ML20128H060
| ML20128H060 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 01/28/1993 |
| From: | Knapp K FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9302160255 | |
| Download: ML20128H060 (37) | |
Text
_ _ _ _ _ _
B&W FUEL COMPANY ON An American Ccurvant weth Worldwtde Rewurves Po. On 1164G lynchbum. VA 24506-1646 Telephone 904 522-6000 January 28, 1993 Mr. John Ilickey Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Safety, NMSS Nuclear Regulatory Commission Washington, D.C.
20555
REFERENCE:
SNM-1168 License, Docket 70-1201
Dear Mr. !!ickey:
Condition 17 of B&W Fuel Company's (BWFC) SNM License required us to evaluate our license against the Branch Technical Positions (BTP) and propose license conditions for compliance.
Our revisions were submitted to you on March 16, 1992.
NRC requested additional information on September 23, 1992.
We then committed in correspondence dated November 4, 1992 to include additional revisions by February 1, 1993.
These revisions have been made and identified by a sido bar.
Attachment I provides details of each revision and follows the format of your request for additional information.
The changes effected chapters 2, 6 and 10 of our SNM license.
Please replace the former chapters in their entirety with the ones provided.
As required, six copies are provided.
If you should have any questions regarding this matter, please feel free to call me at (804) 522-6202.
Sincerely,
(
B&W FUEL COMPANY COMMERCIAL NUCLEAR FUEL PLANT 1(.o w v & w S
Kathryn S.
Knapp l
Manager, Safety & Licensing
)
1 080050
[l'F 930a16o233 9aotaa o
PDR ADOCK 07001201 C
O B&W FUEL COMPANY 05
'~
An Arnencan Coneny with Woridwide Resources P.O. Box 11646 iynchbuty. VA 245061648 e
Telephone: 904-522-6000 January 28, 1993 Mr. John Hickey Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Safety, NMSS Nuclear Regulatory Commission Washington, D.C.
20555
REFERENCE:
SNM-1160 License, Docket 70-3201 rear Mr. Hickey:
Condition 17 of B&W Fuel Company's (BWFC) SNM License required us to evaluate our license against the Branch Technical Positions (BTP) and propose license conditions for compliance, our revisions were submitted to you on March 16, 1992.
NRC requested additional information on September 23, 1992.
We then committed in correspondence dated November 4, 1992_to include additional revisions by February 1, 1993.
These revisions have been made and identified by a side bar.
Attachment I provides details of each revision and followc. the format of your request for additional information.
The changes effected chapters 2, 6 and 10 of our SNM license.
Please replace the former chapters in their entirety with the ones provided.- As required, six copies are provided.
If you shcald have any questions regarding this matter, please feel free to call me at (804) 522-6202.
Sincerely, B&W FUEL COMP;JY 1
COMMERCIAL NUCLEAR FUEL PLANT SW k,,j h(Wp i
Kathryn S. Knapp Manager, cafety & Licensing
ATTAClIMENT I
.I.
!4ANAGEMENT COliTRQldi A.
Section 2.6 should include commitments for establishing the following:
1.
Operational procedures which include measures for controlling chemical and fire hazards.
Section 2.3.1 was added to address pre-operational evaluations.
It commits to conducting an evaluation prior to initial operations on new operations and facilities and major operational changes.
The evaluation is performed to ensure that adequats protection is established for radiation, nuclear, fire, and chemical safety is established.
Section 2.6 " Operating Procedures" was expanded to state that changes which require revisions to procedures or local safety rules that the modifications must be in place prior to implementatiop.
2.
Written procedures for specified standards or criteria and detailed testing for safety-related equipment.
800 November 4, 1992 correspondence.
3.
Managerial control for monitoring the effectivuness of the Requirements for Operation programs.
The Requirements for Operation are defined in the BTP.
800 November 4, 1992 correspondence.
B.
In Part I, the licensee should commit to conducting a safety analysis of the facility's operations to identify potential hazards, operational parameters, and specf.fications for these parameters.
Based on the safety analysis results, establish and document the basis for Requirements for Operation.
Boo November 4, 1992 correspondence.
II.
CHEMICAL SAFETY A.
Identification of Chemical Risks 1.
Part II of the license application.should include a list of chemical risks identified as type B (posed by radioactive materials) and type c (plant.
conditions which may directly or indirectly affect radiation risk), as defined in the BTP on Chemical Safety.
Section 10.6 " Chemical Safety" was added to provide general information on our chemical usage, quar.tities involved, storage of-chemicals and associated risks.
E 2.
Part II chould alco includa the cmounto of the cbovo identified chemicalo that cro etored et tho facility.
Section 10.5.2 describes the implementation of our fire protection program.
It illustrates that our pre-fire plan contains pertinent information on chemicals stored at the CNFP and associated fire hasards.
Section 10.5.2 also discusses the quantities of chemicals at the CNFP.
B.
Safe Storage and handling of Hazardous Chemicals 1.
Section 6.5 should include a statement that the Hazardous communications Program (or other appropriate documents) defines the proper facilities, equipment, and procedures for the safe handling and storage of the chemicals identified in A.1 above.
Section 6.5.1 was revised to include the appropriate statement.
2.
Part II should include a description of the facilities, equi.pment, and procedures for the safe handling and storage of hazardous chemicals as-defined in thr. Hazardoun Communications Program or other documents referenced in the above statement.
As discusned in A.1.
nbove, Section 10.6 " Chemical safety" was added to. provide information on our chemical safety'progras.
C.
Accidental Release of Hazardous Chemicals 1.
The Radiological Contingency Plan (RCP):should include a description of the facilities, equipraent, and procedures for measuring the1 extent of and mitigating consequences ~from a release of-hazardous chemicals.
After further review, it was determined that.due to the low quantities of chemicals on site a spill' would not warrant being included in the RCP as it-would not'be classified as a site Area. Emergency or.as an Alert.
An appropriate spill control and clean-up internal procedure will.be used to ensure compliance.
2.
The RCP should-specifically list'the. organizations.
to be contacted in case of a release'of-hazardous chemicals..
See Novembcr'4, 1992 correspondence.
3.
Tho'RCP'should describe the operator training provided.for responding to a release of-hazardous chemicals.
See November 4,"1992 correspondencv.
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II.
EIRE PROTECTION A.
Firo Protcction Progrca 1.
A statement should be made indicating that a Fire Protection Progran is established and implemented.
The documents describing this program should be identified.
Section 6.2 has been expanded to describe the implementation of our fire protection program and the supporting documents.
2.
The position title of the senior level management official directing the progran should be stated.
The Hanager, Dafety and Licensing has been identified in section 6.2 as the director of the prograu.
3.
A statement should be made regarding the frequency of audits of the program.
(Monthly walk-down audits and annual review by a safety review committee are acceptablo.)
B00 November 4, 1992 correspondence.
B.
Fire Protection Equipment 1.
Section 6.2.2, 4.1, and 8 describe the fire protection equipment.
Please identify other facility areas protected by sprinkler or other systems, such as halon.
See November 4, 1992 correspondence.
2.
In Section 6.2.5, please state whether or not the fire protection equipment will be inspected, tested, and maintained according to prevalent industry standards, such as those of the National Fire Protection Association.
Section 6.1.5 has added "in accordance with NFPA standards."
C.
Fire Hazard Analysis 1.
A statement should be made that a fire hazard analysis has been performed, deficiencies (if any) revealed by the analysis have been corrected, and that the fire protection systems are adequate for all credible fire scenarios.
The date of-the last analysis should be stated.
See November 4, A992 correspondence.
2.
The licensee should commit to reviewing and updating fire hazard analyses at regular intervals (2 years is acceptable), unless there are substantial-modifications of the facility buildings or procesces, in which case the-analysis should be reviewed and updated as frequently as needed.
