ML20135B129
| ML20135B129 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/25/1997 |
| From: | Reda R GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-L10079, NUDOCS 9702280098 | |
| Download: ML20135B129 (30) | |
Text
GE Nuclear Energy t
y&g um mm cam
,rh PD % iLC M h m an FC.^tua:
V 9h765!M February 25,1997 Mr. M. F. Weber, Licensing Branch, NMSS U.S. Nuclear Regulatory Commission Mail Stop T 8-D-14 Washington, DC 20555-0001
Subject:
License Renewal - Response to Request for Additional Information (TAC No.
L10079)
Reference:
(1)
NRC License SNM-1097, Docket 70-1113 (2)
License Renewal Application,4/5/96 (3)
Submittal, RJ Reda to ED Flack,5/6/96 m
(4)
Submittal, RJ Reda to RC Pierson,5/14/96 V
(5)
Letter, RC Pierson to RJ Reda,7/18/96 (6)
Submittal, RJ Reda to RC Pierson,8/30/96 (7)
Submittal, RJ Reda to ED Flack,9/26/96 (8)
Letter, MA Lamastra to RJ Reda,10/2/96 (9)
Submittal, RJ Reda to MA Lamastra,11/22/96 (10)
Application, RJ Reda to MF Weber,12/16/96 (11)
Letter, MA Lamastra to RJ Reda, 12/17/96 (12)
Submittal, RJ Reda to MF Weber,2/5/97 (13)
Letter, MA Lamastra to RJ Reda,2/10/97 (14)
Submittal, RJ Reda to MF Weber,2/19/97
Dear Mr. Weber:
GE's Nuclear Energy Production (NEP) facility in Wilmington, N.C., hereby transmits the enclosed information in response to your above request dated 2/10/97. This information is being provided in support of our license renewal request.
Attachment I contains the requested information (italicized) identified in Mr. Lamastra's letter dated 2/10/97, and our responses (bold print).
O
'h '
/ V
, Sj-(,)
9702280098 970225 I
9 PDR ADOCK 07001113 N
C PDR
~%1 l
16 i
t Mr. M. F. Weber 4
I February 25,1997
' Page' 2 O?
i contains (1) a description of the changes made to the license renewal by page and section, and (2) the page changes to our license renewal application for pages contained in the l
Table of Contents, Chapter 4, Chapter 7 and Chapter 9. The changes in Chapter 9 are word l
changes discussed with Mr. Flack earlier this month relating to our Radiological Contingency l
l and Emergency Plan (RC&EP). Each chapter is provided in its entirety for easy replacement.
Each page within the chapter that contains a change is indicated with a horizontal line ( I) in the right hand column to show where a change has taken place. All replacement pages contain the
. date of this submittal (2/25/97) and are shown as revision zero.
l Six copies of this submittal are being provided for your use.
?
L Please contact Charlie Vaughan on (910) 675-5656 or me on (910) 675-5889, if you have any l
questions or would like to discuss this matter further.
Sincerely, i
T i
GE NUCLEAR ENERGY i
t r
C i
p Ralph J. Reda, Manager Fuels & Facility Licensing
/zb 4
Attachments cc:
RJR-97-018 L. A. Reyes, Region II Administrator G. L. Troup, NRC-Atlanta M. Fry, State of NC 1
0 ij
l i
Mr. M. F. Weber -
February 25,1997 Page'l ofI O.
e l
ATTACHMENT 1 l
I Response to Request for Additional Information Contained in Letter from MA Lamastra to RJ Reda Dated February 10,1997 O
j l
O
]
\\
i
l Mr. M. F. Weber i
February 25,1997 l
l Page 1 of 9 G.E. - Wilmington Renewal Application Comments ChemicalSafety Program Chapter 3.0- Conduct of Operations 1.
Page 3.1, Section 3.1.1, At whatfrequency areperiodic comparison assessments conducted?
ISAs undergo assessment anytime changes are made which require the IF A to be reevaluated or changed and as a minimum every five years where no change j
takes place.
- 2. Page 3.1, Section 3.1.2, Please elaborate on the statement "The specific content of the information depends on the age ofthe design and the requirements in place at the time ofdesign" andprovide an example. For chemicalprocess safety, what is the safety basis documentation and how is it maintained?
The statement in the referenced section of the draft license refers to the fact that
]
the plant is some 28 years old and that the procedures and processes for doing work have changed with time and in all cases when these changes were made j
they have not necessarily been made retroactive. Therefore when one looks at the files of safety related information it is not always in the same form or format but in all cases we have the information necessary to assure the safety of the plant. As we move toward baselining the plant to the integrated safety basis as defined in Chapter 4 and as applied to the DCP there will be more uniformity in the information.
With regard to the form of chemical safety information the DCP facility information is included in the ISA documentation in the configuration management system defined in the draft license. For the balance of the plant it is mainly found in the Chemical Job Hazards Analysis, Job Hazards Analysis, Emergency Plan, training plans and some related documents that are maintained under configuration management in the configuration management system defined in the draft license.
3.
