ML20059B590

Application for Renewal of License SNM-1227,consisting of Rev 24 to ANF-2

ML20059B590
Person / Time
Site:	Framatome ANP Richland
Issue date:	07/25/1990
From:	SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:
References
NUDOCS 9008290182
Download: ML20059B590 (37)

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't ADVANCED NUCLEAR FUELS CORPORATION TRANSMITTAL FOR DOClMENT, REVISION, i,

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OR RECEIPT FOR OFF-SITE DISTRIBUTION j

llj, DATE: 07/25/90' DISTRIBUTION:

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' TO:: DISTRIBUTION LA BISPING-t L

~TA BJORNARD FROM:~- DOCl#ENT. CONTROL BN FEMtEITE ADVANCED NUCLEAR FUELS CORP.

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RICHLA W, WA 99352 CJ FRANCIS

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DOClMENT NO: ANF-2 LD GERRALD L

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TRANSMITTAL ONLY.

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ADVANCED-NUCLEAR FUELS CORPORATION t

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~ l PAGE OF DOCUMENT REVillON INSTRUCfION SHEET

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DOCUMENT NUMBER:

DOCUMENT TITLE:

DOCUMENT REVISION:

24 lDENTIFICATION REMOVE INSERT-(1.E., SPECIFICATION, DRAWING, PROCEDURE, ETC,)

PAGE(S)

REVISION PAGE(S) L REVISION Revision No. update and the original Amendment Application Date were the only changes to the following chapters; no text change occurred.

1 Chapter 2 All 22 All 24 i.

Chapter 3 3-1 22 3-1

-24 3-9 22 3-9 24 I

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Chaptor 4 4-1 22 41 24 4-2 22 4-2 24 4-4 22 44 24'

' Chapter 6 6-1 22 6 24 Chapter 11 11-52 22 11 52 24 11-55 22.

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ANF 2, Rev. 24 -

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Issue Date: 07/25/90

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1 APPUCATION FOR RENEWAL-

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.SPECIAL NUCLEAR MATERIAL UCENSE NO. SNM 1227 j!

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.j s-E ADitANCED M) CLEAR MELS CORPORA 110bi gn p.g SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 l

PART I LICENSE CONDITIONS REV.

24

. CHAPTER 2 ORGANIZATION AND ADMINISTRATION The President of Advanced Nuclear Fuels Corporation has the ultimate responsibility for ensuring that all Company operations are conducted safely, and in full compliance with applicable Federal, State and local regulations, licenses, and permits.

All functions, which handle or store special nuclear material authorized by this License, reside within two divisions of the Company; Operations and Engineering. The 3

relationship of those segments of the organization which conteln a significant safety or licensing responsibilii, ls depleted in Figure 12.1. _ The organization of the Safety, Security, and Ucensing Department which contains the responsible safety specialists and professionals is depicted in Figure 1-2.2.-

2.1 Orr.ier,izetional Responsibilities and Authority 2.1.1 President and Chief Executive Officer In connection with his ultimate safety responsibility, the President shall assure that p

adequate manpower, funding, and resources are made available within the Company to j

i achieve the capabilities comm!!ted in tr)is Application. Additionally, he is responsible for assuring that there is a sound, consistent safety philosophy throughout the Company.

2.1.2 Vice President. Operations Division The Vice President, Operations Division, is responsible for the overall management y

of the fabrict.tlon of nuclear fuels. He carries the responsibilities of the Senior Site -

)

Representative. With this responsibility are the safety-related functions of operations,

.l maintenance, transportation, materials handling and storage, licensing and industrial, j

radiological, and nuclear safety.

2.1.3 Manaaer. Operations Richland i

The operation of the nuclear fuel manufacturing and ancillary facilities at the plant are directed by the Manager, Operations Richland, who reports to the Vice President, Operations Division.

The Manager, Operations Richland, is responsible for the fabrication of nuclear fuels within the constraints imposed by product, process, quality assurance, licensing, l

and safety requirements. His responsibilities include plant operations, quality control, laboratories, and maintenance. He has the full authority required to discharge his responsibilities for safe operation of all site manufacturing facilities.

O April 27,1989 21 ANF-3830.051 (6/89) p ;

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'h ADVANCEDNUCLEARMELS CORPORATION guy.f -

' SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 I

PART I UCENSE CONDITIONS REV.

24 2.1.4 Manaaer. Plant Operations The operation of the fuel manufacturing facilities are directed by the Manager, Plant Operations, who reports to the Manager, Operations-Richland, l

The safe operation and control of plant activities, including the safety of the environs as influenced by the conducted activities, are the responsibility of the Manager.

Plant Operations. Other responsibilities include:

- 1.

Preparation of detailed work and operating procedures, and training of employees for activities under his direction.

i 2.

. Compliance with license conditions and any required corrective actions i

resulting from either Advanced Nuclear Fuels or NRC compliance inspections.

3.

Supervision of all manufacturing activities within the respective plants.

4.-

Special nuclear materials safeguards control and protection for activities under his management.

5.

Membership in the Emergency Cadre.

6..

Membership in the ALARA Committee.

1The Manager, Plant Operations, has the full authority required to discharge his

. responsibilities for safe operation of his plant.

2.1.5 ' Manaaer. Plant Maintenance

All plant maintenance activities are directed by the Manager, Plant Maintenance, who reports to the Manager, Operations Richland.

In' addition to common maintenance activities, the Manager, Plant Maintenance, is responsible for conducting established preventative maintenance and routine inspection

. programs for all safety related equipment and systems. He schedules maintenance activities with. Manager, Plant Operations, and he.is responsible for alerting the plant management of deteriorating and/or substandard conditions of safety-related equipment and systems.

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ANF 3830.051 (6/89)

ADM6NCED ARoCLEAR MELS CORPORATION.

ynp.g SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257.,

PART I - LICENSE CONDITIONS REV.

24 He is responsible for maintaining and calibrating radiation protection instruments and equipment, the criticality accident alarm system, and the fire detection and alarm system in accordance with established programs. He is also responsible for conducting tests of safety and emergency related equipment as required by established programs.

2.1.6 Manaaer. Operations Plannina and Schedulina The nuclear material traffic activities for ANF Richland facilities are directed by the Manager, Operations Planning and Scheduling, who reports to the Manager, Materials and Scheduling.

The responsibilities of the Manager, Operations Planning and Scheduling, include.

shipping, receiving, and warehousing of nuclear materials, maintaining nuclear material transfer records, and assuring that plant inventories of nuclear materials do not exceed authorized possession limits.

These activities are conducted within the confines of licensing and safety requirements, 2.1.7 Manaaer. Safety. Security, and Licensino The Manager, Safety, Security, and Ucensing, reports to the Vice President, Operations Division, and is responsible for developing, administering, and auditing the licensing, health physics, criticality safety, environmental surveillance, Al. ARA, security, and safeguards programs for all Advanced Nuclear Fuels facilities located at Richland, Washington.

The Manager, Safety, Security, and Ucensing, is wholly independent with no -

manufacturing responsibliity, and has direct access to the upper management of the Company.

If the Manager, Safety, Security, and Ucensing, judges any operation as un' safe, he has the authority to request management to shutdown the affected operation, in the event of disagreement between line management and the Manager, Safety, Security, and Ucensing, the operation shall be immediately shutdown, and the issue promptly brought to the attention of the Vice President, Operations Division. Actions following from this authority are subject to review and approval solely by the President of the Company.

AMENDMENT APPtlCAflON DATE.

PAGE NO :

ANF 3830.051 (6/80)

AD%RNCEDNUCLEARFUELS CORPORATION gup.2 3

SPECIAL NUCLEAR MATEICAb LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 p

PART I - LICENSE CONDITIONS REv.

24 2.1.8' Supervisor. RW!&! cel and Industrial Safety I

--The Supervisor, Radiological and Industrial Safety, who reports to the Manager, Safety, Security, and Licensir:g, directs the activities of industrial safety, criticality safety, and radiological safety personnel in conformance with approved Company policies and programs in direct support of plant operations.