4 D
800 N;veab r-4, 1992 COrrOCpondOCCO.
D.
Firo Em0rg:ncy Plcn (Pro-Firo Plen) 1.
Your Pro-Fire Plan may servo as the Fire Emergency Plan, if it has the elements stated in the attached Technical Position.
If this is the case, than the opening paragraph of Section 6.2 can be considered adequate.
See November 4, 1992 correspondence.
2.
If any of the required information is contained in the Radiological Contingency Plan, then clear referenco should be made in the Pre-Fire plan.
See November 4, 1992 correspondence.
E.
Training 1.
Section 6.2.3, which describes training commitments, woulo be complete with the inclucion.
of a statement that the training program shall include fire drill performed at least annually.
See November 4, 1992 correspondence.
F.
Administrative Controls 1.
The licensee should propose to control welding and other hot working in tho facility.
A commitment to control much operations was added to Dection 10.5.2.
2.
The licensoo should propose to~ control plant or process modif! cation that may impact fire safoty, e.g.,
increase of fire load, introduction of flammable substances, and disablinglof firo-protection systems As stated in response to A.1.,.Section 2.3.1 was added'to address pre-operational evaluations.
It commits'to conducting an evaluation prior to initial operations on new operations and facilities and major operational changes.
=The" evaluation is performed tol ensure that adequate protection is. established for radiation, nuclear, fire, and chemical safety is established.
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B&W 'rUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLAllT
- USNRC LICENSE SNM-1168, DOCKET 70-2203 ORGANIZATION AND ADMINISTRATIVE CilAPTER 2.0 PART I g
(
)
2.1 Qrganigational_ Responsibilities and Authorlly 2.1.1 Management It is the responsibility of the Plant Manager to assure the safety of the operation and compliance with license conditions.
Control shall be established by:
designation of responsibility to qualified personnel review and approval of llcalth-Safety procedures review of program effectivenons prompt correction of nonconforming conditions The CNFP management structure is as shown in Figure 2.I.
Eigure 2.1 SAFETY REVIEW CNFP PLANT NUCLEAR CRITICALITY
~ ~ ~ "
BOARD CilAIRMAN MANAGER SPECIALIST C]'\\
- PRODUCTION MANAGER, SAFETY
- ADMINISTRATIVE
(
MANAGERS
& LICENSING MANAGERS I
t OPERATIONAL llEALTil llS INDUSTRIAL &
SUPERVISORS _
PilYSICIST FOREMAN ENV. CONTROL I
llEALTil SAFETY MONITORS (e.g., Mfg. Eng., Fuel Manufacturing & Fiel(. Operations)
(e.g.,
Accounting, Personnel, Purchasing, Info.
- Services, Production and Inventory Control - not directly responsible for production functions) 2.1.2 Er_qduction MaDacters Production Managers report-directly to the plant manager with except for the Manager, Field Operations who reports to the President of the Company.
They are responsible for managing operational _ area supervisors and are responsible for production functions.
The Managers of Manufacturing Engineering, Fuel (3
Manufacturing and Field Operations are production Q
managers.
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4 B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT "USNRC LICENSE SNH-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE CHAPTER 2.0 PART 1 O
2.1 Orcanizational Resoonsibilities and Autitority 2.1.2 Production lMDA9ar.E The Production Managers shall have, at a minimum, a bachelor's degree in science or engineering, followed by two years experience in the nuclear industry.
2.1.3 pparAtio.Dal Area Supervision Operational area supervision is that uupervision directly responsible for the control of materials, personnel, equipment, and activities in specific areas.
Those responsibilities include assuring that approved control procedures developed by Health-Safety shall be available in writing to operators and other concerned personnel and shall be adhered to.
Minimum qualification of operational area supervision shall include:
(a)
A high schcol education and a minimum of 2 years experience in the nuclear industry.
Experience shall include the practical application of criticality control techniques and a familiarity O
with the applicable specifja limitations imposed' on CNFP operations.
2.1.4 The !!ealth-Safety SectlQD The Health-Safety Section shall be responsible - to interpret the license conditions, provido monitoring facilities, develop safe operation guidelines, maintain -
training programs, and revie" and approve operating procedures to assure safe operation and license compliance. 'These responsibilities include maintenance -
of nuclear safety and radiation safety with ~the approval authority limited to authorized specific <or general license conditicns.. The Health-Safety section -
shall not be directly responsible for the performance-of-manufacturing-operations.
2.1.4 The-Health-Safety Section The. Manager, Safety and Licensing or their qualified designee shall be responsible to provide management.
with assurance of the of factiveness of the safety-program by maintaining an audit program that includes periodic inspection of controls and operations, reports; to management, follow-up or nonconforming conditions.
O and necessary documentation (see Audits, Section 2.7).
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B&W ' FUEL COMPAllY, COMMERCIAL liUCLEAR FUEL PLAtlT
' USHRC LICEllSE SilM-1168, DOCKET 70-1201 ORGANI7 ATIOli AND ADMIllISTRATIVE CilAPTER 2.0 PART I (v)
~
2.2 Personnel EducatioA_and Exnerience Recuirements 2.2.1 P_lant ManangI The plant Manager shall have a Bachelor's Degree in Science or Engineering, a
minimum of 10 years experience _in the nuclear
- industry, and 5
years experience in nanagement.
2.2.2 linnaggr.Sq f ety f, Licensing The manager to whom the section reports shall have a Bachelor's Degree and a
minimum of five years experience, which would develop an understanding of nuclear and radiation safety.
Such experience shall be of a nature which demonstrates to the Plant Manager sufficient judgment and capability to establish and maintain an effective nuclear criticality and radiation safety program for the activities authorized by license.
2.2.3 Health Physicist The llealth-Safety Section shall include a person who 9
shall act as the plant 11oalth Physicist.
This person (V
shall have a
Bachelor's Degree in Science or Engineering.
A minimum of 2 years experience in applied health physics is required along with sufficient formal training that provides an understanding of the health physics and nuclear safety hazards involved at the CNFP.
2.2.4 Health-Safqty Foreman The llealth-Safety Foreman shall have a high school education and three years experience in radiatior, safety which would develop an understanding of nuclear and radiation safety.
2.2.5 liealth-Safety MQnitorg IIcalth-Safety Monitors set up and conduct routine monitoring, sample collection and analytical tests in the plant to determine whether-tho' amount of radioactivity is within acceptable limits and assists in verifying the radiolcgical and industrial safety of employees.
(-V I
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,B&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT I
USNRC LICENSE SNM-1168, DOCl;ET 70-1201 OkGANIZATION AllD ADMINISTRATIVE CllAPTER 2.0 PART I U
2.2 Psrsonnel Education and Exnerierag_ReJIuirementa 2.2.5 lipalth-Safety MonLter.g The Health-Safety Monitors shall have, as a minimum, a high school diploma or GED equivalent with six months of experience as a radiation monitor. _ They may fulfill the experience requirements on the job a.s a llealth-Safety Monitor trainco.
2.2.6 Nuclear Criticality Safety Specialist The Nuclear Criticality Safety Specialist is a separato component within the corporate structure and thus is organizationally indopondent of the CNFP, with no interest in plant operations, other than the nuclear criticality safety aspecto.
The Nuclear Criticality safety Specialist is responsible for evaluating the basic nuclear criticality safety limitations upon which plant safety was originally
- assessed, potential
- changes, validity of assumption, and accuracy of results.
The minimum qualifications for the Nuclear Criticality Safety Specialist shall be a Bachelor's Degrve in V}
Science or Engineering and a minimum of two years experience in nuclear reactor physics and one year experience in nuclear criticality analysis or two years experience performing nuclear criticality safety analyses.