Page 3.2, Section 3.1.3, Who conducts initial trainingfor the approved safety reviewer and is refresher training conducted?
l Training for Safety Reviewers is identical to the training provided to Qualified Reviewers. The reviewers are trained by members of the EHS staff, and the s
s training covers radiological safety, criticality safety, environmental protection, 1
Mr. M. F. Weber February 25,1997 Page 2 of 9 O
chemical safety, and industrial safety. Refresher training, per se,is not provided: however, ad hoc training is provided when there are major changes, for example in regulations.
4.
Page 3.2, Section 3.1.4, Are theprocess descriptions maintainedin the same manner l
as otherfive types ofinformation listed or are they covered under the technical specifications and requirements category?
Yes. Process descriptions are considered a subset of the technical specifications and requirements category.
- 5. Page 3.2, Section 3.2, Does maintenancepersonnel conductpost maintenance functional testing on equipment other than safety related equipment?
Yes, however, this work is not performed using the functional test instruction (FTI) routine used for safety systems.
Maintenance on non-safety relMed nructures, systems and components deal with operating systems. The restart procedures for operations verify the Q
functionality during the restart. Additional functional tests are not needed, l
- 6. Page 3.3, Section 3.2, Are maintenance instructionsprovidedfor every maintenance operation conducted by licensee maintenance personnel and contractor maintenance personnel not onlyfor safety equipment butfor preventive and corrective racintenance activities? Is there guidancefor " skill ofthe craft" activities?
Maintenance instructions are not provided for every maintenance operation conducted. Where that work needs a special instruction to be successful these instructions are provided. Where the work donc can be accomplished successfully by persons possessing an appropriate " skill of the craft" knowledge, additionalinstructions are generally not provided. We do however have some generalinstructions and work rules which must be adhered to for all work. A complete list of procedures and instructions are available on site.
With regard to " skill of the craft", management has the responsibility to i
establish job functions with responsibilities and authorities appropriate to get the work done safely and effectively and a portim. of d<,. 7 this includes ensuring that properly skilled and qualified people of Mncient number are in place in the organization. The primary method of ensuring " skill of the craft" is through the management process. Additionally a number of tools are used to
.A augment this. For example GE uses Master Mechanics which are certified by V
the State under the National Labor Board Master Mechanic Program. GE uses l
l l
l.
i Mr. M. F. Weber February 25,1997 Page 3 of 9 licensed electricians. Instrument Technicians are certified by the Instrument Society of America.
l 7.
Page 3.3, Section 3.2, is there apredictive maintenance program in place and documented?
GE uses very little predictive maintenance. Most of our maintenance is based l
on preventative maintenance program routines and GE has found this to be l
acceptable for the type of operations in our factory. Our maintenance 1
programs are documented.
8.
Page 3. 7, Section 3.4.2, Are evaluations conducted to assess the adequacy of i
operator and subcontractorpersonnel chemical safety training, are independent audits conducted?
l
\\
As GE has indicated, one of the key management responsibilities is the assurance that properly trained and qualified people are in place on each job so that the plant operates safely. The qualification, selection and maintenance of that system has also been discussed. From the management standpoint
' -Q assessments of the adequacy of training are conducted on an ongoing basis by the first line of management.
l On a quarterly minimum frequency the product line managers and safety l
manager conduct walkthroughs and audits of each process area and included as a part of the scope of these activities is operator behavior relative to chemical safety.
The overall training program and its effectiveness is also included in the scope of the biennial audits discussed in Section 3.6.1.
9.
Page 3.8, Section 3.6.1, What is thefrequency ofchemicalsafety audits andare there a minimum requiredperyear?
Chemical safety audits are conducted in several ways. Monthly self-inspections by area coordinators and employees include chemical safety. In addition, chemical safety is checked as a part of EHS audits done quarterly.
- 10. Page 3.9, Section 3.6.3, Do the independent audits cover the chemicalsafety i
program? What is thefrequency ofaudits?
Audits are performed by a mix ofindependent internal and external personnel
Mr. M. F. Weber February 25,1997 A'ttachment 1 i
lO Page 4 of 9 l
l that include many of the safety programs, including Chemical Safety. These l
audits are performed biennially.
1
- 11. Page 3.12, Section 3.9.2, What is thefrequencyfor reviewing operatingprocedures that involve chemicalsafety?
Every three years.
- 12. General, Configw ation Management, How are license amendments captured by the CMprogram?
All changes to operations, regardless of the origin, follow our change control process and are included in configuration management.
License amendments that affect an area are developed at the request or with the knowledge of the area manager (s). Once the application is submitted to the NRC, a copy is distributed to the area manager and those responsible for implementing the change. Once NRC approvalis received, these individuals are sent a copy of the approval.
O Chapter 4.0 - Interrated Safety A nalysis
- 13. Page 4.2, Section 4.4, List the processes covered or the reference in Chapter 1.0.
The processes that are covered and the reference to Chapter 1 is to Chapter 1, Section 1.2.3 - Activity where a summary of all the processes covered is j
included.
- 14. Page 4.4, Section 4.9, What is considered to be " extreme on-site catastrophes" and
" serious on-site consequences "for chemical safety?