If the Supervisor, Radiolodcal and Industrial Safety, judgos any operation as unsafe, he has the authority to request management to shutdown tno affected operation, in the event of disagreement between line management and the Supervisor, Raciological

'and Industrial Safety, the operations shall be immediately shutdown, and the issue promptly brought to the attention of the cognizant department manager.

2.1.9 Radiological Safety Component The ' general function of the Radiological Safety Component is to provide information, advice, and assistance to the operating and engineering components such that personnei;and environmental protection are maximized, and to keep adequate records to properly document conditions.- Specific responsibilities of the Radiological Safety Component include the following:

1.

- Administering the plant radiological safety programs, and directing the

- activities of the Haalth Physics Technicians.

2.

. Establishing radiological safety programs in accordance with criteria and standards provided. by the Manager, Regula'. ry Compliance.

Such programs include air sampling, contamination and radiation surveys, bloassay in vivo examination, and associated records systems.

3.

Reviewing established programs and evaluating effectiveness.

4.

- Providing radiological safety analysis of proposed operational changes or modifications.

5.

Preparing Radiation Work Procedures.

6,

' Assisting in preparation of reports to regulatory agencies.

7.

Auditing operations for compilance with regulatory criteria, license conditions, and Advanced Nuclear Fuels criteria.

8.

Assisting in health physics and radiation safety training.

AMENOMENT APPLICALON DATE, PAGE NO -

j ANF 3830.051 (6/89)

4 ADVANCEDNUCLEARMJELS CORPORATION l

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SPECIAL-NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 1

Q PART I - LICENSE CONDITIONS REV.

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'l 9.

Membership in the Emergency Cadre.

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10. Membership in the ALARA Committee.

2.1.10 Health Physics Technicians The collection and accumulation of basic radiological data, along with providing rottine radiation monitoring services, is conducted by Health Physics Technicians who report.to the Supervisor, Radiological and Industrial Safety. ' Senior Health Physics l

Technicians may be assigned special duties, along with appropriate titles.

1 L

Health Physics Technicians carry out established programs, and assist in initiating new or necessary programs; specific responsibilities shall include the following:

1..

Providing radiation monitoring.

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2.

Collecting air and effluent samples.

3.

Issuing and controlling personnel dosimeters.

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4.

Maintaining all records pertaining to personnel exposure, contamination and air surveys, sampling, inspections, tests, etc.

- 5, Inspecting operations and reporting violations of written radiation protection procedures.

i 6.

Membership in the Emergency Crew.

7.

Providing personnel decontamination.

8.

Providing training in radio!cgical safety.

1 2.1.11 Health Physics Compo_n.ect There is a Health Physics Component within the Radiological Safety organization.

The responsibilities of the Health Physics Component include the following:

1.

Providing technical bases, criteria, and methods related to health physics.

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April 27,1989 2-5 ANF-3830.0SI (6/89)

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'4 ADIRNCEDNUCLEARMMS CORPORATION

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SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227,' NRC DOCKET NO. 701257 1

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Providing for outside sources for aid an'd special services related to health physics and emergencies.-

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Performing compliance inspections.

' 4.

Membership in the Emergency Cadre.

5.

Membership in the ALARA Committee.

6. ~

Approving exceptions-to whole body exposure limits, if required and l,

justified.

4 7.

Reviewing Radiation Work Procedures.

8.

Providing professional advice and counsel concerning matters within his p

cognizance. -

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2.1.12 Criticality Safety Component -

-There is a Criticality Safety Component within the Radiological and Industrial L

Safety organization.

The responsibilities of the Criticality Safety Component include the following:

7 ll 1..

Providing' technical bases,' criteria, and methods related to nuclear 3

criticality safety' 2.

Preparing the Nuclear Criticality Physics Methodology Manual.

- 3.

Providing criticality safety determinations for designs and procedures,

3 including second party reviews.

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Providing professional advice and counsel concerning matters within his y

cognizance.

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' 5.

- Membership in the Emergency Cadre, j

6.

Performing compliance inspections.

7.

Approving Criticality Safety Specifications and Limit Cards.

All determinations concerning nuclear criticality safety shall be reviewed by a Second Party Reviewer who shall be knowledgeable in the technical data and qualified AMENOMENT APPLICATION 0 ATE.

PAGE NO:

l ANF 3830.051 (G/89)

ADMANCEDNUCLEARMMLS CORPORATION.

gup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.12'.7, NRC DOCKET NO. 701257 REv.

PARTI LICENSE CNDITIONS 24 in the techniques of criticality physics. Second party reviews shall be arranged by the Criticality Safety Component, and may be either from within the component or by an outside reviewer.

All nuclear criticality safety calculations and reviews shall be documented, and documents shall be held in permanent Company records. Calculational details, work sheets, etc., shall be held for a minimum period of six months following termination of the process or operation reviewed.

2.1.13 Manaaer. Reaulatory Comollance

The Manager, Regulatory Compliance, reports to the Manager, Safety, Security, and Ucensing, and is responsible for obtaining all licenses, permits, and amendments thereto necessary for plant operation that involve the safety of the workers, public, or environment. He is also responsible for the safegucrds program. He is responsible for ensuring that all licensing and permit requirements are appropriately implemented, and implementation adequately documented. This is accomplished through issuance of appropriate Company Policies and Standards, and by approval of certain implementing procedures. He is the Company interface with regulatory agencies, and will host audits by Regulatory Representatives and respond to any audit reports for the Company.-

~ 2.1.14 Vice President. Enaineerina Division The Vice President, Engineering Division, is responsible for engineering support of the fabrication of nuclear fuels, including the conduct of certain demonstrations involving special nuclear materials.

2.1.15 Manacer. Process and Eauloment Enaineerina All engineering activities to provide = maintenance engineering, methods

. engineering, process engineering, and design and construction of new or modified equipment,= and facilities are directed by the Manager, Process and Equipment Engineering, who reports to the Vice President, Engineering Division.

He is responsible for providing process specifications to establish limits wherein the fuel fabrication process can be operated, for providing design criteria, and Engineering Change Notices which specify the bases mquired for the design and.

const uction of new or modified equipment and facilities, and for providing manufacturing engineering support to the nuclear fuels fabrication plant. The latter activity includes maintenance engineering (to establish preventative / routine maintenance and instrument and equipment calibration requirements), methods engineering (to provide industrial y

l Apli27,1989

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• 2-7 ANF 3830.051 (6/89)

ADMSNCEDNUCLEARMRLS CORPORATION:

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SPECIAL' NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257

}

PART I LICENSE CONDITIONS REv.

24 engineering and product fabricability), equipment engineering (to implement the use of new and modified equipment), and process engineering (to provide process support and -

' development).

e He has the full authority required to assure that new or modified facilities are designed and constructed to operate within licensing and safety requirements.

1 2.1.16-Manaaer. Eauipment and Maintenance Enaineerina f

Plant engineering assistance for all process, utility, and safety systems is provided q

by the Manager, Egeipment and Maintenance Engineering, who reports to the Manager, Process and Equipment Engineering.

The Manager, Equipment and Maintenance Engineering, is responsible for the design and/or modification of new and existing equipment and facilities for Maintenance Engineering. He is also responsible for establishing preventative maintenance; routine maintenance: routine equipment inspection; instrument calibration schedules, procedures, and equipment; and instrument and system testing programs for all plant facilities and

. operations. This incluoes equipment and. systems installed to maintain personnel exposures to radiation and radioactive mater'als, as well as releases;of radioactive 1

7 materials to.the environment, as low as is reasonably achievable. Radiation protection -

Instruments'and equipment, the criticality accident and fire alarm systems, and the electrical power emergency generators are included in these programs.

1 L

a' 2.1.17 Manecer. Procesa Succort Enaineerina <

Process engineering activities are directed by the. Manager, Process Support-Engineering, who reports to the Manager, Process and Equipment Engineering.

The Managet, Process Support Engineering,is responsible for providing process g

L engineering support to the fuel fabrication p! ant. This includes the preparation of process parameter operating limits and process specifications. He provides technical support for welding operations and for developing improved welding methods. These activities are E

conducted within licensing and safety requirements.

