ML20137H561

Forwards Response to Request for Addl Info Contained in Ltr from Ma Lamastra to Rj Reda

ML20137H561
Person / Time
Site:	07001113
Issue date:	03/27/1997
From:	Reda R GENERAL ELECTRIC CO.
To:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
TAC-L10079, NUDOCS 9704020279
Download: ML20137H561 (49)

Text

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GENuclear Energy conwameanc cwwy (n

F0 Box 780. Wimmyton NC 8C

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910 E75 !M March 27,1997 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) j i

Reference:

(1)

NRC License SNM-1097, Docket 70-!!!3 (2)

License Renewal Application,4/5/96 l

(3)

Submittal, RJ Reda to ED Flack,5/6/96 (4)

Submittal, RJ Reda to RC Pierson,5/14/96 (5)

Letter, RC Pierson to RJ Reda,7/18/96 (6)

Submittal, RJ Reda to RC Pierson,8/30/96 i

(7)

Submittal, RJ Reda to ED Flack,9/26/96 (8)

Letter, MA Lamastra to RJ Reda,10/2/96 l

(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)

Submit 1, RJ Reda to MF Weber,2/19/97 (15)

Subm;.al, RJ Reh to MF Weber,2/25/97 (16)

Lette., MA Lamastra to RJ Reda,3/5/97

Dear Mr. Weber:

GE's Nuclear Energy Production (NEP) facility in Wilmington, N.C., hereby transmits the enclosed information in response to the above referenced letter dated 3/5/97, and a page revision based upon our 8/30/96 submittal. This information is being provided in support of our license renewal request.'

9704020279 970327

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Mr. M. F. Weber March 27,1997 Page 2 O

Attachment I contains the requested information (italicized) identified in Mr. Lamastra's letter j

dated 3/5/97, and our responses (bold print).

l 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 I

Table of Contents, Chapter 1.0, Chapter 3.0 and Chapter 7.0. 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 (l ) in the right hand column to show where a change has taken place. All replacement pages contain the date of this submittal (3/27/97) and are shown as revision zero.

I Six copies of this submittal are being provided for your use.

Please contact Charlie Vaughan on (910) 675-5656 or me on (910) 675-5889, if you have any questions or would like to discuss this matter further.

Sincerely, GEN AR ENERGY 0

L' Ralp e

ag r Fuels & Faci ity Licensing

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' Attachments l

ec:

RJR-97-037 L. A. Reyes, Region II Administrator G. L. Troup, NRC-Atlanta

)

M. Fry, State of NC 4

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4 o

Mr. M. F. Weber March 27,1997 Page1of1 O

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ATTACliMENT 1 Response to Request for Additional Information Contained in Letter from MA Lamastra to RJ Reda Dated March 5,1997 O

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Mr. M. F. Weber March 27,1997 Page 1 of 3

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G.E. - Wilmington Renewal Application Comments Chemical Safety Program i

Request for AdditionalInformation 3/5/97 Chapter 3.0- Conduct of Operations 1.

Chapter 3.0, The phrase " written, approvedpractices"and "documentedplant practices"is used throughout Chapter 3.0. What is the definition ofpractices as used in this chapter and license application? As described in the license application they should be maintained / controlled / approved in the same manner as procedures.

At the Wilmington GE site, we generally use the term " Practices and Procedures" to cover those documents that are customarily simply called i

" procedures". Practices generally set forth guidelines and basic requirements i

while procedures provide more detailed "how to"information. The Practices and Procedures System is documented in lead documents which define its i

O organization and the operations and requirements for documentation. All such documents are maintained, controlled and approved.

2.

Page 3.12, Section 3.9.2, There does not appear to be a statement that explicitly states that " Licensed materialprocessing will be conducted in accordance with properly issuedprocedures or instructions". This statement or similar words should i

be included in the license application.

This statement is being added to Section 3.9.2. The modification is in the first sentence where the wording "..., approved and issued..." has been inserted.

3.

Page 3.12, Section 3.9.2, The table listing the reviewfrequencyfor operating procedures is every three years but the " Reviewing and Approving Functional Manager" does not include the chemical orfire safetyfimetion. They should be includedin the License Application.

Actually they are included since the table calls out "EHS Discipiine (...

Environmental, Industrial,...). Environmentalincludes some aspects of chemical safety and Industrial includes both chemical safety and fire safety.

This has been added as note 4) to the review and updating frequencies table on page 3.12.

Q

Mr. M. F. Weber March 27,1997 Attachment i Page 2 0f 3 Chapter 4.0 - Integrated Safety A nalysis 4.

Follow-up to Question 17from GE RAIresponses dated 2/25/97. It appears that safety controls associated with "Afid-Level Risk"should have a periodicfunctional test. Based on the Level 2 Likelihood ofoccurring during the life ofthefacility and Consequences ofserious injury; exceeding permit limits or regulatory limits; lost time injury; or a reportable release. Please review andprovide rationale and discussion on the reasonfor not including a periodicfunctional testfor Afid-Level Risk.

There was an error in the table we transmitted in the answer to question 17 and while it does not address the exact situation of this follow-on question the error does have a bearing on the appropriateness of GE's program. Mid-level risks in both the " Active Engineered" and the " Administrative Controls" should have included a check as requiring preoperational audits. This change is being included.

O The checks in the table are minimum and inspectable requirements of the license and as such do not preclude the licensee from using functional tests for any system the licensee deems appropriate. One of the items that comes from the ISA Team output is a set of recommendations that management must review and disposition. One such recommendation could be that for some particular system functional tests on some frequency should be considered. In these cases management will evaluate the benefit and disposition the recommendation.

The key to safety assurance comes in the fact that all as-built systems are "preoperationally audited" to verify that the configuration is appropriate. The systems are maintained under configuration management and during the operating life the ISAs are reviewed as changes are made and updated where appropriate. The broad scope of Configuration Management is discussed in Section 3.1.1.

l Quality Assurance of safety systems is discussed in Section 3.3. Section 3.3.1 includes the assurance elements used. Section 3.3.2 provides an overview of the way these assurance measures are applied.

It is also important to note, that the ISAs are revisited each time a change is made and as a minimum must be revalidated every five years as required by procedure. This provides an ongoing degree of assurance that the systems O

continue to be configured such that they will function.

Mr. M. F. Weber March 27,1997 Page 3 of 3 Chapter 4.0 -IntegratedSafety Analrsis (Correction to Ouestion #17 Dated 2/25/97)

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 i

be finalized as a part of the implementation of Chapter 4.0 requirements.

Below is a table that summarizes our current operating guidelines:

importance High Mid-level Low i

Active Engineered Controls periodic functional test x

calibration x

x x

verification following maintenance x

drawings x

x x

l preoperational audit x

x p

technical report x

x

(

Administrative Controls operating procedure x

x x

training x

x x

technical report x

x l

preoperational audit x

x Passive Controls technical report x

x x

j manufacturing tolerance, corrosion x

tolerance periodic test or dimensional verification x

Chapter 7.0 - ChemicalSafety 5.