2.3 Safety Review Board The Safety Review Loard reviews the following as a minimum on a quarterly basis:
New or revised facilitics Analysis of equipment and processes involving hazardous materials Maintenance of fire safety e
The continuing effectiveness of established controls and e
safeguards Maintenance of ALARA critoria (review of quarterly air sample averages, review of surface contamination surveys)
Safety-related audit and inspection findings e
Other items (such as abnormal occurrences) that Safety Review Board members wish to discuss.
/
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r4 B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
'USNRC LICENSE SNM-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE CHAPTER 2.0 PART I 2.3 Safety Review Board The Safety Review Board Chairman shall have a Bachelor's Degree in Science or Engineering and a minimum of five years experience in responsible positions which would develop an understandir.g c,f nuclear and radiation safety.
The Safety Review Board Chairman shall be directly responsib.1e to the Plant Manager for the pr: 'er conduct _of the. Saf ety Review Board.
The Plant Manager L3all be kopt informed in writing of Safety Review Board action.
The permanent membership of the Board shall consist of representatives from production management (section 2.1.2), Manager, Safety and Licensing and others as deemed necessary by the Chairman.
Technical representatives of outside consulting organizations
^
shall be included as necessary.
Board meetings :nay be convened at the discretion of.the Safety Review Board chairman, but shall be held at least quarterly.
The Safety Review Board Chairman shall decide whether or not the necessary disciplines are present during a board meeting-to evaluate the item (s) under consideration.
There shall be a minimum of 4 Safety Review Board members present during-a board meeting.
'd Records of Safety Review Board proceedings, including supporting calculations and approvals, shall be retained for l
d 2 years minimum after the completion or termination of the subject activity.
An annual ALARA report shall be prepared under the direction of the Manager, Safety and Licensing.
The report'shall be submitted to the Safety Review Board in which they will review to determine:
- 1) if there are any upward trends developing in l
personnel exposures (internal and external) for identafiable categories of workers, types of operations, or effluent releases; 2) if exposures -and releases might be lowered-in accordance with the ALARA concept;~and~3) if equipment for effluent and exposure controls is' being properly used, 1
maintained, and inspected. A copy of the report shall_ be sent to the. Plant Manager along with the results of the review and recommendations.
At least every two years, the Safety Review Board shall o
evaluate the effectiveness of'the radiation / nuclear safety training program.
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B&W TUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT USNRC LICEllSE SNM-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE CHAPTER 2.0 PART I i
l V
2.3.1 Pre-onorational Evaluationg New operations and facilities and major operational changes require Health Safety to perform an evaluation prior to initial operation to ensure that adequate radiation, nuclaar, fire, and chemical pretection is established.
The Safety Review Board Chairman reviews all pre-operational ovaluations which involve hazardous materiale and determines if Board review is necessary.
In the case of minor changes where existing safety practice remains the same, tho Safety Review Board Chairman may determine that Board review is not necessary.
Safety Review Board members shall be kept appraised of actions taken by the Safety Review Board chairman on such minor changes. Where other than minor changes are involved, the Safety Review Board review and approval process shall be conducted in accord with procedures approved by the Plant Manager.
2.4 Aporoval Authority for Personnel Selection Personnel selection for those CNFP staf f level positions shall
(]
be apprcved by the Plant Manager.
(")
2.5 Trainina Initial indoctrination of employees to nuclear and radiological safoty shall be the responsibility of Health-Safety and shall conform with 10 CFR 19.
Initial indoctrination training shall, as a minimum, include the following topica:
- license conditions federal regulations e
operating procedures e
radiation safety e
nuclear safety e
emergency procedure e
chemical and fire safety e
The extent and depth of the training, relativa to the detailed aspects of the radiation, chemical, firs and nuclear safety programs, is dependent on the employee's job assignment and potential exposure to radioactive materials as determined by Health-Safety.
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l B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
'USHRU LICENSE SNM-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE CilAPTER 2.0 PART I i
(G 2.5 Training Initial indoctrination of employees to nuclear and radiological safoty shall be the responsibility of Health-Safety and shall conform with 10 CFR 19.
Initial indoctrination training shall, as a minimum, include the following topics:
license conditions e
federal regulations e
operating procedures e
radiation safety e
e nuclear safety emergency procedure e
chemical and fire safety e
The extent and depth of the training, relative to the detailed aspects of the radiation, chemical, firs and nuclear safety is dependent on the employee's job assignment and
- programs, potential exposure to radioactive materials as determined by Health-Safety.
The initial indoctrination training shall be reinforced (as appropriate to the individual's job assignment) by the (nv) employee's immediate supervisor or his designee with respect The initial indoctrination training shall be reinforced (as appropriate to the individual's job assignment) by the employee's immediate cupervisor or his designee with respect to individual unit safety requirements, location of emergency
- exits, contamination control techniques, specific local controls, and operating procedures, prior to the employee being. released to operate independently.
The employee's immediate supervisor shall complete a new employee training verification form prior to allowing the employee to operate independently.
A continuing safety training program shall be conducted by Health-Safety to the extent necessary to assure the maintenance of acceptable saf ety practices.
Such training may be conducted on an individual or group basis.
The content of retraining programs may be varied by Health-Safety but will include radiological and nuclear safety as a
minimum.
Empnasis is placed on new er revised safety criteria or areas in need of reinforccment.
A formal retraining of. radiation workers shall be conducted at least annually.
Documentation of formal training and retraining shall be maintained by Health-Safety and retained for at least two-years.
AN.]
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DEW' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
- USNRC LICENSE ENH-ll68, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE CHAPTER 2.0 PART I O
2.5 Training The Manager, Safety and_ Licensing shall be responsible to assure that personnel assigned to Health-Safety are properly trained.
The extent and depth of the training is based on the specific job assignment involved.
Health-Safety monitoring personnel shall receive a combination of formal and "on-the-job" training such that they can successfully demonstrate their proficiency in basic nuclear and radiation physics monitoring and control techniques and regulatory requirements before being allowed to function without direct oversight.
2.6 Qggratina Procedures Written procedures for the _ conduct of specific operations includino maintenance and development of work within the plant are prepared by the functional component responsible for that activity and shall be reviewed and approved by appropriate production management and Manager, Safety and Licensing.
Operating procedures which involve SUM shall be reviewed at least every two years by the appropriate production manager and Manager, Safety and Licensing.
Applicable procedures shall be available in the work area and adherence to procedure shall be required of all personnel. Procedures for operations where nuclear and radiological safety are involved shall O'
include specific reference to applicable safety requirements.
Procedure and format shall be such that operations are clearly detailed and specific directions are provided for operation under both normal and abnormal conditions.
-Deviation from written procedures for the handling of radioactive' materials shall be approved by the Manager, Safety and Licensing, or their qualified designee.
In
- addition, administrative procedures shall supplement operating procedures to encure proper procedural' implementation. _
Procedural control of-activities at the CNFP are categorized as follows:
Health-Safety Procedures developed by Health-Safety specify the method by which safety related functions are to be accomplished.
The -procedures shall encompass all health physics activities-required by the license.
Such procedures may be for internal Health-Safety _ use or may be intended for general distribution to af fected individuals _vithin other components. As a minimum, Health-Saf t ty procedures shall-be approved in' writing _ by the Manager, Safety' and Licensing as = well as approved by af fected -- members. of.
plant management.
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B&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PIANT
- USNRC LICENSE SNM-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE Cl! APTER 2.0 PART I (D
V 2.6 goerating Procqdunga Sl{NJccountability Nuclear Materials control procedures provide techniques for the accountability and measurement of SNM.
As a minimum, such procedures shall be approved in writing by the Manager, Safety and Licensing and the Manager, Production and Materials Control.