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O WENDMENT AMCATON DATE April 27,1989 2-8 i

ANF-3830.05 I (6/89)

' i AIALANCED NUCLEAR FE,ELS CORPORATION l

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SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 i

I PART I - LICENSE CONDITIONS REv.

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2.1.18 Manager. Chemical and Ceramic Development The Manager, Chemical and Ceramic Development, is responsible for process development actMtles-for new and improved chemical and ceramic processes for preparing UOi, and for treating liquid and solid wastes. These activities are conducted within licensing and safety requirements.

2.1.19 Manaaer. Materials Research The operatidn of the Engineering Laboratory Operations (ELO) facility.ls directed by the Manager, Materials Research, who reports to the Manager, Fuel Research and Development.

The safe operation and control of facility activities, including the safety of the environs as influenced by the conducted activities, are the responsibility of the Manager, Materials Research.

l-Other responsibilities include preparation of operating procedures, training, and supervision of all activities involving radioactive materials within the ELO facility.

The Manager, Materials Research, has the full authority required to discharge his -

responsibi!! ties for safe operation of his facility.

L 2.1.20 Manaaer. Fuel Development and Testina The operation of the Fuel Cooling Test Facility (FCTF) (where reactor simulated flow tests involving a single fuel element are conducted) is directed by the Manager, Fuel Development and Testing, who reports to the Manager, Fuel Research and Development.

The Manager, Fuel Development and Testing, is responsible for the safe operation of the. FCTF within the constraints imposed by license conditions, Radiation Work Procedures, and Criticality Safety Specifications.

2.2 Personnel Education and Experience Reauirements Responsibilities and authorities of allline managers shall be provided in writing.

Hiring of managers and key professionals in plant operations, health physics, and nuclear criticality safety shall be subject to approval by the Vice President, Operations Division.

The Manager, Operations Richland, and managers in engineering and technical services functions which have responsibilities for the processing, storing, or handling of p

special nuclear materials, shall have a minimum of two years of experience in the nuclear

(,

industry, and a degree in Science or Engineering. There are certain other positions l

AMENOMENT APPUCAflON DATE.

PAGE NO.:

ANF.3830.051 (6/89)

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ADuhNCEDNUCLEARFLELS CORPORATION 3np.f

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 1

PART I - LICENSE CONDITIONS REv.

24

_ where a technical degree is not required such as the Manager, Maintenance.- In those f

- cases, the incumbent will have adequate job training, and technical support and overview will be available. Specific requirements for those key safety professionals whose meM responsibility.is in a safety. field are listed below.

l 2.2.1 Manaaer. Safety. Securitv. and Licensina i

The minimum qualifications of the Manager, Safety, Security, and Ucensing, shall t

be a'BS degree in a technical field with 10 years experience in the nuclear energy field, of which four shall have been in positions with nuclear safety responsibility.

1 L

2.2.2 Supervisor. Radioloalcal and Industrial Safety The minimum qualifications shall be a BS degree in a technical field, with five years experience in radiation safety, or, in the absence of a degree, then 10 years 7

L experience shall be requir.

i 2.2.3 Health Physics Technician The min'imum qualifications of certified Health Physics Technicians shall be a high school diploma with two years of radiation monitoring experience, or four years of similar experience in lieu of a high school diploma. Health Physics Technicians shall complete

'a formal Advanced Nuclear Fuels training program, or shall have had equivalent prior training;'they shall become proficient in Advanced Nuclear Fuels radiological safety programs, criteria, specifications, procedures, and routines.

2.2.4 Health Physics Specialist

- The minimum qua!ifications of at least one member of the Health Physics Component shall be a BS degree in Science or Engineering with five years experience in radiation protection, including at least two years of radiation protection experience allied with nuclear fuel fabrication.

2.2.5 Criticality Safety Specialist The minimum qualifications of at least one member of the Criticality Safety Component, as well as for each Second Party Reviewer, shall be a BS degree in Science or Engineering with at least two years of experience in nuclear criticality safety analysis.

AMENDMEN1 APPUCAflON DATE PAGE NO ANF-3830.051 (6/89)

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,o SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 -

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i PART I-LICENSE CONDITIONS REv.

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2.2.6 Manager. Regulatory Compliance

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The minimum qualification for the Manager, Regulatory Compliance, shall be a BA

-1 or BS degree in Science or Engineering, plus eight years experience in the nuclear field of which four years experience shall have been in positions with nuclear' safety, or

}

radiological safety responsibility.-

-2.3 Safety Review Committees 2.3.1 HeaHh and Safety Council Advanced Nuclear Fuels has established the Health and Safety Council which convenes monthly.at Advanced Nuclear Fuels's fuel manufacturing plant in Richland, Washingtonito review various aspects of the safety program, including:

1.

Industrial safety practices and trends.

2.

Radiological safety practices and trends.'

3.

Criticality safety practices and trends.

4.

Adequacy of emergency planning and procedures (including results of 4

tests and drills),

p 5.

Overall safety awareness and attitude of employees and programs for

^

promoting improvements.

6.

Unusual occurrences and accident' ' investigations, including recommendations to prevent recurrences.

7.

Status of Council related action items.

q j!j Membership of this Councilincludes:

o 1.

Vice President, Operations Division (Chairman).

2.

Supervisor, Radiological and Industrial Safety (Secretary).

C e 3.

Manager, Safety, Security, and Ucensing (Co-Chairman).

4.

Vice President, Operations Division, staff.

5.

Vice President, Engineering Division, and his staff.

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• April ",1989 2H R

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ANF 3830.051 (6/89)

l AD%$NCEDNUCLEARMELE CORPORATION '

g7.5 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227,' NRC DOCKET NO. 701257 PART I LICENSE CONDITIONS REV.

24-

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6.

Appropriate managers wl thin other organizations.

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7.

Key safety engineers and specialists.

Designated members of the Council make monthly inspections of buildings and-grounds for housekeeping and safety practices, and report the findings to the Council at the monthly meetings. Findings are assigned to individuals for resolution and are held open until resolved.

2.3.2 ALARA Committee-

_ _ An ALARA (6s Low as Beasonably 6chievable) Committee maintains awareness of trends in employee radiation exposure and radioactivity content of effluent releases.

The membership of the Committee includes:

1,

_ Manager, Regulatory Compliance (Chairman).

2.'

Health _ Physics Specialist (Secretary).

3.

Supervisor, Radiological and Industrial Safety.

4.

Manager, Equipment and Maintenance Engineering.

5, Manager, Plant Maintenance.

16.

Manager, Plant Operations.

'7.

- Manager, Process Support Engineering.

The ALARA' Committee shall convene at least semi-annually. The ALARA Committee shall issue a formal report at least annually to the Health and Safety Council

-reviewing employee exposures and effluent release data to determine:

1.

Trends in personnel exposures and effluents.

2.

If personnel exposures or radioactive effluents might be lowered under the concept of ALARA.

3.

If equipment for effluent and exposure control is properly designed, used, maintained, and inspected.

I auenouent appucation oats.

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gggy 3gg N2 ANF 3830 051 (6/89)

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~I ADMANCEDNUCLEARPERLS CORPORATION 3yp.2 ~

h 1SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 v

PART I - LICENSE CONDITIONS:

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3 24 Their reports shall include review of required audits and inspections pwformed 1

during the past year, and review of employee external exposures, bloassay. results,-

unusual occurrences, effluent releases, in-plant airborne radioactivity, and environmental monitoring.

2.4 Trainino In addition to normal on-the-job training, employees are Instructed in radiation l

protection and criticality _ safety requirements and procedures, industrial. safety, fire protection, and emergency procedures. _The degree of training is commensurato with each employee's position in the Company (related to general and special responsibilities),

and with the extent of the employee's contact with radioactive and fissionable materials.

The minimum safety related training requirements for various employee positions are J

l established by the Safety, Security, and Ucensing Department, including training and I

retraining schedules and training course content. Employee instruction is provided by -

personnel knowledgeable in the varbus training topics. All formal training is documented, and records are maintained by the Safety, Security, and Ucensing Department.