Page 7.1, Section 7.1, Follow-up to question # 20from G.E. 2/25/97lbfIresponse, ll7 tat chemicalsfollow the OSIbf Process SafetyManagement Standard (29 CFR 1910.119)? Elements ofthe chemicalsafetyprogramfor UFs andhydrofluoric acid should be included in the license application.

The regulations as referenced in our answer to Question #20 in our February 25,1997 submittal are implemented through internal procedures as typified by out internal safety procedure #303 Safety Considerations in Design.

O

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e Mr. M. F. Weber March 27,1997 Page1of1 0

ATTACHMENT 2

1) Description of Revisions to the License Renewal Application by Page and Section j

2) License Renewal Page Changes l

O 1

4

4

. Mr. M. F. Weber

[

- March 27,1997

'j

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i p Page1 of1 j

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l Description of Revisions 4

Pagg Section Description 1.18 1.3.14 The last paragraph of this section has been removed. As a result of NRC licensing action on September 23,1996, the authorization to base DAC or ALI on current models

]

recommended by organizations such as the ICRP is withdrawn from the license submittal.

3.11 3.9.2 Added the words " approved and issued"(NRC Question

1. 2).

lo 4

3.12 3.9.2 Added note 4,"EHS Discipline..."(NRC Question #3).

7.1 7.1 Added an explanation of the elements of the chemical i

l' safety program (NRC Question #5).

a 7.3 7.2.6 Added a reference to where other elements of our l

chemical safety program may be found (NRC Question j

1. 5).

4 4

9 5

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TABl E OF CONTENTS Section Title Page CII APTER 1.0 GENERAL INFORMATION I

1.1 Facility and Process Description 1.1 1.2 Institutional Information 1.7 l.3 Special Authorizations 1.10 CIIAPTER 2.0 ORGANIZATION AND ADMINISTRATION 4

I 2.1 Policy 2.1 2.2 Organizational Responsibilities and Authority 2.1 2.3 Safety Committees 2.10 CII APTER 3.0 i

CONDUCT OF OPERATIONS 3.1 Configuration Management (CM) 3.1 0

32 u i ie =ce 32 1

3.3 Quality Assurance (QA) 3.4 3.4 Training and Qualification 3.6 i

3.5 Iluman Factors 3.7 3.6 Audits and Assessments 3.7

(

3.7 incident Investigations 3.9 3.8 Records Management 3.10 4

I 3.9 Procedures 3.11 CII APTER 4.0 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 03/27/97 Page

[]

DOCKET 70-1113 REVISION 0

1

i e

TABLE OF CONTENTS

.O i

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 l

4.10 Administrative Control of the ISA 4.7

[

l CHAPTER 5.0 RADIATION SAFETY 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 5.7 Internal Exposure 5.7 5.8 Summing Internal and External Exposure 5.9 i

5.9 Action Levels for Radiation Exposures 5.9 Q

5.10 Respiratory Protection Program 5.9 5.11 Instrumentation 5.10 l

}

CHAPTER 6.0 NUCLEAR CRITICALITY SAFETY

[

6.1 Program Administration 6.1 6.2 Technical Practices 6.5 6.3 Control Documents 6.28 6.4 Criticality Accident Alarm System 6.36 Cil APTER 7.0 CHEMICAL SAFETY 7.1 Chemical Safety Program 7.1 7.2 Contents of Chemical Safety Program 7.1

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LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70 1113 REVISION 0

2

i l

i TAHLE OF CONTENTS O

Section Title l' age CIIAPTER M!

FIRE SAFETY 8.1 Fire Protection Program Responsibility 8.1 8.2 Fire Protection Program 8.1 8.3 Administrative Controls 8.2 8.4 Huilding Construction 8.2 8.5 Ventilation Systems 8.3

)

8.6 Process Fire Safety 8.3 8.7 Fire Detection and Alarm Systems 8.3 j

8.8 Fire Suppression Equipment 8.4 8.9 Fire Protection Water System 8.4 8.10 Radiological Contingency and Emergency Plan (RC&EP) 8.5 1

8.11 Emergency Response Team 8.5 CII APTER 9.0 i

RADIOLOGICAL CONTINGENCY AND EMERGENCY PLAN 9.1 Q

CIIAPTER 10.0 l

ENVIRONMENTAL PROTECTION

)

10.1 Air Effluent Controls and Monitoring 10.1 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 CII APTER 11.0 DECOMMISSIONING 11.1

'l LICENSE SNM-1097 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

3

1 t

REVISIONS BY CliAPTER O

Application Application

, Page Date Page Date i

l TABLE OF CONTENTS l

l CllAPTER 6.0 l

1 through 4 03/27/97 l

1 through 36 12/16/96 l

CliAPTER 1.0 l

l CHAPTER 7.0 l

1 through 21 03/27/97 l

1 through 3 03/27/97 l

t l

CilAPTER 2.0 l

l CIIAPTER 8.0 l

1 through 11 02/05/97 1 through 5 04/05/96 O

l CIIAPTER 3.0 l

l CllAPTER 9.0 l

1 through 12 03/27/97 l

1 02/25/97 l

C11 APTER 4.0 l

l CliAPTER 10.0 l

)

I through 8 02/25/97 1 through 16 04/05/96 l

CIIAPTER 5.0 l

l CliAPTER 11.0 l

I through 13 08/30/96 1

04/05/96 LICENSE SNM-1097 DATE 03/27/97 Page O

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CH APTER 1.0

{y GENERAL INFORMATION

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1.1 FACILITY AND PROCESS DESCRIPTION i

The primary purpose of the GE-Nuclear Energy Production facility in Wilmington, North Carolina (identified in this document as GE-Wilmington) is the manufacture of fuel assemblies for commercial nuclear reactors. Nuclear materials enriched to less than or equal to 6.0 weight percent U-235 are utilized in the product manufacturing operations authorized by this license. The safety, environmental, quality assurance and emergency preparedness aspects of the manufacturing operations are managed and controlled as described in this license.

)

1.1.1 SITE DESCRIPTION AND LOCATION GE-Wilmington is situated on a 1,664-acre tract ofland, located on U.S. liighway

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117 and approximately six miles north of the City of Wilmington, North Carolina in New Ilanover County (refer to Figures 1.1 and 1.2). New IIanover County is situated in the southern coastal plains section of southeastern North Carolina, with the Atlantic Ocean on the east and the Cape Fear River on the west. The Atlantic O

ocean iies aggreximateir i0 miies ea81 and 26.4 miies eouth of GE-wiiminston.

The surrounding terrain is low-lying, with an average elevation ofless than 40 feet above mean sea level.

Castle liayne, the nearest community, is approximately three miles north of GE-Wilmington. The region around the site is lightly settled with large areas of heavily l

timbered tracts ofland. Farms, single-family dwellings and light commercial activities are located along U.S. I17. The Wilmington airport is located approximately 3.5 miles southeast of the site.

