legal limits are permissible in emergency situations during or imiaediately af ter an accident. l'h e justification for this is the rescue or individuals, tne prevention of exposure of a large numoer of

people, or the savings of a

valuable installation. In an emergency where life saving actions are neeaed, the guidelines listed below will be followea: 1) descue personnel will be informed of the risks involved before they accept such exposures. j 2) Permissible dose to the whole oody will not exceec 100 rems. 3) Other ractors ceing equal, volunteers over tne age or 45 will oe selected. The emergency actions requiring less urg ent

resoonse, tne permissible whole cody cose will not exceec 25 reas.

Time -o f -s tay during re-entry shall ce limited. Sucn time-of-stay will commence uoon penetrating beyond tne 100 mr/hr coundary and terminatec uoon recrossing it while exiting. tio personnel are a llowed to re-enter the arrectec plant area unless autnorized by tne Eaergency Director. Prior to start-up af ter a site emergency, the plant will ce returneo to a safe condition. Spills will be cleaned up and no radiation levels in excess of normal operating levels as specified in tne Su 4-1007 license will ce present. Radiological and nonraciological monitoring will ce concuctaa as appropriate f or a noncriticality site emergency. O V devision 2 Date: 5/21/S2 Page: 3-22

General Meercencv Accidents that aave the po tential for serious radiological consequences to the puolic health anc safety have been analyzed previously and were not found to be crecible for tne C-E OFM-dindsor rac ility i reference paragrapn 3.1. 3.3 Hange of Postulated =ad;idents hgetron nr Po s t u l a t e<1_icid e n t s The emergency planning for tne rance of postulatec accicents are covereo in Section 3.2. Utt-site impact of the spectrum of accidents discussed in the Environmental Impact Inrormation is shown in the following taole: incident Classification Off-Sita ! 221C1 Injurea Employee Hotification of hone Unusual Event Contaminatec notification of None Employee Unusual Ev en t Process Leak Alert done fs(,) or Spill Fire Atert none .delease or 2cuCi Site Area <ou of ave for or Airoorne Emergency insoluole U235 Hacioac tive at site councary. Particulates into C-d Site environs Criticality Site Area ,1 hole cody Jose 1.184 HAD Accident dmergency ihyroid Jos e 2.93 DAD Emergency Alert General daergency aone ( o f f -s i te imoact from rron General Emergencies which are reclassifisc into Alert or Site Area Emergencies are descri'ec ecove). n O nevision 2 Date: o/21/S2 vage: 3-23

O( / 4.0 ornanization ror Control of Had io loci c a l Cnntiacencies 4.1 agr~al Plant Ormanizatica The Vice President, auclear Power Systems is respcnsible for all activities carried out in both auclear Fuel Manufacturing and the Development Department Lacor atories. He has delegated the responsibility for all activ. ties carriec out uncer License Saa-10c7 to the Vice President, auclear Fuel. 4.1 I lieve lon aen t G eo a r tm a,,at (Nucleer L c o r e t n r l e s,1 i The Vice Presicent, Develocment, is responsicle through the Vice Presicent,

Products, Services anc Development to tne Vice Presicent,

.luclear Power Systems for the

quantity, accountability, nuclear safety, and radiological safety relatec to all Special suclear and Source Materials received by the Development Laboratories and used in any development process.

He assures como11ance with feceral and state regulations and the requirements and limitations set forth in the license during all operations of the laboratories. In this position, the Vice Presiden t-NPS Develooment rg Department nas delecated to the

Manager, Health

(,/ Physics, responsioility to assure that all operations involving nuclear materials have oeen analyzec to estaolish the required sarety limits and controls. In aodition to providing the above safety restrictions, the

Manager, health Physics is responsible for the surveillance of all touclear Laboratory ac tivities in which radioactivity is involved to ensure that the nealth and safety stancards set rorth in the license acplication are met.

He has the necessary authority to halt any operation wnica rails outsice those limits, anc ne is responsible f or indicating wha t remecial action is necessary to bring the operation within acceptacle limits. The basic organization structure for the auclear Laboratories is shown in Figure 4-1. 4.l.2 uneienr Ruet unuricturiac-vncser The General Manager reports to th e Vice President, auclear Fuel ano is resconsible for the acc oun tac ili ty, nuclear criticality safety anc raciolacical safety related to all Scecial uuclear anc Source Material received by the Nuclear Fuel Manuracturing facility and usec in any manufacturinc process. He assures compliance with federal anc state ( regulations and the recuirements and limitations set devision 2 Date: S/21/S2 dage: 4-1

rorth in the license during all phases of 73 (_) manufacturing. In this position, the General Manager has delegated to the Produc tic. Superintendent and the Engin ee ring Manager responsibility to assure that all operations involving nuclear materials have been analyzec to estaolish the required safety limits and controls. The Manager, NLS&A or .1uclear Licensing Consultant shall assist the Engineering Manager and Production Superintendent by actually cerforming 'the analysis required and establishing the aporopriate controls. In addition, the Supervisor, Health Physics and Safety shall assure that tne required safety limits and controls are being followed by the use of daily internal audits. The dealth Physics and Safety Supervisor is responsible for the surveillance of all nuclear Fuel Manufacturing activities in wnich radioactivity is involved to ensure tnat the health and safety, as well as criticality s tandards se t forth in the license, are met. he nas tne necessary authority to nalt any operation which falls outside those

limits, anc is responsible for inoicating what remecial action is necessary to bring tne operation within acceptable limits.

However, if the operation is halted because fs t of criticality safety considerations, the Health Physics a Safety Supervisor will contact the .aanager, aLSsA or the nuclear Safety Co mmi tt ee wno shall determine necessary corrective actions to be ta ken. 1~ne basic organizational structure for duclear Fuel Manufacturing is shown in Figure 4-2. 4.1.J drarcency Procaduras The lice Presicent, Nuclear Power Systems has delegated the overall responsioility, in the event of an emergency involving areas covered oy License Sa M -l u o '/, to the /. P. Nuclear Fuel and has autnorized hita to function as the Emergency Director for the auclear Fuel Manuf acturing f acility as well as the Development De pa r tmen t Laboratories. (S ee Figure 4-Ja). During the day shif t, in his absence, he nas delegated this resconsioility to the General Manacer auclear fuel.4anuracturing for emergencies occurring in the ruel manuracturing facility and to the Manager, Health Physics for emeroencies occurring in the Development Department Labs. Alternates are shown in Figure 4-3b. Un evening and nicht

shifts, tne responsiollity is delegated to the snitt foreman.

The V ice Pr es icent, Develooment is resconsicle through g-) (_ tne Vice President, Products, Services s Develcoment devision 2 Date: n/21/02 Page: 4-2

r-to the Vice Presicent, duclear Power Systems for the (g Development Laboratories. He has celegated safety anc / emergency response to the Manager of Health Physics anc has directed him to report directly to the Vice Pre.siaent-ieuclear Fuel for all emergencies involving areas covered by License SNM-10o7 Trained Fire Brigade memoers, First Aic Team

4emoers anc health Physics Technicians are present on site for eacn produc tion shif t.

A telechone c a ll-in list is usec by security on weekends and nolidays to obtain emergency organization personnel as required in the event of an emergency situation. It management personnel are recalled to tne site during an emergency, the highest ranking person assumes control of his emergency runction. 4.2 On -S i e waa t ol ra ic a l continc acv Jgscense At such time as the Emergency Plan is out into

effect, all aspects or the emergency situation will ce coordinated by the Emergency Director, althougn requests for on-s i t e emergency response organizations will ce made within the scope of the emergency organization.

(See Figure 4-3c). 4. 2.1 Direction and Cecrdination () Cnercency Oirectan a) Activate Emergency Control Center at duilding

c, or establish an alternate control coint from which activities can ce cirected.

o) Determine status ano necessity for snutcown of plant systems. c) Direct, coorcinate, and evaluate actions to ce taken by functioning emergency

teams, inclucina rescue and re-entry operations.

c) Es taclish contact and communications with tne ,iindsor Site Direc tor of Emergency Services for possible activation of acoltional on-site emergency response teams. e) Collect anc organize information pertaining to tne energency ror acproval oy management anc c ommun ica te to the C-E Puolic delations Officer. r) Direct perrormance of preoarecnes3 functions (i.e., crills, training, exercises, etc.), (n-) 1 nevision 2 Dates c/21/82 vage 4-3

() 4.2.2 slant Staf* qadiclocical contingancv Acelenmants tiuc lea r Lic esinc. 9daty 4 Accountanility vanacar a) Emergency planning and coordination, updating and rev is ing of plan and procedures, and proper distribution thereof. insoections, servicing or b) Emergency supplies obtaining servicing and orocurement of emergency equipment and suoplies. c) Direc t.aanuf ac turing Health Physics s taf f in tneir a ssigned emergency f unctions. Fact Finding '2n-mittae

4emoers to serve on this committee will be selected by the Emergency Director depending on tne nature of the emergency.

rhe Chairman of the Committee snall ce an individual who is not a memoer of the immediate response teams. The Committee shall: a) Connunicate with the Emergency Director and others to oo tain f acts for determining the cause and etrect or the emergency. v b) Interview personnel who witnessec the incident or those who can contricute inrormation leading to cause and efrect. c) Heview and examine a ll evidences (anotographs, recoveraole materials, etc.) that may oe considered pertinent and informative for evaluation purposes. c) Keeo records and prepare a written recort for C-E management. i R ac i ol c a ic a l Safety Ad vi so r a) Accumulate anc evaluate known raciological cata to ce termine tne exten t of the emergency. c) Establisn a liaison cetween tne Emergency Director anc direct source of availaole information. c) bstablish policies with tne Energency Jirector regarcing tne emergency plan or action for controlling the incicent. c) Collect inf ormation pertaining to the emergency () for the Director to disseminate to tne C-E euclic hevision 2 Date: 5/21/d2 dage: 4-4

delations Officer. e) Maintain a close liaison with the Emergency Direc tor regarding emergency activity progress. r) Inform and consult witn the Fact Finding Co mmi t t ee. Sooervisors a) Each supervisor is responsible for proper implementation of the Emergency Plan, c) Assure that personnel under his supervision are ramiliar with the location and use of emergency equipment. c) Assure personnel familiarization with the Emergency Plan and Procedures. d) Account for their personnel during an emergency, including visitors and contractor personnel in I their area. e) Prepare Supervisor's Report of Injury of Personnel under his supervision. () t.ia nur ac tu ri nc s Labor,no-v Wealth Physics staff The health physics staff consists of health physics personnel from coth manufacturing anc the laooratories. These personnel are resconsible for their respective facilities, under the cirection of the Emergency Director, because or their familiarity with their own f ac ilities. However, they will assist eacn other as needed in the time of an emergency upon i request of the Energency Director, a) Shall assess and delineate an emeroency radiation or toxic fume, vapor, or mist condition, including j radiological survey monitoring. I r c) Frovide personnel moni to ring, recover accicent dosime try f or analysis, and collec t health anysics or inuustrial nygiene samples for analysis. c) Conduc t environmen tal monitoring. d) Assis t with f irst aid and emerg ency rescue. l e) Procure, store and issue protective clothing anc equioment for recovery operations, t) Yrepare necessary recoros ana reports. l devision 2 Date: 5/21/d2 eage: 4-5 l