Other Plant Groups Procedures from other plant groups (i.e., Manufacturing, Quality Assurance) where nuclear
- chemical, fire or radiological safety, license conditions, or regulatory requiraments are involved require prior approval by the Manager, Safety and Licensing as well as approval by affected members o" plant nanagement.
New operations and majo. operational changes shall require the written recommendation of the Safety Review Board Chairman prior to implementation.
If the change requires revisions to procedures or the local safety rules, those modifications shall be in place prior to implementation.
f-Revised procedures shall be subject to approval in the same manner as new procedures.
llealth-Safety procedures shall be reviewed at 1 cast annually for technical correctness and applicability.
The Manager, Safety and Licensing shall use their discretion to assure that the appropriate personnel of Section 2.2 performs the procedure review.
Procedure distribution and control shall be in accord with procedures approved by plant management.
2.7 Audits and Inspections An internal llealth-Safety inspection program shall be maintained to provide assurance that plant activities are conducted safely and in accord with license specifications.
The Manager, Safety and Licensing shall be responsible to assure that the inspection program is conducted effectively.
The internal Health-Safety inspection program at the CNFP is structured as follows:
Ci V
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D&V FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
- USNRC LICENSE Stim-1168, DOCKET _70-2201 ORGANIZATION AND ADMINISTRATIVE CHAPTER 2.0 PART I 2.7 A11dits arld_LtLqpectio_ng Monthly Safety Insnections Health-Safety personnel shall conduct, at least monthly, a fornal inspection of plant status relative _to safety related functions to include fire safety, except during plant shutdown of a week-or longer.
Inspection results shall be-documented, reported to plant-management and supervision as appropriate, and wall be maintained on file by Health-Safety _for-at least 2 years.
The monthly safety inspections shall be conducted by person el _ technically-qualified to perform this function and in the application of license specifications.
Informal Dai]v Inspections licalth-Safety personnel shall, as part of their routino
- duties, conduct informal daily inspections of plant activities.
These inspections are not formally documented unless adverso findings are identified.
Other InspectiQna V
Ventilation, containment, and air cleaning equipment shall be' routinely inspected at least annually by llealth-Safety personnel to assure continued effectiveness and compliance with license specifications.
Indeoendent Audits Independent auditors shall conduct, as a minimum, semi-t annually nuclear safety,_ fire safety and health; physics inspections at the CNFP. These audits shall be conducted in accordance with written instructions or procedures.
The audit scope shall consist of physical inspections 'and records reviews for the industrial, nuclear,-
and-
-radiological safety elements.
of plant- -activities including:
- effectiveness of procedural controls. impacting on operational safoty--parameters.
- audit of oporating records, where such records provide
-a means-of verifying procedural compliance with safety specifications.
- review and evaluation of contamination survey data.
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-B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT i
'USNRC LICENSE SNM-1168, DOCKET 70-1201 ORGANIZATION AND ADMINISTRATIVE
{
CHAPTER 2.0 PART-I O
2.7 Audits _and Inspections Indonendent Audits
- ascertaining the overall performance of the plant i
functions in providing adequate controls, surveillance, and follow-up to assure safety and license compliance.
Independent auditor's reports shall be submitted to the plant Manager for his revioW.
He will ensure that the proper management reviews the report. The audit report shall include any audit finding or recommendations.-
Actions taken as a result of audit f ndings shall be documented.
Qualifications of the independent auditors shall include competence in tha areas of health physics or nuclear physics as appropriate at a level at Icast equivalent to Paragraph 2.2.3 or 2.2.6 respectively.
Deuignation of the independent-auditors shall be the responalbility of the CNFP Plant Manager.
2.8 Investications and Renortina Unusual events requiring reporting under NRC regulations shall Os be investigated as appropriate, with results reported to plant management and NRC.
Events not otherwise requiring-a report may be reported to NRC based on potential _ public or1 media involvement, etc.,
in order to keep NRC appraised of the situation.
2.9 Records Plant alterations or additions, abnormal occurrences, events associeted with radioactive _ releases, criticality analyses, audits, inspections, instrument calibration, ALARA findings,.
employee training and retaining, personnel exposures, routine radiation
- surveys, and environmental
- surveys shall. be
-maintained on file for a minimum of-2_ years or as otherwise required by' federal' regulation or other license condition,. for-review by CNFP management and regulatory agencies.
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i, B&W l'UEL COMPA11Y, COMMERCIAL NUCLEAR TUEL PLA!1T
'USliRC LICEllSE Stim-1168, DOCKET 70-1201 SPECIAL PROCESSES CHAPTER 6.0 PART I l
6.1 lionexenpt_Scalgfl_ Source Control 6.1.1 Use of nonexempt sources for training and instrument calibration shall be limited to, or under the direct control of, the IIcalth-Safety Section.
6.1.2 Sources utilized as a functional component of devices designated for manufacturing and quality control purposes shall be operated only by approved personnel who have been instructed in safe practice by llealth-Safety.
11ealth-Saf ety shall provide appropriate monitoring support during maintenance -or other operations that may entail increased exposure levels.
A register of approved operators shall be maintained in the licalth-Safety Office.
6.1.3 Maximum whole body exposure rates in any constantly occupied area in the vicinity of operating manufacturing or quality control units utilizing by-product material sources shall not exceed 2 mrem /hr.
6.1.4 In addition to dosimetric devices routinely worn by designated CNFP employees, appropriate self-reading dosimeters shall be utilized by personnel involved in
(]
source manipulation in cases where the exposure may C/
exceed 2 mrom/hr.
6.1.5 Each scaled source shall be tested for leakage at intervals not to exceed six (6) months.
In the absence of a certificate from a transferor indicating that a test has been made within six (6) months prior to the transfer, the scaled source shall not be put into use until tested.
6.1.5.1 The test shall be capable of detecting the presence of 0.005 microcurie of contamination on the test sample.
The test sample shall be taken from the source or from appropriate accessible surf aces of the device in which the sealed source is permanently or semi-permanently mounted or stored.
Records of leak test results shall be kept in unitr of '
microcuries and maintained for inspection by -
the commission.
6.1.5.2 If the _ test reveals the presence of 0,005 microcurie or mora of removable contamination, the source shall be withdrawn from use and shall oc decontaminated and repaired by a p
person appropriately licensed to make such repairs or disposed of in accordance with (w _
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1 B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
6.1 Nonexempt Scaled Source Control Commission regulations.
Within fivo (5) days after datormining that any sourco has leaked, a report shall be filed with the U.S. Nuclear Regulatory Commission describing the source, the test results, the extent of contamination, the apparent or suspected cause of source failure, and the corrective action taken.
A copy of the report shall be sont to the Director the nearest NRC Rogional Compliance Offico listed in Appendix D of Title 10, Code of Federal Regulations, Part 20, 6.1.5.3 The periodic leak test required by this q
condition does not apply to scaled sources.
that are stored and not being used.
The sources excorpted from this test shall be tested for leakago prior to any
._u s o or transfer to another person unless they have-boon leak testod within six (6) mor,* 1 prior to the date of use or transfer.
6.1.6 Adequate records shall be maintained to insure offectivo source documentation, including leak test results.
6.1.7 When not in use, sourcos shall be stored in approved secured containors in a mannor solocted to provent unauthorimod removal or use.
Adequato posting of the source container and storago/ operation area-shall be maintained to insure complianco with appropriate regulations.
6.2 Eire ProtectioD The CNFP fire protection program is administered by the Health:-
Safety Section with the
- Manager, Safety and-Licensing lcyorsoning the program.
CNFP utilizos internal Health Safety; proceduros to ensure adequate fire protection in established, inspected and maintained' for now' f acilities, equipment and/or operations.
