ML20142A169
| ML20142A169 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/10/1986 |
| From: | Watters J BABCOCK & WILCOX CO. |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 26451, NUDOCS 8603190394 | |
| Download: ML20142A169 (91) | |
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Babcock & Wilcox
@%%w a McDermott company PdNx M646 LynchbutWNA 24506 1646 (804) 522 %
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February 10, 1986
'86 FEB 18 N l
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United States Nuclear Regulatory Commission t 'c. FEE MGML M i
Attn:
Mr. W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle & Material Safety Washington, D. C.
20555
References:
(1) SNM-1168, Docket 70-1201 (2) Letter from R.
G. Page to D.
W.
Zeff dated 7-1-80, "SNM-1168, Amendment No. 13"
)
Gentlemen:
The Babcock & Wilcox Company, Commercial Nuclear Fuel Plant requests amendment of SNM-1168 to accommodate changes in our organizational structure, to allow for routine localized operations involving pellets outside the controlled area, and to clarify certain sections in Section V involving ECHO 330 l
operations.
Attachment I to this letter explains the new organizational relationships and functions at the CNFP.
Attachment II to this letter describes the requested change involving pellets outside the controlled area and the justification for the change, j
Attachment III to this letter is a brief general description j
of the changes requested for the ECHO 330 operations.
i The following revised pages of SNM-1168 are included to incorporate the requested changes as described above.
All pages are dated 2-10-86 and are included as Attachment IV to this letter.
Section I:
Pages 3, 5,
7, 9, Appendix A - Pages 3, 4,
5, 9,
10 t
l Section III:
Pages 44, 110, 112, 115, 119, 120, (p
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United States Nuclear Regulatory Commission Page 2 February 10, 1986 Section IV:
Pages 1, 3 through 7, 10, 11, 12, 14, 21 through 31, 33 through 36, 39, 40, 43, Appendix 1 - Page 10 Section V:
Pages 6, 7,
8, 11 through 16, 18 through 21, 23, 28, 31, 42, 43, 49 through 59, 67 through 75.
Enclosed is a check for $150 to cover the initial administrative licensing fee.
If there are any questions, please feel free to call me at (804) 522-6202.
Sincerely, BABCOCK & WILCOX COMPANY COMMERCIAL NUCLEAR FUEL PLANT J.
P. Watters License & Control Administrator JPW:cmr cc:
W/O Attachments J. C.
Frost D.
W.
Zeff
ATTACHMENT I The CNFP is revising the organizational structure to improve our effectiveness in assuring the health and safety of our employees, compliance with NRC regulations, and to recognize a changing market environment.
The functions, titles, and personnel affected are as follows:
The Health-Safety function will report to the Manager of Quality Assurance, Mr. W. T. Engelke.
This structure will consolidate the control functions, and provide a larger resource base to assure adequate attention to personnel and public safety and compliance with regulations.
Mr. Engelke has held a variety of management assignments at the CNFP over the past 10 years.
In addition to his previous experience, he has been a member and active participant of the CNFP Safety Review Board for many years and is very knowledgeable of CNFP activities.
He has shown a keen recognition of the importance of implementing and maintaining effective control programs to assure the health and safety of employees and the need for compliance with NRC requirements.
Functionally, the Quality Assurance Manager will have full authority to act in the capacity of the currently-licensed function of Regulatory Control Manager in the areas of Health-Safety and Nuclear Safety, including procedure approval authority.
Mr. D. W. Zeff is returning to the CNFP as the Manager, Operations Support.
He will retain his previous role as Chairman of the Safety Review Board, assuring all new and revised operations receive proper attention prior to implementation, and will also be responsible for NRC licensing and computer activities.
Mr.
B.
W.
Pugh is the Manager, Production & Materials Control and will manage the Nuclear Materials Control function.
Mr. D. V.
Ferree is the Manager, Manufacturing and is responsible for all fuel and specialty manufceturing and manufacturing engineering at the CNFP.
Mr. Ferree has over 15 years experience in the nuclear industry in the QA and manufacturing areas.
The qualifications of the personnel listed above are included in resume form in Section I of SNM-1168.
