ML20137Z212

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Application for Amend to License SNM-1067,reflecting Proposed Reduction in Activities & Matl Possession Authorization & Transfer of Lab Activities to Windsor Site Broad Scope License
ML20137Z212
Person / Time
Site: 07001100
Issue date: 04/16/1997
From: Rickard I
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To: Weber M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
TAC-L30875, NUDOCS 9704240031
Download: ML20137Z212 (53)


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ABB ASEA BROWN BOVERI Docket No. 70-1100 April 16,1997 License No. SNM-1067 TAC No. L30875 Mr. Michael F. Weber, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Materials Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Amendment Request To Downgrade License No. SNM-1067

References:

(A)

Letter, l. C. Rickard (CE) to R. C. Pierson (NRC),

" Amendment Request To Downgrade SNM License,"

dated April 23,1996.

(B)

Letter, l. C. Rickard (CE) to R. C. Pierson (NRC),

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" Response To NRC Request For Additional Information On Amendment Request To Downgrade License No. SNM-i 1067," dated December 20,1996.

(C)

Letter, L. Bickwit, Jr. (Miller and Chevalier) to Robert L.

Fonner (NRC), dated March 4,1997.

(D)

Letter, R. L. Fonner (NRC) to L. Bickwit, Jr. (Miller and Chevalier), dated March 28,1997.

Dear Mr. Weber:

Reference (A) requested a downgrade of License SNM-1067 to reflect the on-proposed reduction in activities and material possession authorization and the E;

transfer of laboratory activities to the Windsor site Broad Scope License.

E.

Reference (B) responded to questions from the NRC on the Reference (A)

E:

request. After some further discussions, we agreed with your Staff to resubmit E.

the entire Application document with the revisions proposed to References (A)

M' and (B) and in the discussions with your Staff. Therefore, this submittal supersedes and completely replaces those submittals. Unaffected portions of the currently approved Application are reproduced in this submittal and related statements and representations made by CE in previously approved submittals are hereby reaffirmed, except as changed or removed by this Application.

9704240031 970416 PDR ADOCK 07001100

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PDR ABB Combustion Engineering Nuclear Power Combuston Engreemq Irc 000 Prospec1 H Road Tei one (M) M81911 Wassor, Connectcut 06095 0500 Teen 99297 COMBEN WSOR

i This Application is intended to be consistent with the understanding of Combustion Engineering given in Reference (C) and the concurrence of NRC Counsel as stated in Reference (D), regarding the possession of uranium wastes on the Windsor site that have been collected by CE and that are to be included in the DOE Formerly Utilized Sites Remedial Action Program ("FUSRAP") for j

disposal.

Enclosure (1) provides a description of the proposed revisions to the currently approved version of the Application, including the applicable revisions proposed

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in References (A) and (B). Enclosure (2) provides a list of the pages of the currently approved version of the Application and of the pages in this submittal that would replace them. Enclosure (3) provides a listing of the resulting effective pages of the Application. Enclosure (4) provides the entire Application containing all the changes. Six (6) copies are enclosed for your use.

If there are questions or comments regarding this matter, please feel free to contact me or Mr. J F. Conant at (860) 285-5002.

Very truly yours, COMBUSTION ENGT ING, INC.

0 d R a.

1. [RickaV Director of Operations Licensing ABB-CE Nuclear Operations xc:

Dr. S. Soong (NRC)

J. J. Kottan (NRC-Region 1)

Enclosures:

As stated

1 April 16,1997 Enclosure (1) i COMBUSTION ENGINEERING, INC.

WINDSOR SPECIAL NUCLEAR MATER!AL LICENSE AMENDMENT REQUEST TO DOWNGRADE LICENSE NO. SNM-1067 EXPLANATION OF CHANGES j

This amendment request would delete from License No. SNM-1067 references i

- to all buildings except Building 21 and all activities except those related to the

. decommissioning of Building 21 and to the SNM waste from prior operations collected by CE at the Windsor site. With these exceptions, all possession and licensed laboratory activities and operations with SNM and SM at the Windsor site have been licensed under the Broad Scope Materials License 06-00217-06, Amendment No. 42, dated October 1,1996, and would be no longer covered under SNM-1067.

This amendment request would delay the decommissioning of Building 17, the former fuel manufacturing facility. The delay is requested in order to allow the building to be used for processing equipment returned from reactor sites and contaminated with byproduct material. Use of Building 17 would make,it unnecessary for Combustion Engineering to develop.a new building on the Windsor site for such work. Such a delay in decommissioning would be pursuant to the specific provisions of 10 CFR 70.38. This matter was discussed with the I

Licensing Branch staff and the Region I staff in a meeting with Combustion Engineering at White Flint on February 7,1996. We understand that the approved Decomrnissioning Plan for the Building 17/21 complex would remain in effect during the delay while Building 17 is being used for processing byproduct material. The operations in Building 17 would be conducted under the Broad Scope license. Building 21 continues to be decommissioned without delay under SNM-1067.'

The Broad Scope license application, approved by License Amendment No. 42, dated October 1,1996, includes provision for decommissioning funding for the facilities that were added to the Broad Scope license. The existing decommissioning funding for License No. SNM-1067 would be continued while Building 21 is being decommissioned.

The possession authorization in Section 1.4 would be changed to delete _ Items 1,.

2, and 3, for enriched uranium, natural and/or depleted uranium and sealed _

plutonium sources. The authorization for 1000 grams U-235 in uranium enriched to greater than or equal to 5% by weight would remain and would become item

1. The possession authorization for uranium enriched to less than 5% would be reduced to 150 grams U-235 and would become item 2.

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4 The proposed authorized location for material greater than 5% would be limited to Specified Storage Areas, defined in Section 1.5 as locked, trailer sized, ground level containers and the paved area in the wooded section of the Windsor site and the DOE FUSRAP-designated (Formerly Utilized Sites Remedial Action Program) Building 3 and its environs. The proposed authorized i

activities for this material would be specified in Section 1.5 as packaging, repackaging, evaluation, storage, handling, and transportation.

This proposed scope of authorized activities is consistent with the understanding of Combustion Engineering of the positions taken by the NRC staff and CE regarding the Windsor site and License No. SNM-1067 governing special nuclear materials on the site. CE understands that the possession limitation relating to 1000 grams of U-235 material contained in uranium enriched to levels of 5 percent and greater in U-235 applies only to enriched uranium low level wastes located on the Windsor site that have been collected, and that may be collected, by CE and are to be included in the DOE FUSRAP for disposal.