A hydrogen explosion is an example of an extreme on-site catastrophe. Acid burns suffered by a worker that required medical treatment would be considered a serious on-site consequence.
- 15. Page 4.4, Section 4.9, Examples ofassurances to maintain readiness ofcontrols to prevent or mitigate accidents are listed. Should Configuration Management, QA, l
and A udits and Assessments be included in this list?
Yes. These are assurance measures and Section 4.9 has been modified to include these items.
l l
1 l
l Mr. M. F. Weber 17 bruary 25,1997 e
i A*ttachment 1 i
Page 5 of 9 lO l
i
- 16. Page 4.5, Section 4.9, Table 4.1, For Level 2 Consequences, what are the chemical
" regulatory limitsfor safety"?
T'ie regulatory limits for chemical safety include but are not limited to the 29 CFR 1910.119 standard (Process Safety Management of Highly Hazardous Chemicals) and 29 CFR 1910.1000 Standard (Air Contaminants).
- 17. Page 4. 7, Section 4.9, For chemical safety, identify the controlsfor the highest risk category. What are the " appropriate assurance elements"for mid-level risk controls? Provide examples oflow-risk controls.
Our graded application of controls assurances is contained in a draft plant policy / procedure which GE is currently using as a guide. This procedure will be finalized as a part of the implementation of Chapter 4 requirements. Below is a table that summarizes our current operating guidelines:
Importance High Mid-level Low Active Engineered Controls periodic functional test x
calibration x
x x
O verification following maintenance x
drawings x
x x
preoperational audit x
technical report x
x Administrative Controls operating procedure x
x x
training x
x x
technical report x
x preoperational audit x
Passive Controls technical report x
x x
manufacturing tolerance, corrosion x
tolerance periodic test or dimensional verification x
Chapter 7.0- ChemicalSafety
- 18. Page 7.1, Section 7.0, Who is responsiblefor managing the chemicalsafetyprogram at thefacility?
The Manager, GENE EHS, is responsible for managing the chemical safety program.
n The Manager, GENE EHS delegates to the Manager, Site EHS and others
- V certain elements of the program for implementation. Operating to safe I
Mr. M. F. Weber February 25,1997 i
A'ttachment 1 Page 6 of 9 practices and procedures regarding chemical safety are the responsibility of the GE-Wilmington facility manager delegated to the Product Line Managers.
- 19. Page 7.1, Section 7.1, is the chemical safetyprogram containedin aprocedure, i.e.,
is there a document that lists how ai. Aeprogram elements (IntegratedSafety Analyses (15A), Conduct ofOperatio,.s, Emergency Management, etc.) are related and expected to perform at the facility.:
Yes. Site practices procedures and operating procedures cover chemical review and approval, Integrated Safety Analyses, Conduct of Operations, Emergency Plan & Procedures, Training, Configuration Management, Chemical Job Hazards Analysis (including Personal Protective Equipment - PPE), and other aspects of chemical safety.
- 20. Page 7.1, Section 7.1, What is the basis ofthe chemical safetyprogram, i.e., is it based on a corporate program or related chemicalprocess safety requirements (29 CFR Part 1910.119)?
The chemical safety program is based on OSHA and EPA regulations. In Q
addition, GE Wilmington's chemical safety program incorporates industry and GE company best practices. Where applicable, GE follows OSHA's Process Safety Management Standard (29 CFR 1910.119).
- 21. Page 7.1, Section 7.1, What chemicals arepresently covered by the chemicalprocess safetyprogram (chemicals that have been evaluated through ha:ard evaluations or JSA)?
Chemicals used in the DCP process have been evaluated through the Hazop and ISA reviews. In addition, the DCP chemicals and other chemicals used throughout the GE site are reviewed through site procedures (chemical approvals, Chemical Job Hazard Analysis, and others).
l Currently on the site, anhydrous ammonia is the only chemical regulated under OSHA's Process Safety Management Standard (29 CFR 1910.119). The Process Safety Management Standard has been complied with.
- 22. Page 7.1, Section 7.1, What is the criteria used to determine ifa chemicalis hazardous and could effect the nuclear safetyprogram and what is the nuclear safety program?
The criteria used to determine if a chemicalimpacts the established nuclear O
sarety basis ror a given process or e,ui, ment can be divided into two primary
- ~. -
1 Mr. M. F. Weber February 25,1997 A'ttachment 1 Page 7 of 9 categories; those that directly and those that indirectly effect the nuclear safety program.