2.4.1 Initial Trainino i

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Each employee is provided initial instruction adequate to allow him to safely start L

on-the-job training; they are provided tho full instruction within two weeks after starting E

work. Prior to assignment to independent operatlon, each employee is required to have o

been instructed in radiation protection, criticailty safety, and emergency requirements and procedures as appropriate to his position.

2.4.2 Followuo Trainina q

h When changes are made in radiation protection, criticality safety controls

(procedures, specifications, etc.), or in emergency procedures, each employee affected -

=

.ls promptly informed and properly instructed.

L Safety topics are routinely discussed in monthly safety meetings. Additionally, each employee routinely working with special nuclear material receives annual refresher instruction as part of Advanced Nuclear Fuels continuing program in radiation protection and criticality safety awarenoss. The effectiveness of this annual refresher training is j

determined by giving the employees a= written examination and reviewing the correct answers to the questions at the end of the test.

2.4.3 Health Physics Technician Trainina p

Health Physics Technicians are given special training related to their radiation I

protection assignment. Previous training is accepted if considered equivalent to the L

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ANF 3830.051 (6/69)

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ADMANCEDNUCLEARPUELS CORPORATION

'l m p.g l SPRCIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 PART I - LICENSE CONDITIONS L

= REv. '

l 24 Advanced Nuclear Fuels training program. Despite previous acceptable training, the

. Health Physics Technicians are required to become proficient in Advanced Nuclear Fuels

radiation protection and criticality safety programs, criteria, specifications, procedures, and routines, as demonstrated by successfully passing an Advanced Nuclear Fuels certification examination within six months after_ employment as a Health Physics Technician, in addition, refresher training is provided to all Health Physics Technicians annually.

2.4.4' Trainina Evaluations Employee awareness of, and conformity to, safety requirements and procedures, f

g as well as the effectiveness of safety training programs, shall be evaluated at least L..

monthly by the Radiological Safety Component for radiation protectioni and by the Criticality Safety Component for criticality safety. These Advanced Nuclear Fuels staff i

members have the authority to require retraining of employees. These evaluations chall' be documented along with actions required by them, j

2.5 'soeratincq Procedures. Standards and Guld.e_g.

t Advanced Nuclear Fuels conducts its business in accordance with a system o,f Standard Operating Procedures, Company Standards, and Policy Guides. - Advanced i

- Nuclear Fuels is committed to controlling activities involving special nuclear materials in 1

accordance;with these approved written procedures, standards, and guides. - These

~

e documents'are preparodi reviewed, revised, approved, and implemented in accordance with the Approval and Responsibility Matrix (Figure 1-2.3) Plant and facility managers _are responsible for assuring compliance with all pertinent radiation protection and criticality p

safety procedures, specifications, and practices within their respective facilities. Violations l

of radiation protection or criticality procedures, or specifications which are of repetitive or serious nature, are subject to disciplinary action, e

The Supervisor, Radiological and Industrial Safety, is responsible for assuring that Health Physics Technician activities are conducted in accordance with established and approved procedures, methods, and frequencies.

l 2.6 Internal Audits and Inspections l: :o -

Audits and inspections are conducted to determine that plant operations are conducted in compliance with regulatory requirements, license conditions, and written procedures. These audits and inspections apply to radiation protection, criticality safety, hazardous chemical safety, fire protection, and environmental protection.

O AMENOMENT APPLICAttON DATE-PAGE NO ANF.3830.051 (189)

I

e ADMANCEDNUCLEARFUELS CORPORATION g p.2 C iSPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 q:'

y

' PART l'- LICENSE CONDITIONS REVc 24 r

2.6.1 Radiation Protection As part of their normal activities, the Supervisor, Radiological and Industrial Safety,

.end Health Physics Technicians perform daily inspections as a part of their procedures-j for collecting air samples and performing radiation and contamination surveys of all areas of the plant where uncontained radioactive materials are stored, processed, or otherwise ~

l handledi Detected infractions of radiation protection procedures, exposure controls, and 4

sound radiation protection practices are corrected on the spot as part of a continuing.

education effort in their field of expertise. Serious infractions and noncompliance with license conditions are documented and distributed to the respective facility management, and to the Manager, Safety, Security, and Ucensing, The Health Physics Component of Safety, Security, and Ucensing makes monthly 1

- audits.of radiation protection practices and exposure controls. These _ audits are made in accordance with a written plan. Results of these audits are documented, including any j!

l~

recommended corrective actions, and distributed to the respective facility management, L

and to the Manager, Safety, Security and Ucensing. The Health Physics Component.shall E

- followup on each detected discrepancy lh subsequent audits until there is satisfactory -

L

. resolution.

t q

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2.6.2 - Criticality Safety

{

. hile performing their ~ daily duties, Health Physics Technicians are alert for W

infractions of criticality safety specifications and limits.

Detected infractions are communicated to the Criticality Safety Component.

The Criticality Safety Component conducts monthly audits of the various criticality safety control systems, (e.g., moderation control, enrichment control, neutron absorber 1

inspections, process alarms, and trips related to criticality safety, etc.). The Criticality-J Safety Component also audits new installations and modifications to equipment and L

processes prior to their operation with special nuclear material. These audits are L

performed in accordance with a written plan, and reports of the findings are submitted to the respective facility manas ament, and to the Manager, Safety, Security, and Ucensing.

l The Criticality Safety Compo ient shall followup on each detected infraction in subsequent l

audits until there is satisfactory resolution.

i l

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,,,,y,,,

2., 3 ANF 3830.051 (G'89)

L

a:

ADnU0C8DNUCLEARRELS CORPORATION gnp.;;

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO.1701257 PART I LICENSE CONDITIONS REV.

24 2.6.3. Hazardous Chemical Safety As part of their normal duties, the Supervisor, Radiological and Industrial Safety, land the Industrial Hygiene Specialist make periodic inspections of all areas of the plant where_ hazardous chemicals are stored, procened, or otherwise handled. Detected discrepancies of exposure controls, and sound industrial hygiene practicas are corrected on-the-spot as part of their continuing educational effort.

The Industrial Hygiene Specialist also monitors the levels of the various chemicals that are present on our plant. site in accordance;with a written Industrial Hygiene Monitoring Program Plan. Results of these inspections are documented, including any

- recommended corrective actions, and distributed to the respective facility management, and to the Manager, Safety, Security, and Ucensing. The industrial Hygiene Specialist shall followup on each detected discrepancy in subsequent inspections until theri e satisfactory resolution.

- 2.6.4 Fire Protection The Inspection Committee of the Richland Health and Safety Council performs monthly inspections of selected areas of the Richland facility. These inspections include housekeeping-concerns, as well as industrial safety concerns. A facility with good

. housekeeping (combustible wastes properly contained, emergency exits accessible and unc' uttered, fire extinguishers properly maintained),will experience fewer and less serious

fires.. Results of these inspections are documented,. including any: recommended corrective actions, and distributed to the respective facility management. The Inspection Committee shall followup on each detected discrepancy and recommended corrective action in subsequent inspections until there is satisfactory resolution.

The Radiological and Industrial Safety Supervisor ensures that a monthly inspection is made of all plant fire extinguishers in accordance with a written plan.

Resultsiof these inspections are documented, and any detected discrepancies are corrected during the inspection.

2.6.5 Environmental Protection Inspections The Industrial Hygiene Specialist monitors the levels of regulated material released to the environment in accordance with a written plan. The Health Physics Technicians are responsible for the field sampling under the guidance of the Industrial Hygiene Specialist. Results of this monitoring are documented and distributed to the Manager, Safety, Security, and Licensing.

9

,,,,,,m,,,

ANF-3830.051 (6/89)

3.

• ADunlCED NUCLEAR RELS CORPORATION '

jnp.y SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 -

i PART I - LICENSE CONDITIONS.

REV.