1.1.2 FACILITY DESCRIPTION The location and arrangement of buildings at the GE-Wilmington site, and their relative distance from the site boundary are shown in Figure 1.3. Located on the GE-Wilmington site are the following major facilities: (1) the GE Aircraft Engine (AE)

LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

1.1

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l FIGURE 1.3 (Continued)

O GE-WILMINGTON SITE PLAN LEGEND Fuel Manufacturing Operation (FMO) 1 j

2 :

Fuel Components Operation (FCO) 3 :

Aircraft Engine Operation (AE) 2 4 :

Services Components Operation (SCO) 5 :

Final Process Basins 6 :

Waste Treatment Facility 7 :

Incinerator Building 8 :

Filter Facility 9 :

DA Building 10 :

Boiler / URLS 11.

Office Building i

12 :

Site Maintenance 13 :

Site Warehouse 14 :

FMO Storage Building 15 :

FMO Maintenance Building I

16 :

AE Maintenance Building 17 :

Waste Treatment Basins 18 :

Fuel Examination Technology 1

19 :

Dry Conversion Process Building (DCP) 20 :

Warehouse 21 :

CaF Storage Warehouse 2

LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION O

1.5

4 facility which is not involved in the nuclear fuel manufacturing operation, (2) The q

Services Components Operation (SCO) facility where non-radioactive reactor i

V components are manufactured, (3) the Fuel Components Operation (FCO) facility i

where non-radioactive components for reactor fuel assemblies are manufactured, and (4) the fuels complex containing the fuel manufacturing facility. The fuels complex, which includes the Fuel Manufacturing Operation and Dry Conversion Process (FMO/FMOX & DCP) buildings and supporting facilities, is enclosed by a fence with restricted access. This complex is called the Controlled Access Area (CAA).

l 1.1.3 FACILITY RESISTANCE TO ENVIRONMENTAL EVENTS In the coastal area of North Carolina, where GE-Wilmington is located, severe weather conditions may result from hurricanes, tornadoes, ice storms, and snow storms. The greatest severe weather threat in this area is due to high winds from hurricanes and possible tornadoes. Facility construction meets or exceeds local i

codes for strength and in the case of hurricanes, advance notice provides an oppmtmity for further mitigating acticns. Since high winds could impact electrical power, key afety systems are protected with adequate back-up power supplies or fail safe features. Earthquakes are not considered a major threat because this section of the southern Atlantic Seaboard is an area of relatively low seismic activity.

The Fuel Manufacturing Operation building in which radioactive materials are o

processed and stored, is designed to provide for containment of material under d

adverse environmental conditions such as fire, wind, flooding or earthquake to the limits of the building code. The roof construction meets Factory Mutual requirements for fire hazard and wind resistance.

Detailed information regarding the facility resistance to the effects of potential credible accident events is contained in Chapters 2 and 5 of the Radiological Contingency and Emergency Plan for GE-Wilmington, which is de.<ned in Chapter 9.0 of this license, and in Chapters 2 and 6 of the Environmental Rept et for GE-Wilmington which is described in Chapter 10.0 of this license.

1.1.4 PROCESS DESCRIPTION The product manufacturing operations authorized by this license consist of receiving low-enriched, less than or equal to 6.0 weight percent U-235, uranium hexafluoride; converting the uranium hexafluoride to uranium dioxide powder; and processing the LICENSE SNM-1997 DATE 03/27/97 Page fS DOCKET 70-1113 REVISION 0

1.6 NJ

uranium dioxide through pelletizing steps, fuel rod loading and sealing, and fuel

,Q assembly fabrication.

V Two types of processes are used to convert uranium hexafluoride to uranium dioxide l

powder -- the Ammonium Diuranate (ADU) process, and Dry Conversion Process (DCP). The manufacturing operations are served by support systems such as scrap recovery, waste disposal, laboratary, and manufacturing technology development, which are also described in this license.

1.2 INSTITUTIONAL INFORMATION i

The GE-Wilmington NRC license number is SNM-1097 (Docket #70-1113).

1.2.1 IDENTITY AND ADDRESS This application for license renewal is filed by the GE-Nuclear Energy Production facility of the General Electric Company, a major corporation with corporate headquarters in Fairfield, Connecticut. General Electric's nuclear energy business, i

known as GE Nuclear Energy, is headquartered in San Jose, California, with the principal manufacturing facility located in Wilmington, North Carolina.

The full address is as follows: GE Nuclear Energy Production,(name of person and Q

mail code), P.O. Box 780, Wilmington, NC 28402.

i 1,2.2 TYPE, QUANTITY, AND FORM OF LICENSED MATERIAL Uranium normally will be used at GE-Wilmington in the Controlled Access Area (CAA) only. Conversion and fabrication is conducted within the fuel manufacturing building (FMO/FMOX & DCP). Small quantities (i.e., less than one safe batch of uranium in a non-dispersible form) may be temporarily moved to other buildings or site locations outside of the CAA for special tests under special authorizations and controls.

The following types, maximum quantities, and forms of special nuclear materials are authoriz 3:

1) 50,000 kilograms of U-235 contained in uranium enriched to a maximum enrichment ofless than or equal to 6%, in any chemical or physical form except metal;

. LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

1.7

i

2) 500 kilograms of U-235 at enrichments from 6% to <10% contained in uranium compounds for use in laboratory and process development operations;

3) 9.649 kilograms of U-235 at enrichments from 10% to <l5% contained in uranium compounds for use in laboratory and process development operations;

4) 350 grams of U-235 in any form contained in uranium at any enrichment, for use in measurements, detection, research or development activities;

5) Plutonium - 1 milligram in samples for analytical purposes, I milligram as standards for checking the alpha radiation response of radiation detection instrumentation,20 grams as sealed neutron sources, and in nuclear fuel rods at a 4

2 level ofless than 1 x 10 gram ofplutonium per gram of U n,

6) 50 milligrams U-233 for analytical purposes.

1.2.3 ACTIVITY GE-Wilmington complies with applicable parts of Title 10, Code of Federal Regulations, unless specifically amended or exempted by NRC staff.

Authorized activities at GE-Wilmington include:

1.2.3.1 Product Processing Operations i}

k UF6 Conversion - Conversion of uranium hexafluoride to uranium oxides by e

the ADU process, and the Dry Conversion Process.

Fuel Manufacture - Fabrication of nuclear reactor fuel (powder, pellets, or assemblies) containing uranium.

Scrap Recovery - Reprocessing of unirradiated material from GE-Wilmington 1

e and from other sources with nuclear safety characteristics not significantly different from GE-Wilmington in-process materials.

Waste Recovery - Recovery of uranium from wet and dry material stored in on-site pits and basins. The recovered unmium will be returned to the fuel processing facility.

LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

1.8

1.2.3.2 Process Technology Operations 0

Deveiopment and fabrication of reactor ruei, ruei eiements aed fuei e

assemblies of advanced design in small amoums.

i Develop;nent of scrap recovery processes.

l e

t Determination ofinteraction between fuel additives and fuel materials.

e Chemical analysis and material testing, including physical and chemical testing and analysis, metallurgical examination and radiography of uranium compounds, alloys and mixtures.

Instrument research and calibration, including development, calibration and e

functional testing of nuclear instrumentation and measuring devices.

A conversion of UF6 to UO and other intermediate compounds using 2

chemical and dry processes.