Chemicals which may directly impact the safety basis are explicitly addressed in safety analysis and associated safety limits and/or controls. Examples of chemicals important to criticality safety is the determination of the water n
equivalent moderation effect. For example, certain UO2 Powder additives consist oflong hydrocarbon chains that contain significant quantities of i
hydrogen. GE considers the effectiveness of this ' moderator' when establishing the additive limits. Similarly, other moderators are considered (e.g. ammonium oxalate, scrawax, lubricating oils, etc.). The safety function also takes into I
account known chemical uranium compounds and their formation (e.g. UF, red 6
l oil formation, uranyl nitrate hexahydrate, acid solutions or chemical systems j
l known to cause precipitation), and concentrating agents such as those used in the solvent extraction process (e.g. percent TBP in dodecane) which directly influence uranium extraction.
l Chemicals which may indirectly impact the nuclear safety program are usually the same chemicals identified by the chemical safety program as having a direct j
l impact on chemical safety. For example, a fire hazard or explosion risk could l
have radiological consequences, however, protective actions would be driven by the fire / explosion hazard so as to mitigate the risk of both. The Radiological i
Contingency and Emergency Plan includes provisions to assess dose to an l
individual as a result of an accident. The radiological safety program also l
actively monitors individuals' exposure to soluble uranium compounds that i
exhibit chemical toxicity (in accordance with 10 CFR 20).
l Both the criticality safety and radiological safety program functions are clearly described in chapters 2,5 and 6 of the SNM-1997 license renewal application, as amended.
i L
- 23. Page 7.1, Section 7.1, Are all ha:ardous chemicals evaluated or are some determinedto have no impact? How is thisprocess conducted, documentedand venfled? What is the thresholdfor conducting hazards :aalyses?
Yes. Chemicals are evaluated prior to use at the site as described in Section 7.2.2.
i Chemical safety is considered as part of the ISA process (reference Sections 4.7 1
and 7.2.1. The ISAs are documented in reports as described in Section 4.8.
O Administrative centroiis described in Section 4.10.
l
Mr. M. F. Weber February 25,1997 A'ttachment 1 Page 8 of 9 As denoted in the response to question #21 most chemicals have a threshold value ibr significance as a hazardous chemical and the regulations dealing with hazardous chemicals identifies when hazards analysis are to be done. GE follows these regulations, however, may consider other chemicals and values of l
significance as define by management.
l
- 24. Page 7.2, Section 7.2.2, is there aprocedure that outlines the approval / evaluation l
process describedin 7.2.2? Is chemicalincompatibility considered as apotential hazard? In the secondparagraph, the phrase, "not NRC regulated" should be deleted.
Yes. Plant practices and procedures (reference Section 3.9) addresses the chemical approval and evaluation process. The ISA process considers chemical i
incompatibility. Site chemicals and their hazards not connected with special l
nuclear material handling require other considerations such as noted in the 2nd paragraph of 7.2.2.
The second group ofitems in Section 7.2.2 has been eliminated as they dealt
]
with information related to GE's overall chemical safety program but were not appropriate to include in the licensing docun'ent. This includes the wording:
"not NRC regulated".
1
- 25. Page 7.2, Section 7.2.2, Does theformalapprovaldescribedin 7.2.2 require approval ofthe person described in Question #18 above?
l l
Yes. The plant practices and procedures describe the review and approval process and include the Manager, Site EHS as an approver.
- 26. Page 7.2, Section 7.2.2, is this program audited on a specified basis?
l Yes. Chemical approvalis reviewed as a part of the audits described in the response to question #10.
- 27. Page 7.2, Section 7.2.3, What are the applicable regulationsfor labeling or identifying ha:ardous materials? How are personnel made aware ofthese regulations? Is training required? Is compliance with applicable regadations auditedanddocumented?
The applicable regulations which govern labeling, identification and training of employees with regard to Hazardous Materials include 29 CFR 1910.1200
'O (llazard Communication Standard),40 CFR 262 (Standards Applicable To
i Mr. M. F. Weber February 25,1997 j
A*ttachment I Page 9 of 9 I
O Generators Of Hazardous Waste),49 CFR 172.704 Subpart H (Training Requirements for Shipping - DOT), and 49 CFR 172.400, Table 101 (Labeling).
i Hazard Communication Training is given to employees upon initial assignment.
l Chemical specific training via Chemical Job Hazard Analysis (CJHA), is l
reviewed with appropriate employees annually. Hazardous Waste and DOT l
training is given to employees upon initial assignment and every three years.
Conformance to standards is assured by visual observation and employee interviews. See Question #10 regarding audits.
l l
- 28. Page 7.3, Section 7.2.4, The statement in 7.2.4 "Conformance to these standards is i
not NRC regulated" should be deleted. NRC responsibilities do involve plant conditions related to the presence ofhazardous chemicals on or near afuel cycle site that could afect radiation safety. This area is discussedspecifically under paragraph C ofthe Branch Technical Position on Chemical Safety For Fuel Cycle Facilities dated March 21,1989, andshould be understood.
i Section 7.2.4 has been reworded to contain only that language that is required by the NRC for licensing. The wording: "not NRC regulated" has been
- ]
removed.
- 29. Page 7.3, Section 7.2.5, Are root causes analyzed and usedfor a lessons learned l
program and is this program proceduralized?