The proposed authorized location for the material less than or equal to 5% would be limited in Section 1.4 to Building 21, and the authorized activity would be limited to decommissioning Building 21, the former commercial nuclear fuel manufacturing facility warehouse.

In Section 1.5, authorized activities in all buildings except Building 21 would be deleted. These activities and buildings are authorized under the Broad Scope license. Accordingly, throughout the Application, reference to the laboratories and laboratory activities would be deleted.

The deletion of laboratory activities from the Application and the delay in the decommissioning of Building 17 would remove potential sources of liquid and airborne effluents related to the activities authorized by this license. Accordingly, references to radioactive effluents and environmental monitoring would be deleted throughout the Application, including from Sections 2.9,3.1.3,4.1.2,4.2, 10.0,11.1,11.2, and 11.3, along with the associated tables and figures.

Environmental monitoring is provided by reference to the site Broad Scope license, as noted in Section 4.2 of this Application.

The personnel organization would be changed to reflect the proposed reduced scope of SNM activities to only activities related to waste material. A statement is added to Section 2.1.2 that CE management is responsible for safe operation under the license. The Radiation Safety Officer would be given responsibility for the related radiological activities. The RSO's immediate superior, formerly the Supervisor, Chemistry Services, would be deleted from Section 2.2.1 of Part I of the Application and replaced in Part Il by the Radiological Services Leader, who reports to the Senior Project Manager, Site Remediation. A revised Figure 8-1 would show the changes to the personnel organization.

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Section 2.3, Safety Committee, would be deleted, consistent with the proposed reduced scope of activities. There would be little activity for a formal Safety Committee to review. However, the annual report to the Radiological Services Leader, the supervisor. of the RSO, would be continued. Routine RSO inspections and the annual audit of the Health Physics program would provide management control. Reference to the Safety Committee would be deleted from Section 2.9, Records, and Section 3.1.3, Annual Report. Section 3.1.1, ALARA, would be changed to remove the setting of ALARA targets, consistent with the minimal proposed activity and potential exposure.

The deletion of buildings from this application would make the discussion of laboratory hoods and ventilation systems in Section 3.2.3 unnecessary. This section would be revised to make it consistent with the proposed reduced scope of authorized activities. The discussion in Section 3.2.7, Contamination Surveys, would be revised to reflect removal of laboratory activities and the discussion in Section 3.2.8 Respiratory Protection, would be revised to reflect the proposed reduced scope of activities.

Section 3.2.10 specifies the requirements for control and testing of sealed sources. Since the proposed authorized material possession would not include sources, the entire Section 3.2.10 would be deleted.

In Section 3.2.1, Control of Licensed Material, and Section 4.1.1, Low-Level Radioactive Waste, minor wording changes would be made consistent with the proposed reduced scope of authorized activity and the definition in Section 1.5 for Specified Storage Areas.

In Part 11 of the Application, in Section 6.1, changes are proposed to update the j

corporate information for Combustion Engineering, Inc. Also, the information in Section 6.1.3, Company Background, and Section 6.6, History of Licensed Activities in Buildings On Site, would be revised consistent with the transfer of laboratory activities to the site Broad Scope license. Figure 6-3, Location of Buildings On the Windsor Site, would be revised to add the proposed Specified Storage Areas that would be defined in Section 1.5.

In Section 6.2, the Operating Objective woule N revised to include only the conduct of activities related to residual material from prior operations.

Section 7.1, Use of Buildings, would be deleted except for a statement about Building 21, which would be the only building remaining under this license.

Section 7.2, Fire Protection, would be revised to reflect the fact that there would be no remaining facilities or activities that would require protection or that might potentially initiate emergency response action.

The resume in Section 8.2 for the Supervisor, Chemistry Services, would be deleted. That would leave the Application with the resume for only the RSO, 3

consistent with the proposed reduced scope of authorized activities under this license.

The street address for the Windsor site has been changed by the town of Windsor, CT from 1000 Prospect Hill Road to 2000 Day Hill Road. This change would be made in several places in the Application. There is no change in the physical location of the facilities.

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April 16,1997 Enclosure (2)

COMBUSTION ENGINEERING, INC.

WINDSOR SPECIAL NUCLEAR MATERIALS LICENSE AMENDMENT REQUEST TO DOWNGRADE LICENSE NO. SNM-1067 LIST OF AFFECTED PAGES Combustion Engineering, Inc. is superseding its requests dated April 23,1996 and December 20,1996 to amand the application for the Windsor Special Nuclear Materials License No. SNM-1067 by replacing the pages of those requests and all other pages of the Application with this Amendment Request. The pages of the currently approved version of the Application and the pages of this Amendment Request which relace them are listed below:

DELETE PAGES ADD PAGES P_aga D_ ate Eaga D. ate

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04/16/97 li 5/4/95 ii 04/16/97 ill 1/17/95 iii 04/16/97 iv 1/17/95 iv 04/16/97 1-1 5/4/95 1-1 04/16/97 1-2 12/8/95 1-2 04/16/97 1-3 10/25/95 1-3 04/16/97

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2-1 6/30/95 2-1 04/16/97 2-2 6/30/95 2-2 04/16/97 2-3 5/4/95 2-3 04/16/97 2-4 6/30/95 2-4 04/16/97 2-5 5/4/95 2-5 04/16/97 3-1 5/4/95 3-1 04/16/97 3-2 5/4/95 3-2 04/16/97 3-2a 5/4/95 (Deleted) 3-3 5/4/95 3-3 04/16/97 3-4 5/4/95 3-4 04/16/97 3-5 5/4/95 3-5 04/16/97 3-6 6/30/95 3-6 04/16/97 3-7 5/4/95 3-7 04/16/97 3-8 1/17/95 (Deleted) 4-1 10/31/96 4-1 04/16/97 4-2 8/8/96 4-2 04/16/97 1

4-3 1/17/95 (Deleted) 5-1 6/30/95 5-1 04/16/97 6-1 1/17/95 6-1 04/16/97 6-2 1/17/95 6-2 04/16/97-6-3 1/17/95 6-3 04/16/97 6-4 1/17/95 6-4 04/16/97-6-5 5/4/95 6-5 04/16/97 6-6 5/4/95 6-6 04/16/97 6-7 1/17/95 6-7 04/16/97 6-8' 1/17/95 6-8 04/16/97 6-9 5/4/95 6-9 04/16/97 7-1

-1/17/95 7-1 04/16/97 2 5/4/95 (Deleted) 7-3 5/4/95 (Deleted) 8-1

- 1/17/95-8-1 04/16/97 8-2 1/17/95 8-2 04/16/97 8-3 1/17/95 8-3 04/16/97 8 1/17/95 8-4 04/16/97 l