() g) Direct cecontamination or p erso nne l. an /or equipment. Site Sacurity Officar a) Direct and coorcinate security guarc activities. b) Hestrict access to the site to autnorized personnel and outside succorting services. c) Coordinate activities with state and local police. Fire Marshal a) Coorcinate the f ire-f iahting activities of tne site fire origade with local fire cepart.nent. c) Organize site fire brigades, c) Assure that personnel have been tr11nec in fire-fignting technicues in vo lv i., racioactive materials, as well as fire-fignting.. Nautions to be taken in criticality areas. Securinv Guaros O) \\_ a) erovide trafric control and c ommun ica t ion with outsice supporting services. b) be ramiliar with special guard orders for all emergency occurrences, whicn include maintaining plant security and access control. 'ncineerin, s Services (aaintenance) Facilities 4 a)

<aintain or discontinue as necessary, utility services during the emergency.

b) Provice, faoricate or mocity equipment neecea for recovery operations. I l c) erovide e cuipmen t and personnel ror

recovery, repair and salvage operations.

c.iec i c a l D a r e r t,a a t a) Provice assistance in the cecontamination ano medical treatment of cersonnel, o) Coorcinate and supervise medical activities. c) Prepare medical recoros and reports. p), \\_ devision 2 Dates c/21/82 vage: 4-o

fj) All Personnel s_ a) be familiar with coth the nuclear and non-nuclear alarms. b) Know evacuation routes and respective emergency assemoly areas. 4.2.2.1 PI'nt sta?? co m,on i c a t i en chaie Notification of <ev Parsonnel A) Norma! dorvinc unors (7:10 Aa-arlo uv) 1) Key b5bo, give dame, Descrice fype anc Location of Emergency, Heques t Serv ices or personnel needed, anc receat. The S556 call is receivec cy tne Security Guard (East Guard House). 2) Depending on the emergency, tne gua rd will taxe one or more of tne rollowing actions: a) Emergencies in cuilding #6: Call one of the following in the order listed: g-) V Jim Limbert (Radiological Engineer) Ext. 2145 T. Moreau (H.P. Technician) Ext. 2896 W. B. Clark (H.P. Technician) Ex t. 5600 P. H. Hosenthal (Agr. Health Pnysics) Ext. 336s Emor encias in Softdin- *17 or 491: H. E. Sheeran (H.P. Supervisor) Ext. 5675 J. Vo11aro (H.P. Technician) Ext. 5o84 F.J. Pianki (Veneral aanager) Ext. 2393 c) Call speciric emergency response teams needed - First Aid (l4ec ical ) . ire brigade. Ext. 4402. dxt. 3338, c) Activate the Emergency Intercom System. Teleonones are installed in eleven locations where key personnel can be notified (Table 4-1), de will contact all of these locations at one time by keying in tne intercom button and Station ding for tour seconcs.

Then, cicking uo the

handset, he cescrioes the tyce anc location or tne emergency.

fhese key persornel (~S x/ will respond as neeced or recuested devision 2 Date: 3/21/92 Pace: 4-7

depencing on the emergency. d) Fv ninc 4 Nicht 9hirts (weildi-, dI 7 and 12 L1 1) dealth Physics Technician and Shift Foreman are located in duilcing

17 (Health Physics Ext. 5o84 or Foreman Ext.

3574) and snould be notified immediately of any emergency situation. 2) The f ore:aan than makes the 5555 ca ll to initiate the site call in list (Procedure 2.2) and to recues t outsice assistance as necessary (i.e.,

Fire, Police or Ambulance).

3) It re que s ted, the guard can notify the dindsor Fire & Sarety Comolex via the Emergency dot Line. 4) Site Security Vehicles and/or amoulances are available to transport injured to St. Francis Hospital. Buildinc

S

- The guard will initiate the site call-in list at anytime other tnan () normal working hours. C) Maekends and "clidazi I) Guarcs are on cuty 24-hours a cay. The 5Doo call may be mace at any time for assistance. 2) dhen the nuclear or non-nuclear alarm is activated in a vacant ouilcing, it wi ll activate a light on the Panalarm Annunciator Panel in the East Guarchouse l. or may De heard oy the guard curing routine surveillance of the site buildings. 3) CAUTI0d If tne auclear Alarm (continuous horn) is

nearc, do not a ttempt to enter the ouilding.

4) HEPCHT rdE SITUATI0ri I.c;EDI ATELY to tne l Guarchouse. Descrite tne alarm (nuclear or non-nuc lea r ) and tne builcinq affecte3. l 5) The guard at the East Guaranouse notitisc r~) (j oy either the Annunciator Panel or another guarc, initiates the site call-in nevision 2 Date: D/21/82 vage: 4-8 l

list (Procedure 2.2). V( g D) Site ca l l-i n List (Ourin~ S e cu tea uco-s) Emercencies in Builcinc 49 I) The guard will call one of the following in the order listec and inform them of the location and type of emergency: J. Limoert (Haciological dngineer) 1-413-786-3028 T. t,ioreau (n.d. Technician) 1-o53-4731 8. d. Clark (n.d.fechnician) 1-372-7d33 ?. d. dosenthal (.Agr. Health rhysics) 1-388-3020 2) The guarc will await further instructions. 3) If the situation warrants. the person notif ied should contact the Emergency Director (1-o58-4245 or alternate 1-388-3020). E) Durine Agekends and Ho l id avs (4r coctinn Not Oceratine) rx Emernencies in ruildinc d17 or *01 () 1) Call one of the f ollowing in the order listed and inform them of the location and type of emergency: H. E. Sheeran, d. P. Supervisor 1-233-0459 A. F. Joseph, Sr. H.P. re chnici an 1 -c2 3-3 79 5 or I-c23-9242 J.J. Vo 11 a ro, S r. d. /. Technician 1-o43-9o77 i d. Kula, h.v. Technician 1-749-0243 n. n. Locoy Jr., n.d. Technician 1-o23-2334 F. J. Pian 41. General i.ianager 1 -c51 -5J 7 o 2) The guard will await rurther l instructions. r 1 J) It tne situation

warrants, tne person notified shoulc contact tne dmergency i

Director ( 1 -o5 8 -4 24 b ) or alternate I (1-o51-d090). l l F) 12;11dena! Assistnace (:4cn fe71ai n M I Emercencies) l (")g guildia, er l \\_ 1 l i aevision 2 Date: c/21/d2 vage: 4-9 l 'l

n. F. Hill ( 4gr. Lab Services) 1-658-7906

((m, / L.

d. Megow (Lac Supervisor) 1-529-74o8 A. a. Viets (Lac Supervisor) 1-o58-7713 a.

P. Wytenus (Lab Supervisor) 1-o23-0194 D. C. boyle (Senior Lab rechnician) 1-413-569-5721 soilcin, 417 P. Arnold (Grid Area Foreman) 1-044-1943 U. Bucdenhagen (Pellet Shop Foreman) 1 -741 -0156 D. dyerly ( Pe lle t Shop Foreman) 1-o88-9382

d. dard (Sr. Foreman - Pellet Shop) 1-o53-2831

4. Felber (Aachine Shop Foreman) 1-875-0591

.<. Gonsorowski, (Suilding v21 Foreman) 1-749-o003 G) Manacomant Notification Buildinc d6 P. d. dosenthal (Mgr. Health Physics) 1-388-3620 d. J. Selig (Dir. Eng dev & Services) 1-233-5845 n.V. Lientenberger (V.P.auclear Fuel) 1-o58-4245 4.3 Off-Mit Assistqnce to Cec i l i ty Local Servicas Sonnert O k/ Agreements have been reached with various private and civil organizations to provide assistance as requirec. St. Crancis Hosnit=1 has agreed to accept victims of accidents having injuries possibly complicated by racioactive contamination. St. Francis Hospital has a procedure for hanoling patients who are contaminated with radioactive materials. The victim is brought to a cesignated section of the emergency room where trained hospital personnel will care for the victim with monitoring assistance from C-E Health Physics personnel. The connec ticut State Polica and the local Mindser solica Decartment have agreed to provice assistance to C-E elindsor in an emergency. fhis assistance includes coordination with otner civil autnorities as necessary, traffic

control, and control or civil disturbances.

Ihe Windsor. vii ls;n and do cuanoc k cira nacartmaats resoono to emergency calls at C-E teFM-Windsor. If the response is for a fire involving radioactive material, Nuclear Licensing anc Safety will provide monitoring as necessary to protect fire department personnel. Transportation of injured personnel to of t-site treatment (~% facilities is accomolisnec using site security venicles. No (_/ f ormal agreement exists for outside provision or ambulance .<evision 2 Dates c/21/S2 Page: 4-10

rT services. V 4.4 Cecedination with Particisatine Government Acencies l As previously s ta ted, analysis of the postulated C-E HFIA-dindsor accident spectrum shows thac there is no credible accident with significant off-site consequences. A list,of cognizant government agencies and current telephone numbers is maintained, however, and they will be contactec should an emergency arise involv ing a consideration within their jurisciction. The con tact would be in the form of notif ication, although a request for emergency assistance would be made as neeced. These agencies incluces Connec ticut Sta te Police, Ha rtf ord, CT DOE Hadiological Assistance Team, Brookhaven

Office, Upton, dY State or Connecticut, Office of Civil Preparedness, Hartford, CT (OCP has agreed to coorainate the ef forts of off-site agencies as necessary to cope w f,th any emergency involving oft-site impact).

USWRC, Region I,. King of Prussia, PA will be notified in tne (} event of a site emergency. The above agencies are listeo, with their area of

interest, in the Emergency Procedures l4anual.