Section 3.7 mentioned incident investigations, root cause determinations, and lessons learned documentation. As the UIR (UnusualIncident Report) and Taproot @ investigation results become available, the lessons learned are shared with effected personnelin building meetings and with other site l
management le daily NEP production meetings. The lessons learned from l
major incidents are further reviewed at meetings of the WSRC (Wilmington Safety Review Cotamittee). NEP procedures address the UIR system, root cause investigations and the functions of the WSRC."
l l
O
- -.... _ ~..... - _.. _. -. - -... -..
t',
1-1
- Mr. M. F. Weber February 25,'1997 Phge1of1 O
i ATTACHMENT 2 r
i
- 1) Description of Revisions to the License Renewal Application by Page and Section
- 2) License Renewal Page Changes l
S I
O -
l l
l I
l i
l l
l
\\
i i
I 1
1 4
4 i
- 0 1
.. ~ -,.. -,...
.,-i
i Mr. M. F. Weber -
February 25,1997 A'ttachment 2 Page1of1
.o Description of Revisions Pagg Section Description 4.4 4.9 Inserted references to quality assurance, configuration management, audits and assessments as additional examples of assurances typically used at GE-Wilmington.
as controls to prevent accidents (NRC Question #15).
7.2 7.2.2 The section containing the phrase "not NRC regulated" has been deleted since these are not issues that the NRC regulates (NRC Question #24).
7.2 7.2.4 This section has been rewritten to clarify the employee
)
training and awareness, and to exclude the statement' I
"Conformances to these standards is not NRC regulated" (NRC Question #28).
9.1 Chapter 9 This section has been rewritten to clarify reference to the RC&EP, to simplify the wording that references future revisions, and also to correct the title and address of where j
changes that do not decrease the plan's effectiveness will be sent (per discussion with Mr. E. Flack).'
O
)
i 1
i
[O TABLE OF CONTENTS Section Title Page CHAPTER 1 GENERAL INFORMATION 1.1 Facility and Process Description 1.1 1.2 InstitutionalInformation 1.7 1.3 Special Authorizations 1.10 l
CHAPTER 2 ORGANIZATION AND ADMINISTRATION i
i 2.1 Policy 2.1 2.2 Organizational Responsibilities and Authority 2.1 2.3 Safety Committees 2.10 CHAPTER 3 CONDUCT OF OPERATIONS 3.1 Configuration Management (CM) 3.1 O
3.2 Maintena.ce 3.2 3.3 Quality Assurance (QA) 3.4 3.4 Training and Qualification 3.6 3.5 Human Factors 3.7 3.6 Audits and Assessments 3.7 3.7 Incident Investigations 3.9 3.8 Records Management 3.10 3.9 Procedures 3.11 CHAPTER 4 INTEGRATED SAFETY ANALYSIS 4.1 Integrated Safety Analysis 4.1 4.2 Site Description 4.1 4.3 Facility Description 4.1 4.4 Process Description 4.2 4.5 Process Safety Information 4.2 LICENSE SNM-1997 DATE 02/25/97 Page DOCKET 70-1113 REVISION 0
1
.-.. -... -... -. ~
TABLE OF CONTENTS O
Section Title Page 4.6 Training and Qualifications of the ISA Team 4.2 4.7 ISA Methods 4.2 4.8 Results of the ISA 4.3 4.9 Controls for Prevention and Mitigation of Accidents 4.4 4.10 Administrative Control of the ISA 4.7 CHAPTER 5 RADIATION SAFETY l
5.1 ALARA (As Low As is Reasonably Achievable) Policy 5.1 5.2 Radiation Safety Procedures and Radiation Work Permits (RWPS) 5.1 5.3 Ventilation Requirements 5.2 5.4 Air Sampling Program 5.3 5.5 Contamination Control 5.5 l
5.6 External Exposure 5.7 l
5.7 Internal Exposure 5.7 5.8 Summing Internal and External Exposure 5.9 l
5.9 Action Levels for Radiation Exposures 5.9 lh 5.10 Respiratory Protection Program 5.9 l V 5.11 Instrumentation 5.10 l
CHAPTER 6 NUCLEAR CRITICALITY SAFETY 6.1 Program Administration 6.1 6.2 Technical Practices 6.5 l
6.3 Control Documents 6.28 6.4 Criticality Accident Alarm System 6.36 l
CHAPTER 7 CHEMICAL SAFETY 7.1 Chemical Safety Program 7.1 7.2 Contents of Chemical Safety Program 7.1 i
l LICENSE SNM-1997 DATE 02/25/97 Page l
DOCKET 70-1113 REVISION 0
2
1 TABLE OF CONTENTS l
Section Title Page CHAPTER 8 l
FIRE SAFETY l
8.1 Fire Protection Program Responsibility 8.1 l
8.2 Fire Protection Program 8.1 8.3 Administrative Controls 8.2 8.4 Building Construction 8.2 8.5 Ventilation Systems 8.3 l
8.6 Process Fire Safety 8.3 8.7 Fire Detection and Alarm Systems 8.3 8.8 Fire Suppression Equipment 8.4 i
8.9 Fire Protection Water System 8.4 8.10 Radiological Contingency and Emergency Plan (RC&EP) 8.5 l
8.11 Emergency Response Team 8.5 l
CHAPTER 9 RADIOLOGICAL CONTINGENCY AND EMERGENCY PLAN 9.1 l
CHAPTER 10 ENVIRONMENTAL PROTECTION i
10.1 Air Efiluent Controls and Monitoring 10.1 l
10.2 Liquid Treatment Facilities 10.1 10.3 Solid Waste Management Facilities 10.2 10.4 Program Documentation 10.2 10.5 Evaluations 10.3 10.6 Off-site Dose 10.3 10.7 ALARA 10.4 l
CHAPTER 11 DECOMMISSIONING 11.1 LICENSE SNM-1997 DATE 02/25/97 Page DOCKET 70-1113 REVISION 0
3 1
i i
REVISIONS BY CHAPTER o
Application Application Page Date Page Date i
l TABLE OF CONTENTS l
l CHAPTER 6 l
1 through 4 02/25/97 l
1 through 36 12/16/96
(
CHAPTER 1 l
l CHAPTER 7 l
i i through 22 08/30/96 1 through 3 02/25/97 l