8-5 1/17/95 (Deleted) 8-6 1/17/95 (Deleted) 8-7 1/17/95 (Deleted) 8-8 1/17/95 (Deleted) 9 1/17/95 9-1 04/16/97 10-1 1/17/95 10-1 04/16/97 10-2 5/4/95 (Deleted) 10-3 5/4/95 (Deleted) 11-1 '5/4/95 11-1 04/16/97 11-1a 5/4/95 (Deleted) 11-2 5/4/95 (Deleted) 11-3 -8/8/96 (Deleted) 11-4 1/17/95 (Deleted) 11-5 5/4/95 (Deleted) 11-6 5/4/95 (Deleted) 11-7. 1/17/95 (Deleted) 1 11-8 1/17/95 (Deleted) 11-9 1/17/95 (Deleted) 11-10 1/17/95 (Deleted)

-j 11-11 1/17/95 (Deleted) 11-12 1/17/95 (Deleted) 2

4 April 16,1997 Enclosure (3)

COMBUSTION ENGINEERING, INC, WINDSOR SPECIAL NUCLEAR MATERIALS LICENSE AMENDMENT REQUEST TO DOWNGRADE LICENSE NO. SNM-1067 LIST OF EFFECTIVE PAGES Combustion Engineering, Inc. is superseding its requests dated April 23,1996 and December 20,1996 to amend the Application for the Windsor Special Nuclear Materials License No. SNM-1067 by replacing the pages of those requests and all other pages of the Application with this Amendment Request. The following is a comprehensive List of Effective Pages for the resulting Apolication, Pages Ratg Pages Qalg Chaoter 2 License Acolication Title Paae 2-1 04/16/97 1

04/16/97 2-2 04/16/97 2-3 04/16/97 2-4 04/16/97 Table of Contents 2-5 04/16/97 li 04/16/97 lii-04/16/97 Chaoter 3 3-1

'04/16/97 Part i Title Paae 3-2 04/16/97 3-3 04/16/97 iv 04/16/97 3-4 04/16/97 3-5 04/16/97 1

3-6 04/16/97 Chaoter 1 3-7 04/16/97 1-1 04/16/97 1-2 04/16/97 1-3 04/16/97 Chaoter 4 4-1 04/16/97 4-2 04/16/97 i

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Chaoter 5 Chaoter 10 5-1 04/16/97 10-1 04/16/97 Part ll Title Paag l

Chaoter 11 l

Chaoter 6 11-1 04/16/97 6 04/16/97 6-2 04/16/97 6-3 04/16/97 6-4 04/16/97 6-5 04/16/97 6-6 04/16/97 l

6-7 04/16/97 6-8 04/16/97 6-9 04/10/97 Chapter 7 7-1 04/16/97 Chaoter 8 8-1 04/16/97 8-2 04/16/97 8-3 04/16/97 8-4 04/16/97 Chaoter 9 9-1 04/16/97 l

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April 16,1997 Enclosure (4) l COMBUSTION ENGINEERING, INC.

WINDSOR SPECIAL NUCLEAR MATERIALS LICENSE AMENDMENT REQUEST TO DOWNGRADE LICENSE NO. SNM-1067 AFFECTED PAGES l

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WINDSOR SNM LABORATORY f

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COMBUSTION ENGINEERING, INC.

2000 Day Hill Road Windsor, Connecticut 06095-0500

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i-License No. SNM-1067 Date:04/16/97 Docket No. 70-1100 Page: i

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2 TABLE OF CONTENTS SECTION TJT.LE PART I-LICENSE CONDITIONS 1.0 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1.1 NAME 1.2 LOCATION 1.3 LICENSE NUMBER 1.4 POSSESSION LIMITS AND LOCATION 1.5 AUTHORIZED ACTIVITIES 1.6 EXEMPTIONS AND SPECIAL AUTHORIZATIONS 2.0 ORGANIZATION AND ADMINISTRATION 2.1 ORGANIZATION RESPONSIBILITIES AND AUTHORITY FOR KEY POSITIONS IMPORTANT TO SAFETY 2.2 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS FOR KEY POSITIONS IMPORTANT TO SAFETY 2.3 (Deleted) 2.4 APPROVAL AUTHORITY FOR PERSONNEL SELECTION 2.5 TRAINING 2.6 OPERATING PROCEDURES 2.7 INTERNAL INSPECTIONS 2.8 INVESTIGATIONS AND REPORTING 2.9 RECORDS 3.0 RADIATION PROTECTION 3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3.2 TECHNICAL REQUIREMENTS 4.0 ENVIRONMENTAL PROTECTION 4.1 EFFLUENT CONTROL SYSTEMS COMMITMENTS License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: ii

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l TABLE OF CONTENTS SECTION TlTLE 1

4.2 ENVIRONMENTAL MONITORING PROGRAM t

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5.0 DECOMMISSIONING FUNDING

PLAN l

PART ll - SAFETY DEMONSTRATION i

l 6.0 OVERVIEW OF OPERATIONS I

6.1 CORPORATE INFORMATION AND FINANCIAL QUALIFICATIONS 6.2 OPERATING OBJECTIVE 6.3 SITE DESCRIPTION 6.4 LOCATIONS OF BUILDINGS ON SITE 6.5 HISTORY OF LICENSE 6.6 HISTORY OF LICENSED ACTIVITIES IN BUILDINGS ON SITE 7.0 FACILITY DESCRIPTION 7.1 USE OF BUILDINGS 7.2 FIRE PROTECTION 8.0 ORGANIZATION AND PERSONNEL 8.1 FUNCTIONS OF KEY PERSONNEL 8.2 RESUMES OF KEY PERSONNEL IMPORTANT TO SAFETY 9.0 RADIATION PROTECTION PROCEDURES AND EQUIPMENT 9.1 PROCEDURES 9.2 INSTRUMENTS 10.0 OCCUPATIONAL RADIATION EXPOSURES 11.0 ENVIRONMENTAL SAFETY 1

l License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: iii

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WINDSOR SNM LABORATORY r

LICENSE APPLICATION 2

PART I-LICENSE CONDITIONS 4

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PART I-LICENSE CONDITIONS

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1.0 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1.1 nAME Combustion Engineering, Inc., is incorporated in the State of Delaware with a principal office at 2000 Day Hill Road in Windsor, CT. The location where licensed activities are i

conducted is at 2000 Day Hill Road in Windsor, CT.

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1.2 LOCATION The mailing address for all license correspondence is:

I Combustion Engineering, Inc.