In the event of a plant emergency, only local agencies woulc 'e contacted (as o discussec in Section 4.3). In the event of a site emergency, i all the agencies would be contacted. l n\\+/ devision 2 Date: 5/21/82 dage: 4-il

CAMLF 4-1 K FY ?FRSour1FL 0:4 CM C400:40Y f ra FFHCO:.t S Y S T F'.1 normal Office nome Locntien agcg Talachone avt. Tolanhene 1 Communication East Guaro house Dispatener 45o1 Cen te r 2. Guarc ,les t Guard House Uuard Supervisor 2263 Supervisor 3. Aedical Bldg. #19E Dr. E. F. Murphy 3338 1-683-1914 4 .4uc. Sidg. #5 T. B. Bowie 5574 1-521-4004 Accountaoility o. r ac. Eng. s Bldg. #6A A. M. Clarey 4402 1-529-o243 Services G. E. Cody 4401 1-684-7906 o. V.P. auclear Slag. so H. V. Lichtenberger 3385 1-o58-4245 Fuel ( Emergency Jirector) /. General.4gr. dlag. #17 F. J. Pianki 2898 l-o51-8070 Fuel (dmergency / Director - Alt) d. Industrial dicg. #4 Susan Walker 4170 1-o53-651o dygiene ). Acministrative dicg. 419d D. J. Sridges 3327 1-688-1587 Services a H. D. Brosman 2243 1-289-2042 Security

10. auclear didg. #1/

d. E. Sheeran 5075 1-233-0437 Licensing 6 Sarety 11 A.anager, health Bldg. #9 F. H. Hosentnal 330o 1-383-3o20 enysics (dmergency Jirector - Alt.) 3 )( 1 devision 2 Date: n/21/82 vage 4-12

Eigure 4_; ( I auclear Power 1 l Systems Division I l _ _ __ ________l l Vice President i i l I i Products, Servicesi I and Development l l___________________l l Vice President I i i l I I i Uevelopment l l___________________l l Vice President I i i l I I (:) l l l l l l Fuels l IAaterials andi i ! Engin ee ring I l Product i I Development i I Chemistry I I IDevelopment si IEngineering al I i i I i i Services i I Development l l________-- l l_____________l l l_____________l l_____________l I director I i Director I I i Director i I Director I i i i i l I i l I I i i i i i I l I outsice Funcec d&DI I C-E/K.1U i i

Manager, I

I anc CE/Knu.11nasori l Erlangen I l nealth vnysics I l___________________l l___________________l l___________________l l l l l 1 l l I I I I I I i l l O I I l Hevision 2 Date: 5/21/92 Page: 4-13 1

Elgure 4-2 I i4UCLEAH P0.1Ed i I SYSTEMS DI /ISION I I I i Vice President i I .I I I I i 140 CLEAR I I I SAFETY I I I C0x41TTEE I l__ l i I NUCLEAR FUEL i l i I Vice President i I i i i1UCLEAR MATERIALS I I I & SECURITY I I I I I I Manager i I I I i i4UCLEAH FUEL i 1 MANUFACTUdING I I I I General Manager i Ci i I I I I I I I I I .I I I I I I I I I l.aVCLEAH I I I I I I I I P 40D0Cfl0N I I L I CEi4S Ii4G, I I I I di4GI.i EER ING l IPRODUCTIO.4 I la MATERIAL 1 i SAFETY d. I I .iUCLEAR I I i i i i C044THO L l i ACCOUNT-1 I LICEi4 SING I I I I I I I I ABILITY I I I I I I Super-1 I I I I I I I iaan ager i i intendent i I Manager I I Aanager i ICOnsultant i I I I I I I I I l_ l I l . I __ __I I iSUCLEAd i4AfERIAL i I HEAliH ?HISICS I I ACCOU.4rAdILITY l I s S AFErY I I I I l l Supervisor i i Supervisor I I I I I l l O nevision 2 Datas 5/21/82 vage: 4-14

C-E ORGAf4I4ATION I /. P. huclear I i Power Systems 1 I I I I I I I I I V.P. Produc ts, I I V.P. iiuclear Fuel i I Services and l I (Emergency i I Development 1 I Director) l I I I I I I I I I V. P. De velopraen t i l i I I I I I I I I I I Director i i General Manager I I l Development i I Fuel Fabrication I l l Dept. I I I I I I I I i l I Aanager riealtn 1 I Physics I -I FIGUd5 4-3a O Er.tEHGE.4CY DIRECTod & ALTEdNATES I V.P. .4uclear Fuel i Development dept. I I Fuel..;anuracturing Laos l I Facility i I I I I I i aanager dealth i I General tanager i I dhysics I i Fuel Facrication I l__ l i I I I I l i I vrocuction I I l Superintencent i I daciological i I I I Engineer I i l I I i i Shirt Foremen i I I 2nd & 3rd Shifts i I I I I l l l_ I felepnone Call-in i i Telephone Call-in i Os i List (Arter hours)I I List (weekends & I I I i holidays) i I I I I FIGUdE 4-3b devision 2 Date: o/21/d2 ? age: 4-15

Q g1RE4-3C LICEtlSE SilM-106r EMERGEtlCY ORGAtlIZATI0ff Emergency Director V. P. fluclear Fuel Alt. As Designated in Figure 81.1} b Site Security Fire Marshal Accounting Site Security Mgr. Facilities for Officer Eng.& Services Fact Finding Personnel l or Sr. Rep. Conuni ttee Security Guards Supervisors Appointed by Appointed by Facilities Emergency Site Security Off. Eng. & Services Director (continuous coverage) Mgr.-Fac. Eng. Manufacturing & Laboratory & Services or llealth Physics Staff Senior Rep. Radiological flLS&A Manager (!!fg. Also acts as emergency planning Safety coordinator) Fire Advisor Mfg. llealth Physics (Labs) Brigade Days - Radiation Spec. Alt. - Senior H.P. Techs . l Trained Members of Alt. - Radiological Engineer I Survey First Aid Fac.Eng.& Serv. Dept. (Developnent Dept.) Team Team l flights - II.P. Techs. Maintenance Appointed by ll.P. Technicians Personnel (2nd & 3rd shifts) li.P. Sup. (Mfg) CE fiedical Dept. Mgr.11. P. (Labs) Appointed by Mgr.of Fac.Eng.& Serv. Dept. Revision: 0 Figure 4-3C

STATE OF CONNECTIC ET CEPART'.DT OF PUELIC 3AFITY O. CGNECTICUT STATE FCL:CI ~ l March 16, 1982 Mr. R. E. Sheeran Supervisor, Health Physics & Safety C-E Power Systems 1000 Prospect Hill Road Windsor, CT 06095

Dear Mr. Sheeran:

This is in response to your letter of February 19, 1982. In the event of a nuclear or non-nuclear emergency at Combustion Engineering, Inc., Windsor, the Connecticut j State Police Department will assist and cooperate with the local police to the fullest extent possible. Assistance will be rendered in compliance with plans being formulated by the State Office of Civil Preparedness. (V3 Similar plans for other nuclear facilities withing the State provide for traffic control, evacuation and controlling of access to affected areas. Sincerely, h Lt. Colonel John A. Mulligan EXECUTIVE OFFICER CONNECTICUT STATE POLICE l l t 1 l O i Phone i .:

ashington Street - P.O. 2cx 730. ".2rticr. C 2 3 - -

An Ec'd Cp;c:w:ird =~r~

@E o Departrnent of Energy Brockhaven Area Office Uptenc New York 11973 February 22, 1982 R. E. Sheeran, Superintendent Health Physics and Safety C. E. Power Systems Combustion Engineering Corp. 1000 Prospect Hill Road Windsor, CT 06095

Dear Mr. Sheeran:

SUBJECT:

RADIOLOGICAL ASSISTANCE Since your nuclear facility is located in Region I, the Brookhaven Area Of fice is charged with the responsibility for providing radiological assistance in the event of an emergency. Such assistance can be requested at all times by calling 516-282-2200 and asking for radiological assis-tance, indicating the nature of the incident, the location, and how to contact authorities to coordinate our response. The Department of Energy (DOE) will respond to requests for radio-logical assistance f rom licensees, Federal, State, and local agencies, private organizations, or individuals involved in or cognizant of an inc ident believed to involve source, by-product, or special nuclear materials as defined by the Atomic Energy Act of 1954, as amended, or other ionizing radiation sources. Unless the DOE or a DOE contractor is responsible for the activity, ionizing radiation source, or radioactive material involved in an inci-dent, DOE radiological assistance will be limited to advice and emergency action essential for the control of the immediate hazards to health and safety. Radiological emergency assistance will be terminated as soon as the emergency situation is under control. Therefore, responsibility for l po s t-inc iden t recovery, including further action for the protection of individuals and the public health and saf ety, should be assumed by the appropriate responsible Federal, State or local government, or private authority as soon as the emergency conditions are stabilized. If you have any further questions or desire further information, feel free to contact me. Sincerely, p ,/{l,~;(' 7 k...: I a David Schweller Area Manager cc: L. J. Deal L. Cohen

.47 .-... A:... )* . :'. L.! O w$1L. town ofwihos'or MN050M CONN 06095

PHONf(NJ) 688 3675
Tkf!!RST TOWN IN Tkf staff
COUNCIL-MANAGER Govf4NMENT December 3, 1981 Mr. Robert Sheeran Supervisor of Health, Physics & Safety Nuclear Fuel Manufacturing - Windsor 1000 Prospect Hill Road Windsor, CT 06095

Dear Mr. Sheeran:

This letter serves as an acknowledgement of our intent to make available services of the Windsor Police Department to Combustion Engineering's Windsor site in the event of a nuclear or non-O' nuclear emergency. Services which would be pro-vided, within out ability, include but are not limited to the following: Preventing unauthorized entry into the emergency area. Notification of ambulance services to St. Francis Hospital for victims having injuries possibly complicated by radio-active contamination. Assisting in traffic control and communi-cations. Sincerely, g s M4 s,y m Maxie L. Patterson Chief of Police sk O

faint [rancis %cspital anh [thical @snter n 114 Joahlanh Street krifath, @annecticut 06105 re w e e une de som oppics or Tus sxacutiva ciascTom February 19, 1982 R. E. Sheeran, Supervisor Health, Physics and Safet.7 Combustion Engineering, Inc. 1000 Prospect Hill Road Windsor, CT 06095

Dear Mr. Sheeran:

D) We have continued to maintain our capacity and interest in ( receiving and treating patients with radicactive contamination and medical-surgical problems. This, of course, includes those frem Cembustion Engineering, Inc. should the need arise. We have available a locker and cabinet centaining supplies and equipment dedicated to this need. We have develeped and practice protocols for this service and conduct at least one formal drill per year. We stand ready, therefore, to meet your needs in this direction and others as they may develop. Sincerely, c&_I CuCu h&4q ' )I[sterFrancisMarie Executive Director SFM:jth cc: Mary Ellen Doyle Thomas Horrigan, M.D. nU

rt N ,v6 4 town ofwhms'or WINDSCR. CONN 06t25tf

PWON!Nt31) 6MM75
TNT //ASTTOWNIN TNf $747f e CCynt*/l MANAGER GovfRNMENT February 24, 1982