Internal procedures-also provido instruction forL our omorgency rescue team in the event of aiminor orfmajor; fire. Our pro-fire plan providos-a hazard analysis associated with separato plant areas, firo emergency plans,- and training. -
The = Plan' shall be reviewed ' -by al1 firo - fighting support; agencies end updated accordingly.
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D&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT USNRC LICENSE SNM-1168, DOCKET 70-1201 SPECIAL PROCESSES CllAPTER 6.0 PART 1 O
6.2
_F_ ire Protection Accumulations of combustible materials within the CNFP shall be limited to the greatest extent practicable, consistent with operational requirements.
Supervision is responsible for assuring that areas under their cognizance are maintained in accord with good housekeeping and fire prevention practice.
6.2.1 Flammable 11gulds shall be stored in approved containers.
6.2.2 Fire extinguisher systems compatible with area nuclear safety requirements shall be installed or provided in accord with insurance and federal regulations.
The above systems shall include portable extinguisher of a and dry chemical) and size type (pressurized water, CO 2 based on the potential hazard. Agents such as "Motl-X" are available in areas where metal fires may occur.
Sprinkler systems and other water-type extinguishing systems are not installed in moderation - controlled areas.
6.2.3 As part of its emergency program, the CNFP organization shall include a " fire brigade" staf fed by qualified personnel, familiar with_ basic fire fighting O
techniques, the equipment available for their immediato use onsite, and the nuclear safety and health physics considerations that are involved. Fire Brigade members shall be retrained at least annually.
The Manager, Safety & Licensing shall have oversight of the-fire brigade.
6.2.4 Fire protection water shall be available at all times.
There shall be a low pressure detection and alarm device and annual waterflow/ pressure tests shall be conducted routinely.
6.2.5 Fire protection equipment shall be inspected routir.ely in accordance with NFPA standards to ensure reliability.
6.2.6 Areas under moderation controls shall be prominently posted ar.d approved fire fighting techniques defined.-
Deviations from the posted techniques can be approved only by one of the following members of the CNFP Emergency Team:
Plant Manager, - Emergency Of ficer, Health-Safety E
l Officer O
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B&W' FUEL COMPANY, COMMERCIAL 11UCLEAR FUEL PLA11T IISilRC LICENSE SNH-1168, DOCKET 70-1201 SPECIAL PROCESSES CHAPTER 6.0 PART 1 I
\\
k) 6.2 firn_f.rJ211G.tiqn During periods when the plant is not in oporation, at least two tours por shift shall be made by a
representativo of the security forco or a
CNFP employce.
6.2.7 An early warning fire detection / alarm system shall be installed in the S-1 storage facility.
The system shall alarm at the continuously manned guard houuo.
Further precautions, detailed in 10.5 of this document, will also be implemented.
6.2.8 A sprinklor system shall be installed and maintained in the SERF-3 in accord with 11FPA codes.
Further precautions, outlined in 10.5 of this document, will also be implemented.
6.3 fact.gency Utilities Backup battery power is provided for the criticality alarm, fire alarm, public address system and for emergency lighting.
The nature of our operations is such that a loss of utilities simply results in a totally safe halt in operations.
IV) 6.4 Radioactive Waste control The " Guideline for Decontamination of Facilition and Equipment Prior to Releano for Unrestricted Use or Termination of Licenson for By-Product, source or Special Nuclear Material",
USNRC August 1987, Exhibit A of Chapter 1 shall be used for disposal control of materials or equipment.
Additionally, these guidelines will be followed regarding radioactive waste control:
a.
Any item which cannot be thoroughly surveyed due to physical construction, painting, or other rocson shall be assumed to bo in excess of the abovo limits and shall be disposed of in a controlled manner, unloss indirect methods such as acid etching verify the absence of si.gnificant contamination as defined in a-d above, b.
When possible and practicable, reasonable attempts shall be mado to decontaminato all items with "dotectablo contamination" to a non-detectable level.
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B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
USHRC LICENSE-SNM-1168, DOCKET 70-1201 SPECI/L PROCESSES CilAPTER 6.0 PART I o.5 Chemical Safety 6.5.1 Written procedures shall be used fcr the implementation of the criteria set forth in 29 CPR and 40 CFR for chemical safety. This is to include the implementation of a Hazardous Communications Program that defines the proper storage
- facility, equipmeat,- and chemical handling procedures.
6.5.2 Storage of chemicals in tanks and/or buildings shall be incorporate a pressure relief system. Storage shall be maintained an adequate distance from v.he main plant.
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i B&W FUEL COMPAll'1, COMMERCIAL NUCLEAR FUEL PLANT
' USNRC LICENSE SNH-1168, DOCKET 70-1201 FACILITY DESCRIPTION j
CHAPTER 10.0 PART I l
t 10.1 Plant Layout and Onerationn Figure 10,1 is a layout of the CNFP illustrating the various production areas on sito. The plant's primary function is the manufacture of nuclear fuel assemblion for use in commercial power reactors. These operations may be subdivided into three production phases:
(unclad SNM llandling, Puol Rod Processing and Inspection, and Fuel Bundle Assembly).
There are occasions when the fuel has to be downloaded.
For downloading operations, the phases are revorced.
The numbers in parenthesis are taken-from Figure 10.1.
The CNFP also supports the Field Operations Department for the refurbishment of contaminated equipment.
The majority of the t
operations are performed in the south bay of the main plant, known au tho Sorvico Equipaont Rofurbishment Facility (SERF-
- 1).
Refurbishment operations for the liquid volume reduction-and chemical cleaning processos are performed in the SERF-3.
10.1.1 Unclad SNM llandlina Unclad SHM receiving, storago, and rod loading aro located at the south and o" the plant, as shown;in Figuro 10.1.
The area includes pollet receiving (#1),_
the pollet vault (#4), and the pollet loading room O
(/6).
Other than the laooratory (#10), this -is the only part. of.the process in which unclad special-nuclear material (SNM) is handled. - The entire pollet vault / rod-loading area is separated'from the remainder of the plant by means of concreto block and metal walls.
A slight negative pressure is maintained in this area with respect to the rest of the plant-to provent contamination spread.
10.1.2 Fuel Rod Procosnina and Inspection Loading fuel rods are processed - and stored in the vuntral portion of the plant (#7). Processing includes _
ond cap welding, quality control inspection, cleaning
(/14), holium-leak testing,_and' accumulation of rods into groups of the number required for a fuel assembly. -
Rods are then stored until nooded for assembly production.-
Individual. unclad fuel-pollots are processed in the laboratory-(#10)-which,is located in this portion of the plant.
10.1.3 Fuel Bundle Assembl.y Fuel rods are assembled into their final configuration-
/-
(#11),- checked for quality, and shipped to the customer from the north end of the plant (#12).
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B&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT j
USNRC LICENSE SNH-1168, DOCKET 70-1201
~ '
FACILITY DESCRIPTION CHAPTER 10.0 PART I O
10.1.3 Fuel Bundle Acsembly Ancillary production activities conducted within the i
plant consist of non-nuclear component fabrication i
which inay be characterized as light machining and fabrication. Examples 6f this type of activity include grid and end cap production, incore detectors, and dimensional adjustment on vendor-supplied components.
10.2 Utilities and Suonort Systema 10.2.1 Electric Powpg Electric power to the Mt. Athos site is provided by Appalachian Power company.
This power is supplied via a nearby electrical substation and is stepped down'to 480V 3-phase, 3-wire service.
A further step down to 240V, 120V, and 277V is made for lighting and general convenience power.
Backup battery power is provided for the criticality alarm, fire alarm and public address in addition to emergency lighting.
The nature of our operations is such that a loss of utilities simply results in a totally safe halt in operations.
10.2.2 C_omnressed Air compressed air is utilized primarily for routino industrial purposes.
We do not use any protective masks or clothing that require compressed air' to-maintain their-effectiveness.