2000 Day Hill Road Windsor, CT 06095-0500 l

1.3 LICENSE NUMBER Activities are covered by NRC License SNM-1067; Docket 70-1100.

t License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 1~1

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1.4 POSSESSION LIMITS AND LOCATION Combustion Engineering, Inc., requests authorization at its Windsor Site for the following quantities of radioactive materials:

Material Emm Quantity Location

.(1)

Uranium enriched Residue 1000 gms 23sU Specified Storage to greater than or (LLRW)

Areas equal to 5.0 weight 235 percent U

(2)

Uranium enriched Residual 150 gms 23sU Building 21 to less than or Uranium equal to 5.0 weight Oxides 235 percent U

(LLRW)

As stated in the letter from L. Bickwit, Jr. (Miller and Chevalier) to R. L. Fonner (NRC), dated March,4,1997, the material in item 1, above, applies only to enriched uranium low-level wastes now located on the Windsor site that have been collected by CE and am to be included in the DOE Formerly Utilized Sites Remedial Action Program ("FUSRAP") for dispocc!. Tha 1000- gram possession limit also covers any such FUSRAP U-235 that is further collected by CE for disposal.

CE believes that these wastes originated under contracts performed by CE for the Atomic Energy Commission in the late 1950's and early 1960's and that the wastes are covered or should be covered by the Department of Energy's designation of the Windsor site under FUSRAP. All other uranium residues that originated under the contracts referred to and have not been collected by CE should not be regarded as covered by, or subject to the possession limitations of, the license until such residues are collected by CE.

License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 1-2

1.5 AUTHORIZED ACTIVITIES The activities carried out with Special Nuclear Material (SNM) at the Windsor Site are limited to activities involving LLRW as follows:

Specified Storage Packaging, repackaging, evaluation, storage, handling, 4

Areas * -

and transportation of waste from prior operations for the purpose of SNM control. These activities pertain to the 3

material under item 1 of Section 1.4.

Building 21 -

Decommissioning the former commercial nuclear fuel manufacturing facility warehouse under an approved Decommissioning Plan. This activity pertains to the material under item 2 of Section 1.4.

1.6 EXEMPTIONS AND SPECIAL AUTHORIZATIONS 1.6.1 In accordance with the exemptions allowed in 10 CFR 70.24(d), the Specified Storage Areas

  • and Building 21 shall be exempt from the requirement of a criticality monitoring system as specified in 10 CFR 70.24(a)(1). CE shall separate the wastes into batches no larger than 350 g contained 235U and shall maintain a minimum separation of 12 feet between batches.

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  • The Specified Storage Areas are defined as locked, trailer sized, ground level storage containers and the paved area in the wooded section of the Windsor site and the DOE FUSRAP-designated Building 3 and its immediate environs. Analyses may be made, under License No. 06-00217-06, on samples of waste.

License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 1-3 r

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2.0 ORGANIZATION AND ADMINISTRATION 2.1 ORGANIZATION RESPONSIBILITIES AND AUTHORITY FOR KEY POSITIONS IMPORTANT TO SAFETY 2.1.1 (Deleted) 2.1.2 Radiation Safetv Officer (RSO)

CE management is responsible for safe operation under this license. The Radiation Safety Officer is responsible for defining and implementing procedures related to radiological safety. Procedures address safety criteria, monitoring, and training necessary to ensure the protection of employees, the public and the environment.

The Radiation Safety Officer is responsible for supervising the radiological protection team. The radiological protection team performs radiological surveys, air sampling, and radiological safety job coverage. If the Radiation Safety Officer believes an operation to be unsafe, he or she has the authority to halt that operation, and to restart such operation.

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License No. SNM 1067.

Date: 04/16/97 Docket No. 70-1100 Page: 2-1

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2.2 PElISONNEL EDUCATION AND EXPERIENCE REQUIREMENTS FOR KEY POSITIONS IMPORTANT TO SAFETY 2.2.1 (Deleted)

I 2.2.2 Eadiation Safety Officer The minimum :,Jalifications for this position are a bachelor's degree in one of the sciences or engineering or its equivalent with two (2) years experience in health physics.

2.3 (Deleted).

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 2-2

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2.4 APPROVAL AUTHORITY FOR PERSONNEL SELECTION The personnel for key positions important to safety who are involved in activities within the scope of this application are approved by a higher level of management than the position of concern.

2.5 TRAINING t

Training for personnel working with licensed material is provided commensurate with the hazards faced by the worker The training program defines tra!ning requirements for in-house workers, contractors, and visitors. Personnel will not work unsupervised with licensed material prior to completion of the r inimum training requirements.

n Topics that are included in personnel training programs for persons working with licensed materialinclude:

(1)

Procedures for the storage, transfer, and use of radioactive materials.

(2)

Health protection problems associatsd with exposure to the types of radioactive materials and radiation that are encountered.

(3)

Precautions or procedures to minimize exposure.

(4)

The purposes and functions of protective devices and/or equipment employed.

(5)

The need to observe the applicable provisions of Nuclear Regulatory Commission regulations and licenses for the protection of personnel from exposures to radiation or radioactive material, especially for the l

purpose of ensuring the worker has the ability to recognize and mitigate the hazards to which he is exposed.

s License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 2-3 i

l (6)

The responsibility of the worker to promptly report to Combustion Engineering, Inc., management any condition which may lead to or cause a violation of Nuclear Regulatory Commission regulations and licenses or unnecessary exposure to radiation or to radioactive material.

(7)

The appropriate response to warnings made in the event of an unusual occurrence or malfunction that may involve exposure to radiation or radioactive material.

(8)

The radiation exposure reports which workers may request (as referenced in 10 CFR 619.13).

Training methods include lecture, classroom participative training, programmed instruction, challenge testing, on-the-job training, or other training methods as appropriate.

The effectiveness of training shall be suitably demonstrated; e.g., by written, oral or practical examination, or other suitable means. The adequacy of each individual's training shall be evaluated on a biennial basis, and retraining shall be provided as appropriate.

2.6 OPERATING PROCEDURES Activities involving licensed materials are conducted in accordance with approved written procedures and radiation work permits. Health physics activities shall be conducted in accordance with written procedures approved by the RSO and reviewed for potential update on a biennial basis, i

2.7 INTERNAL INSPECTIONS l

Inspections are performed to determine if operations are being conducted in accordance l

with applicable license conditions and written procedures. Annualinspections cover radiological and environmental safety and are conducted based upon a written plan.

Qualified personnel having no direct responsibility for the operation being inspected are used as inspectors to ensure unbiased and competent results. The annual inspection for License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 2-4

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3 radiological safety shall be performed by an individual with at least two years experience in applied health physics. Items requiring corrective action are documented in a report distributed to the Radiological Services Leader. Follow-up actions will be documented.