Other process technology development activities related to, but not limited by, the above.

i i

1.2.3.3 Laboratory Operations Chemical, physical or metallurgical analysis and testing of uranium compounds and i

p mixtures, including but not limited to, preparation oflaboratory standards.

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1.2.3.4 General Services Operations Storage of unitradiated fuel assemblies, uranium compounds and mixtures in e

areas arranged specifically for maintenance cf criticality and radiological safety.

Design, fabrication and testing of uranium prototype processing equipment.

Maintenance and repair of uranium processing equipment and auxiliary systems.

Storage and nondestructive testing of fuel rods containing trace amounts of plutonium as authorized in the license.

LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

1.9

1.2.3.5 Waste Treatment and Disposal 0

Treatment. etorase and discesei a#deor shipmeni efiiamid and seiid wa tes whose discharges are regulated.

Decontamination of non-combustible contaminated wastes to reduce uranium contamination levels, and subsequent shipment of such low-level radioactive wastes to licensed burial sites for disposal or as authorized by the NRC.

Treatment or disposal of combustible waste and scrap material by incineration pursuant to 10 CFR 20.2002 and 10 CFR 20.2004.

1.2.3.6 Off-site Activities Testing, demonstration, non-destructive modification and storage of materials and devices containing unirradiated uranium, provided that such materials and devices shall be under GE control at all times.

1.3 SPECIAL AUTHORIZATIONS 1.3.1 ACTIVITIES REQUIRING PRIOR NRC AUTHORIZATION BY LICENSE AMENDMENT 1.3.1.1 Major changes or additions to existing processes which may involve a significant increase in potential or actual environmental impact resulting from utilizing such changes or additions.

1.3.1.2 Major process changes or major additions which involve a new process technology for which the safety demonstration has not been previously subjected to review by the NRC. In determining whether a new process technology requires such prior authorization by license amendment, the following factors will be considered: (1) type of equipment utilized, (2) chemical reactions involved and (3) potential and/or actual environmentalimpact.

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l.3.1.3 groposed activities for which specific application and prior approval are required by

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NRC regulations.

1.3.2 CONTAMINATION-FREE ARTICLES i

Authorization to use the guidelines, contamination and exposure rate limits specified

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at the end of this Section, " Guidelines for Decontamination of Facilities and Equipment erior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," US NRC, April 1993 for l

decontamination and survey of surfaces or premises and equipment prior to i

abandonment or release for unrestricted use.

i 1.3.3 TRANSFER OF CONTAMINATION-FREE LIQUIDS 1.3.3.1 Transfer of11ydrofluoric Acid (HF) for Testing Authorization to transfer test quantities ofliF to potential buyers / customers or laboratories for the purpose of analyzing, examination or evaluation, without continuing NRC controls as described in GE-Wilmington's letter to the NRC dated February 26,1996.

O restquantities may netcontein morethan 3 eg u urenium with an enrichmcateette exceed 6% U-235.

1 The recipients will be advised that this material is not a nuclear hazard, but will be advised that the material should be handled carefully and in such a manner so as not to be consumed by humans nor used in products used on or in the body or in the food

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chain.

1.3.3.2 Ilydrogen Fluoride Solutions Authorization, pursuant to 10 CFR 70.42(b)(3), to transfer liquid hydrofluoric acid to Brush Wellman, Elmore, Ohio, through the chemical supplier, Consolidated Chemical Company, Kansas City, Missouri, without either company possessing an NRC or Agreement State license for special nuclear material, provided that the concentration of uranium does not exceed three parts per million by weight of the liquid and the enrichment is less than or equal to 6 weight percent U-235.

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The hydrofluoric acid is transferred and used in such a manner that the minute Q

quantity of uranium does not enter into any food, beverage, cosmetic, drug or other commodity designated for ingestion or inhalation by, or application to, a human being such that the uranium concentration in these items would exceed that which naturally exists. Additionally, the acid is used in a process which will not release the low levels of radioactivity to the atmosphere as airborne material and whose residues will remain in a wastewater or other treatment system.

Prior to shipment, each transfer is sampled and measured to assure that the concentration does not exceed three parts per million of uranium.

GE-Wilmington shall maintain records under this condition oflicense including, as a minimum, the date, uranium concentration and quantity of hydrofluoric acid transferred.

1.3.3.3 Nitrate-Bearing Liquids Authorization to transfer nitrate-bearing liquids, provided that the uranium concentration does not exceed a 30-day average of 5 parts per million by weight of the liquids and the enrichment is less than or equal to 6 weight percent U-235 by transport to an off-site liquid treatment system located at Federal Paper Board Corporation, Riegelwood, North Carolina, in which decomposition of the nitrates q

will occur and from which the denitrified liquids will be discharged in the effluent v-from the system.

The environmental monitoring program as described in Chapter 10.0 of this license is used to control these activities.

1.3.4 TRANSFER OF CALCIUM FLUORIDE TEST QUANTITIES Authorization to transfer test quantities of calcium fluoride (CaF ) to potential buyers 2

for the purpose of their examination and evaluation as described in GE-Wilmington's letter to the NRC dated September 24,1992.

Test quantities may not contain more than 30 pCi per gram on a dry weight basis and are limited to 1 gram U-235 at each off-site location.

Test activities and end uses of the material will be limited to those that do not allow chemical separation of the uranium or entry of the product into the food chain.

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l.3.5 TRANSFER OF CALCIUM FLUORIDE (CAF ) TO VENDORS FOR 2

{J BENEFICIAL REUSE Authorization to transfer quantities ofindustrial waste treatment products (primarily CaF ) to Cametco, Inc., Pittsburgh, PA, for the purpose of briquette manufacturing 2

and use as a steel flux forming material in the production of steel as described in GE-Wilmington's letter to the NRC dated December 20,1989.

Measurements are made using a sample plan to provide at a 95% confidence level that the population mean for each shipment is less than 30pCi of uranium per gram of material on a dry weight basis.

Activities and end use of the material will be limited to those that do not allow chemical separation of the uranium or entry of the product into the food chain.

1.3.6 DISPOSAL OF INDUSTRIAL WASTE TREATMENT PRODUCTS Notwithstanding any requirements for state or local government agency disposal permits, GE-Wilmington is authorized to dispose ofindustrial waste treatment products without continuing NRC controls provided that either of the two following conditions are met:

O i.3.6.i Free-stendiasiiauidehaiiheremovedvriertoshiement.

The uranium concentration in the material shipped for disposal shall not exceed 30 pCi per gram after free-standing liquid has been removed.

The licensee shall possess authorization from appropriate state officials prior to disposing of the waste material. The authorization shall be available for inspection at the GE-Wilmington facility.

1.3.6.2 The uranium concentration in the material shipped for disposal only at approved facilities such as Pinewood, South Carolina (licensed by the State of South Carolina),

shall not exceed 250 pCi per gram of uranium activity, of which no more than 100 pCi per gram shall be soluble.

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1.3.7 SANITARY SLUDGE Dried sanitary sludge is collected and disposed of at approved offsite facilities in accordance with Section 1.3.6. Authorization to store treated sanitary sludge containing trace amounts of uranium in the sanitary sludge land application area pending final disposal.