24 The Health Physics Component makes monthly lInspec;5ns of environmental i

< protection practices and exposure controls. These Inspections are mace in accordance with a written plan. Results of these inspections are documented, including any recommended corrective actions, and distributed to the respective facility management, and to the Manager, Safety, Security, and Ucensing, The Health Physics Component shall followup on each detected discrepancy and recommended corrective action In subsequent inspections until there is satisfactory resolution,

'i 2.7 Investiaations and'Reportino of Reportable incidente in addition to, and/or in line with, the reporting requir'ements specified in other 4

sections of this Application, or in Regulatory Guide 10.1, the following reporting schedule la adhered to:

1.-

Employee, former employee, or terminating employee radiation exposure

'information'shall be reported to individuals in accordance with 10 CFR L,

19.13(b)(c)(e);;

L 2.

Personnel exposure upon termination of employment or work shall be-E

.i submitted to the NRC in accordance with 10 CFR 20.408(b) and 10 CFR

- 20.409; 3.

Employee exposures and monitoring information shall be reported to the NRC in accordance with 10 CFR 20.407;

• a

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4.

Overexposures and excessive levels and concentrations shall be reported to the NRC In accordance with 10 CFR 20.405(a) and 10 CFR 20.409;_

5.

The NRC shall be notified of incidents in accordance with 10 CFR 20.403(a)(b);

6.

Theft, or loss of licensed material, shall be reported in accordance with 10 CFR 20.402(a)(b)(c);

7.

Effluent monitoring information shall be reported to the NRC in accordance

'}

with 10 CFR 70.59; A

8.

In the event that the radioactivity in plant gaseous effluents exceeds 50 microcurles per calendar quarter, a report shall be submitted within 30 days to the NRC' (Director, Office of Nuclear Material Safety and Safeguards, with a copy to NRC Region V Office of l&E), identifying the O-cause for exceeding this value, and the corrective actions to be taken to reduce release rates; Autwouse appuccion oue.

I 989 M

ANF-3830.051 (fv89)

~

>a.

ADMANCED NUCLEAR M,ELS CORPORATION:

\\ny,y '

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 -

PART I - LICENSE CONDITIONS" REV.

24-c 9.

If parameters important to dose assessment of the 'public relative to gaseous effluents from the plant change, a report shall be submitted to the -

NRC (Director, Office of Nucicar Material Safety and_ Safeguards, with a -

copy. to NRC Region V-Office of I&E) within 30 days identifying the, changes in parameters, and providing an estimate of the resultant change -

in cose commitment; 10.

Reports of excessive radioact!ve contamination on packages of radioactive material, and excessive radiation levels external to the packages on receipt, shall be reported to the NRC immediately in accordance with 10 CFR 20.205(b)(2) and 10 CFR 20.205(c)(2);

11.

Accident reports on transportation of licensed material shall be reported to the NRC and DOT in accordance with 10 CFR 71.5(b) and 49 CFR

.171.15 and 49 CFR 171.16.

. The Manager, Safety, Security, and Ucensing, has_ the_ responsibility for investigating,_ recording, reporting, and following up on actions taken for raportable Incidents in accordance with NRC reporting requirements.

2.8 - Records in addition to, and/or in line 'with, the documentation requirements specified in

, other sections of this Application and 10 CFR 20.401, the following records are retained:

1.=

Personnel radiation exposure histories and determinations of personnel-

=

accumulated dose.- (Information on personnel prior radiation exposure -

histories is obtained in accordance with 10 CFR 20.102(c)(1).)

2.

Employee radiation exposures, external and Internal, including dose evaluations.

3.

Health Physics Technicians' radiation and contamination surveys, including room air and exhaust air monitoring.

4.

Environmental surveillance data and waste discharge reports.

5.

Incident investi;;ation reports.

6.

Employee Indoctrination, training, and retraining reports.

J 7.

Facility and process acceptance tests.

AMENDMENT AppuCATION DATE:

PAGE NO.

ANF-3830.051 (6/89)

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' ADuhNCEDnNJCLEARRELSCORPORATION j'

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i l 1SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 A4

. PART I - L1 CENSE CONDITIONS REV.

24-o.

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' 8.

Radiation safsty, health physics, and criticality safety inspection reports; i

9.

Richland Health and Safety Council meeting reports.

~

10.

ALARA Committee reports.-

11.

Criticality doslmeter inspection reports 12.

Reports of test results for the criticality accident alarm system..

13.

Reports of test results for the emergency electrical power supply system.

I 1

14.

Radiation detection instrument maintenance and calibration; also for the neutron detectors of.the criticality accident alarm system.

O

15..

Results'of sealed source leak checks.

e!

+

18.

HVAC system monitoring and test results.

17.

. Engineering Change Notices (ECN).

18.'

Revisions to Nuclear, Criticality Safety Analysis.

Such records are maintained for a minimum period of five years, unless there are 6

legal requirements for longer retention periods for specific records, g

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' Q( " T PART I - LICENSE CONDITIONS REv.

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24 1

Chapter 3 RADIATION PROTECTION 3.1 Special Administrative Meauirements 1

3.1.1 'ALARA Pollev Advanced Nuclear Fuels's policy is to conduct its business in a manner such as to assure that its facilities are in compliance with radiatiori end other nuclear regulations, and that its operations will not be detrimental to the environs. In implementing this policy, Advanced Nuclear Fuels shall assure that radiation exoosure to persons both in plant and off-site is maintained as low as reasonably achiMble (ALARA). In providing this assurance, conditions of applicable NRC and State lluenses, and other regulatory permits or licenses, shall be complied with, and regard shall be given to applicable NRC regulatory guides and industry standards.

Responsibility for establishing and assuring adherence to this policy shall rest with j

the President, Advanced Nuclear Fuels Corporation. This policy shall be implemented q

L through appropriate delegations to Vice Presidents responsible for facilities procesr8ng 1

O ct handling radioactive and nuclear materials, l

in order to facilitate implementation of this policy, key positions in organizations Involved with facilities processing or handling radioactive or nuclear materials shall be filled by persons knowledgeable of, and experienced in, the nuclear industry, and the responsibilities under this policy shall be identified in writing. Each responsible manager shall be required to know, understand, and carry out the provisions of this policy, and the procedures for its Implementation.

3.1.2 Radiation Work Procedurg l

Radiation Work Procedures (RWPs) are prepared by Radiological and Industrial l

Safety, and establish the radiological safety requirements of all work (operation and maintenance) involving radiation and/o radioactive materials. The RWP shall be immediately available to personnel working with the material.

RWPs are approved in accordance with Figure i-2.3.

RWPs cover such items as:

1.

The identification numbar of the procedure; 2.

A description of the nature and extent of the work to be done and the location of the work;

,O AuthoutNT APPucAfeoN DATE PAGE NV ANF 3830.051 (fv89' l

i s

mnRJCLEARFIREACORPCRATCN AN52 l

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227. NRC 6CCKET NO. 70-1967 s

t PART I - LICENSE CONDITIONS R E V.

13 3.

A description of types and levels of rodlotion exposures and contamination that may be encountered;

4.. A statement of the exposure rates or. instructions for self-monitor-ing for exposure.*otes; 5.

Personal' survey requirements and protective clothing requirements; 6.

Personal dosimetry requirements; 7.

A statement of the respiratory equipment required for entry into an airborne radioactive materials oreo.

3.2 Technical Requirements 3.2.1 Controlled Arcos All rodlooctive materials at Advanced Nuclear Fuel's nuclear fuel fabrica-tion plant are stored and processed within a controlled access area. Access is controlled by Advanced Nuclear Fuel security personnel at all personnel and vehicle entrances in accordance with a phyt.ical security plan.

q j

3.2.l.1 Restricted Areas Radioactive Material, airborne radioactivity, radiation and high radiation arcos, as defined by 10 CFR 20, are identified and their boundorles are visibly marked.

Signs are placed denoting these creas so that at least one sign is visible from any approach.

Radiation Work Procedures for the respective creas specify the existing or potential conditions and the protection measures required in these areas.

3.2.1.2 Clean, Intermediate and Contaminated, Radioactive Materials /Rodio-

, tion Areas Noncontaminated Radioactive Material Areas (clean areas) are separated -

from the Contaminated Rodlooctive Material Areas (contaminated areas) by Intermediate creas. Intermediate orcos are identified and their boundorles are visibly marked.