I 2.8 INVESTIGATIONS AND REPORTING Abnormal occurrences are investigated and reported to the Radiological Services Leader.

Reports to the Nuclear Regulatory Commission are made in accordance with specific conditions of this application and the applicable Federal Regulations. The level of I

investigation and the need for corrective action are deterrnined based on the severity of the incident.

2.9 RECORDS 1

Records pertaining to health and safety, abnormal occurrences, inspections, employee training, personnel exposures, and routine radiation and contamination surveys are retained to demonstrate compliance with the conditions of this application and the l

applicable Ft f.;;@, State and local regulations. Such records are retained for at least two years, unless otherwise specified in the governing regulations.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 2-5

3.0 RADIATION PROTECTION 3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3.1.1 ALARA Commitment Combustion Engineering has a strong commitment to the ALARA philosophy, In support of this commitment, the Radiological Services Leader periodically reviews safety related activities, including abnormal occurrences and the implementation of ALARA policies. The following policies are implemented for work at the site:

(1)

The key ALARA objective is to minimize exposure to radioactive material for the public, the environment, and the workers at the Windsor site.

(2) in the interest of limiting exposures to the public, the objective is to have minimal effluents from the activities under this license.

i (3)

The preferred method of limiting intake is the use of engineering controls.

Engineering control of intake is achieved with ventilation control as described in Section 3.2.3, and, when engineering controls are not 9dequate, intake is limited by the use of respiratory protection as described in Section 3.2.8.

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l License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 3-1 l

l 3.1.2 Radiation Work Permit l

Work with licensed materials is covered by Radiation Work Permits (RWP). The Radiation Safety Officer (RSO), or his designee (with a minimum of 2 years experience in applied health physics with material similar to that authorized by this license), approves RWPs.

RWPs specify applicable radiological controls for the activity, such as special radiological l

equipment, special personnel monitoring devices, protective clothing or air sampling requirements. Radiation Protection Technicians are responsible for ensuring the proper implementation of radiation work permits. RWPs which remain open for more than a month are reviewed on a monthly basis to ensure the controls are effective; RWPs which are no longer needed are closed.

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3.1.3 Annual Report The Radiation Safety Officer shall submit to the Radiological Services Leader an annual report that reviews the employee radiation exposures to determine:

t (1) if there are any upward trends developing in personnel exposures, (2) if personnel exposures might be lower under the concept of As Low As Reasonably Achievable (ALARA); and (3) if equipment for personnel exposure control is properly used, maintained, and inspected.

l This report shall include the review of other required audits and inspections performed during the past 12 months and review of the data from the following areas as applicable:

employees exposures (intemal and external), bioassay results, and unusual occurrences.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 3-2

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3.2 TECHNICAL REQUIREMENTS l

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3.2.1 Control of Licensed Material Access to licensed material is controlled.

1 3.2.2 Protective Clothina and Personnel Monitorina Reauirements l

Protective clothing, when required, is prescribed by the applicable radiation work permit.

Personnel exiting contaminated areas are required to survey themselves after removing protective clothing to ensure that they are free of contamination. Emergency evacuations are an exception to the personnel survey requirement.

3.2.3 Ventilation Reauirements Airbome effluents generated from operations involving licensed material, other than j

operations potentially involving trace amounts of licensed material, shall be j

controlled as necessary, in accordance with good health physics practices. When ventilation systems are required, they are designed and maintained to limit the spread l

of contamination into the environment. Exhaust from systems will be sampled, monitored and controlled pursuant to 10 CFR 20.3.2.3 l

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 3-3

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1 3.2.4 Instrumentation r

l Instrumen's used for radiation detection and measurement have capabilities as follows (more than one instrument may be utilized to cover the specified range):

5 1 DPM to 1x10 DPM (disintegrations per Alpha / Beta Counting Systems:

minute) 5 10 CPM to 1x10 CPM (counts per minute)

Alpha Survey Meters:

Beta / Gamma Survey Meters:

1 mR/h to 5,000 mR/h (millirem per hour)

Gamma Survey Meters:

1 uR/h to 50 mR/h (microrem/ millirem per hour)

Radiation detection instruments are calibrated semiannually and after each repair that would affect accuracy.

3.2.5 Radiation Exoosures The intake of radioactive material shall be monitored for individuals likely to receive l

In excess of 10% of the applicable Annual Limit on intake (All). Soluble uranium intake shall be limited to less than 10 milligrams per week per individual. Work activity restrictions sha!I be imposed when an individual reaches 50% of the applicable limit; i.e.,0.5 ALI (1,000 DAC hours) and 5 milligrams per week for soluble uranium. A diagnostic study to evaluate intakes shall be started at these action levels.

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l Exposure to radiation shall be monitored for individuals likely to receive, in one year from sources external to the body, in excess of 10% of the occupational dose limits of 10 CFR

20. The personnel monitoring device will be a thermoluminescent dosimeter (TLD). TLDs shall be processed for dose reading on at least a quarterly basis by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited dosimetry processor. The action level for investigation and possible work restrictions shall be 1 rem for deep dose equivalent (DDE) on an annual basis.

Total Effective Dose Equivalent for occupational exposures shall be calculated in accordance with 10 CFR 20 using a combination of personal lapel air sampling data, personnel radiation exposure data and/or bioassay measurement data.

The primary method of calculating Committed Effective Dose Equivalent is by using personal lapel air sampling results. Personal lapel monitors shall be counted on a daily basis when in use for this purpose.

3.2.6 Bioassav Proaram if a respiratory protection program is utilized or personnel are iikely to receive greater than 10% ALI such that monitoring is required, then a bioassay program shall be maintained for confirmation and evaluation ofintabs. If a bioassay program is required, then bioassay assessme..ts of intakes shall be performed on an annual basis, or, for personnel exposed to soluble uranium, bloassay assessment shall be on a monthly basis. Bioassay assessment may also be used to perform the diagnostic study at the action levels of Section 3.2.5.

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1 License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 3-5

1 3.2.7 Contamination Surveys Contamination surveys are performed at a minimum of once per week in loose surface contaminated areas where work involving radioactive materials may be in progress.

Surveys in step-off pad areas in use are performed on a daily basis. Contamination surveys are performed on a quarterly basis in clean areas designated by the RSO, based on their potential to become contaminated. Surveys conducted in support of work performed uncer a Radiation Work Permit (RWP) may be used to meet the survey requirement.