1.3.8 USE OF MATERIALS AT OFF-SITE LOCATIONS 1.3.8.1 Authorization to use up to 15 grams of U-235 at other sites within the limits of the United States and at temporaryjob sites of the licensee anywhere in the United States where the Nuclear Regulatory Commission maintains jurisdiction for regulating the use oflicensed material.

The manager of the radiation safety function shall establish the safety criteria for material being used at off-site locations and shall designate the individual who will be responsible for carrying out these criteria.

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1.3.8.2 Authorization to store at nuclear reactor sites, uranium fully packaged fcr transport in any NRC approved package, in accordance with the conditions of a license authorizing delivery of such containers to a carrier for NRC approved transport, at j

locations in the United States providing such locations minimize the severity of -

potential accident conditions to be no greater than those in the design bases for the containers during transportation.

Provisions for compliance with applicable 10 CFR 73 requirements are described in the NRC-approved GE-Wilmington Physical Security Plan as currently revised in accordance with regulatory provisions.

Storage at nuclear reactor sites is subject to the financial protection and indemnity provision of 10 CFR 140.

1.3.8.3 Authorization to store at nuclear reactor sites, arrays of finished reactor fuel rods and/or assemblies in any of the inner metal containers of the RA-series shipping package described in NRC Certificate of Compliance Number 4986 at locations in the United States providing such locations minimize the severity of patential accident LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

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conditions to be no greater than those in the design bases for the containers during Q

transportation.

Arrays may be constructed without limit to the number of containers so stored, except that each array shall be stacked to the smaller of 4 containers high or the height demonstrated to comply with the criticality safety reruirements of this license.

Each container must be separated by nominal 2-inch woou i studs, with the width and length for each array and separation between arrays determined only by container handling requirements.

Provisions for compliance with applicable 10 CFR 73 requirements are described in the NRC-approved GE Wilmington Physical Security Plan as currently revised in accordance with regulatory provisions.

Storage at nuclear reactor sites is subject to the financial protection and indemnity provision of 10 CFR 140.

1.3.8.4 Authorization to transfer, possess, use and store unirradiated reactor fuel of GE-Wilmington manufacture or procured to GE specification at nuclear reactor sites, for purposes ofinspection, fuel bundle disassembly and assembly, including fuel rod replacement, provided that the following conditions are met:

A valid NRC license ha, been issued to the reactor licensee, which authorizes

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receipt, possession and storage of the fuel at the reactor site. GE Wilmington possesses the fuel only within the i idemnified location.

For dry fuel reconstitution, not more than 99 (9x9 lattices or greater) or 88 (8x8 lattices) unassembled fuel rods may be possessed by GE-Wilmington at any one reactor site at any one time, except when the fuel has been packaged for transport or as described in Section 1.3.8.3. The fuel rods must be of the types described in NRC Certificate of Compliance Number 4986.

For underwater fuel reconstitution, not more than one fuel assembly plus e

unassembled fuel rods so that the total number of rods, including the assembly, possessed by GE-Wilmington at any one reactor site at any one time does not exceed 99 (9x9 lattices or greater) or 88 (8x8 lattices), except when the fuel has been packaged for transport or as described in Section 1.3.8.3. The fuel rods must be of the types described in NRC Certificate of Compliance Number 4986.

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i Operations involving the fuel are conducted by or under the direct i

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supervision of a member f the GE-Wilmington staff who shall be responsible for work on the fuel element assembly. The person shall comply

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with applicable reactor license and procedure requirements as directed by reactor site representatives, including appropriate actions that are to be taken i

in the event of emergencies at the site.

4 Loose rods are stored in RA-series inner metal containers.

Fuel is handled in accordance with pertinent provisions of t.he reactor license, and also in accordance with applicable GE-Wilmington procedures which are jointly verified for completion by GE-Wilmington and the reactor licensee.

Records of the operation, including the GE-Wilmington procedures used, are

- maintained at the GE-Wilmington facility.

1.3.9 -

WASTL OXIDATION-REDUCTION FACILITY Authoriza. ion to treat waste and scrap material containing special nuclear material by oxidatior and reduction.

1.3.10 DILUTION FACTOR FOR AIRBORNE EFFLUENTS O

Authorization 1o utiiize a diiution facter ie the meaeured steck discharges for 1he purpose of evaluating the airborne radioactivity at the closest site boundary of stack discharges from the uranium processing facilities. For purposes of control, this dilution factor shall be no greater than 100. For other purposes, specific dilution factors, which consider dispersion model parameters, may be calculated and used.

1.3.11 CRITICALITY MONITORING SYSTEM Authorization that it is not necessary to maintain the criticality accident monitoring system requirements of 10 CFR 70.24 when it is demonstrated that a credible criticality risk does not exist for each area in which there is not more than:

1.3.11.1 A quantity of finished reactor fuel rods equal to or less than 45% of a minimum critical number under conditions in which double batching is credible, or equal to or LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

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less than 75% of a minimum critical number under conditions in which double O

8 icai a is #et creaisie. er 1.3.11.2 The quantity of uranium authorized for delivery to a carrier when fully packaged as for transport according to a valid NRC authorization for such packages without limit on the number of such packages, provided storage locations preclude mechanical damage and flooding, or 1.3.11.3 Arrays of finished reactor fuel rods and/or assemblies in any of the inner metal containers of the RA-series shipping package described in NRC Certificate of Compliance Number 4986, under storage conditions described in Section 1.3.8.3, or 1.3.11.4 Unassembled fuel rods under the restrictions and transfer, possession, use and storage conditions in Section 1.3.8.4.

1.3.12 POSTING Authorization to post areas within the Controlled Access Area in which radioactive

,q materials are processed, used, or stored, with a sign stating "Every container in this V

area may contain radioactive material" in lieu of the labeling requirements of 10 CFR 20.1904.

1.3.13 EXTREMITY DOSE DETERMINATION 2

Authorization to use a skin thickness of 38 milligrams /cm in the assessment of worker fingertip doses from uranium and for determining compliance to NRC extremity dose limits.

1.3.14 AUTHORIZED WORKPLACE AIR SAMPLING ADJUSTMENTS Authorization to adjust Derived Air Concentration (DAC) limits and Annual Limit of Intake (ALI) values in process areas to reflect chemical and physical characteristics of the airborne uranium.

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GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR' BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR M.ATERIAL t

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P U.S. Nuclear Regulatory Commission Division of Fuel Cycle Safety and Safeguards Washington, DC 20555 1

April 1993 LICENSE SNM-1997 DATE 03/27/97 Page I

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O The instructions in this guide, in conjunction with Table 1, specify the radionuclides and radiation exposure rate limits which should be used in decontamination and survey of surfaces or premises and equipment prior to abandonment or release for unrestricted use. The limits in Table I do not apply to premises, equipment, or scrap containing induced radioactivity for which the l

radiological considerations pertinent to their use may be different. The release of such facilities or items from regulatory control is considered on a case-by-case basis.

1.

The licensee shall make a reasonable effort to eliminate residual contamination.

2.

Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in Table 1 prior to the application of the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering.

3.

The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the limits.

4.