Special res'rictions or procedures required before ertry to i

intermediate or clean areas from a contaminated area are posted.

3.2.l.3 Change Rooms and Step-Of f Areas Change rooms nre divided into contaminated, intermediate and clean areas to facilitate controlled entrance to and egress from contaminated areas.

Step-of f pods are provided when exiting contaminated creas. Separate toilet AMENDMENT APPLICATION D ATE:

P AGE NO.:

l July 1987 3-2 XN NF.F01422 (6/67)

ADuhNCEDNUCLEARMMSCOR, )RATKW Q.,2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257

.U PART l-UCENSE CONDmONS REv.

24 3.

Contaminated Radioactive Material.Attg. Visible contamination in these areas and/or smearable contamination in excess of 10,000 dpm/100 cm' (alpha) will be cleaned up immediately. These limits are not applicable to nonroutine tasks being conducted under special controls.

4.

Plutonium Contamination. Plutonium contamination is limited to 100 dpm/100 cm' average fixed, 300 dpm/100 cm' maximum fixed, and 20 dpm/100 cm' removable.

3.2.6.2 Release of Personnel. Materials. Eauipment. FacilRies. and Shloments Contamination surveys are performed on all personnelleaving contaminated areas, on all materials, equipment and facilities to be released from radiation protection requirements, and on all incoming and outgoing shipments of radioactive material *.

l Release of equipment and packages from the plant site, or to clean areas on site, shall I

be in accordance with NRC guidelines dated May 1987 (see Appendix A).

1.

Personnel. Personnel contamination surveys are conducted according to the following schedule:

a.

All persons leaving contaminated areas are required to survey themselves for contamination with survey instruments located at respective step-off areas after removing protective clothing, and prior to leaving the step-off area.

b.

Personnel are not released to eat or leave the respective facility, except with the approval of the Radiological tad Industrial Safety i

Supervisor and the respective facility manarer, if their personal j

clothing is contaminated in excess of 200* t pm/100 cm' (alpha) direct, or skin is contaminated in excess c! 200* dpm/100 cm' i

(alpha).

c.

Protective clothing is not reused if the removable alpha O

contamination exceeds 1000 dpm/100 cm' after laundering. During the workday, protective clothing in a contaminated area will be j

changed if contamination is visible (>10,000 dpm/100 cm' alpha).

i 200 dpm/100 cm (alpha) represents the practical lower detection level for most e

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direct-reading contamination survey instruments, meermi amicciou our April 27,1989 39 ANF-3830.051 (WB9)

L

j s

ADuhNCEDNUCLEAMMELSCORPORATCN ANF-t c

-1 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-122't, NRC DOCKET NO. 70-1257 l

1

)

PART I - LICENSE CONDITIONS'

'1 R E V.-

3 o

13 j

I 2.

Materials, Equipment, Focilities and Shipments.. Contamination i

surveys are performed by Meoith Physics Technicians on oil l

materials and equipment removed from contaminated creas, and on areas or facilities to be released from rodlotion protection require-ments. Limits for release ore:

1 Smeorable:

Less than or equal to 220 d/m/100 cm2 alpho Fixed:

500 d/m/100 cm2 olpho 4

in special cases, the NRC guidelines contained in Appendix A to j

this chopter may be ~ utilized.

3.

Shipments of rodlocctive materials arriving at the f acility are surveyed to the requirements of 10 CFR 20.205. All outgoing shipments of rodlooctive materials are packaged or.d surveyed in occordance with 10 CFR 71 and 49 CFR 173.443.

a'l 3.2.7 Bloossoy Progrom Bloossoy measurements 4holl be conducted so os t'o assure comrPence I

'with 10 CFR 20.103 and the ALARA policy.

The bloossoy progrom will normally be used os a verificotlon of contamination control, but may in 1

occident or obnormal situations be used to estimate the uptoke by on 1

individual or estimote the exposure that on individual has or will receive. The-normal bloossay progrom shall consist of a monthly urinolysis and yearly lung

-j

-count.

The lung counts shall be schedued among the workers-throughout the a

year (as possible) to provide a continuing status of the plant environment.

Additional-diagnostic assays may be performed on workers who have entered on airborne radiooctivity creo os indicated by air sompling results.

The pertinent elements of the Advanced Nuclear Fuels bloossoy program I

are outlined below, l.

Employees routinely working in contaminated area submit mmthly urine specimens for routine uranium analysis.

2.

Employees routinely working in contaminated arco shall receive In-vivo examinations at least annually.

3.

If the most recent quarterly overoge of the 91rborne uranium concentration for any work crea exceeds 25 percr.nt of the respec-tive DAC, the frequency of sompling and the type of bioossay measurements for workers in that work creo shall be modified to that given in Table 3 of Regulatory Guide 8.11, " Application of Bioossoy for Uranium," June 1974.

t 9l AMENDMENT APPLIC ATION DATE:

P AGE NO.:

July 1987 3-10 xN NF F01422 $57) 4 h

i p

' ADMANCED ANCLEAR MEl3 CORPORATION.

m p.g p - SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 V

PARTI LICENSE CONDITIONS REv.

l l.

24 l

j.

CHAPTER 4 NUCLEAR CRITICAUTY SAFETY Nuclear criticailty safety shall be assured through both administrative and technical practices. Administrative practices clearly include establishing the responsibilities for nuclear criticality safety, providing adequate and skilled personnel, preparing written standards - and procedures, process analysis, materials and operational controls, operational and incident reviews, and emergency procedures. Technical practices include oxercising control over the mass and distribution of significant quantities of special nuclear materials, and the mass, distribution, and nuclear properties of all other materials

{

with which special nuclear materials are associated.

4.1 Administrative Conditions t

The responsibilities and authorities for nuclear criticality safety are as described in Chapter 2 of this Application, as well as the professional requirements for criticelity l

safety personnel.

l 4.1.1 Process Analyses (Critically Safe Determinations)

Before any operation with special nuclear material is begun or changed, it is determined that the entire process will be subcritical under both normal and credible abnormal conditions, and within the technical requirements specified in Section 4.2.

Criticality safety analyses are performed on all applicabic processes in accordance with Section 2.1.12, and all determinations of nuclear criticality safety are reviewed and approved by a second-party reviewer in accordance-with the requicments specified therein.

Criticality safety analyses are performed and/or reviewed by Advanced Nuclear Fuels or contractor personnel who meet the professional requirements specified in-Section 2.2.5.

Records of criticality safety analyses of processes shall be documented and retained in accordance with Section 2.1.12. Additionally, basic criteria, data, methods, and references pertaining to nuclear criticality safety shall be documented and retained in Company files by the Criticality Safety Component.

Operations, in which nyalear criticality safety is pertinent, are govemed by written procedures, and all persons participating in these operations are required to be familiar with the procedures. Each major process step is described by a written Process Spec!!ication,0lch, together with the respective Criticality Safety Specification (CSS),

provides the basis for written Operating Procedures.

O avioite appucate cave.

D M u t 1989 41 ANF-3830.051 (6'89)

ADuhNCEDNUCLEARMELSCORPORATICW g.y SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET No. 701257

)

]

PART I-LICENSE CtaDITIONS REv.

24 CSS's are prepared in a standardized format containing the following information:

work location, equipment description, special nuclear material description (element, isotope, enrichment, form. density), operation involved, control limits, moderator and reflector restrictions, spacing restrictions, criticality safety proceduren, date, and i

approvals.

?

CSS's are maintained up-to date.and reflect all approved process and/or equipment changes, Additionally, they shall be kept current by annual reviews, and updated as appropriate.

CSS's are prepared based on limits established in criticality safety analyses.

s The CSS's are accepted and approved in accordance with Figure 12.3.

Copies of current CSS's are maintained in the work or storage areas in which the respective specifications apply.