l CHAPTER 2 l
l CHAPTER 8 l
1 through 11 02/05/97 1 through 5 04/05/96 l
CHAPTER 3 l
l CHAPTER 9 l
1 through 12 02/05/97 1
02/25/97 l
l CHAPTER 4 l
l CHAPTER 10 l
1 through 8 02/25/97 l
1 through 16 04/05/96 l
CHAPTER 5 l
l CHAPTER 11 l
1 through 13 08/30/96 1
04/05/96 l
l LICENSE SNM-1997 DATE 02/25/97 Page 3
DOCKET 70-1113 REVISION 0
4 1
O CHAPTER 4J INTEGRATED SAFETY ANALYSIS i
4.1 INTEGRATED SAFETY ANALYSIS a
l Integrated Safety Analysis (ISA) is the focal point for safety at GE-Wilmington. ISA is a process in which multifunctional teams analyze the hazards at the site to determine accident scenarios and risk, and ensure that controls are in place to prevent and/or mitigate accidents. The risk associated with an accident scenario is used to judge the level of ongoing assurance that is applied to controls which are in place to prevent the accident. The broad scope of the team's analysis includes criticality safety, radiological safety, environmental protection and industrial safety including 4
chemical safety and fire protection. The accident scenarios identified in the ISA are reviewed by the appropriate safety functions to ensure that the plant continues to comply with site safety policy and regulatory limits.
This program applies to the Dry Conversion Process (DCP) and other process areas as they become baselined using the ISA process.
l 4.2 SITE DESCRIPTION O
A general description of the site is included in Chapter 1.0. More detailed site i
information is included in the Environmental Report described in Chapter 10.0. The credible external events which are considered by the ISA teams are defined in an established written practice.
4.3 FACILITY DESCRIPTION Safety-significant information describing the facility, including arrangement of buildings on the site, location with respect to the site boundary, and the facility's ability to withstand credible external events, is included in drawings and reports maintained under configuration managemer*
I LICENSE SNM-1097 DATE 02/25/97 Page Q
DOCKET 70-1113 REVISION 0
4.1 l
h.
4.4 PROCESS DESCFJPTION O
Processes covered by this license are summarized in Chapter 1.0. Detailed information concerning these processes is typically included in technical reports, nuclear safety analyses, operating procedures, Process & Instrumentation Drawings i
(P&lDs), and other detailed process information, which is maintained under configuration management.
4.5 PROCESS SAFETY INFORMATION Process technology information is gathered and maintained for future use by ISA teams. Technical reports, which typically include process chemistry, intended inventories, and safe upper and lower limits for process variables such as temperature, pressure, flow, and composition, are maintained under configuration management.
Process equipment information is maintained in accurate condition through configuration management. Examples include P&lDs, materials of construction, electrical classification, ventilation system design, and safety systems including interlocks, detection, and suppression systems.
Hazardous material information, including toxicity, permissible exposure limits, q
physical data, reactivity data, corrosivity data, and thermal and chemical stability V
data, is available to employees and ISA teams in the form of Material Safety Data Sheets (MSDS's).
4.6 TRAINING AND QUALIFICATIONS OF THE ISA TEAM ISAs are conducted by teams ofindividuals with diverse, pertinent knowledge and experience. The team members are chosen to provide operational and technical expertise in the study area, and appropriate safety expertise based on the hazards that are known to exist in the study area. The camposition of the team is defined in an established plant practice.
4.7 ISA METHODS The hazards in the facility are identified and analyzed usir.g methodology that is widely accepted throughout the chemical industry. Examples of the methodology are LICENSE SNM-1097 DATE 02/25/97 Page
(\\s)
DOCKET 70-1113 REVISION 0
4.2
j e
described in Guidelines for Hazard Evaluation Procedures, published by th( Colu l
O, for Chemical Process Safety of the American Institute of Chemical Engineers 0992).
l Hazards are analyzed using established methods, for example.
Preliminary Hazards Analysis e
What If/ Checklist Hazards and Operability Analysis e
Failure Mode and Effect e
Fault Tree e
Event Tree Human Reliability Analysis e
Procedural guidance is provided to the ISA teams in the form of a written plant practice that outlines the special treatment these methods require when applied to processes in the nuclear industry. Examples of this special treatment includes the consideration of criticality and radiological hazards. In this procedure, the teams are instructed to consider start-up, shutdown, upsets, and maintenance, in addition to nonnal operating conditions. Guidance is provided conceming the external events which must be considered in ISAs.