!!r. R.E. Shu,u.1 Nuclear Fuel Manufacturing Canbustion Engineering 1000 Prospect Hill Road Windsor, Connecticut 06095 Dear Mr. Shau aw In response to your request for a letter of argreement fran the Windsor Fire Ccmpanies we have stated our position with regards to fires or energencies at your facility. As to radioactive materials incidents: 'The Fire Canpanies of the Town of Windsor will respond to incidents of this nature and l in conjunction with the staff of your office and Canbustion Engineering will be available to assist in safely resolving the incident to the extent our resources allow. The Poquonock Fire Canpany is the first due Canpany to your facility and would be the in-charge Canpany at any alann." It is our sincere hope that this will satisfy your needs. We look forxard to working with you in the future. Sincerely, h:pr!ClG ! Raymond A. Walker, Jr. Fire liarshal \\ n Edward K. Endee, Chief (/ Poqucnock Fire Carpany knc l

o.0 saciolo,ical contingancy

te a s ungs D.I Activation er J M olecical caariacancy wasnnnsa Orm an unh 3.1.1 Hacortinc_1ha Emermancy Any person cognizant or an emergency situation should initiate assistance oys 1)

Use of the nearest telephones Key 5555 - Pause and listen ror a response from the East Guardnouse, i40TE : In an energency re qu iring evacuation, the telepnone in the Emergency Control Center (duilding~ do) may be used to obtain assis tance. 2) Heport the emergency, speaking slowly and clearly, stating a)

1ame b) uature of the emergency (Fire, Explosion, etc.)

c) Location (Area and duilding #) d) Hequest any services or personnel neeced e) depeat information O o.l.2 dersonnal Cmarcancy An emergency wnich involves treatment of one or more incivicuals, nas no att ec t on the

facility, anc no potential for escalation to more severe, emergency conditions.

(It does not involve sounding of an alarm). draccigs: Any serious

injury, contamination, or radiation exoosure.

initiated dra The attectec incivicual or nearoy suoervisory personnel, iC.lic.C : 1) neport the incicent to the foreman or suoervisor i mmed ia te ly. 2) The toreman or supervisor will ca ll Ext. 5555 and request on-site medical assistance it necessary. 3) The toreman will call Ext. 5o84 (Arg. health Physics) for duildings all anc 421 or Ext. 5000 ( Lacoratory He alth enysics) for builcing 45 ror O rirst alc assistance anc/or any emergencies devision 2 Date 3/21/d2 dages a-l

involving radioactive materials. O V 4) For emergencies involving radioactive materials. Health Physics personnel will take over and cirect any decontamination or assessment procedures.

5) a)

Durine off-hours (4:30 P.4 - 7:30 AM, weekdays), First aid a ss is tance is available at Ext. 5694 (!4f g. He alth Physics ). The foremen shall ca ll Ext. 5555 and request an amoulance or Company vehicle to transport injured personnel to St. Francis Hospital for additional mecical assistance. Call dxt. 5555 and c) daak nds and Holldaxi recuest assistance

the quard will obtain of f-site medical assistance or initiate site call in list if necessary.

5.1.3 EcgE2221Y. 11ar_t Situations recognized as having a hazard potential. Examnles: Bomb threats, civil cisturbances, tornado or seismic warning, forest fire, initiated _dga Anyone can report an emergency alert () condition, but the daergency Director is responsible for classifying and declaring the emergency alert. Action: 1) Call bbco ano descrice the situation. 2) The guard then activates the emergency intercom

system, explains the emergency situation, and requests the Emergency Director.

3) The Emergency Director then decides a) fo evacuate personnel to the Emergency Assemoly Areas or the Emergency Control Center (Builcing

o) for protection by manually I

activating tne non-nuclear alarm or b) To instruct personnel to remain insice olant builcings b/ telephone communication anc security guard assistance. c) fo contact of f -s i te agencies as ne cess ary, i.e., (local

police, Office of Civil dreparedness, etc.).

devision 2 Dates o/21/82 Pace: 6-2 e

4) The Emergency Alert is terminatec cy the Emergency Os Director when the threatening situation has passed or is reclassitled into a plant or site emergency. 5.1.4 Plant Caercency An emergency which has no affect on the Windsor site environs outside of Buildings 45, 417, or #21. Franci s Fire not controllable by personnel in the immediate vicinity Explosion contained within the buildingst Major process leak or spill (toxic or radioactive) contained within the ouilding. Initiated bv Automatic or manual activation of the non-nuclear alarms continuously ringing bell. (vull boxes are strategically loca ted througnout Buildings

5,
17,and #21).

Actions 1) All personnel must evacuate to Emergency Assemoly Areas promptly. (Building #o - Manufacturing or Building #3-Laos). () 2) a) The Emergency Director assures that tne 5555 call is made, b) He will then recuest medical assistance, fira brigade, and/or site security as needed. 3) All personnel will assemble behind their immediate supervisor and inform him of any information pertaining to the emergency. Escorts are responsible for tneir visitors. 4) The Supervisors will account for a ll of their personnel and report to the Emergency Director. All personnel who are unaccounted for are assumed to oe in the affected area. 5) Site Security Guards will orevent unauthorizec entry into the afrected areas. o) The Emeroency Director determines final classification of the emergency (plant or site), and the need for additional assistance, and initiates the call in of accrooriate off-site agencie s as needed, (i.e., dindsor Fire Safety Complex, St. Francis Hospital, etc. () l) The Emergency Director assures that C-E.4anagement devision 2 Dates b/21/82 Page: 5-3

is notified of the emergency. 5.l.5 Site Enercencv An emergency having the potential f or of t-s ite impact. Mrnantes: Criticality

accident, major fire or explosion, release of 25 uCi or greater of airborne radioactive particulates into the C-E dindsor site environs averaged over a

24-hour period. Initiated bv I) Automatic sounding of the nuclear criticality alarm (radiation levels of 5 mr/hr or greater at any area radiation monitor) or 2) Sound ing of the non-nuclear alarm initiated automatically or by any cerson cognizant of the emercency s i tua tion. ( Pu ll boxes are s tra tegica lly located throughout Buildings

S,

17, ana #21 ) or 3)

A release of 25uCi of airoorne radioactive particulates averaged over a 24-hour period to the Windsor sita environs. s aUCLFAH l f,d !.rLic0: 1) All personnel must evacuate to Emergency Assemoly

nanufacturing or Areas promptly (duilding so cui1 Jing #3 - Laos).

W.LNOi ArrFWT 49C0 /E4Y 0 >M4 ATIOaS ? 2) a) Tne Emergency Direc tor assures tha t the 5555 call is made. b) He will reauest mecical assistance, fire brigace, and/or site security as neeced. 3) A ll nersornel will 3ssemble behina their inneciate supervisor and inform him or any information pe rta ining to the emergency. Escorts are responsicle for their visitors. 4) Euaervitati will account for all of their personnel and report to the Emergency Director. All personnel who are unaccountec for are assumec to be in the a f f ec ted areas. O l l I l Hevision 2 Date: :/21/82 Page: 5-4 i - ~ -, __

,r3 a) Site securi ty cunrds will prevent unauthorized (_) entry into the af!ected areas. o) The Rmarcency oirecter instructs the re-entry team to confirm criticality accident. If critic =11tv is con?ir ad: a) A site emergency is declared oy the Emergency Director and he in i tia tes assessment procedures, b) The Emergency Director then begins notification of o f f -s i t e agencies witn information regarding the emergency and requests assistance as required, c) The Office of Civil Precareaness will coordinate all of f-site agencies in assessing o f f -s i te impact and oossiole evacuation of residents. 7) It criticality is not confirmad: a) iha 6 erc9ncv Diracter notifies the guarc with the 5556 call that this was a false alarm and rs terminates the emergency. O c) A follow-up investigation is then conductec under the direction of the Emergency Director. h23-dUCLCAH ALAJM 1CJt.iC3: (1-6) Evacuation is initiated anc stens 1 -5 f rom the nuclear Alarm Procedures acove are f o llowec. (o) Tha Emarca-cv Oiract,r classifies the emergency, initiates acpropriate assessment crocedures, anc cegins notirication of o f f -s i te agencies witn information regarcing the emergency and r e cu e s t s assis tance as required. WA0!dACf!VC >ARTIPULATC JCLC AM irJiCa: 1) Eat any ma'or spill or dispersal of racioactive particuistes, health Physics is to ce notified. (l4anufacturinc - 3o84 Lacoratories 6o00 or 33c0). (s) 2) Tha Wa a ltn ?nvsics fe chni ci an then pulls the stack nevision 2 Date: b/21/82 ? age: 5-5

r11ter samples and determines the magnitude or the () release. 3) If the activity is 25 uCi or greater averaged over a 24-hour period, the Emarcencv nirector will ce no tif ied via the 5555 call and a Site Emergency will ce ceclared. 4) The Enercancv Director then notifies personnel to remain within their ouildings via the emergency intercom system, telephone system, and assis tance from the site security guards. 6) All off-site agencies listed are then notified anc the need for assistance is determined, o) The State Office of Civil Preparedness will then coordinate all off-site agencies in both assessing off-site impact and possible evacuation of res id en ts. o.2 Assassmant Actions See daragraph 3.1. o.3 Co rrec t ive Actions () See Paragraph b.l. o.4 drotective Actions 3.4.1 varsonnat Evac ua t i on from site =ad Acennatantlity All personnel are responsible for knowing anAf TO D0 and WhEdd fo GU during any emergency situation. The ref ore, the evacuation routes should be clearly understocc oy all persons working in Builcings 35, #17 and #21 The sounding of the nuclear alarm is activatec by a general radiation level of b mr/nr or greater. The non-nuclear alarm is activateo autonatically or manually by pulling the fire alarm ooxes located at various tocations throuanout Builcings =5. el7 and s21. fhe non-nuclear alarm may oe activated it conditions necessitate the evacuation of the olant. When the nuclear or non-nuclear alarms

sound, the f ollowing procedures apply:

1) All personnel evacuate immediately via tne evacuation routes to the cesianated emercency assemoly areas. (In front of cuilcing 43 ror (-)s lacoratory personnel (Ficure 5-1) and in front of devision 2 Date: o/21/82 dage: 5 -o

Building so ror .4anufacturing personnel (Figure f] s-2). 00 '40T AM WT J ECOV9V 0?dRATIOlS. 2) Escorts are responsiole for tneir visitors. The building #17 Security Guarc will also bring the visitors log to tne Suilding #o emer:)ency assemoly area to aid in tne accounting of any visitors to the manufacturing area. 3) Each Supervisor will verify evacuation of their respec tive personnel. It will be assumed that any personnel unaccounted for are injured or tracped in the building. 4) Any information pertaining to tne emergency and/or missing personnel is then reportec to the Emergency Director, who will direct any recovery or rescue operations which are necessary. 3) Evacuated personnel will be monitorea in accordance with varacraph 5.4.3. S.4.2 use of vectective Eculo, nt and sucolies The despira tory Protection Program is cesignec to provide guidance that will assist all prospective res pira tory users with the required knowlecce to (~T effectively wear respiratory orotection., Through the N/ use of full face masks or sucplied air type respiratory protec tion

devices, individual internal exposures will be kept as low as possible.