)

4.1.2 Criticality Safety Standards Advanced Nuclear Fuels has established, and maintains, a system of written

' ~

Criticality Safety Standards for processes, equipment, and facilities involving special nuclear material. These Standards are prepared and maintained by the Manager, Regulatory Compliance, and are approved and accepted in accordance with Figure 12.3.

These standards shall be kept current by annual review, and updated as appropriate.

j 4.1.3 Fisalle Content Verification

'l The tissile isotope content of all incoming special nuclear material is verified by gamma energy analysis techniques or laboratory analysis of representative samples prior I

to the conduct of any activity other than storage.

4.1.4 Special Nuclear Material Control The movement of fissionable materials is controlled. The CSS's describes the materials control practices, including the following requirements:

1.

Workstations, procedurally controlled only on the basis of a safe mass of material, are limited to one safe batch, where a safe batch is defined as no more than 0.45 of the minimum critical mass of the material in process.

)

l April 27,1989 4-2 l

ANF-3830.051 (r>'89)

n

~

. AD%UMDMJCLEARFIRLC CCRPCRATION ANF-2 i

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227. NHC DOCKET NO. 70-1257 1

j

.p m

U PART I - LICENSE CONDITIONS i

p REV.

13 J

2.

No more than one safe botch may be moved at one time when introducing or removing material from o work station.

j 3.

Individual safe-batches are spaced a specified minimum distance aport.

.j 4.

A record is maintoined of the special nuclear material inventory at each mass limited work station.

l These requirements do not apply in systems controlled by geometry,

)

moderation, or fixed neutron absorbers (see Section 4.2).

4.l.5 Labeling of Special Nuclear Material J

Insofar as practi:ol, all special nuclear material in the plant is identified with distinctive labels.

When possible, the label is applied to the outer container of special nuclear material. When such labeling is not practical, as for fuel pellets outside of containers, each item is identified by identification coding posted in the immediate vicinity of unlobeled items.

l.

Content.

The label or sign shows, as appropriate, the type of h]/

material, form, enrichment, gross, fore and net weights, element or

(

fissile isotope weight, fuel identification number, date, and initials of. person preparing the label.

2.

Segregation.

Materials of.dif ferent enrichment, physical and/or chemical form, and isotopic content are kept segregated until combination of different materials is required in the process.

4.1.6 Posting of Special Nuclear Material Locations Each location where speciol' nuclear material is handled, processed, transported or stored is identified by a distinctive symbol which will be observable from all approaches at a distance at least equal to the spacing requirement from other special nuclear material.

For work locotions separ-ated from other areas by partitions, walls, etc., posting on the opposite side of the obstruction will indicate the spacing firnit requirements for special nuclear material in that area.

In addition to the symbol, the location is posted with a sign showing limits specified in the respective Criticolity Sofety Specification, including type and form of material permitted, allowable quantity (containers, pieces, weight, or volume), restrictions on moderators, required spacing f rom other special nuclear material, and the applicable Criticality Safety Specification number.

~O jV'

~

AMENDMENT APPLICATION DATE:

P AGE NO.:

g XN-NF FOl 822 (6/8A

ADMSNCEDNUCLEARMELSCORPORATION m7 5 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257

)

1 PART I LICENSE CONDITIONS REV.

24

)

4.1.7 Qonfirmation of Analysis Assumgii901 Prior to the introduction of special nuclear material into a new operation or process, a criticality safety analysis will be performed, and the Criticality Safety Component shall inspect the respective facility and/or equipment and confirm that the 1

assumed controls are in place and/or functional. The results of these inspections shall i

be appropriately documented.

4.2 Technical Practices Wherever practicable, criticality safety will depend upon equipment designs where dimensions are limited, rather than upon decisions or actions of people. Wheie this is not practicable, reasons for not using favorable geometry shall be documented as a part l

of the criticality safety analysis. The following criteria form the bases for criticality safety controls.

4.2.1 Double Continnent y Policy

Process and equipment designs and operating procedures in' corporate sufficient factors of safety to require at least two unlikely, independent, and concurrent errors, accidents, equipment malfunctions, or changes in process conditions before a criticality accident is possible.

4.2.2 Utnits on Maximum Multiolication Factors i

The maximum evaluated neutron multiplication factor at normal and credible

- i abnormal conditions shall not exceed k, as defined below.

7 The maximum allowable multiplication factor will be calculated from the expression:

k, = k, - A k, - A k, where:

k,,

The value of k,,, that results from the calculation of benchmark

=

i experiments using a particular calculational method. ' The value represents a combination of theoretical techniques and numerical data.

A k,.

The uncertainty in the benchmark experiments, including random

=

and systematic errors (blas) within the range of parameters encountered in the equipment design.

au ~oueura m ' '" "

April 27,1989 44 ANF.3830 051 (&B9)

+

i

• ADMAMMDMJCLEARFRELSCORPORATION

,n p.g n

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 U

PART l LICENSE CONDITIONS REv.

24 CHAPTER 6 SPECIAL PROGRAMS 6.1 Proprotarv information With application for license amendment dated June 12,1985 for operation of a dry conversion process, Advanced Nuclear Fuels submitted copies of document XN-NF 837, Part II, "Ucense Amendment Application, Dry Conversion Process, Proprietary i

Supplement," dated June 1985, and requested that it be withht'd from public disclosure pursuant to 10 CFR 2.790. An accompanying affidavit dated June 13,1985 was also submitted. The U.S. Nuclear Regulatory Commission (NRC) did determine that the submitted document did contain trade secrets or confidential or proprietary commercial information (letter, R. E. Cunningham to C. W. Malody, dated July 19,1985). Amendment No. 26, dated November 7,1986, was subsequently issued permitting operation, and no additional conditions of license were imposed.

6.2 Occupational Safety Advanced Nuclear Fuels follows the current American Conference of Governmental Industrial Hygienists (ACGlH), Washington Industrial Safety and Health Administration O-(WISHA), and the NRC maximum permissible concentrations, threshold value limits, and permissible exposure limits for radioactive and hazardous chemicals in the design and operation of its fuel fabrication facility, in case of a known release, Plant Operations personnel will contact Safety, Security, and Licensing personnel to ascertain the concentration levels and the recommended personnel protective equipment required for cleanup operations to proceed.- Safety, Security, and Licensing personnel conduct routine or periodic surveys, as appropriate, to determine the concentrations of routinely utilized radioactive and hazardous chemicals, 6.3 Emeroency Utilities 6.3.1 Emeroency Electrical Power Sygpjy Turbine generator sets are instalied to provide emergency electrical power to operate the Criticality Accident Alarm System, selected exhaust fans, telephones, radiation detection instrumentation, critical process equipment, and also provide emergency lighting.

These generators are tested at least monthly for proper startup and operation.

Functional tests consisting of tying the generator to a normal emergency load are performed at least annually.

April 27,1989 6-1 ANF 3830.051 (&B9)

3 V

MMbCLEAMMRLSCORPCRATICN ANF-3l

?

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1267 PART I - LICENSE CONDITIONS REV.

13 6.3.2 Emergency Backup Water Supply The water supply to the Advanced Nuclear Fuels manufacturing facilities is furnished by the City of Richland through separate 10-inch and 12-inch mainlines connected into a loop feeding the plant fire loop.- The City of Richland estimates the flow at the fire loop to be 1600 gpm at 40 psi through each line, resulting in 3200 3pm of 40 psi from the two lines.

A more conservative estimate of reliable, om table flow of 2500 gpm at 40 psi provides ample supply for hose lines and exhaust ventilotion filter deluge protection. Normal UO2 Building water needs are about 200 gpm.

The source of water for Richland is the Columbio River.

Primary backup is furnished by a 15 million gallon equalizing reservoir on a bluf f south of the City at an elevation of 545 feet._ Wells, which were the earlier source of water for the City before the construction of the present water-filtration plant on the river, have been kept in condition as a seconoary backup source.

6.4 Radlooctive Waste Monogement 6.4.1 Llquid Wastes

,<adioactive and chemical wastes from the process and laboratories are.

i routed to the Process Chemical Waste Storage Lagoon System.