RWP termination surveys will include alpha / beta scans to verify that no contamination has resulted from the work performed under the RWP. The following are action levels for contamination control:

Arga Action Levcl*

Contamination Control Area 5,000 Step-Off Pad Areas (in use) 50 Clean Areas 10 2

  • dpm alpha /100 cm as determined by smear survey Clean up action is started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when removable surface contamination exceeds the action level limits specified above.

3.2.8 Resoiratorv Protection To the extent practicable, process or other engineering controls will be used to control the concentration of radioactive material in air. When it is not practicable to apply these controls to limit the concentration of radioactive material in air to values below those that define an airborne radioactivity area, other controls will be implemented to limit intake, which could include use of respiratory protection equipmant. Respiratory protection will be consistent with 10 CFR 20.

i License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 3-6

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l 3.2.9 Materials and Eauloment Released for Unrestricted Use 1

Release of equipment and materials from restricted areas to clean areas on-site or unrestricted areas shall be in accordance with the NRC's " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or 1

Termination of Licenses for Byproduct, Source, or Special Nuclear Material,"

l dated April,1993.

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3.2.10 Nonexemot Sealed Source Control (This section is deleted. There are no sealed sources under this license application.)

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4.0 ENVIRONMENTAL PROTECTION l

i 4.1 EFFLUENT CONTROL SYSTEMS COMMITMENTS

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4.1.1 Low-Level Radioactive Waste Low level radioactive wastes (LLRW) will be packaged in accordance with applicable regulations and delivered to a carrier for transport to an approved waste processor and/or disposal facility. Current copies of processor or disposal facility licenses shall be maintained.

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LLRW packages awaiting shipment to a processor or disposal facility may be temporarily i

stored for up to one year on site. LLRW packages in such temporary storage will be l

checked quarterly for integrity and exterior contamination. LLRW storage areas shall be i

appropriately posted and LLRW shall be secured from unauthorized removal. Prior to l

being placed into storage, packages will be checked for exterior contamination and 23s labeled as radioactive material and, for SNM, as to u content. LLRW packages may be l

stored for up to ten years as interim storage provided they are protected from the elements. Interim LLRW storage shall be in the Specified Storage Areas defined in Section 1.5. LLRW in interim storage will be checked annually for integrity and exterior contamination.

1 Records will be maintained of the contents of the LLRW packages. All packages will be stored on raised platforms (e.g., built in or portable pallets) or legs and stacking will be limited to three (3) high. When placed into storage, the packages shall be sealed in a

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manner which precludes casual entry (e.g., by the use of steel clips or strapping) until final sealing is accomplished prior to shipment to the processor or disposal facility.

i License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 4-1 l

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Containers containing liquid wastes shall not be stored outside, shall be segregated from solid waste containers (e.g., stacked separately) and shall be appropriately labeled.

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I 4.1.2 Liauid Effluents 1

There are no liquid effluents.

4.1.3 Airborne Effluents Airbome effluents are monitored in accordance with Section 3.2.3.

4.2 ENVIRONMENTAL MONITORING PROGRAM The only materials authorization requested in this application is for residual material in the form of Low Level Radioactive Waste. The effectiveness of the controls over this material will be monitored under the Windsor Broad Scope Radioactive Materials License No. 06-00217-06. Section 10.7 of the Application for the Broad Scope License describes the environmental monitoring program.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 4-2 M. !. r 1

5.0 DECOMMISSIONING FUNDING

PLAN Combustion Engineering reaffirms that, upon terminating activities involving materials

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1 authorized under license SNM-1067, the premises where the licensed activities were cerried out will be decommissioned in a manner that will protect the health and safety of the public in accordance with 10 CFR 70.38. Combustion Engineering's financial

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assurances in the letters dated July 19,1990, July 2,1992, November 10,1993, May 23, 1994, and July 30,1994, should be considered a part of this license application.

j License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 5-1

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WINDSOR SNM LABORATORY LICENSE APPLICATION PART 11-SAFETY DEMONSTRATION i

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l-PART 11 - SAFETY DEMONSTRATION 6.0 OVERVIEW OF OPERATIONS 6.1 CORPORATE INFORMATION AND FINANCIAL QUALIFICATIONS 6.1.1 Name and Address of Licensee Combustion Engineering, Inc.

2000 Day Hill Road Windsor, CT 06095-0500 Combustion Engineering, Inc. is incorporated in the State of Delaware. The principal office location is in Windsor, Connecticut.

6.1.2 Name. Address and Citizenshio of Princioal Officers The following is a listing of all directors and principal officers of Combustion Engineering, Inc.

Directors R. F. Cronin*

D. M. Kuzmak*

R. G. Kemp, Jr.

R. S. Siudek*

l Officers R. F. Auclair*

R. F. Cronin*

D. E. Lewis

  • A. M. Pfeffer R. D. Austin
  • A. E. Fornier, Jr.*

T. E. Liggett V. B. Probst*

G. F. Barcikowski*

J. Guarino E. B. Lyon T. N. Sacco*

M. F. Barnoski*

D. E. Harris

  • D. J. McDermott*

D. H. Simpson*

l R. S. Bell, Jr.*

R. W. Jewell J. H. Mulholland*

R. S. Siudek*

J. P. Brett R. G. Kemp, Jr.

R. E. Newman*

D. R. Zabilansky*

E. Bysiek D. M. Kuzmak*

T. L. Pajonas*

License No. SNM-1067 Date: 04/16/97 l

Docket No. 70-1100 Page: 6-1 l

These individuals are citizens of the United States of America. Except for the individuals with an asterisk, whose address is shown in Section 6.1.1, a common address is given below:

Combustion Engineering, Inc.

501 Merritt 7 Norwalk, CT 06856-5308 6.1.3 Company Backaround Combustion Engineering, Inc. is a wholly owned subsidiary of Asea Brown Boveri Inc.,

also a corporation organized under the corporation law of the state of Delaware. Asea

' Brown Boveri Inc. is a wholly owned subsidiary of ABB Asea Brown Boveri Ltd., a Swiss corporation which is jointly owned by ABB AB, a publicly held Swedish corporation, and ABB AG, a publicly held Swiss corporation.

l The commercial nuclear fuel manufacturing history of the Windsor site dates from late 1968, when SNM-1067 was first issued to Combustion Engineering, Inc. Commercial activities covered by SNM-1067 have involved development and production of fuel products for the commercial nuclear industry. Initially, uranium dioxide (UO ) fuel pellets 2

purchased from an outside supplier were processed and loaded into fuel rods in Building 17, the manufacturing facility at the Windsor site. In 1970, a fuel pellet operation was l

added to the already existing fuel pellet loading and fuel assembly operation. At that time, Building 17 began to receive uranium dioxide powder, which was subsequently pressed into fuel pellets. UO pellet pressing and powder handling operations continued until 2

permanently halted in December of 1989.