Traininc Training in the use of respiratory eculpment shall be performed as follows: Jew Employees - Prior to using respiratory protective equipment for the first time. Hourly Employees - On an annual basis for those wno are authorized to wear respiratory protective ecpipment. Subject ma tter to be covered in the training sessions will be as listea below: 1) Discussion or airoorne u02 and other contaminants against wnich tne wearer is to ce protected, including their pnysical properties,

MFCs, physiological

action, toxicity, anc means of cetection.

2) Discussion or tne operating princiales, anc limitation or ruil face resoirators and Sco tt Air eacxs and the criteria ror ' selection of tne proper (]) devision 2 Date: 5/21/32 dage: 5-7

respirator for the particular purpose. ,U 3) Discussion of the reasons for using respirators and an explanation of why permanent engineered safety features may not always be immedia tely

feasible, including recognition that every reasonaole effort is being made to reduce or eliminate the neeo for respirators.

4) Instruc tion in procedures f or ensuring that the respirator is in proper working condition. 5) Instruction in fitting the respirator croperly and checking for adequacy of fit. o) Instruction in the proper use of the respirator. 7) Discussion of tne cartridges used for air-purif ying respira tors. 8) Instruction in emergency action to be taken in the event or malfunction of the respirator. 9) Heview of radiation and contamination

hazarcs, including the use of other protective eculpment that may be used with respirators.

(]) Selection of Wesoiratots The use of respirators in the Building al 7 pellet shoo during normal operatina conditions is not consicered 4 necessary, since all process operations on unclac UO2 are performed in ventilateo enclosures to minimize personnel exposure to airborne racioactive material. A minimum air flow rate of 100 fpm into all ventilated enclosures has historically provided suf ficient means or maintaining personnel exposures as low as possible. Additional assurance from an eYtensive general air and fixec air sampling program indicate that no additional respiratory protection is necessary during normal operations. Personnel creathing zone sampling will oe used to assess actual exposures and to conrirm the adequacy of the ventilation system.

However, two types or respirators are availaole for nonrcutine and emergency situations and these are utilizec as f o llows :

a) A rull' face respirator may oe required whenever breaking containment on ventilatec systems becomes necessary, sucn as ror repair or process equipment, b) A full face respirator may also ce re cu ired () whenever direct exposure to unciad UO2 outside tne nevision 2 Date: 5/21/82 vage: 5-3

ventilation system becomes necessary as curing (') enrichment cleanuo or when the snitt H.P. Techn ic ian considers it necessary to avoid unnecessarily hign exposures. c) Sco tt Air vaks are available for emergency situations such as a leak on the ammonia cracker. Fittino anc Testinn After it has oeen determined by the company pnysician that an incividual is capable of performing work usina respiratory protection eculpment, the individual will oe initially fitted with a respirator and tested with irritant smoke to assure that an acecuate rit can ce obtained. I) All respiratory equipment will ce fi tted, adjustec to anc removea from the indivioual only by the nealth Physics Technician. It will be his responsioility to test tne respirators for operaoility. Each user will have the respirator removed by the dealth Physics Technician after approximately 60 minutes. A nasal smear will ce taken at that time, and the user's SZ samole will be counted. If indicated, the user may be removec from the operation to assure against high () exposure. 2) The Health Physics fechnician will instruct the user in the use of the ecuipment, and will advise him that ne may leave the area in case of equipment malfunction, physical or psychological discomfort, or other conditions which may recuce the pro tection aff orded the user. Under these concitions ne need not await the Healtn Physics Tecnnician f or mask remova l, but nust exercise care when removing the mask to prevent dusting. 3) bef ore the user starts work in a resoirator, he is to ce given a copy of "Acknowlec;ement of Instructions in the use of despiratory Ecuipment", ror nis stucy and sianature. 4) The user will be ecuipped with a BZ samoler. 5) fhe Health vnysics Technician will acoly a full face respirator using the followino quicelines: a) Fut respirator over f ace b) Full straps over the top and cown in oack of tne head LJ .sevision 2 Dates o/21/82 dage: 5-9,

a0fE de sur.e straps are adjusted tight enougn to (j) rorm a seal between respirator and face, c) Place the palms of the hands over the filter openings. d) Instruct the wearer to attempt inhalation. WOTE: It respirator is croperly

sealed, there should be no air leak for the 10 second

" hold" period and the mask should collapse inward toward the wearer's f ace. e) If there is no

leak, proceed with desired operation (s).

t) If a leak is

noticed, adjust ruboer straps until desired tension is achieved and recheck for adequate fit.

6) The procedure to be used in fitting an individual with a Scott Air Pak is as follows: a) Check cylinder pressure gauge for "F U LL " ind ica tion. If cylinder pressure is celow " FULL", replace with a fully charged cylincer. () b) Check that regulator cy-pass valve (red knoo) is closed (full cloc kwis e) and regulator shut-of f valve (yellow .<n o o ) is open ( f u ll-counter-clockwise). c) Open cylinder valve knob l-1/2 turns). The cylinder gauge and the regulator gauge should indicate the same pressure, d) Connect cuicx connect coupling to the regulator and breathe rroa the faceciece to ensure proper operation. e) Disconnect quick connect couplina tram the regulator. r) daise anc rotate the cylincer valve safety locx, close cylincer valve knoo and release residual air pressure by gracually coening tne ny pass valve (red knon); Pak-Alarm will ring momentarily. After resicual air is

purged, close by-pass valve.

g) Swing the apoaratus straight up and over tne nead keeping your eloows close to your body. West the aoparatus on your oack while s ti ll () slightly cent over. The shoulder straos will nevision 2 Date: 3/21/32 Page 5-10 ,c,

slide along arms and fall into place on s snoulders. Connect the chest buc kl e t then while straignteninc uo, pull cown on the sice straos to adjust the harness to cody fit, h) Connect and adjust the waist celt. 1) Oon the mask as follows: Ad jus t the head straps to a rull outward position. dold the head harness out of the way with one hand or cack over the lens. Place the facepiece on the face with chin properly located in the chin pocket. Full the head harness over the head and tighten the neck straps oy pulling on tne two appropria te tabs. Stroke the head harness down to the back using one or both hancs. fighten the two temple straps. detighten neck straos if requirec. In most cases, the top heac strap will oe tight on the " Full Out" position. Check the seal by closing off the creathing tuce witn your hanc and slowly inhale, no leakage should be cetectec and the (]) f acepiece should oe drawn onto the f ace. j) Connect the creathing tuce on the regulator at the cuick connect coucling when ready to enter the contaminated area; tignten fincer tight, k) Check the regulator pressure gauge occasionally for remaining air sucoly to allow sufricient time for egress from the contaminatec area. daintgnance af dessirator Protectiva Mmi~, ant ihe f o llowing procedure for decontamination anc restoring of respirators shall be adhered to: 1) negative pressure full race respirator. The following procedure for cecontamination anc returoishing of rescirators snali ce achered to: 30fE: All maintenance of resp ira tory protective equipment will ce cone by a health Physics Technician, a) Disassemole full face respirator anc recove () filters, intake and exhaust flaps. devision 2 Date: 5/21/82 vage 5-11 n

im(j) b) Decontaminate by washing tnoroughly with soap and warm water and scruo crush, c) Hinse with clean, warm water. d) Dry respirator and parts. e) dipe inside rubber surfaces with alcoho l to sterilize. f) Inspect and assemole parts to respirator. Assure that it is-aporoved for reissue by checking the face shield, head strap, exhaust flap, intake valves, and ruober plianility, if parts need replacing, use only accroved parts designed for the respiratory. g) Insert two filters cesignec for the respirator using at least one new filter. h) Smear tne inside of the mask for detection of removable alpha contamination. Decontaminate until removable alpha level is <10 com per 100 cm2. 1) Complete the "despiratory Protective Eouipment () Utilization Log" form. j) Place the respirator into a

clean, plastic bag, staple anc place into lo cke r labeled

" Clean Wespirators". 2) Scott " Air Pak" a) Carefully wash mask assemoly witn warm water (~100 degrees F) using a scruo brush and mile t soap. l b) Winse mask tharoughly with warm water, c) Allow to completely air dry and/or towel cry, c) Disinfect the skin contact area or the mask oy j wiping or sponging with alconol. e) If the Sco tt " Air Pak" assemoly has oeen used i in an airborne radioactive environment. l decontaminate the complete assemoly (harness, tank, valves, regula tor, etc) witn alechol i and/or soap and water. r) If assecoly had been usec in an airoorne O radioactive environment, take snears to Hevision 2 Dates c/21/S2 dages 3-12

ascertain that the removable alpha level is O < 10 dpa/100 cm2. g) Complete the "Hespiratory Protective Eculoment Utilization Log" form. h) Pack the assembly into the case, checking the folloWing: Pressure gauge for full or nearly full ind ica tion. Hegulator cy-pass valve is closec. degulator shut-off valve is ooen. Open cylinder knoo I turn. Check that regulator gauge and cylinder aauge incicate tne same pressure. Close cylinder valve. Open by-pass valve sligntly to purge system and check f or ring-alarm operation. ,Vhe n comoletely

purged, close oy-pass valve.

Close case and store in Builoing #17 Guard

House, s ta.1, d ignacree anc deturn of aessirators 1)

All respiratory equipment will ce controlled by h,)- the dealth Physics department. 2) Hespirator ecuipment is not issued to indivicuals. The Health Physics representative

rits, adjus ts and removes tne respirator tro.a eaca individual.