We-have-a ' main cornpressor located at the north end of 'the CNFP that provides the compressed air for plant use.
A desiccant is used to dry all plant compressed air.
10,2.3 }iatu The Mt.-Athos site utilized several walls on-site-to obtain groundwater.
The groundwater supply is stored-in two 150,000 gallon tanks..-
Additionally, 2 - one-million gallon storage tanks are maintained for service water.
Typically, the CNFP uses approximately 2500 gallons per day.
A loss of water supply wouldnot -lead to any
. degradation of our. safety systems.or. contribute to an accident that could release uranium to the plant or the environment.
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-D&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUVL PLANT
10.3 yentilation System.a 10.3.1 General Airborno contamination will be maintained as f ar below 10 CFR 20 Appendix B
limits as is practicable.
Containment and isolation of areas where unclad SHM is processed in significant quantities is assured by enforcing pressure differential criteria so that such areas are negative with respect to the remainder of the plant.
Air circulation within controlled ' areas is maintained by the use of a combination of fresh
" makeup" and filtered air. The relative percentages of fresh. and recycled air will be determined ' by air handling and tempering requirements, for example, air conditioning.
Recycled al*t is routed through a pre-filter and is HEPA filtered before return-to - the operating area.
Determination on the necessary number of air changes per given period of time will be. based on design criteria and health physics ' operational experience.
- 10. 3.2 Overall System Desicin Figure,10.2 is a schematic which illustrates the O
configuration of the controlled area ventilation system including the relative location of sampling points, pro-filters, HEPA filters and the effluent release point.
Certain design criteria have been established and maintained for this system as follows:
1.
Individual HEPA filter units are installed at the rate of 1 filter /1000 CFM of air flow, or-more if allowed by filter specifications. (typical ' HEPA filter specifications are shown in Table 10.1).
2.
Effluents exhausted to the environment shall be HEPA filtered.
3.
Self-closing louvers are installed at outside ' air intake points to the south. bay.
4.
HEPA filter banks are contained in metal units specifically designed to allow:
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.B&W' FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
'* USNRC LICENSE SNM-1168, DOCKET 70-1201 FACILITY DESCRIPTION CHAPTER'10.0 PART I
):
' ' ~ ' '
10.3.2 Overell System DesLgn Access to space between filter banks to allow An'-place monitoring for defects.
Removal and replacement of filters from outside the housing structures with the use of
" bag-out" techniques for contamination control.
Measurement of pressure drop.
5.
Pre-filters will be used to limit duct contamination and to provide protection' to the HEPA filters if necessary.
Selection of single or dual profiltration is based.on filter loading potential.
6.
Duck construction will be metal with scaled mechanical joints where practicable.
Connections to containment units may be fabricated o#
flexible or semi-flexible material with joi? -
bolted or fastened by an equally effect' technique.
7.
Recirculated air 19 first passed through pre-filters and
$s. then HEPA filtered before g
f reenterir.g the area.
( y; y
8.
Provision for DOP testing and _ sampling is incorporated in the ventilation system' design.
TABLE 10.1 TYPICAL FILTFR SPECIFICATIONS w
.x.
Manu. &
Filter Frace Rated Capacity Max.
Model Media Material Effic.
CFM Temp.
HEPA Cambridge Glass Steel or 99.97
-1100 2 5 0*F-ET-1000-1 24" x Wood 0.3 uDOP
- 24" x 11.5" Pre-filters Glass Galvaniz 60%
1000'-
2 5 0'F -
Cambridge ed Steel ASHRAE (AEROPAC) 3CP or Wood Std.
24246.23.3/8"-_x S268 23 3/8" x 5 7/8" Fladers Glass Pressed 95% NBS 2000 (Econocel) 2424F, Board
" Duct 79 23 3/8" x 23'.3/8" Spot"
()
x 11 1/2" l
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EB&N FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT USNRC LICENSE SNM-1168, DOCKET 70-1201-FACILITY DESCRIPTION-CHAPTER 10.0 PART I
}r
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10.3.3-Overall System Maintenance and Control-Pressure-drop across pre-filter systems _Will,be monitored and the filter replaced when'the pressure-differential reaches 4 inches of-water.
Calcalations by a consultant indicate that, ' for the purposes of nuclear safety, pressure drop measurements will provide effective control. over the quantity of SNM. that may accumulate in a filter.
Calculations show a " worst-filter-case" P of 2 inches of water for c 2.72 kg UO3 load, assuming a P of.5 inches H 0 for a new-filter, _
3 a UO density of 5 g/cc, and for conservatism, a linear 2
function between P and load.
Further _ scaling indicates that for a P of 4" H 0, the.
2 total accumulation of UO would be 5. 4 4 - Kg.
This is_
2 aquivalent to_200 grams of 2"U or approximately 25% of' the 850 g safe mass limit.
The pre-filters-are therefore inherently safe and may be handled 'for maintenance and cleaning, etc., within.the handling limits imposed for nuclear safety purposes.
Typical pre-filter and HEPA filter housings ~ are designed by the. manufacturer.to accommodate safe bag-
_n out techniques for contaminated.fjlters.
in order to accomplish the above,. air flow through the filter is shutoff and the housing coverplate removed.
~A plastic bag may then be attached to the filter housing port; the _ filter housing release handles loosened, and;the filter withdrawn into the bag which can be sealed ~and removed from the housing.
The bag-out technique, applied -as needed, effectively; precludes significant -
airborne and surface contamination spread..
Flow sensing elements are installed withinLductwork at appropriate locations to provide an. audible: and.. isual v
alarm if flow is interrupted.
If-flow loss is other than a
nomentary disruption, operations will be-terminated if necessary until -proper ventilation is.
restored.
Pressure sensing devices are _ routinely monitored to assure that'the controlled area remains negative with' raspectEto the remainder of_the plant.-
Air recirculated back 'into the controlled. area:--is' samples-on a _ continuous - basis to. verify filter.
effectiveness and will not be recirculated-if - the levels are above 25%.MPC of 10.CFR 20. Appendix B.
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N BMI FUEL COMPANY, COMMERCIAL HUCLEARL FUEL FLANT
' _ USNRC LICENSE SNM-1168,-DOCKET 70-1201 CHAPTER 10.0
' FACILITY DESCRIPTION PART I
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'!v/ =
10.3.3 Overall System Maintenance and Control Procedures required notificatien of Health-Safety prior to servicing or maintenance on those portions of the fans or HEPA systems that may be contaminated.-
10.3.4 IDdividual Operations cc7tainment The degrea and type of containment required for individual operations is determined based on the dust generation potential of the activity being conducted.
Three generalized categories of containment have been utilized in developing the airborne exposure control.
systems as follows:
1.
Gloveboxes, locally fabricated or commercially "vailable, for use in areas of high potential contamination spread including:
2.
Containment hoods are designed to accommodate specific equipment or operations and incorporate specific measures to minimize the po'cential for contamination sptsad including:
- a. Minimization of normally open penetrations to (n")
those necessary for roatine operation.
(NOTE:
In some cases no "normally open" access will be required.)
- b. Penetrations that may be required for infrequent non-routine activities will be sealed by "normally closed" covers at all times when not in use.
3.
Standard fume or. " chemical -type" (open face).
hoods for use in
_aperations with minimal potential for dust generation and to accommodate-analyf ical activities if needed.. As appropriate,
- measures, such as blocking of doors, will be utilized to minimize open face areas.
10.3.5 Ind.ividual Containment - Desian Criteria The following criteria have been established for the design and construction of Lindividual containment devices:
a.
Design face velocity shall be 100 LFM with-all ports open.- The air handling system incorporates the -capability to adjust-' face velocity? as A
necessary in order to satisfy. exposure contirol y'
needs.