The written plant practice also provides guidelines for ranking accident scenarios
_O accordina to ris*. that is.
niti ated conse9uence and iikeitheed. The team then 8
ensures that the controls that prevent or mitigt.te accidents are of the appropriate quality and reliability.
4.8 RESULTS OF THE ISA Ta results of the ISA team's analysis are communicated in a summary report to appropriate levels of management. This report summarizes the elements that are important to safety in the area studied. The lists of hazards and accident scenarios are compiled and maintained by the configuration management function. Guidance to the teams is provided in a written plant practice to ensure comprehensive reports.
i h
DOCKET 70-1113 REVISION 0
' 4.3
-~
~ - -
s 1
4.9 CONTROLS FOR PREVENTION AND MITIGATION OF ACCIDENTS U
Controls which are relied upon to prevent or mitigate serious accidents are maintained in a ready state through the application of a wide range of assurances.
Examples of assurances typically used at GE-Wilmington include: configuration management, preventative maintenance, functional tests, quality assurance, purchasing specifications, training, procedures, audits, assessments and inspections.
The level of assurance applied is consistent with the level of risk associated with the specific accident scenario. Responsible risk management requires consideration of -
the components of risk, specifically consequences and likelihood. Accident scenarios are rated by the ISA teams in terms of unmitigated consequences and likelihood of an initiating event according to criteria defined in written plant practices.
The general categories of consequences are defined as follows: the highest category is assigned to accidents that could result in injury to the public located outside the site boundary and to extreme on-site catastrophes. The middle level is assigned to accidents that would result in regulatory violations and/or serious on-site consequences. All other accidents are assigned to the lower level. These categories are summarized in Table 4.1.
LICENSE SNM-1997 DATE 02/25/97 Page DOCKET 70-1113 REVISION 0
4.4
m..
.. _. ~. _ -..
i
! LO Table 4.1 Consequence Levels Severity Radiological /
Environmental /
[
Ranking Criticality Industrial / Chemical i
3 e
exposure to an individual fatality e
j member of the public off-site medical treatment for a (5 rem,30 mg intake of U) member of the public off-a severe exposure to an site e
employee (400 rem internal permanent disability e
plus external dose or 230 mg off-site contamination e
intake of U) above regulatory standards i
2 e
exceed regulatorylimits for serious injury e
employee exposure (5 rem,10 exceed permit limits or e
l mg U internal) regulatory limits
)
lost time injury e
reportable release e
4!O i
exceea aamiaistrative iimits osa^ receraabie i Jerr l
on daily air samples, lung e first aid i
counts, bioassays,
. exceedintemallimits contamination, TLDs spill inside containment e
10% of annual exposure limit e UIR e
4 Accident scenarios are rated according to the likelihood of occurrence. The i-j_
likelihood is categorized in qualitative terms that can easily be applied by the ISA teams. The highest category oflikelihood is applied to initiating events that could occur at any time in the immediate future. The middle category is for events that are likely to occur during the life of the operation. The lowest likelihood category is used for events that are not expected to occur during the life of the facility. In order to provide consistency in ranking, quantitative levels are provided as guidelines to s
i 1
the teams. These levels are summarized in Table 4.2.
5 a
i i
LICENSE SNM-1997 DATE 02/25/97 Page j
DOCKET 70-1113 REVISION 0
4.5 i
I k
OQ Table 4.2 Likelihood Levels t
i LEVEL FREOUENCY LIKELIHOOD 3
more frequent than once every likely to occur in the immediate two years future 2
every two to fifty years likely to occur during the life of I
the facility I
less frequent than once every not likely to occur during the life fifty years of the facility I
J 0
incredible likelihood is indistinguishable from zero The levels of consequence and likelihood are combined to estimate the level of risk ofinitiating a particular accident. Figure 4.1 demonstrates the risk assignment matrix. This risk assignment is used by the teams to determine the level of assurance
- O thet wiii he aggiied te the contreis ihat protect aseinst thet garticuiar accident.
3 4
2 1
i 4
LICENSE SNM-1997 DATE 02/25/97 Page i
DOCKET 70-1113 REVISION 0
4.6 f
\\
\\
Figure 4.1 O
Risk ^ssignment Matrix l
C o
3 Mid-level n
Risk -
s e
q 2
Low Risk
.Mid-level u
Risk e
4 n
c 1
Low Risk Low Risk Mid-level l
e Risk -
J 1
2 3
Likelihood l
Controls that prevent or mitigate events in the highest risk category receive full evaluation and appropriate application of all assurance elements defined in Chapter 3.0. Appropriate assurance elements are applied to mid-level risk controls. Low risk controls are treated with normal, prudent attention.
i l
4.10 ADMINISTRATIVE CONTROL OF THE ISA l
The ISA is maintained current through a configuration management program that 4
ensures that: 1) facility changes receive adequate integrated safety review, and 2) changes are adequately documented.