The resumes indicate that these people have the essential qualifications to carry out the described license functions.
ATTACHMENT II Currently, the CNFP is performing a downloading operation for the fuel assemblies originally scheduled to be delivered to one of our customers.
This operation involves disassembly of each fuel bundle, and removal of one end cap and unloading of the scrap pellets into standard containers under local ventilation control.
The entire operation except for the actual removal of pellets from rods is performed in an uncontrolled area.
Airborne contamination limits for this area are presently defined by the table on Page 42 of Section V of SNM-ll68.
This table utilizes contamination controls based on percentages of 10 CFR 20 Appendix B, Table 2 (Environmental MPC limits).
The table on Page 42 indicates an exception for the end weld area such that no action is required as long as the quarterly average of the air effluent samples stay under 50% of environmental MPC.
This exception was approved by letter from R. G.
Page to D.
W.
Zeff dated 7-1-80.
Our application for this exception demonstrated that engineering efforts to keep the air effluent under 10% of environmental MPC at the end weld station was not achievable.
It was also demonstrated that contamination levels seen at the end weld area did not exceed uncontrolled area limits.
The CNFP is now faced with the same situation at the end cap removal station for the Midland download operation.
Air effluents for this operation have been on the order of 25% of environmental MPC.
We have exhausted all engineering efforts to keep the area under the 10% MPC criteria.
Based on our engineering efforts we have concluded that the most effective air-capture technique was selected for the end cap removal area.
We have performed extensive contamination surveys in the download area since this area has been in operation with the results distributed as shown in Tables 1 and 2 below.
TABLE 1 SMEAR SURVEY (REMOVABLE)(
2 CNFP CLEAN AREA LIMIT 200 DPM/100 cm RANGE (DPM/100 cm )
- OF SURVEYS 0 to 50 1108 51 to 100 164 101 -
200 59 (2)
> 200 1
TOTAL 1332
ATTACHMENT II TABLE 2 TOTAL SURVEY (FIXED & REMOVABLE) 2 CNFP CLEAN AREA LIMIT (500 DPM/50 cm )
RANGE (DPM/50 cm )
- OF SURVEYS 0 - 100 1207 200 51 300 31 400 41 500 0( }
600 1(4I 700 1
TOTAL 1332 Data from 8-14-85 through 10-lg-) 85 2
Localized area (281 DPMfl00 cm counted 45 DPM/100 cm after decon II 2
Localized area - counted 200 DPM/50 cm after decon (4) Localized area - counted 400 DPM/50 cm2 after decon Tables 1 and 2 clearly illustrate that there has not been a contamination problem in the download area.
Only 3 results out of 2664 yielded values that resulted in any decon activity and those instances were limited to the immediate work tables.
Floor contamination levels were all below clean area levels; therefore there is not a real potential for contamination spread.
We are therefore requesting that the end cap removal station be included with the end weld area on the table on Page 42 of Section V of SNM-ll68 to permit air effluent values of 50% of environmental MPC based on the engineering effort and on the actual contamination levels seen in the download area.
ATTACHMENT III Part 10 of Section V of SNM-ll68 pertains to the controls placed on the ECHO 330 reactor inspection equipment (by-product contamination).
In addition to incorporating the organizational changes, other changes are requested for clarity and to eliminate ambiguities and redundancies to other sections of SNM-ll68.
l l
G ATTACHMENT IV
BABC00( & WIL(DX C&PANY, CatERCIAL NUClfAR REL PIM USNRC LICENSE SNrt-ll68 DOCKET &l201 SECTIO 4 I - GENERAL IllFORMATION The Connercial Nuclear Fuel Plant has been established for the purpose of fabyicating fuel assemblies for commercial utility reactor cores.
10 CFR 70,22 (a)(1)
- 1) Name of Applicant Babcock & Wilcox Company Commercial Nuclear Fuel Plant
- 2) State of Incorporation Babcock & Wilcox is a segment of McDermott, Incorporated, and is organized and exists under the laws of the State of Delaware.