Upon request, the Commission may authorize a licensee to relinquish possession or l

O centroi erpremises, cauipment, er ecreg havina surfaces contamieated with meteriais in i

excess of the limits specified. This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organization continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must:

l a.

Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual i

surface contamination.

i b.

Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment, or scrap, are unlikely to result in an unreasonable risk to the health and safety of the public.

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5.

Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contamination is within the limits specified in Table 1. A copy of the survey report shall be filed with the Division of Fuel Cycle Safety and Safeguards, U. S. Nuclear Regulatory Commission, Washington, DC 20555, and also the Administrator of the NRC Regional Office havingjurisdiction. The report should be filed at least 30 days prior to the planned date of abandonment. The survey report shall:

t a.

Identify the premises, b.

Show that reasonable effort has been made to eliminate residual contamination.

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c.

Describe the scope of the survey and general procedures followed.

d.

State the findings of the survey in units specified in the instruction.

C) the survey.

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TABLE 1 i

O ACCEPTABLE SURFACE CONTAMINATION LEVELS f

I b

bd b

NUCLIDES*

AVERAGE er MAXIMUM r REMOVABLE

U-nat, U-235, U-23 8, and 5,000 dpm a/100 cm 15,000 dpm a/100 cm 1,000 dpm a/100 cm l

2 2

2 associated decay products r

2 2

Transuranics, Ra 226, Ra-100 dpm/100 cm 300 dpm/100 cm' 20 dpm/100 cm 228, Th-230, Th-228, Pa-i 231 Ac-227,1-125,1-129 i

Th-nat, Th-232, Sr-90, Ra-1000 dpm/100 cm 3000 dpm/100 cm' 200 dpnt'100 cm l

2 2

223, Ra-224, U-232,1 126, l

1-131,1-133 Beta-gamma emitters 5,000 dpm py/100 cm' 15,000 dpm py/100 cm 1,000 dpm py/100 cm i

2 2

(nuclides with decay modes other than alpha emission or

. spontaneous fission) except Sr-90 and others noted above.

"Where surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting nuclides should apply independently.

DAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

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' Measurements of average contaminant should not be averaged over more than I square meter. For objects ofless surface area, the average should be derived for each such object.

d 2

The maximum contamination level applies to an area of not more than 100 cm,

2

'The amount of removable radioactive material per 100 cm of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

rThe average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not er.ceed 0.2 mrad'hr at I cm and 1.0 mrad'hr at I cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.

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.e CH APTER 3.0 CONDUCT OF OPERATIONS 3.1 CONFIGURATION MANAGEMENT (CM) 3.1.1 CONFIGURATION MANAGEMENT PROGRAM A formal configuration management process, governed by written, approved practices, ensures that plant design changes do not adversely impact on safety, health, or environmental protection programs at GE-Wilmington. The configuration i

management program ensures that the information used to operate and maintain safety controls is kept current. Safety controls are systems, structures, components and procedures which prevent and/or mitigate the risk of accidents. The use of current plant information is an integral part of the integrated safety analysis program i

described in Chapter 4.0.

The CM program includes the following activities:

Maintenance of the design information for the plant Control ofinformation used to operate and maintain the plant Documentation of changes e

Assurance of adequate safety reviews for changes Periodic comparison assessment of the conformance of specific safety 4

e cont'.ols to the documentation of plant design bases i

s 3.1.2 PLANT DESIGN REQUIREMENTS Written plant practices define the development, application, and maintenance of the design specifications and requirements. Plant design specifications and requirements are maintained as controlled information. The specific content of the information depends on the age of the design and the requirements in place at the time of design.

As a minimum the information required for safe operation of the facility is available.

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3.1.3 C11ANGE CONTROL

'O Written plant practices describe the configuration management program for change management, including approval to install and operate facility changes. Facility

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chanrg nre assessed by a trained and approved safety reviewer to determine if the

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applicable ISA is impacted, and if further review and approval is required by an ISA team as described in Chapter 4.0.

The written plant practices also prescribe controls and derme the distinction between types of changes, ranging from replacement with identical designs which are authorized as part of normal maintenance, to new or different designs which require specified review and approval.

3.1.4 DOCUMENT CONTROL Documented plant practices define the control system, including creation, revision, storage, tracking, distribution and retrieval of applicable information including :

Operating procedures Drawings Technical specifications and requirements e

t Software for safety controls Calibratiou instructions e

e Functional test instructions The documented plant practices describe the responsibilities and activities which maintain consistency between the facility design, the physical facility, and the documentation. They also describe how the latest approved revisions are made available for cperations.

l 3.2 MAINTENANCE The purpose of planned and scheduled maintenance for safety controls is to assure that systems are kept in a condi: ion of readiness to perfonn the planned and designed functions when required. Area Managers are responsible to assure the operational I

readiness of safety controls in their assigned facility areas. For this reason the maintenance ftmetion is administratively part of or closely coupled to fuel production LICENSE SNM-1997 DATE 03/27/97 Page DOCKET 70-1113 REVISION 0

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operations. The maintenance function utilizes a systems-based program to plan,

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schedule, track and maintain records for maintenance activities. Maintenance j

instructions are an integral part of the maintenance system for maintenance activities.

Discrimination between specified safety controls and other systems based on integrated safety analyses is maintained in the database. Key maintenance requirements for safety controls such as calibration, functional testing, and replacement of specified components are derived from integrated safety analyses described in Chapter 4.0, and the application of the graded approach to assurance elements.

Maintenance activities generally fall into the categories described below:

3.2.1 SCHEDULED PREVENTIVE MAINTENANCE i

Examples of safety controls included for scheduled preventive maintenance are :

Radiation Measurement Instruments Criticality Detection Devices Effluent Measurement & Control Devices

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Emergency Power Generators Fire Detection and Control Systems

,3U Pressure Relief Valves e

Air Compressors Steam Boilers s

3.2.2 PERIODIC FUNCTIONAL TESTING Examples of safety controls included for periodic functional testing include :

Criticality Warning System Fire Alarm System Specified Active Engineered Controls on Process Equipment Frequencies and requirements for functional testing of various safety controls are derived through quality and reliability activities using a graded approach to assurance LICENSE SNM-1097 DATE 03/27/97 Page

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as described in Section 3.3. The integrated safety analysis is the basis for this O

impiementetio.

3.2.3 REPAIR OF SAFETY CONTROLS The maintenance planning and control system provides documentation and records of systems and components which have been repaired or replaced.

When a component of specified safety control is repaired or replaced, the component is functionally verified to assure that it has the capability to perform its planned and designed function when called upon to do so.

I If the performance of a repaired or replaced safety control could be different from that or the original component, the change to the safety control is specifically approved under the configuration management program and tested to assure it is

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likely to perform its desired function when called upon to do so.

l 3.3 QUALITY ASSURANCE (QA)

The application of assurance measures to safety controls at GE-Wilmington focuses on assuring that these controls are designed, installed, operated and maintained such that their planned function is not compromised.