Proposed facility changes are reviewed by a trained and approved integrated safety reviewer to determine if the change impacts the existing ISA. If so, an ISA team is assembled, and the change is analyzed. The results of the ISA and the recommendations of the team are used in approving or rejecting the proposed change.
After the change is implemented, the revised ISA becomes a part of the controlled documentation for the facility.
The trained and approved integrated safety reviewer possesses the experience, training and skills to consider criticality, radiological, environmental, chemical, and industrial impact within a predefined set oflimits. The reviewer is approved by the LICENSE SNM-1097 DATE 02/25/97 Page O
oocker va->>>>
nevisio" a
47
. = - - ~
manager of the EHS function and reports organizationally to the manufacturing
-O product line. This organizational structure gives ownership of operational safety to I
the manufacturing function.
I i
j l
i O
i LICENSE SNM-1097 DATE 02/25/97 Page O
oocxer 7a->>>>
aEvisioN o
4.8 l
i g
CHAPTER 7.0 CHEMICAL SAFETY 7.1 -
CHEMICAL SAFETY PROGRA1,1.
It is the policy of GE-Wilmington to provide a safe and healthy work place by minimizing the risk of chemical exposure to employees and members of the general public. The GE-Wilmington chemical safety program is documented in written, approved practices, and ensures that processes and operations comply with applicable federal and state regulations pertaining to chemical safety.
Hazard evaluations are performed on nuclear and non-nuclear operations within the nuclear manufacturing operations where the potential exists for hazardous chemicals to be used in such a manner that they could effect the nuclear safety program. This ensures appropriate controls are in place for adequate protection of the general public and safe use by employees, and that the use of chemicals does not create potential conditions that adversely effect the handling oflicensed nuclear materials.
Employees using hazardous materials are trained to ensure safe handling, use, and disposal.
l Q
7.2 CONTENTS OF CHEMICAL SAFETY PROGRAM The following management control elements are incorporated into GE-Wilmington chemical safety program:
7.2.1 CHEMICAL SAFETY IN INTEGRATED SAFETY ANALYSIS l
Considerations of chemical safety for hazardous materials as described in this l
Chapter are incorporated in GE-Wilmington's Integrated Safety Analysis program.
GE-Wilmington's Integrated Safety Analysis Program is explained in detail within l
Chapter 4.0.
l l
I LICENSE SNM-1997 DATE 02/25/97 Page O
oocxer 7a->>>>
x8visio" a
7'
t 4
7.2.2 CHEMICAL APPROVAL / EVALUATION Q
1 Prior to new hazardous materials being brought on-site or used in a process, they are approved through the environmental protection function and the chemical and fire safety function. The formal approval process consists of evaluations of the following potential hazards:
j Physical Hazards e
e
~
Health Hazards e
Fire / Explosive Hazards -
j Potential Impact on handling oflicensed nuclear material i
e I
The conclusions of this approval process may dictate the following assurance of chemical process safety:
New procedures or changes in existing procedures i
e Maintenance programs for control related equipment l
Configuration management Emergency Planning Training O
7.2.3 LABELING & IDENTIFICATION l
Hazardous materials or conveyance systems are labeled or identified to meet applicable regulations. The proper identification of hazardous materials decreases the likelihood ofimproper use, handling and disposal reducing potential negative consequences.
d i
7.2.4 EMPLOYEE TRAINING & AWARENESS i
Radiation workers receive nuclear safety training and otherjob related training i
l (Chapter 3, Section 3.4) which includes safety information related to chemicals 4
associated with nuclear material and chemicals in the area which could impact the nuclear safety of the process.
5 LICENSE SNM-1997 DATE 02/25/97 Page i
DOCKET 70-1113 REVISION 0
7.2
I 7.2.5 INCIDENT CLASSIFICATION & INVESTIGATION O
GE-Wilmington's incident classification and investigatian program is discussed in Chapter 3.0.
O LICENSE SNM-1997 DATE 02/25/97 Page DOCKET 70-1113 REVISION 0
7.3
I i
CHAPTER 9.0 I
U^
RADIOLOGICAL CONTINGENCY AND EMERGENCY PLAN GE-Wilmington shall naintain and execute the response measure in the Radiological Contingency and Emergency Plan as specified in Safety License Condition S-3 of Materials License SNM-1097; or as further revised by the licensee consistent with 10 CFR 70.32(i). The Radiological Contingency and Emergency Plan incorporates the requirements established by the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Publication L 99-499.
i GE-Wilmington will make no changes to the Radiological Contingency and i
Emergency Plan which would decrease its effectiveness without prior approval of the NRC.
1 Changes, which do not decrease the effectiveness of the Radiological Contingency and Emergency Plan, will be reported within six months of the change to the Chief, Licensing Branch, Division of Fuel Cycle Safety and Safeguards, U.S. Nuclear l
j Regulatory Commission, Washington, D.C. 20555.
The requirements of the Radiological Contingency and Emergency Plan are implemented through approved documented procedures maintained by GE-Wilmington.
i LICENSE SNM-1997 DATE 02/25/97 Page
(
DOCKET 70-1113 REVISION 0
9.1