- 3) Addresses of Principal Offices Babcock & Wilcox Op'erating Unit, McDermott Incorporated 1010 Common Street P. 0. Box 60035 New Orleans, Louisiana 70160 Babcock & Wilcox Commercial Nuclear Fuel Plant P. O. Box 11646 Lynchburg, Virginia 24506-1646 DATE 2-10-86 REVISIO4 NO.
1 PAGE 3
CURRENT REVISION:
SUPERSEDES: PAGE 3
USNRC APPROVAL REFERENCE 2-27-81 0
DATE ggg
e BABC00( & WILC0X QNANY, C0WERCIAL NVQfAR REL PIAT USNRC LICENSE SNM-ll68 DOCKET &l201 I - GENERAL. INFORMATION SECTICN 10 CFR 70.22 (a)(4)
Name Low (4.05%) enriched uranium oxide Uranium as low enriched UF6 Uranium as natural UF6 Depleted or natural uranium oxide By-product material SNM as Pu and Cf sealed sources Amount This application requests authorization for:
235
- 25,000 Kg U in powder or pellet form
- 5,000 Kg U as enriched UF f r storage only 6
- 3,000,000 lbs. uranium as natural UF f r storage only 6
- 20,000 Kg depleted or natural uranium oxide as powder or pellets 235
- Up to 100 grams U in any form SJecifications
- Up to 51 ci by-product material as sealed sources
- By-product material in contamination quantities on returned, unirradiated fuel assemblies
- Up to 6 grams encapsulated plutonium
- Up to 3.0 mg Californium - 252 as sealed sources
- Up to 0.1 curies of by-product material as contamination ***
on equipment or as waste 10 CFR 70.22 (a)(6)
Technical qualifications, training, and experience are shown in Appendix A of this section.
Description of equipment and facilities to protect health and property is provided in Section III and IV.
Procedures to provide for protection of health and property due to accidental criticality are provided 1
5 DATE 2-10-86 REVISIO1 NO.
PAGE CURRENT REVISION:
S WEEEDES:
REN l 2 0
DATE REVISIQ1
BABQu( & WIL(DX CDPANY, GPPERCIAl. NlX1 EAR REL PLAVf USNRC LICENSE SNft-ll68 DOCKET E1201 I - GENERAL INFORMATION FIGURE 1 SECTICN
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PAGE 7
CURRENT REVISIQ1:
SUPERSEDES: PAGE 7
USNRC APPROVAL REFERENCE 1
DATE 5-04-84 REVISIQ1
BABOXX & WILCDX CTPANY, COMERCIAL NUCLEAR REL PIM USNRC LICENSE Stet-ll68 DOCKET D E l SECTIO 4 I - GENERAL INFORMATION FIGURE 3 C0mERCIAL NUCLEAR FUEL PLANT R. A. Alto Plant Manager OPERATIONS MANUFACTURING SPECIALTY QUALITY PRODUCTION AND SUPPORT UFACERING E URANE WRIALS CMTROL D. V. Ferree
- 0. W. Zeff Manager C. A. Moore W. T. Engelke B. W. Pugh Manager Manager Manager Manager SAFETY REVIEW BOARD
- The Safety Review Board Chairman is the Manager of ' Operations Support.
The permanent membership of the Board shall consist of representatives of CNFP operational and technical management.
1 DATE 2-10-86 REVISION NO.
3 PAGE 9
CLERENT REVISION
- SUPERSEDES: PAGE 9
USNRC APPROVAL REFERENCE 2
2-04-85 DATE REVISIQ1
PACOG( & WILWX C&PNh', CatERCIAL 1UCLEAR REL PLM USNRC LICENSE Snit-ll68 DOCKET 70-]201 I - GENERAL INFORMATION SECTIO 4 NAME:
David W. Zeff TITLE:
Manager, Operations Support CITIZEN OF UNITED STATES 1
EDUCATION:
1972 University of Wisconsin - B.S. Physics 1973 Purdue University - H.S. Indus. trial Administra-tion EXPERIENCE:
1973-1974 Planning analyst, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for capital appropriation requests, market analysis, acquisition analysis, advanced planning, P & L analysis, cash flow analysis, etc.