3) The Health Physics representative will assure that the respirators are properly used. 4) The Health vnysics representative will remove tne respira tor, clean it, and check f or contamination prior to reassemoling and returning it to tne storage cabinet. o.4.3 h a d cation control Measures 1) Any emergency response oersonnel or ecuipment entering contaminated areas will be monitorec when leaving the affected area by memoers of tne survey team. 2) The Emergency Director assigns a member of the survey team to chec k personnel ILD cadges for indium foil activation () Place the probe of a GM Survey Instrument close to i nevision 2 Date: b/21/82 Page: 5-13

the surface of the TLD badge. The TLD bacge () contains an indium foil whien, upon exposure to

neutrons, cecomes ac tiva ted and will cause a

response from a UA Survey Instrument. A 0:4 survey proce placea approximately one-half inch from a f oil approximately 1/2 inch square anc 0.000 thick will cause a response of at least 100 c/m for each rad of neutron dose (10 rem of neutron exoosure). It is inaportant that this survey be carried out within is minutes of evacuation, decorc each response in excess of 100 c/m. 3) Exposure to neutrons can also oe immediately identified oy a Gia survey of gold foils or rings. The gold, althougn less sensitive than tne incium, has a long half-lif e (o5 hours) p erni tting the identification of highly exposec personnel for several cays rollowing exposure. It is imoortant to remencer that a variety of metals that are commonly f ound in materials that are carried or worn by people (cigarette

lionters, rings, jewelery, belt

buckles, etc.)

become activated upon exposure to neutrons anc would be extremely valuaole fort I a) Confirmino that a nuclear accident has occurrec. (\\ s_/ b) Identification of radionuclices. c) Determination of personnel exoosure to neutrons. This information woula ce proviced through radiochemical analyses. 4) A ll FLD badges or personnel in or near tne af r ec tec area shall oe collected, identitiec, and sent to a lacoratory for emergency processing. d) Isolation of and acce ss control to contaminatec areas shall be monitorec cy the H. v. Te chn ici ans. Personnel entering isolated areas uncer contro11ec concitions shall wear protective eculpment previously described, drernence Ecuicment The following is a typical listino of emergency equipment in the various plant areas and the Emergency Control Center: Statien 41 ( Huild i n, a17 u. a. Orfice) i Alpha survey meter 7s t_) 1 3e ta-gamma survey.neter s .4evision 2 Date: b/21/32 vage: 5-14

2 Scott Air Paks (Sica. #17 Guard House) 2 Spare bottles f or Scott Air Paks 2 First aid kits 2 Full f ace respirators i Stretcher 2 Sets of protective clothing i Emergency blanket 2 Flashlights 1 Copy of Emergency Plan & Procedures Decontamination supplies SIation 4* 2 (soildinn do. Fmernency contrni centeti 2 fLD badges 2 vairs coveralls 2 Full face respirators i Stretcher i Emergency Blanket i Flashlight I de ta-gamma survey meter i First aid kit I Copy of Emergency Plan & Procedures Decontamination supplies I vortaole air sampler 10 docket dosimeters Station

3 (Boildinn d5,.taenine Shen entrance) 73U 2

Scott Air Paks 2 Full face respirators i Fire olanket 2 Sets protective clothing I Copy of Emergency Plan & Procedures Decontamination supplies i Stretcher i First alc kit I ce ta-gamma survey saeter i Flashlight i Emergency Blanket Etntion

a (Enst Guard,ouse) 2 Scott Air Pass 2

Full race respirators i Fire olanket 4 fLD bacges 4 Sets of protective clothing 5 Fairs plastic booties i Stretcher i First ala kit I deta-gamma survey meter 2 Flashlignts l dmergency 31anset (~) I i4ylon rope s, itevision 2 Dates o/21/82 dage: 5-15 l l i -.m - ~,

1 Copy of Emergency Plan & Procecures Uecontamination supplies () D.o dynesure control in waciolo,1c=1 cnntinnancias 3.3.1 Emeroency Excosure control Prcerem D.o.l.1 Evcosura Guida!inas 14uclaar Alne, Proceduras 1) He-entry into tne building will be made by a minimum of two persons designated by the Emergency Director. At least one member of the re-entry team will be a member of the survey team. 2) Ecuinment fecofred a) f4ew film cadge b) Pocket Dosimeter c) Portable GM Survey Meter on 0 to 20 H/hr scale (available in duilding

o Emergency Control Center) 3)

de-entrv Team instructions ~ (') a) Se sure meters are functioning properly (use check source on the sice of the meter) and orobe shield is covering GM tuce. b) Aporoach plant cautiously c) One member of the re-entry team shall closely watch reacings on the GM meter while the other ooserves the surrouncing area. c) Proceed in norta entrance of duildinc

17 or main entrance of Suilding 45 to the nuclear alarm cnntrol canel.

Determine which area has alarmec. 00fE: Neport back to tne Emergency Direc tor immediately if general raciation levels of 5 mr/hr are found and indium foil on area cadces is activated. e) Approach the alarmed area caref u lly, no tin g closely the survey meter reacings anc any abnormalities in suspected areas. Hevision 2 Date: o/21/32 Page: 5-1 o

=..- t) deport all information to tne () Emergency Director. WLE.C.:a 1) .1 hen personnel are not accounted for, it is assumed they are still in the builcing and rescue operations are initiated. 2) RESTRIrr!ONS: a) In extreme life-saving situations, permissaole dose to the whole body sha ll not exceed 100 rems. For emergency ac tions requiring less urgent

resconse, the permissaole whole body dose shall not exc eed 25 rems.

'o ) Prompt evacuation is requirec it the radiation level seems to fluctuate or suddenly ' rises without accarent

reason, Avoid unnecessary exposure.

c) Do not enter a radiation tield in excess of 1000 d/hr. () 3) Permissible Evrosure a) He-entry into areas grea ter than 100 mr/hr must ce authorizec by tne Emergency Director for the purpose of rescue of indivicuals, prevention of exposure to a large . number of individuals, or saving of a valuaale installation, b) Time-of-stay limits in Ta' ole 3-1 are based upon the highest dose rate to which the re-entry team will ce exposed and will limit their exposure to the recommenced 25 rems. (Note: Cuality f actor assumec to ce I ror chi and gamma raciation. 4eutron radiation should ce minimal ucon re-entry. c) Wescue personnel will be informed of the risks involved cefore thev accept sucn exposures. d) Other factors ceing ecual, volunteers over the age of 40 will be selectec. O devision 2 Date: D/21/32 dage 3-1/

4) Protective Equipment Availaole for Hescue 7-) (_j Operations: Covera 11s Shoe Covers fLD Badge Pocket Dosimeter Gloves Scott Air Paks o) Following the table for permissible time in area, try to locate and remove a ll victims in high radiation areas to areas less tnan 6 mr/hr where possible anc to locations wnere first aid assistance may oe rendered. tie -e n t r y and Wascua ( a n n -W u c 19 e r Alarm) 1) The re-entry team, with a G:4 Su rvey !.t e t er re-enters the affected area. 2) The re-entry team then verifies that a criticality accident did not occur anc no radiation hazards have been created. 3) Any injurea personnel snould' oe removec as soon as possible. gs 4) ao fire noses are to be used in the pellet shops portaole fire extinguisners must be used. 5) All personnel in the af fectec areas will be monitored by the survey team for contamination orior to leaving the affected areas. (A portable alpha survey ins trumen t is availacle in Building d6, Emergency Control Center). Dosa commitmant eaccres 1) descue team personnel, emergency workers, etc., will be orovicec with i'LD's anc pocke t dosiaeters. These cevices will ce worn by peronnel at all times while performing emergency rescue runctions. Uose records for personnel sna11 ce

naintained and become a

part of their permanent exposure recorc. () sevision 2 Dates o/21/92 Page: 5-15

O earnency descue Ti-a-of-Stav (casad en 'M dan 45mla Medv Ocsa) t.a x. Wadiarien Level dermi ttec Time in Arn 1000 H/hr 1.5.41n. 800 N/hr 1.8 141n. 000 H/hr 2.5 l41n. l 400 d/hr 3.0.d i n. .i 200 W/hr 7.5 :41n. 100 n/hr 15.0 Ain. 30 H/hr 30.0 Ain. 25 H/hr i Hr. 10 H/hr 2 Hrs. 30 ?4in. .40 f E For lifesaving situations, the 100 Hem limit may be useo, therefore, time or stay in Table 5-1 may oe multiollec oy 4 l Pro tac ti vo equimmant availanta der rescno ceararians: Coveralls 4 Shoe Covers O T'o 8ecce. oczet oosimeter Gloves Scott Air Paks 4 s i t c f i l 1 i i !!O ( l j devision d Date* D/21/32 r'ag e 3-19 l ... -. - -., ~ _. - - -. _,. _ _, - _ _ _ _ _ - _ -

c.o.l.2 daciatten Protac tinn Procr=, 3 see 6.6.1.1. o.o.l.3 unmiterfac I) Any emergency response personnel or equipment entering contaminated areas will be monitored wnen leaving the af f ec ted area by members of the survey team. 2) The Emergency Director assians a member of the survey team to enec.< personnel TLD cadges for indium foil activation: Place tne probe of a GA Survey Instrument close to the surf ace of the TLD bacge. The TLD badge contains an indium foil which, upon exposure to neutrons, becomes activated and will cause a resconse from a UM Survey Instrument. A 3..t Survey Probe placed approximately one-nalt inch from a foil approximately 1/2 inch square and 0.000 tnick will cause a response of at least 100 c/m for each rad of neutron cose (10 re.n of neutron exposure). It is C)s important that this survey bs. carried out within 16 minutes of evacuation. hecord each response in excess of 100 c/m. 3) Exposure to - neutrons can also oe immediately identified oy a G4 survey of gold fails or rings. The gold, although less sensitive tnan the

indium, has a

long half-life (oS hours) permitting the identification or highly exposed t personnel for several cays following excosure. It is important to rememoer l that a variety of metals tnat are commonly round in materials that are carried or worn by cecole (cigarette lichters, rings, jewelery, belt

ouckles, e tc. ) cecome ac tivatec uoon exoosure to neutrons and would ce extre.nely valuable ror:

a) Confirming that a nuclear accicent has occurred. b) Identification of radionuclides. c) Determination of cersonnel excosure to neutrons. l /~' ihis information would be orovidea l devision 2 Date: o/21/82 dage: 3-20 ~.-

througn radiochemical analyses. 4) All FLU badges of personnel in or near the af f ec ted area sha ll be collected, identified, anc sent to a laboratory for emergency processing. p.2.2 nac en tam i n a t i nn or 9arsonnal candline o' Osnt,minated Victi-s (Parsnanel gecontamination) 1) The Emergency Director will designate one or the survey team members to monitor oersonnel that were in or near the af f ec tec area f or contamination. 2) The survey team memoer has both portable alpha and 0:4 survey meters available in Suilding

6.