3.3.1 ASSURANCE ELEMENTS The following assurance elements are applied to safety controls at GE-Wilmington:

Organization Program e

Equipment / System Design Control Procurement Documentation Control e

Instructions, Procedures, and Drawings e

e Document Control Control of Purchased Materials, Equipment, and Services e

Identification and Control of Materials, Parts, and Components i

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i Control of Special Processes e

O-Internal Inspect. ions e

e Test Control Control of Measuring and Test Equipment I

Handling, Storage, and Shipping Controls e

Inspection, Test, and Operating Status l

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Control of Nanconforming Materials, Parts, or Components e

Corrective Action

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e Records Audits j

3.3.2 ASSURANCE ELEMENT APPLICATION TO SAFETY CONTROLS In accordance with documented internal practices, the assurance elements are applied to safety controls in proportion to their importance to safety, and as an integral part of the Integrated Safety Assessment program described in Chapter 4.0. This graded approach segregates safety controls and activities into three categories in applying the assurance elements:

For safety controls intended to prevent or mitigate the consequences of the highest risk category, each of the assurance elements are specifically evaluated and applied to the control, and their application requirements documented as part of the ISA. Justification for each assurance element not t

applicable to a control in this category is also documented.

For safety controls intended to prevent or mitigate the consequences of the j

mid-level risk category, each of the assurance elements is thoroughly evaluated and applicable assurance elements and their requirements are applied and documented.

Safety Controls in the low risk category are operated and maintained as part of routine and prudent industry practice, and are controlled by means of normal, established manufacturing assurance systems. No extraordinary assurance element requirements are documented.

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Assurance element requirements and application decisions are based on sound O

enaineeriea rrectices a#d;udament.

Assurance element descriptions and application, are included in documented practices as part of the GE-Wilmington management system. These practices also specify the requirements for related record retention.

3.4 TRAINING AND QUALIFICATION Training is provided for each individual at GE-Wilmington, commensurate with assigned duties. Training and qualification requirements are met prior to personnel fully assuming the duties of safety-significant positions, and before assigned tasks are independently performed. Formal training relative to safety includes radiation and radioactive materials, risks involved in receiving low level radiation exposure in accordance with 10CFR19.12, basic criteria and practices for radiation protection, nuclear criticality safety principles not verbatim, but in general conformance with ANSI /ANS 8.20 guidance, chemical and fire safety, maintaining radiation exposures and radioactivity in effluents As Low As Reasonably Achievable (ALARA), and emergency response.

The system established for maintaining records of training and retraining is described in Section 3.8.

3.4.1 NUCLEAR SAFETY TRAINING Training policy requires that employees complete formal nuclear safety training prior

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to unescorted access in the airborne radioactivity controlled area. Methods for evaluating the understanding and effectiveness of the training includes passing an initial examination covering formal training contents and observations of' operational activities during scheduled audits and inspections.

Such training is performed by trained instructors approved by the manager of the criticality safety function and the manager of the radiation safety function. Training program contents are reviewed on a scheduled basis by the manager of the criticality safety and radiation safety functions to ensure that training program contents are current and adequate.

Previously trained employees who are allowed unescorted access to the airbome j

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,4 of the training program is evaluated by an initial training exam. Visitors are trained O

commensurate with the scope of their visit and/or escorted by trained employees.

3.4.2 OPERATOR TRAINING Operator training is performance based, and incorporates the structured elements of analysis, design, development, implementation, and evaluation. Job-specific training includes applicable procedures and safety provisions, and requirements. Emphasis is placed on safety requirements where human actions are important to safety. Operator training and qualification requirements are met prior to process safety-related tasks being independently performed or before startup following significant changes to safety controls.

3.5 HUMAN FACTORS Human factors are an integral part of the management and operational safety philosophy at GE-Wilmington. The consideration of human factors in relation to operational safety is included in integrated safety analyses.

1 Human factors concepts are also considered in:

Equipment design 7

Safety control design e

Operator training e

Maintenance

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e e

Audits and assessments Incident investigations e

3.6 AUDITS AND ASSESSMENTS Planned and scheduled internal and independent audits are performed to evaluate the application and effectiveness of management controls and implementation of programs related to activities significant to plant safety. Written operating procedures are based on GE-Wilmington practices, applicable regulations and license conditions. Audits are performed to assure that operations are conducted in LICENSE SNM-1997 DATE 03/27/97 Page l

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accordance with the operating procedures, and to assure that safety programs mU reflected in the operating procedures are maintained.

3.6.1 CRITICALITY, RADIATION, CHEMICAL AND FIRE SAFETY AUDITS Representatives of the criticality safety function, the radiological safety function, and the chemical and fire safety function conduct formal, scheduled safety audits of fuel manufacturing and support areas in accordance with documented, approved practices.

These audits are performed to determine that operations conform to criticality, radiation, and chemical and fire safety requirements.

Criticality and radiological audits are performed quarterly (at intervals not to exceed 110 days) under the direction of the manager of the criticality safety function and the j

manager of the radiation safety function. Chemical and fire safety audits are

)

performed under the direction of the chemical and fire safety function manager.

Personnel performing audits do not report to the production organization and have no direct responsibility for the function and area being audited.

adit results are communicated in writing to the cognizant Area Manager and to the

^

manager of the environment, health & safety function. Required corrective actions are documented and approved by the Area Manager, reported to the GE-Wilmington facility manager, and tracked to completion by the environment, health & safety G

function.

L)

Radiation protection personnel within the radiation safety function conduct weekly nuclear safety inspections of fuel manufacturing and support areas in accordance with documented procedures. Inspection findings are documented and sent to the affected Area Manager for resolution.

Records of the audit or inspection, instructions and procedures, persons conducting the audits or inspections, audit or inspection results, and corrective actions for identified violations oflicense conditions are maintained in accordance with procedural requirements for a minimum period of three years.

3.6.2 ENVIRONMENTAL PROTECTION AUDITS An audit schedule of the environmental protection program is developed by the environmental protection function on an annual basis Audits are conducted in accordance with documented practices to ensure that operational activities conform ta documented environmental requirements.

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i Personnel under the direction of the manager of the environmental protection h

function perform the environmental protection audits. Personnel performing the audits do not report to the production organization and have no direct responsibility for the function and area being audited.

Audit findings are communicated to the cognizant Area Manager, who is responsible for nonconformance corrective action commitments in accordance with documented practices. The manager of the environmental protection function or delegate is responsible for resolution follow-up for identified nonconformances. Audit results in the form of corrective action items are reported to the GE-Wilmington facility manager and staff for monitoring of closure status.

3.6.3 INDEPENDENT AUDITS The GE-Wilmington safety program elements (radiation, criticality, chemical, fire protection, industrial safety and environmental protection) are audited biennially by appropriately trained and experienced individuals who have a degree of independence of the GE-Wilmington organization, and are not involved in the routine performance of the work or program being audited. The scope of independent audits covers the adequacy of the safety program as well as compliance l

to requirements.

c Audit results are reported in writing to the GE-Wilmingten facility manager, the Area Managers, the manager of the radiation saf.:ty function, and the manager of the criticality safety function, as appropriate. The safety function and/or Area Managers, as appropriate, take necessary response actions in accordance with documented corrective action commitments.