Lhense No. SNM-1067 Date: 04/16/97 l

Docket No. 70-1100 Page: 6-2 i

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. Upon the cessation of powder operations, a major decontamination project was undertaken in the pellet shop of Building 17, resulting in greatly reduced contamination levels in the manufacturing facility. Since that time, manufacturing activities in Building 17 have been limited to producing finished fuel assemblies from sintered UO, pellets manufactured at and received from another site. Uranium bearing fuel manufacturing operations ceased on September 30,1993. Following the cessation of uranium handling operations, Combustion Engineering Inc. Initiated the decontamination and decommissioning of the Building 17/21 Complex. Laboratory activities, which were continued in the SNM Laboratory facilities, have since been transferred to another license, as was the use of the Building 17 facility for byproduct material. Decontamination of Building 21 is complete and the building is intended to be free released.

6.1.4 Information Known to Acolicant Reaardina Foreian Control Information regarding foreign ownership of Combustion Engineering, Inc., was provided to J

l the NRC in a letter dated November 21,1989.

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6.1.5 Financial Qualifications l

L Combustion Engineering, Inc. is financially qualified to engage in the proposed activities of this license application.

The decommissioning funding plan for the Windsor site areas is referred to in Part l l

Chapter 5 herein.

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l License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 6-3 i

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i 6.2 OPERATING OBJECTIVE l

The operating objectives are as follows:

(1)

Perform the activities involving waste from prior operations as described in'

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Section 1.5.

(2)

- Perform testing and analyses to support the operational activities.

i 6.3 SITE DESCRIPTION l

The Combustion Engineering Windsor site is located in north central Connecticut (Figure 6-1). The site is approximately 600 acres along the section of the Farmington River known as the Rainbow Reservoir in the town of Windsor, Connecticut (Figure 6-2).

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6.4 LOCATIONS OF BUILDINGS ONSITE The locations of buildings on the Windsor site are shown in Figure 6-3.

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6.5 HISTORY OF LICENSE j-Combustion Engineering first applied for this license to process low enriched uranium in 1

1968. License SNM-1067 was then issued for a period of 5 years by the U.S. Atomic Energy Commission (AEC). The license has been renewed at approximately 5 year intervals since then.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 6-4 i

6.6 HISTORY OF LICENSED ACTIVITIES IN BUILDINGS ON SITE License SNM-1067 was initially issued in 1968 to allow use of low enriched uranium special nuclear material and source material in Building 17 for the purpose of commercial nuclear fuel manufacturing. Later, Building 21 was added as a warehouse and shipping and receiving building. Such activities continued in the Building 17/21 Complex until 1993, when commercial nuclear fuel manufacturing of SNM ceased, and decommissioning of those buildings was initiated. In 1996, the decommissioning of Building 17 was delayed while the building is used for procesing of equipment returned from reactor sites and

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contaminated with byproduct material.

in Buildings 1/1 A and 2A licensed activities included the storage of source material.

In Building 2, licensed activities have consisted of storage of sealed test rods containing SNM and mechanical testing using sealed simulated fuel rods containing source material.

In addition, archived special nuclear material had, in the past, been stored in Building 2.

In Building 3/3A, the primary licensed activities involved the use of sealed sources and sealed testing specimens Ie.g., for x-ray measurements).

The primary licensed activities performed in Building 5 have been past developmental fuel manufacturing and the laboratory activities previously associated with the current license application.

d License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 6-5

I In Building 6, activities involving SNM have been radioactive liquid waste processing and low level radioactive waste storage.

In Building 16, the primary licensed activities were the use of sealed sources and source material handling.

In Building 18, the primary licensed activities have been hydraulic loop testing using sealed simulated fuel rods containing source material.

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i License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 6-6

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Figure 6-1 Combustion Engineering Location within Connecticut Combustion Engineering, Inc.

Windsor, Connecticut I

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i MASSACHUSETTS 2

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p ymoson @

HA$TFORD RHODE D

Y K

WATERBURY

/

NEW HA BRIDGEPORT LONGISLAND SOUND

^

STAMFORD North (Not to Scale)

License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 6-7

Figure 6-2 Combustion Engineering Location - Local Area Combustion Engineering Windsor, Connecticut i

SUFFELD ENFIELD 1

OSOF

__ EAST WINDSOR WINDSOR I

\\

9 SOUTH VERN

/BLOOMFELD WINDSOR u

MANCHESTER WEST NW,0 EAS HARTFOR r%RTF D L

7

{

GLASTONBUR y

\\

_\\

\\NEWINGTON

\\

WETH IELD r-5 A

North (Not to Scale)

License No. SNM-1067 Date: 04/16/97 Docket No, 70-1100 Page: 6-8

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l Figure 6 3 l

Location Of Buildings On The Windsor Site I

N i

FARMW8GTON RIVER l

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10 DOE SIC i

LA RW 8

CONTA2sERS -O 2A i 1A EA '

v.

0 SMALL PONO 20 h

$k m BUK.OING 3 64 1

GREAT PONO 16 LOCATION OF SulLDINGS ON THE WINOSL9 $1TE ka 1

1 NUCLEAR FtELD OPERA 110NS STORAGE 12 1A NUCLEAR FIELD OPERATIONS STORAGE 2

NUCLEAR FIELD OPERATIONS TEST FACluTY 2A NUCLEAR FIELD OPERATIONS SERVICES FACluTY

/g S

POWER PLANT LA80RATORIES 24 3A POWER PLANT LA80RATORtES OFFICE 23 4

GENERAL OFFICES 22 S

NUCLEAR OPERAflONS LABORATORIES e

RAOIOACTFWE UQUID WASTE PROCESSING 4A FACluTIES ENGINEERING & SERVICE $

T SolLER HOUSE & CHILuNG PLANT TA SHIPPtNG & RECEMNG 10 INDUSTRA WASTE WATER TREATMENT PLANT 12 NUCLEAR ENGINEERING 14 DNNG. MAIL. ETC.

18 DEVELOPMENT LA80RATORY 17 FUEL FABRICATION FACluTY 18 DEVELOPMENT LABORATORY 18 OENERAL OFFICES to FACluTIES & ENGINEERING SERVICES 21 FUEL MFG WAREHOUSE 22 GENERAL OFFICE $

  • SPECIFIED STORAGE AREAS I

23 OENERAL OFFICES 4

24 OENERAL OFFICES HW HEALT>eNORKS NOTE. DOE sic is A DOE OWNED PROPERTY (10 8 ACRES)

I License No. SNM-1067 Date: 04/16/97 l

Docket No. 70-1100 Page: 6-9 l

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i 7.0 FACILITY DESCRIPTION 7.1 USE OF BUILDINGS l

i Building 21 is the former commercial nuclear tuel manufacturing facility warehouse. it has been decontaminated under an approved decommissioning plan and is awaiting free l

release.