(doergency Control Center). 3) Contamination will be removed under the direction of dealth Physics personnel utilizing the cecontamination supplies in tne emergency supply cabinets. 4) Showers are available in both Building 46 and building #17 locker rooms. 5) Decontamination levels for cersonal clothing and body surf aces shall be as follows: Suniace surveyed Alaha dam / loo e ? Personal Clothing 100 dody Surfaces (hair, Indistincuishaole from rac e, hands, e tc ). background (following normal wasning) 1.2.luti.25_C2'n l i c a t 9d nv 4=d i"Ac*iv9 Csatamiaation 1) Do not a ttempt decontamination on personnel 'vith any serious injury to avoid comolicatinn tne injury. 2) Key does and reouest site security venicle to transport the in jurec to St. Francis Hospital dmergency doom. 3) The injured should be wrapped in blankets to provice maximum degree or contamination control ouring movement. A) (_ 4) The daergency Director is resconsiole for I nevision 2 Date: o/21/92 dages o-21

i notifying St. Francis Hospital tnat there is a s/ contaminated victim enroute anc relaying any inrormation availaole on tne condition or the patient. 5> A Health Physics staff memoer, ecuicped with both alpha and GM survey

meters, will accomoany tne contaminated victim to 5t. Francis Hospital.

o) If Health Physics personnel are not available, initia te the site call-in list and a memoer of the Health Physics staff will meet the injurec at the hospital. 7) The Energency Director will assure all oersonnel anc equipment involved in the handlinc of racioactively contaminated incividuals, are monitored for contamination before leaving the area. b.o

.t ed i c a l Tr an s;2rftE.1.2n I)

.<ey Sobs and request medical assitance ano descrice the extent of injuries. 3!rino tne dav C-E medical will resoond ana initiate additional assistance as needec. s A ll other ri-as: An ambulance will be contacted by the security guarc or an on-site security vehicle will transport injured to St. Francis Hoscital: St. Francis ilospital 114 Acocland Street hartford, Cf 00103 1-043-4000 2) First Aid Taam Formal training in first aid is recuired by all health Physics fechnicians. They will assist the C-E Medical staff in handling or injurec personnel curing tne cay. Jirst Ain Assist,nce availanla waekcavs 7:10 A " -a r lo ?. a) C-E Aeaical Ext. 3333 c) laanuf acturing Health Physics Ext. 5o34 c) Lacoratory nealth Physics Ext. 3o00 or 50J0 svenin-s and A L;hrqa .ianufacturing Health Pnysics Ext. cod 4 I AV sevision 2 Dates o/21/d2 dage: o-22 t i I

Jeevenes n-e Holid,vs The 3993 call will initiate transportation to St. Francis

Hospital, r:i r s t ALd erocecures:

Administer first aid to injurec Prepare injured for transportation' to C-E Aedical Department or of t-site medical f acilities. Set up camporary first aid station for segregating and caring for injured if necessary. JOTE: All emergency supply cabinets are equippec with first aid supplies. Inf orm Emergency Direc tor of neea for an amoulance, additional supplies and first aid oersonnel. A.nemoer of the health Physics staff must accomoany injured to the hospital if the injury is comolicated oy radioactive contamination. 5.7 Mad.ical Treatment Injured personnel will be taken to St. Francis Hosoital, see (s paragraph 3.o.2. In the event that St. Francis Hospital ss) cannot handle all of the

injured, the following backuo hospitals are available At.

Sinai

dospital, Bloomfield, CI., Hartf ord Hospi tal, har t ford, CT:

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o.U GG d I ?'W 4T UD mM'M W T ES o.1 Cantrol Poial The dmergency Control Center is located at Building so, where two independent telephone lines and an emergency sucply cacinet are located. The guardhouse nas an emergency not line to the Windsor Police Dispatcher. Building

o is located south of the manufacturing area which is normally the upwind direction as determined by tne dational deather Service at Bradley International Airport, using data compiled over a period of 30 years.

Alternate locations in other site buildings will be Oetermined at the time of an emergency. The emergency assembly area is in front of Building

o for the manuracturing facility.

The larcer emergency assemoly area in front of Building #3 is necessary for the Development Department, due to the greater number of personnel working in the Labs. o.2 C' wnnications Ocuirm Communications during an emercency may be accomolisned by the following methods: a) f4ormal plant telephone system p)s ( b) 2-way radios c) Voice and hand signals (effective in many cases cue to small size or the plant) d) Loucspea ke rs in firefighting vehicles e) Emergency intercom and paging system. o.3 Egeilities ror Assessmant Tanas The followinc monitoring systems are usec to initiate emergency measures as well as tnose usec for continuing assessment. o.J.I Qa_iite Svstems and Ecuirmant dinc speec and direction and otner meteorological cata is cetermined by calling the U. S. Ideatner Service at oradley International Airport. naciation Monitors anc Alarms nadiation monitors are installed in various areas of the plant manufacturing anc Development Laboratories so that all Special nuclear Aaterial located in or about the facility is monitored oy a detector. The racia tion intensity is shown on a meter mounted on rx a centrally located remote readout panel. Thera is an (_) alarm wnich serves as a local and general auciole l devis ion 2 Date: 5/21/32 dages o-1 I i

(]} radiation evacuation sicnal. These monitors are connected to the emergency power system. Portable Monitor s - Several portaole radiation survey locateo in instruments and radiation dosimeters Builcings 45 and #17 Health Physics ottices, Emergency Control Center, and East Guard House are available. /rocess,4cnitors - normal process control monitors are not related to emergency conditions or situations, o.3.2 FacilitL11_and Ecui' meat far Off-Site "^^1toriac a) Air Samplers b) vortable radiation survey instruments c) Con ta iners, e tc., for sampling

soil, water anc vegetation.

o.J.3 d,eferanca u t e tLa.L1 Emergency Procedure.4anuals are maintained in duilding 40. Equipmen t

drawings, ocerations procedures and otner rererence met? rial is sept in Central Document Control (CDC) in Building 417 o.4 C n -S i t e Vedical Jacilities O

The C-E Aedical Facility is s ta f f ed oy a licensed MD anc registered nurses. Stanaaro first alc sucolies are availaole in various locations at the C-E,11ndsor si te I) Health rhysics Office 2) Site Mecical Department 3) duilcing so (Emercency Control Center) 4) ouilcing #3 D) East Guard House o.o Enernancv a cc.iL2Lind uir'9nt The Emergency Assemoly Areas in front of duilcing do anc duilding s3 are locatea soutneast of the fencec manufacturina area ano are of ad eq uat e size to a cco.acoc a te tne evacuated cersonnel. The assem'oly areas are not in the prevailing winc direction and are located adjacent to Buildinc #o. Emergency Control Center whicn arovides sufficient shielding in tne event of a criticality accident. Locatec in the emercency control anc assemoly area are emergency ecuipment and sucplies, inclucings () a) daciation survey instrument ( 0-20 R/nr ) n) despirators devision 2 Date: 5/21/02 dage: o-2 {

() c) Protective clothing d) Personnel monitoring devices (fLD's & /ccket Dosimeters) e) First aid suoplies r) Decontamination supplies There are three other emergency suoply s ta tioris which are strategically located in Building #17, building 45 and the Eas t Guard House. A detailed list of emergency equipment is provided in Section 3.0 of this plan. The emergency supply stations are checked once a month by the

d. P. Techs.

The-radiation survey instrument is chec ked to ~ verify its operability once per month. Calioration of the radiation survey ins trument is done'once every 3 months. O i l O l sevision 2 Date: 3/21/d2 dages o-3 l l

r O 7.0 'ia i a t 9a an ce of endicincical cantincencv Hracaredaess carabilitz 7.1 aritten Procecures An annual review of the Emergency Plan is performed by tne Emergency Planning Cooroinator (see Figure 4-3c)- and a keview Co mmi tt ee w for tne purpose of up-cating anc _imoroving procedures. desults or training and crills ~ as well as changes on site or in the environs are incorporatec into this review, which is documented. All written agreements are reviewec anc updated at least every two years.

deview Committee is made up of Engineering Manager and Production idanager 7.2 Trainina The purpose or tne training program is to inforg and instruct all employees in the policy and Drograms of tne ccmpany as'-

they relate to safety, emergency procedures, and crocer and safe performance of their assignments. The incoctrination of new employees in the safetyfaspects of the facility is under the direction of the he~alth Pnysics anc O Safety Supervisor for Aanufacturing employees and the health vnysics Manager for Lacoratory employees. The indo'ctrination of all new employees includes as a minimum the foll,owing topics: Description of difrerent

alarms,

, routes of evacuation and location of assemoly

areas, radiation s igns and taeir meanings,-and responsioilities.

This training is documentec.,' personnel Any employees working with radioactive mat rials are 'given acuitional instruction wnica incluces, out-is_not limitec to, l l tne following topics: a) Funcamentals of nuclear criticality saf ety and controls. 01 Funcanentals of. the health Physics program ano controls, c) dmergency alarEs and actions requirec. c) A review of the facilit/ ocerations. e) Jn-the-joo tra ining, under direct aine supervis ion anc/or i oy experienced personnel. r) Incustrial Safet'y-g) Sare performance-of their assignments. After determining that'a new encloyee has attainec suf ficient j kn ow iedg e in the aoove topics (cone oy testino with a Jeview i or tne auestions missed to. a ssure croper uncerstanding of l material), acecuate cerrormance is monitored oy the toreman. I /" 4anufacturing or Lacoratory H. P. staff orior to cernittino work witnout close supervision. All tests are documented ana s, ~ nevision 2 <Jate: 5/21/92 Page: 7-1 a E ?

/~T the Vice President of uuclear Fuel reviews the training A/ programs annually to assure compatibility oetween the programs in both Manuf acturing and the Lacoratory and their adecuacy. This is documented. Hevisions of the training program are made by the nuclear Licensing and Safety.'.lanager, ir requirec. The training and personnel safety program is continued with on-the-joo tra ining supplemented by meetings conducted by line supervision and specialists in the subjects covered. Personnel protective equipment, industrial safety and accident prevention, emercency procedures, and otner safety topics are included. .4anufacturing-foremen receive a formal course in radiation safety, criticality con tro l, emergency plans and procedures under the airection of the Health Physics and Safety Supervisor. Sufficient knowledae to carry out their training functions is determined oy testing. All personnel working with radioac ti ve materials receive retraining in criticality

control, radiation safety and emergency procedures on an annual basis under the direction of the Health Pnysics and Safety Supervisor for Manufacturing employees and the i4a nag er of Health Physics for the Lacoratory employees.

The Emergency Direc tor and all of the designated alternates are requirec to review and familiarize themselves annually O with the emergency

plan, specirically the duties and responsibilities of the emergency Director.

These reviews are occumentea. These responsioilities are then reviewed semi-annually oy participation in the site evacuation drills. First aid team members are requirec to take anc cass a one week first aid certification

course, fhis course is recognizec and aporoved-by the National ded Cross and requires recertification every three years.

The C-E Fire Br igad e is trained quarterly oy Facilities Engineering s Services. L The local fire decartment eniets and assistants are trainec in tighting fires involving radioactive materials and l specific precautions to ne taken in tignting fires in criticality areas uncer tne direction of the Aanager of l Facilities Engineering & Services. The cniets and assistants then in turn train their people. In training the cniets and l assistants, we are assurea that all new personnel in the rire department will be properly trained. All training and retraining specified in tnis clan are doCouentea. l i 7.3 ru n 2 ng7_i,113 demi-annual site emergency evacuation crills are conductec to l l Hevision 2 Date: 5/21/92 Page: 7-2

(' test promptness of

resconse, ace cuacy of procecures, emergency equip;nen t, and the overall effectiveness of the emergency plan.