1974-1978 License Administrator, Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for licens-ing activities associated with nuclear fuel assembly plant, interpretation and applications of NRC regulations, measurement control pro-grams, and statistical methods application in Nuclear Materials Control.
1978-1982 Manager, Health-Safety and Licensing, Babcock and Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for all safety and licensing activities associated with nuclear fuel assembly plant.
1982-1983 Manager, Materials Management, Babcock and Uilcox Company, Conmercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for license administration, Safety Review Board, safeguards, and production control activities.
1983-1985 Manager, Materials & Facilities, Babcock and Wilcox Co., CtlFP, Lynchburg, Va. Responsible for all Regulatory Control activities includ-ing safety, licensing, compliance, safeguards, and nuclear materials control, plus production planning & control, and facility engineering functions.
DATE 2-10-86 REVISION NO, 2
PAGE 3 CURRENT REVISION:
SUPERSEDES: PAGE Appendix A, Page 3 USNRC APPROVAL REFERENCE 1
DATE C-04-84 ggy;3;ct; l
BABGXX & WIL(DX C&P##, CGtEIAL NUCLEAR REL PLKE USNRC LICENSE SNM-ll68 DOCKET D.l3 1 SECTIO 4 I - GENERAL INFORMATION EXPERIENCE:
1985-Present Present Manager, Operations Support at B&W's CNFP.
Responsible for Safety Review Board, NRC licensing, automation, and computer support.
Professional Organizations - Institute of Nuclear Materials***
Management DATE 2-10-86 REVISIO1 NO.
2 PAGE4 CURREffT REVISIQ4:
SUPERSEDES: PAGE Appendix A, Page 4 USNRC APPROVAL REFERENCE 1
5-04-84 ggygggg; DATE I
BABCDC< & WILCDX C&PA#, C0ftERCIAL,10 CLEAR REL PLAIT USNRC LICENSE SNft-ll68 DOCKER 70-1201 I - GENERAL INFORMATION SECTION NAME:
Donald V. Ferree TITLE:
Manager, Manufacturing CITIZEN OF UNITED STATES EDUCATION:
1967 Ohio State University - B.S. Physics 1972 University of Tennessee - M.S. Physics EXPERIENCE:
1967-1972 Associate Physicist, Union Carbide Corp.,
Nuclear Division, Y-12 Plant.
Responsible for R&D in NDE methods of UT, RT, and other radiation techniques.
1972-1974 Senior Research Engineer, B&W, LRC.
Respon-sible for R&D in NDE methods of UT and ET.
1974-1979 NDE Manager, QC Manager, QA Manager, B&W, Mt. Vernon Works.
Responsible for produc-tion NDE, dimensional inspection and all QA.
1979-1981 QC Manager, Pullman Std., Bessimer, Alabama, and Butler, Pennsylvania.
Responsible for all QC/QA in rail freight car plants.
1981-1982 Supervisory Engineer, B&W, NPD-SPIS.
Responsible for NDE at nuclear sites.
1982-1983 Nuclear QA Manager, B&W, UPGD.
Responsi ble for all nuclear QA for division.
1984-1985 Manager of Special Projects, B&W, CNFP.
Responsible for ASME Code QA Manuals and ECH0-330 development.
1985-Present Manager of Manufacturing, B&W, CNFP.
Responsible for all fuel and specialty manufacturing and manufacturing engineer-ing at the CNFP.
Professional Organization - ASME Appendia A DATE 2-10-86 REVISICf1 NO.
2 PAGE 5
CURRENT REVISICN:
SUPERSEEES: PAGE Appendix A, Page 5 p
DATE 5-04-84 1
P.EVISICt1
FABCDG( & WILCOX CCFPAif(, C0ftERCIAL NUClfAR FLEL PLA'lT USNRC LICENSE SNM-ll68 DOCKET 70.1201 SECTIO 4 I - GENERAL INFORMATION NAME:
Bobby W. Pugh TITLE:
Manager, Production & Materials Control CITIZEN OF UNITED STATES 1
EDUCATION:
1963 Phillips Business College - Data Processing EXPERIENCE:
1969-1970 Production Sponsor Jr., Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for requisiting and monitoring Contract Materials.