Audit results in the form of corrective action items are reported to the GE-Wilmington facility manager and staff for tracking until closure.

3.7 INCIDENT INVESTIGATIONS Unusual events which potentially threaten or lessen the effectiveness of health, safety or environmental protection are reviewed by the Area Manager and reported to the environment, health & safety function in accordance with documented practices and methods. Each event is considered in terms of reporting requirements in accordance with applicable regulatory requirements. The depth ofinvestigation relates to the severity or potential severity of the event in judgment of such factors as levels of LICENSE SNM-1997 DATE 03/27/97 Page

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uranium released and/or the degree of potential for exposure of workers, the public or (m) the environment.

Documented incident investigation practices provide for:

Formal and systematic analyses for determination of root cause(s)

Investigations by independent, qualified teams when warranted Documented identification and tracking of corrective actions Documentation and record retention for purposes of application of" lessons learned" The environment, health and safety function is responsible for maintaining a list of agencies to be notified, determining if a report to an agency is required, and for notifying the agency when required. This function has the responsibility for continuing communications with government agencies.

3.8 RECORDS MANAGEMENT Records appropriate to integrated safety analyses and the application of appropriate assurance elements to resulting controls, criticality and radiation safety activities, training / retraining, occupational exposure of personnel to radiation, releases of

,c radioactive materials to the environment, and other pertinent safety activities are C) maintained in such a manner as to demonstrate compliance with license conditions and regulations.

Records ofintegrated safety analyses and results are retained during the conduct of the activities analyzed and for six months following cessation of such activities to l

which they apply or for a minimum of three years.

Records of criticality safety analyses are maintained in sufficient detail and form to pemiit independent review and audit of the method of calculation and results. Such records are retained during the conduct of the activities and for six months following cessation of such activities to which they apply or for a minimum of three years.

l Records associated with personnel radiation exposures are generated and retained in such a manner as to comply with the relevant requirements of 10 CFR 20. The following additional radiation protection records will be maintained for at least three years:

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Surveys of equipment for release to unrestricted areas e

e Instrument calibrations Safety audits e

Personnel training and retraining e

Radiation work permits j

e Surface contamination surveys Concentrations of airbome radioactive material in the facility e

Radiological safety analyses e

j Records associated with the environmental protection activities described in Chapter 10 are generated and retained in such a manner as to comply with the relevant requirements of 10 CFR 20 and this license.

3.9 PROCEDURES 3.9.1 PLANT PRACTICES Licensed material activities are conducted in accordance with management control O

programs descrised in administrative and senerai giant gractices aggroved end issued by cognizant management at a level appropriate to the scope of the practice. These documented practices direct and control activities across the manufacturing functions, and assign functional responsibilities and requirements for these activities.

Management controls described in Chapter 2.0 are included in these practices. These practices are reviewed for updating at least every two years.

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3.9.2 OPERATING PROCEDURES 1

Area Managers are responsible to assure preparation of written, approved and issued l

operating procedures incorporating control and limitation requirements established by the criticality safety function, the radiation safety function, the environmental protection function and the chemical and fire safety function. Integrated safety analysis results as described in Chapter 4.0 are used to identify procedures necessary -

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in Section 3.1. Area Managers assure that operating procedures are made readily O

available in the work area and that operators are trained to the requirements of the i

i procedures and that conformance is mandatory. Operators are trained to report inadequate procedures, and/or the inability to follow procedures.

Nuclear safety control procedure requirements for workers in uranium processing areas are incorporated into the appropriate operating, maintenance and test

. procedures in place for uranium processing operations.

The safety program design requires the establishment and maintenance of documented procedures for environmental, health and safety limitations and requirements to govern the safety aspects of operations. Requirements for procedure control and approval authorities are documented. Procedure review for updating frequencies are as follows:

Document Review Reviewing & Approving Frequency Functional Manager Operating Procedures (ops)

When Area Manager and Affected (Note: Nuclear Safety changed m Ells Discipline (Radiation, Release / Requirement (NSR/R)

Criticality, Environmental, limitations and requirements industrial, or MC&A) are incorporated into ops) g Operating Procedures (ops)

Every 3 Area Manager and Affected v

Yearsm Ells Discipline (Radiation, Criticality, Environmental, Industrial, or MC&A)

Nuclear Safety Instructions Every 2 Radiation & Criticality Safety j

(NSls)

Yearsm Envirorunental Protection Every 2 Environmental Protection Instructions (EPIs)

YearsW

1) The safety awareness portions of these ops are reviewed and updated by the appropriate environment, health, and safety (Ells) discipline when warranted based on process related facility change requests.

2) Every 2 years means a maximum interval of 26 months.

3) Every 3 years means a maximum interval of 39 months

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4) Ells Discipline - Industrial means normal worker safety, chemical safety, and fire and explosion l

protection.

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)O Nuclear safety control procedure requirements for workers in uranium processing areas are incorporated into the appropriate operating, maintenance and test procedures in place for uranium processing operations.

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a CH APTER 7.0 O

CHEMICAL SAFETY 7.1 CHEMICAL SAFETY PROGRAM 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 chemical safety program is applicable to the chemicals associated with the authorized activities described in Chapter 1 and any other chemicals which have a direct bearing on the nuclear safety of these activities. The GE-Wilmington chemical safety program is documented in written, approved practices that are followed, and ensures that processes and operations comply with applicable federal l

and state regulations pertaining to chemical safety.

4 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 4

ensures appropriate controls are in place for adequate protection of the general pu'olic and safe use by employees, and that the use of chemicals does not create potential l

conditions that adversely effect the handling oflicensed nuclear materials.

O Empi yees using hazardous materials are trained to ensure safe handling, use, and 6

d.isposal.

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7.2 CONTENTS OF CIIEMICAL SAFETY PROGRAM i

4 The following management control elements are incorporated into GE-Wilmington 1

chemical safety program:

7.2.1 CHEMICAL SAFETY IN INTEGRATED SAFETY ANALYSIS Considerations of chemical safety for hazardous materials as described in this 4

Chapter are incorporated in GE-Wilmington's Integrated Safety Analysis program.

GE-Wilmington's Integrated Safety Analysis Program is explained in detail within Chapter 4.0.

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7.2.2 CHEMICAL APPROVAL / EVALUATION cO 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:

Physical Hazards e

Health Hazards Fire / Explosive Hazards Potential Impact on handling oflicensed nuclear material e

The conclusions of this approval process may dictate the following assurance of chemical process safety:

New procedures or changes in existing procedures Maintenance programs for control related equipment e

Configuration management e

Emergency Planning Training e

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.

7.2.4 EMPLOYEE TRAINING & AWARENESS Radiation workers receive nuclear safety training and otherjob related training (Chapter 3, Section 3.4) which includes safety information rehted to chemicals associated with nuclear material and chemicals in the area which could impact the nuclear safety of the process.

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7.2.5 INCIDENT CLASSIFICATION & INVESTIGATION O

GE-Wilmington's incident classification and investigation program is discussed in Chapter 3.0.

l 7.2.6 CONDUCT OF OPERATIONS Other elements of the chemical safety program are included in Chapter 3.0, " Conduct of Operations".

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