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BM[ FUEL COMPANY,fCOMMERCIAL NUCLEAR FUEL PLANT
.f:USNRC' LICENSE SNM-1168,; DOCKET
't 70-1201 FACILITY DESCRIPTION
-PART I
.' CHAPTER 10.0 g
d 10.3.5--Indivi hal containment - Desian Criteria
.b.
In-line pre-filter units will bo installed in the downstream air flow path and as: near-to the contamination source as is-practicable based on
+
design and operating criteria.
A negative pressure of approximately 0.25. inches c.
of water relative to room ambient, be maintained:
in glovebox units.
d.
Materials of construction will be nonflammable or-flame retardant.
Structural members and' those portions of the-containment' device not-requiring-visibility will be fabricated of metal.
Where visibility is needed, plexiglas, satisfying ~at a-minia, the "self-extinguishing" criter.la-of ASTM-D635 (" Flammability of.Self-Supporcing Plastics")
or equivalent will be ur,ed.
Tempered glass,'such as is normally used in standard fume hoods is also -acceptable.
Flammable materials such. as polyethylene are not authorized.
10.3.6 Individual containment - Maintnnance'and control
,ph The adequacy of installed systems ig verified by. an air
~
sampling program during the startup phase of <the operations and necessary --modifications or ' design changes made.to 'assuro that operator exposure is as low.
as reasonably achievable.
In addition.to the above, local capture devices (" elephant trunks") could be used to provide added support as necessary.
10.4 Radioactive Waste-Handling 10.4.1 _Liauld Wastes Potentially contaminated liquids generated at the CNFP are controlled by ' means of a dedicated' evaporation-system.
The liquid: effluent is collected and' allowed to evaporate (with heat if necessary) into the. existing':
airborne effluent control system s where it. is HEPA:
filtered prior to release.. The-HEPA system and:.HEPA' filtered prior to release.
The HEPA system and110 CFR=
-20 airborne effluent release limits usedz are as.
described in-8.1.1'.
Vessels used,to collect / evaporate the _ liquid; effluent shall be inspected. monthly s for -
sludge accumulation.
Any dried sludge or other solids 1 collecte4 from the holding / evaporation' vessels will be-
{_ _} -
disposed if as LSA waste.
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'Buf FUEL COMPANY, COMMERCIAL NUCLEAR-FUEL PLANT'
~' USNRC LICENSE SNM-1168, DOCKET 70-1201 FACILITY DESCRIPTION CHAPTER 10.0 PART I fN
)'#j, 10.4.1 Liquid Waste.g Small quantities of contaminated -liquids will be generated in the SERF-3 facility.
The liquids will be solidified and packaged to meet 10 CFR G1 and-transferred to a licensed low-level radioactive burial.
site.
As a backup to the evaporation' system, we will maintain a liquid retention tank system that will collect tho'
^
contaminated liquid if necessary.
The accumulated-liquids in these retention tanks would be sampled, radiometrically analyzed, and treated. as ' necessary,-
prior to release.
The retention tank system incorporates capacity
- alarms, and air agitation capability.
Analytical sensitivity is 1%
of the applicable 10 CFR 20, Appendix B, Table II limit.
The sampling program is under the control of Health-Safety and no releases are made without the prior approval of.
' Health-Safety.
The retention tanks are housed in the-Rad Waste Retention Buildings snown in Figure 10.1.
Figure-10.3 is a schematic of our contaminated liquid-waste system.
10.4.2 Solid Wastes
\\
Uncontrolled disposal of, solid wastes or'equipuent is authorized when contamination levels do not exceed the levels defined in section 1.7.4.and under the concept:
of ALARA.=
Establishment of the above - contamination limits to parmit disposal in. accord with. routine-industrial practice does-not presenti a. hazard. to ;the general public.
The limits are generally accepted.within the nuclear industry, as -not presenting '. any 'significant radiological orenuclear safety. hazards.
Rcutine monitoring. programs are conducted-by Health--
Safety to assure that; material,. contaminated in. excess' of.
specification' limits; is not- ' released
-for-uncontrolled disposal. and to, detect and. alleviate-increasing contamination trends.
Non-contaminated: solid wastes are dispos.ed of through; a-contract hauler.
' Contaminated. solid wastes consist-
. primarily L of = low-' specific activity material and E are disposed of by a licensed contractor by' land burial-on-(~)
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DW PUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
I
'd 10.4.2 Splid Wantqa
'N an NRC or state licensed site.
LSA wastes are packaged in appropriate containers as required by 10 CFR and 49-CFR.
SNM content for each package is estimated using gamma scan or by gross alpha count.
10.5 Fire Protection 10.5.1 General All CNFP buildings are of steel und/or masonry construction and the roofs of all main buildings are Class I construction.
Class I construction requires that the vapor barrier be non-combustible.
Plant operations are typical of metal.. working type facilities; therefore, very few Class A
type combustibles are present. Accumulations of combustible materials within the CNFP shall be limited 'to the greatest extent practicable, consistent with operational requirements.
Supervision is responsible for assuring that areas under their cognizance are maintained in accord with good housekeeping and fire prevention practice.
Plant operating procedures coupled with frequent. inspections deter sloppy C
housekeeping which would allow the accumulation of
(,/
combustibles in the work area. Health-Safety personnel are responsible for inspecting and maintaining fire protection equipment.
10.5.2 Implementation of the Fire Protection Proaram CNFP has neveral documents tnat implement our. fire protection program.
Internal Kealth Safety procedures are used to ensure employees are properly trained on fire safety, to outline training for the CNFP fire
- brigade, to require routine inspection of fire protection and emergency equipment to meet NFPA standards, to control welding and other " hot" work, to provide emergency response in the event of'a fire, and to mandate independent audits of our fire protection program.
Our pre-fire plan is an extenssve; document that provides a hazard analysis for all areas of the plant.
Each area includes-an assesument of.the occupancy, access and
- egress, lighting
'and communication, fixed fire systems
.and manual suppression systems, ventilation system,.tnd guidelines for the attack and special precautions, Hazards (N
)
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&&W FUEL COMPANY, COMMERCIAL NUCLEAR FUEL L.. '~_
DOCKET 70-1201
FACILITY DEF. alp 7' ON CHAPTER 10.O
.PART I
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fy (j-10.5.2 Innlementation of the r? L Protection Procram associated-with each area are also identified which -
include hazardous substances with material safety data sheets, NFA rating and quantities,-physical hazards, electrical hazards, and compressed gases.
10.5.3 Eire Extinquishiner Systems.
Fire extinguishing systems compatible with area nuclear safety requirements shall be installed-or provided in accord with insurance and federal regulations.
The-above systems shall include portable extinguisher of a type (pressurized water, CO2 and dry chemical) and size based on the potential hazard. _ Agents such as "Metl-X" dro available in areas where metal fires-may occur.
Automatic sprinkler systems are installed in accord-with standard industrial practice when compatible.with-nuclear safety and operational requirements.
Sprinkler systems and other water-type. extinguishing systems. are not installed 11 moderation controlled ~
areas.
Only. approved ~ fire-fighting techniques are to be used in moderation control areas.
These-approved.
p methods shall be prominently posted in the affected.
Q areas.
10.5.4 flammable Licruids Flammable liquids'shall be stored in containers that' are approved by FM or UL or are otherwise acceptable to the. insurance carrier.
10.5.5 Fire Brictada As part of its fire. protection - program, the CNFP-organization shall include a " fire brigade". staffed by qualified personnel, familiar with basic fire fighting techniques, the equipment available for theQ immediate; use.onsite, and the nuclear safety and health physics considerations that are involved. - Fire Brigade members shall be retained at_least annually.