At least one of the two crills given annually will be part or an overall exercise that involves participation by of f-site agencies to test as a minimum the communication links and notirication procedures. During these exercises, the following emergency resoonse teams participate to a ssure familiarity and efficiency in perf orming tneir emergency f unc tions site security, survey and re-entry teams. All drills and exercises are cocumented and criticued by the auclear Licensing anc Safety danager (or the health Physics and Safety Supervisor) to evaluate their effectiveness. He is also responsible for revising these drills and exercises to increase their e f f e ctivene ss. 7.4 Weview and 0, -0 9 t i n, ?!an and ?recaduras See Paragraph 7.1. /.o agintanan-a and Invanterv of vaciolomic=1 E ermancv Ecoinnent. Instrumaetation anc Sunnlies fne following is a typical listing of emergency eculpment-in the various plant areas anc the emergency Control Center. Ecu ip:ae nt and Supplies are monitored anc inspected contnly. {) When detective equipment is found it shall ce reolaced with ecuivalent eculpment. Emergency caoinets shall be keot in a lockea condition at all times to prevent oilrering and misappropriation of suoplies, d;ption al (Buildinc O 7 H. ?. Office) 1 Alana survey ;ae ter 1 deta-gamma survey meter 2 Scott Air vaks (Bldg. #17 Guard nouse) 2 Spare cottles ror Sco tt Air vaks 2 First aid kits l 2 Full face respirators l 1 Stretcher 2 Sets or protective clotning l 1 Emergency blan.<e t 2 Flashlights I Copy of Emergency Plan anc Procecures Jecontamination suoplies I sigitan _ 42 (sui!cinc ac. E-arcency c,ntral canta-) 2 TLJ badges 2 Pairs coveralls 2 Full race respirators j (-} I S tr e tene r i l devision 2 Date: 5/21/32 dage: 7-3

_O I Emergency dianxet U i Flashlight I beta-gamma survey meter i First aid kit i Portaole Air Sampler i Copy or Emergency Plan ana Proceaures Decontamination supplies 10 Focket dosimeters station 43 (9uildino as eachina shon Entranco) 2 Scott Air saks 2 Sets of protective clothing 2 Full race respirators i Emergency blanket i Fire dlanket I beta-gamma survey meter i Firs t aid kit i Stretener 1 I Flashlight i Copy of Emercency Plan ana Procedures - Decontamination supolies h ion da (cast quard Housad 2 Sco tt Air Paks O 2 Full face respirators i Fire Blanket 4 TLD badges 4 Sets of protective clothing a Pairs plastic booties i Stretcher i First aid kit I beta-gamma survey meter 2 Flashiights i daergency dlan.<et I bylon rope i Copy of Emergency Plan and Procecures Decontamination supplies l .Hevision 2 Dates b/21/82 Page: 7-4 t

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( lt / ruosi t c uuumeo ~ COMBUSTiott ENGINEERING. IrlC. ':vw:n.cm ;.

( ) 3.0 -s m ~s 6.1 Hacords or Inctignis All health physics recorcs for the current calendar

year,

) inclucing

training, and all reports required oy the regulations or the USibfC and the C-E license 5h4-1067 will ce made available to insoectors uoan request.

However, all reports and records over five years old may oe stored on microfilm.

Hecords relating to health and safety shall ce retained incefinitely. 5uch recorcs shall include olant alterations or additions, aonormal, and of f-normal occurrences and events associated with racioactivity releases, criticality analyses audits and inspections, instrument calibration, ALAdA

rincings, employee training and retraining, personnel exposures, routine radiation

surveys, and environmental

surveys, decords for the four stipulated classes of emergencies shall incluce:

4 cause of the incident j personnel and/or equipment involved (]) extent of injury and/or damace resultino from the incicent. corrective actions taken to terminate tne emeroency action taken or planned to prevent a recurrence of the incident. on-site support assistance requested / received f or recovery action. d.2 ecceds v grao,reeness Assur_atc.g All employees shall attend a formal training session prior to working in res tric ted areas. This will cover orincicles of radiation sarety (ALAdA practices) nuclear criticality j sarety, industrial sarety, emeraency proceaures, acclicaole state and rederal regulations (i.e., 10 CFH Parts 17 and 20) 4 accitional inrormation pertainina to eneir Jon. Soecializec training for raciation protec tion and nuclear criticality safety shall ne commensurate with the extent of tne employee's contac t with radioac tive ma terials. All cersonnel wno will ce working with radioactive materials must comolete a test to ascertain the ef rectiveness of tne training. All trainees shall satisf actorily comolete the test oefore being allowec to hancle racioactive materials without airect supervision. All training will be concucted under the direction or the Health ehysics a Safety Supervisor for tne manufacturino facility enc under the cirection of tne ()

Manager, Health Physics for the Development Department l

Lacoratcries. I i devision 2 Datet o/21/32 Page 3-1

_~ l. ' 'O necords or all-formal training sessions snall ce Kept and will include the date

neld, subject ma tter

covered, attencees, instructor, anc the results of the method used to ascertain tne ef f ectiveness of the training.

All production personnel who work with radioactive materials l shall attend a formal annual safety training session, witn no more than 13 months between training sessions._ This training session will incluce as a minimum the topics covered-in the initial training sessions. In addition, this session shall i emphasize problem or potential proclem areas, involving tne topics covered, or any other safety related areas. [ t4FA-il also maintains a comprehensive system of operating procedures which include the appropriate safe ty precautions. Informal training (not cocumented with lesson

plans, etc..)

l are conducted by production foremen on a continual basis as needed to assure that personnel are properly followino tne approved procedures. The ultimate responsioility - to f o llow tne operating proc edure lies with the emoloyee. Any change which alters the employee's responsibility or actions in i regard to safety (criticality, raciation, and industrial) must be aoproved by the Supervisor, Health Physics &

Safety, or Manager uLS6A who will assure the aopropriate training is conduc ted prior to implementation.

This also incluces (]) changes to the emergency procedures whicn affect employee actions in an emergency situation. All maintenance personnel working in restricted areas snall attend formal training sessions annually not to exc eed 13 months between sessions. If they have not attended this training, they may enter the restrictec area only with a trained escort. .4ain tenanc e training sessions will cover the same tocics as the i production personnel session. Special emchasis will be given l-to internal costamination of eculoment. I Salaried personnel who enter restricted areas shall a ttend l fortal training sessions annually not to exceec 13 montns l oetween sessions. These sessions will be directed toward l observation and supervision in restricted areas rather than actual handling of radioactive material. The topics listed in the initial training shall be discussed with enchasis on the supervisory aspects of these topics. Lacoratory personnel shall conduct formal retraining of all personnel who nandle racioac tive material at least every 2 i years not to exceec 2S months. All work in the lacoratory l which involves radioactive material requires an d i!P. This l sistem allows for continual control or personnel hancling i racioac tive ma terial. 1 ine efractiveness or all re tra inin g is determined bv the instructor cuestioning the personnel to cetermine 'their (f unders tancing of eacn topic. sevision 2 Date: 3/21/S2 dage: 8-2 l ~ _ _ _. _ _. _ _ _ _. _ _ _ _ _ _ _ _ - _ _ _,

Recorcs of all formal training sessions shall be kept and will include the -date

held, subject matter

covered, attendees, ins truc tor, and the resul ts of the me thod us ed - to

-ascertain the effectiveness of the training. Criticality drills shall take place twice per year. Records of such drills shall be maintained in the dealth Physics ofrice. Hecords shall contain, as a

minimum, date,

tiae, participants, and a critique of drill results.

6.3 w nortine Arran,ongnis See Paragraphs 3.2, 4.J and 4.4 A spokesperson snall be appointed oy tne Emergency Director. The spokesperson snall have access to all necessary information.following an accident. O i i i i i i i i 4 \\_) i nevision 2 Dates c/21/92 Pages d-3

7.o s9eovewy 9.1 sa-Entry d e-e n t ry into tne affected area will ce in accoraance with sections 5.0 and 6.0 of this plan. 9.2 dlant Westoration dacn member or the emergency oraanization will assure that sarety related equipment, within nis area of responsioility, is restorec to normal as soon as pra c tic aole following an incident. derer to Section 4.0 ror scecific responsibilities. 9.3 nesu etien of unerations Corrective actions for each type of incident inclucec in this plan are ciscussed in Sections 4.J, b.0 and o.0. bormal operations will resume af ter the concitions soecified in tne above noted sections have been complieo with. Acceptacle i levels or contamination tnat must be achieved before resumption of operations shall ce as notec in Paragraoh 2.2.4 d ad ia t ion levels before resumption or operations shall ce at a level consistent witn normal ocerations. %/ l I l4 sevision 2 Uate: o/21/82 eage: ?-l

\\ I L stv\\ f l/l) c- '"LIC c 4EUDEENTS" gp DocketNo.lv, 3 RECE!VED William 0. Miller, License Fee Management Branch,iEh! jp" 2 I o.s.n%d,o,982>b 9-MATERIALS LICENSE AMENDMENT CLASSIFICATION comm,,, li' wss Y AfailSection Applicant: C [ %v I 4 "~ # License No: 5'~' i n < r r>(, 7 Fee Category: Received: A / 6 - d' ' Application Dated: /- s, u [ Applicant's Classification: 0 The above application for amendment has been reviewed by NMSS in accordance with S170.31 of Part 170, and is classified as follows: 3 l 1. Safety and Environmental Amendments to Licenses in Fee Catecortes 1A throuch 1H, 2A, 2B, 2C, and 4A (a) Major safety and environmental p i~ (b) Minor safety and environmental (c)_ Safety and environmental (Categories ID through 1G only) (d)_ Administrative f 2 Justification for reclassification: ., ~. 3. The application was filed (a) cursuant to written NRC request and the amendment is ing issued for the convenience of the Ccamission, or (b) Other (State reason): n / Gji/ w sadb 0q ? Signa i gq[ [jM kplb3*i h,27w D n of Fuel Cycle & Material L Date b b = b _ _ _ _}}

ML20058B396

Contents

Text

SUMMARY

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Dear Mr. Sheeran:

SUBJECT:

Dear Mr. Sheeran:

Dear Mr. Sheeran:

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ML20058B396

Text

SUMMARY

Dear Mr. Sheeran:

Dear Mr. Sheeran:

SUBJECT:

Dear Mr. Sheeran:

Dear Mr. Sheeran:

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