Based on the chemical and radioactive (uranium) content the lagoon waste may be processed through the Lagoon Uranlum Recovery (LUR) Facility.and/or the Ammonio Recovery Facility prior to being sompled and released to the sewer system.

6.4.2 Solid Radioactive Waste Uranium-contaminated solid waste is segregated into noncombustible and combustible types and is stored either in a warehouse or other designated :.rea within the controlled access area.

Containers used for this purpose are n

L adequately sealed and appropriately labeled prior to being stored, in the event l-that such containers of waste are stored outdoors for extended periods of time, their physical integrity shall be visually inspected and the accumulation shall be surveyed for external radioactive material contamination at least l

quarterly, and records of such inspections and surveys shall be maintained.

Combustible waste may be processed through the Solid Waste Uranium l

Recovery (SWUR) facility to obtain volume reduction and the recovery of uranium.

Noncombustible waste is storea until shipment to a permanent waste disposal site. Waste packaged for disposal is not allowed to remain in storage for extended periods but is scheduled for disposal on a current basis, E

depending upon generation rate and cost-ef fective shipment sizes.

O AMENDMENT APPLICATION DATE:

July 1987 6-2 4

XN NF50b822 (6/87)

s ADuhMMDMJCLMARMELSCORPORATICW gnp.2 t

p SPECIAL NUCLEAR MATERIAL LICENSE NO; SNM 1227, NRC DOCKET NO. 701257 PART II - SAFETY DEMONSTRATION REV.

J 22 11.3.31

.Manaaer. Fuel Development and Testina - J. F. Patterson l

Education BS Mechanical Engineering 1952 Colorado State University i

MS : Nuclear Engineering 1957 University of Michigan Experience 1952 1954 Employed by Phillips Petroleum Compi.ny in the Materials Testing Reactor e

L

. Department as a Design Engineer.

1957-1963 l

Employed by Allis-Chalmers in the Nuclear Power Department as' Supervisor i

of Mechanical Engineering.

1963-1972 Employed by Westinghouse Electric Corporation.

(

Manager, Mechanical Development, Advanced Reactors Division.

e Manager, Reactor Mechanical Development PWR. Systems Divisi.on.

l 1972-Present Employed by-Advanced Nuclear Fuels Corporation (Exxon Nuclear Company,

.Inc.,priortoJanuary'1,1987).

l Manager, Mcchanical Engineering.

Manager, Fuel.. Development and

Testing, responsible for the m

development of new fuel assembly designs, and thermal-hydraulic and l

mechanical testing for reload fuel.

l O

ANF-3830.051 (G'09)

ADnwCEDAUCLEARNRLSCORPORATION w.5

\\

SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 PART ll SAFETY DEMONSTRATION REv.

24 j

11.4 Operating Procedures Plant operations are conducted according to written procedures. The procedures are written by the Manager, Plant Operations, or his designee. They are approved by the Managers of Plant Operations; Quality Control; Safety, Security, and Uconsing Equipment and Maintenance Engineering; and Process Support Engineering. These procedures j

include, by reference, appropriate criticality safety specifications, radiation work permits

.l and other safety related, or pertinent, documents or procedures. The procedures are documented and issued by Document Control to appropriate personnel and locations.

j There are Minl Ubraries located within the various operating facilities which contain copies i

of the approved operating procedures for ease of access by operating personnel.

11.5 Training 1

11.5.1 lD}ilal Trainina Each employee is provided initial instruction adequate to allow them to safely start on the job training by his/her manager or supervisor. This initial Instruction includes

')

emergency procedures, if the employee routinely works with special nuclear material, radiation protection and criticality safety, requirements and procedures will be included.

Within two weeks after starting work, full instruction in Standard Operating Procedures (including instrumentation and control, methods of dealing with process malfunctions, control of hazardous chemicals, control of contamination and decontamination procedures), industrial safety, fire protection, emergency response procedures, radiation protection (including Al. ARA practices, nature and source of radiation, interactions of radiation and matter, biological effects of radiation and the use of radiation monitoring equipment and step-off pad procedures) and criticality safety, requirements and procedures will be provided. The degree of training is commensurate with each employee's position in the Company (related to general and special responsibilities) and with the extent of the employee's contact with radioactive and fissionable materials. Employee instruction is provided by personnel knowledgeable in the various training topics.

Prior to assignment to independent operation, each employee is required, by signature, to indicate that he has been instructed in radiation protection, criticality safety, and emergency response requirements and procedures.

}

• mmowut amication oata

• • ce wo-.

pg ANF 3830.051 (&B9) f

~ ADMSNCEDNUCLEARMELECORPORATION ay,y q SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM.1227, NRC DOCKET NO. 701257 D

PART 11 SAFETY DEMONSTRATION REV.

24 11.6.3 Control / Documentation The ECN form, and any excavation or penetration forms included in the package, are edited for completeness and assigned a number by the Design and Drafting Clerk.

The ECN title and number is recorded in the ECN logbook and a permanent file established in the ECN record file, 11.6.4 Review / Concurrence /Aporoval The ECN receives approval by the User / Operator Manager. Prior to that approval, however, several other managers have reviewed and/or concurred with the package.

Following sign off by the review group, the ECN package is routed in accordance with the Approval and Responsibility Matrix (Figure 12.3).

11.6.6 Execution Work begins upon receipt by either Maintenance or the Construction Engineer of copies of the fully approved ECN package issued by the Design and Drafting Clerk.

11.6.6 Acceptance For projects Dgj involving fissile material, acceptance of the work is documented by signatures of the Project Engineer, the Manager, Plant Maintenance, and the affected manager.

For projects involving fissile material, a physical review of the installation is made prior to introducing fissile material by a Criticality Safety Review Team consisting of the i

I Criticality Safety Component and the Project Engineer.

L The Supervisor, Radiological and Industrial Safety, documents it a team's approval by signing the ECN form, i

l 11.6.6.1 Startuo Council L

A separate overview of certain projects is provided by a Startup Council prior to l

acceptance and operation of facilities, services and equipment which have incurred I

significant change. Projects requiring Startup Council review are:

Those having impact on production.

Those with new safety issues or Implications.

New major projects (facilities / operations).

p Others as determined by the Chairman.

December 1,1989 11 55 ANF 3830.051 (f>'89) v

9 l

ADHSNCWMbCLEARMEl& CORPORATION wp.5 LSPECIAL NUCLEAR MATERIAL LICENSE NO. SNM 1227, NRC DOCKET NO. 701257 1

PART II - SAFETY DEMONSTRATION

REV, 22 I

Membership of the Council consists of:

Chairman:

Manager, Process and Equipment Engineering Secretary:

Manager, Equipment and Maintenance Engineering l

1 At Large:

Manager,. Operations Richland Manager, Safety, Security, and Licensing Manager, Quality Assurance Manager, Plant Operations Manager, Materials and Scheduling Manager, Equipment Development and Methods Engineering Manager, Process Support Engineering Responsible Operations Manager Startup Coordinator (usually Project Engineer)

Startup Council concurrence is required for system operation; however, final authority for approving actual startup rests with the responsible Operations Manager.

l 11.6.6.2 Acceptance Test if an acceptance test is required prior to turnover of the facility, system or equipment to the operating group, acceptance of the work is accomplished via an Acceptance Test Procedure (ATP).

The ATP is signed off prior to performance by the responsible Engineer, the Manager, Plant Maintenance, the Supervisor, Radiation 'and Industrial

Safety, the responsible engineer's manager, and the Manager, Operations-Richland.

1 Final acceptance is then documented by signatures of the responsible engineer, his/her manager, the Manager, Plant Maintenance, and the affected Operations manager, i

11.6.7 Records I

The ECN record file is maintained by the Design and Drafting Clerk.

included in completed files are the original ECN's, a set of detailed

-drawings, specifications, applicable excavation and penetration permits, copy of any Criticality Safety Evaluation requests, and the completed ATP.

Copies of safety, hazard and criticality safety analysis are maintained by the Project Engineer and/or the person performing the analysis.

U l

l AMENDMENT APPttCATION DATE PAGE NO February 7, 1990 11-56 ANF-3830.051 (&89)

.