10.5.6 pffsite Suonort-Arrangements have been made for assistance.fromilocal' area - fire departments.
They-haVe-been : informed of -
B&W's= operations,7 materiels, and characteristics - of G
potential fires and-have toured the facilities.
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DMI FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
' ' USNRC LICENSE SNM-1168, DOCKET 70-1201 FACILITY DESCRIPTION CMAPTER 10.0-PART I-l t
10.5.7 S-1_SigrAafie Facility The storage of flammable, combustible, or reactive liquids in the S-1 building will be strictly prohibited. No burning, welding or other ignition will be permitted.
If welding or such other hot working operations are mandated, a pre-operational evaluation shall be performed under the direction of the SRB chairman and shall be monitored for compliance until the operation has been officially terminated.
Smoking will be prohibited at all times.
10.5.8 SERF-3 The building denoted as SERF-3 incorporates a sprinkler system installed throughout the f acility to NFPA 13 code.
The alarm for the sprinkler system is audible locally and at the guard house which is manned continuously.
Portable fire extinguisher are available througaout the building in accord with NFPA 10.
Fire watches shall be conductel while performing hot working operations and controlled by the use of the local safety rules.
/'
All systems shall be maintained in accord with MFPA V)
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codes.
10.6 Chemical S 6 f
10.6.1 General CNFP differs from other fuel fabricators as it is not licensed to perform any chemical operations which involve special nuclear material such as the conversion of UF6 to UO2 and scrap recovery.
Chemical. usage at CNFP is for cleaning purposes.
- Acetone, TCE, hydrofluoric and nitric acid compromise the majority of the chemicals used at CNFP.
With the exception of acetone, the chemicals are used in our cleaning room which is located within the main plant.
Acetone is used throughout the plant.
- 10. 6.2 Chemical Usaae and Otlantity Acetone is used as a
cleaning agent.
All the containers are fire proof and the largest one has a 2 gallon capacity.
Several of these containers-are located in each area.
Designated locations are set up.
r'^g to ensure proper ~ disposition of the waste.
The
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cleaning room has five sinks that contain acid solution PAGE:
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N&W-FUEL COMPANY,;00MMERCIAL1 NUCLEAR. FUEL PLANT -
- p GUSNRC LICENSE-SNM-1168',fDOCKET:70-1201.
"q FACILITY DESCRIPTION PART'I 1 '-CHAPTERL10.0-
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a.}j' 10;6.2 Chemical'Uapae'and-Ouantity a-for.a totalovolume of about 70 gallons.. A-120. gallon dispensing tank located inLacroom-adjacent-1foeds.thef l
sinks. ~There is also n1400: gallon tankithat' collects the spent -acid.
Both. tanks-=are. constructed..in-accordance with vendor specifications for the contents it retains.- They also meet the VA Department; of: WasteJ Management Regulations' which ^ mandates '. that lthey : be-constructed: to detect -leaks and " requires': dailyc inspections.
A1 chemical storage - building Tisflocatedl-fifty feet-away from the_ main plant; It hopses;about, 500. gallons of acetone and/or.- alcohol and ; about 2 300 :
gallons-of acid.
The acid.-is stored separatelyJin an:
area that ~is. diked - and has.an ~ explosion proof 1: wall..
- L The CNFP -is-licensed to store UF6' cylinders.j '.Since the -
UF6-is - strictly _ for storage, there is ' no : chemical
- hazards associated with-the material.
10.6.3 Chemical-Accident At worst, the chemicals stored at CNFP couldl spill'.E As__
(l illustrated above, this would result in-:aLainor? spill of'. minute. quantities. _ :Due to? the _ low quantities (of :
chemicals involved and the fact:that the chemicals are c' [%
located - adequate ' distance from'.SNM,; aispilliwouldinot' i'N pose a threat'to caune spre'ad_of contamination.-
.r CNFP :does-have _ several employees trained in hazmat and' L
NNFD has agreed _to provide back up" services; ; Health:
Safety has an internal proc _edure to respondEto chemical-
= spills. :
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l P;&d FUEL COMPANY,' COMMERCIAL NUCLEAR FUEL PLANT USHRC LICENSE SNM-1168, DOCKET 70-1201 FACILITY DESCRIPTION CHAPTER 10.0 PART I
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PELLET RECf 4VitJO 1I 2.
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SERF 5.
PELLET VAULT
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PELLET LOADINO RM 37 e
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FUEL ROD FAB.
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EAST OFFICES c-n
- 10. WEST OFFICES a
- 11. METALLUROICN. L AD.
12, FUEL ButOLE+ ASSEMBLY r
- 13. FUEL BUNDLE STORAGE
- 14. ION EXCHAf4GE/ GRIO GRIND 1HO j-IS, CLE ANINO ROOM
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- 16. FINAL FUEL INSPECTION 1h N
- 17. ORID AREA -
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- 18. MAINTENANCE / ELECTRICAL SHOP.
- 19. FIELD OPERATIONS TRAILER 24
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- 20. MACHINE SHOP 3
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- 21. INCORE DETECTORS w
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- 25. S2 BUILDING 9
36 s 35
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- 26. S3 ButLOLNG p) q gM 23 e
3 27.. FUEL ASSEMBLY SHIPPING
- 28. RETENTION TANKS
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- 29. LSA SCAN BUILDING i
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- 30. TRAINING CENTER l6 I 8
11$61 17 I 2t
- 31. RECORDS STORAGE g
2 77 5 H 7l 22 g J
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- 32. GARAGE of l'g y [}
- 33. NORTH OFFICES-g}
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- 34. EMERGENCY EQUIP. BJiLDING t
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- 35. RECEIVING / STOCKROOM BUILDING t L30j c
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SERF-3 COMPf ESSOR DUILDING J8. CHEMICAL STORAGE BUlt.D' jig.
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D&N FUEL COMPANY, COMMERCIAL NUCLEAR FUEL PLANT
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- 'gj FIGURE 10.2 FLOW DIAGRAM OF CIR HANDLING SYSTEM EFFLUENT
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SAMPt.E POINT (*8000 CFM)
I HEPA FILTRATION N
1 1
I i
i f^s PRE-FILTER I
I I
s SAMPLE I
POINT I
I CONTROLLED AREA ROCM AIR PICKUP l
i RECIRCULATING SYSTEM i
i l
i 1
HEPA I
ROOM AIR N
FILTHATION I
RETURN x'/
N l
A i
. _____ ___ ____. ____ _________ I l
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l P RE-F II.TER DRE-FILTER-a A
PROCESS ROOM AIR HOODS PICHUP-
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.B&k FUEL COMPANY, COMMERCIAL NUOLEAR FUEL PLANT
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FIGURE 10.3 FLOW CHAAT OF LIQUID WASTE DISPOSAL SYSTEM CLEANING ROOM GASEO'JS EFFLUENT DRAINS RELEASE v
ACTIVATED' HEpA DEION1ZER CHARCOAL LAB FILTRATION REGENERATION FILidR DRAINS NON CONTAMINb7ED LIQUIDS a
v Y
.y EVADORATION l
e*------------*---------------
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I (SEE NOTE BELOW) i O\\FRFLOW if iP CONMM NATED LIQUID LIQUID
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WASTE WASTE AIR AGITATION RETENTION RETENTION h
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STANDPIPE vg )
N 4
ML LA.A.
' LIQUID WASTE SUMP TO WET WEATHER STREAM NOTE: NORMAL PROCESSING FOR CONTAMINATED LIQUIDS IS THROUGH THE EVAPORATOR / HEPA SYSTEM.
THE RETENTION TANK / WET WEATHER STREAM SYSTEM WILL ONLY BE USED AS A E4ACKUP FOR CONTAMINATED LIQUIDS 1
PROCES SI f 4G.
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