7.2 FIRE PROTECTION Under this license application, there are no facilities that require fire protection and no i'

activities that may potentially initiate emergency response action, f

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 7-1

s 8.0 ORGANIZATION AND PERSONNEL The Windsor SNM personnel organization structure is depicted in Figure 8-1.

8.1 FUNCTIONS OF KEY PERSONNEL The function, responsibilities and authorities of key personnel important to safety are described in Part I, Section 2.1 of this application. This section provides similar information for the remaining " Facility" personnel.

8.1.1 Radiation Safety Enaineer 4

The Radiation Safety Engineer is responsible for assisting the Radiation Safety Officer in the many facets of his duties. This includes procedure development, radiation work permit development, radiological control planning, etc. When deemed qualified, the Radiation Safety Engineer may be delegated functions of the Radiation Safety Officer.

8.1.2 Health Physics Technicians Health physics technicians ensure that the radiological controls requirements established by the Radiation Safety Officer are carried out; this includes monitoring of radiation exposures.

8.2 RESUMES OF KEY PERSONNEL IMPORTANT TO SAFETY Resumes of key personnel important to safety are provided on the following pages.

License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 8-1

D JAMES M. LIMBERT - RADIATION SAFETY OFFICER Education:

Central High School - Red Wing, Minnesota, Graduated 1960 Dunwoody Industrial Institute - Minneapolis, MN,1960 - 1961 U. S. Naval Nuclear Power School,1963 U. S. Naval Nuclear Prototype,1964 U. S. Naval Nuclear Laboratory Technician School,1964 U. S. Naval Nuclear Laboratory Technician Refresher,1965 University of Hartford - Calculus I & II,1973 - 1974 Charter Oak College Continuing Education - Liberal Arts,1980 NRRPT Certified Exoerience:

ABB COMBUSTION ENGINEERING SUPPORT SERVICES 1994 -Present ABB COMBUSTION ENGINEERING NUCLEAR OPERATIONS 1970 -1994 Radiation Safety Officer 1988 - Present Duties and responsibilities include oversite reviews and maintenance activities associated with NRC broad scope materials and special nuclear materials licenses.

Special Projects:

Assigned to the independent fuel manufacturing task force charged with the responsibility to conduct an in-depth audit of the fuel facility in Windsor. Areas of responsibility included:

1.

Radiological Protection 2.

Environmental Protection 3.

Industrial Hygiene and Safety l

Promoted to Radiation Safety Officer in 1988.

Radiation Safety Enaineer 1973-1988 Responsible for planning, advising and administering health physics and radiation protection programs in the Development Department. Developed and maintained radiation workers training programs.

License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 8-2

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I JAMES M. LIMBERT (continued) l Assisted in developing hazardo.us waste management program for the Nuclear Laboratory, l

Developed and administered security accounting programs for special nuclear materials in I

the Nuclear Laboratories.

Developed and supervised a decontamination project involving the reclamation of land contamination with high levels of Natural Thorium and High Enriched Uranium.

Senior Radiolooical Safety Assistant 1972-1973 Responsible for developing, administering and performing the health physics program for the Nuclear Laboratories of the Development Department. Promoted to Radiation Safety i

Engineer.

I Senior Radiochemistrv Technician 1970 -1972 Performed radiochemistry analyses and environmental analyses associated with fuel manufacturing and reactor site surveillance programs. Promoted to Senior Radiologimi Safety Assistant,1972.

U.S. NAVY 1961 -1970 i

Leading Petty Officer - Engineering Laboratory Technician and Radiological Protection Groups. Responsible for all radiological controls and chemistry operations at a naval nuclear prototype.

Senior Operator Instructor - Classroom Phase - responsible for operation and maintenance of classroom instruction of sixty (60) students and staff of 8 instructors at a naval nuclear prototype.

Leading Petty Officer - In charge of chemistry, radiological control and mechanical l

operators aboard three nuclear powered submarines.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 8-3

i Figure 8-1 Personnel Organization 4

i Senior Project Manager, Site Remediation 1

i Radiological Services Leader

" CORPORATE"

" FACILITY" Radiation Safety Officer I

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I Health Physics Radiation Safety Techrialan(s)

Engineer License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 8-4

a 9.0 RADIATION PROTECTION PROCEDURES AND EQUIPMENT

~ 9.1 PROCEDURES i

a Operations involving licensed materials are conducted in accordsnce with written procedures and/or radiation work permits. Radiation work permits are approved by the Radiation Safety Officer or his designee (e.g., Radiation Safety Engineer).

i 9.2 INSTRUMENTS Alpha / Beta counting systems are used for radiation detection and measurement. The Alpha / Beta counting systems are calibrated quarterly and checked daily when in use a

through background and efficiency checi:s.

i Gamma spectroscopy systems are also used for radiation detection and measurement.

Operational integrity of the gamma spectroscopy systems is verified by weekly gamma energy and efficiency calibrsuon checks.

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Radiation sources used in the instrument calibndions are NIST certified.

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1 License No. SNM-1067 Date: 04/16/97 Docket No 70-1100 Page: 9-1

I 10.0 OCCUPATIONAL RADIATION EXPOSURES With cessation of the uranium processing operations the potential for a release of radioactive material is greatly diminished. Combustion Engineering will continue its emphasis on exposure control to minimize intake of uranium. The indicators used include the following:

l-(1)

Shallow Dose Equivalent: Shallow Dose Equivalent is the external dose to the skin.

1 (2)

Total Effective Dose Equivalent (TEDE): TEDE is the sum of the deep i

dose equivalent and committed effective dose equivalent.

(3)

Airborne Radioactivity: A measure of the concentration of radioactivity in the ambient work place air. It is measured through the use of air sampling equipment and expressed in units of Cl/ml (Bq/m3),

I (4)

Contamination: This is a measure of the amount of uranium surface contamination in the work environment, expressed in units of dpm/100cm2, l

When thermoluminescent dosimeters (TLD) are used as monitoring devices, they are processed on at least a quarterly basis by an accredited dosimetry processor.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 10-1

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11.0 ENVIRONMENTAL SAFETY 4

The effectiveness of the controls over the licensed material will be monitored as described i

in Section 4.2 of this application.

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License No. SNM-1067 Date: 04/16/97 Docket No. 70-1100 Page: 11-1

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