1970-1975 Production Sponsor, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for Materials Control Function.
1976-1983 Supervisor, Materials Control, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for Materials Control, Stores, and Shipping and Receiving Functions.
1983-1985 Manager, Special Projects, Babcock & Wilcox Company, Lynchburg, Virginia. Responsible for i
all special project activities.
1985-Present Manager, Production & Materials Control, Babcock &
Wilcox, Lynchburg, Virginia.
r l
Appendix A DATE 2-10-86 REVISICf1 NO.
2 PAGE 9 CURRENT REVISICN:
SUPERSEDES: PAGE Appendix A, Page 9 p
1 DATE 5-04-84 ggyrgier;
BABCOG( & WILCOX C0FPA#, CORERCIAL NUCLEAR FLEL PIM USNRC LICENSE SNM-ll60 DOCKET 70-1201 SECTIO 4 I-GENERAL INFORMATION NAME:
WilTred T. Engelke TITLE:
Manager, Quality Assurance CITIZEN OF UNITED STATES EDUCATION:
1959 University of Maryland - BSME EXPERIENCE:
1959-1960 Engineer, Reaction Motors Division, Denville, New Jersey, in design and test of solid and liquid rocket engines.
1960-1962 Engineer, Chrysler Missile Division, Huntsville, Alabama, involved in design and fabrication in heat transfer instrumentation for the saturn missile.
1962-1974 Research Engineer, Southern Research Institute, Birmingham, Alabama, performing heat transfer research and thernal characterization of materials.
Promoted to Head of Applied Thermal Section.
1974-1977 Engineering and Plant Manager, Tech Air Corporation, Atlanta, Georgia.
Involved in the development, design, installation, and operation of a pyrolysis waste neutralization process, supervised operational crew in development work and around the clock opera-tion of the unit.
{
1977-1985 Manager, Manufacturing Engineering, Babcock & Wilcox, Lynchburg, Virginia, managed the Manufacturing Engineering Section.
Responsible for process engi-necring, technical documentation issuance, qualifi-cation and development of manufacturing operations in the fabrication of nuclear fuel elements.
Al so managed Information Services Section, responsible for the computer data processing and information i
systems.
i 1985-Present Manager, Quality Assurance, Babcock & Uilcox, Lynchburg, Virginia. Manage Quality Assurance and Health and Safety Departments.
Responsible for functions of inspection, data evaluation, radiation and industrial safety.
ss+
Appenaix A DATE 2-10-A6 REVISICt1 NO. 2 PAGE 10 CURRENT REVISICN:
l.
SUPERSEDES: PAC-E Appendix A, Page 10 USNRC APPROVAL REFERENCE 5-04-84 1
DATE REVISICN
O BAB000( & WILOX C&PANY, C0WERCIAL NUQfAR F1EL PLM USNRC LICENSE Snit-ll68 DOCKET h.1201 III NUCLEAR SAFETY ANALYSIS SECTIO 1 7.4 Pelletizing 7.4.2.I _UO Powder Receipt (continued) 2 j
mt.
g 1
I l
3 l
4 5
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Contents of pc.ifer container;, 3 g/cc 1 3 da do do da ao 2
Inrlth-x nt v/o 4.0 do da do do do F/U.
0,6 0.G 0.6 7.24 7.24 7.24 Interspersed roderatic.s (:)
0 7,
100 0
7 100 Icif
.222 s.004
.G7G 1 0.012 0.535 1 0.010 0.9 3 0.011 1.013 2 0.011 0.025 2 0.01 The above results indicate that, except in the case where all available space in all the powder containers is filled with moderator and 7% interspersed moderation is present (Case 5), K-effectives are acceptable. The situation calculated in Case 5 is not credible due to powder pack-aging techniques and moderation controls established for the pelletizing area.
The limitation on the number of vertical containers in the sampling area is assured by physical sampling and conveying equipment limitations as well as by operator work area requirements.
Powder containers are visually inspected upon receipt.
Containers exhibiting damage that could bave resulted in violation of internal packaging are set aside on the
~
loading dock for Health-Safety ins'pection.
Upon Health-Safety determination that the container has not been breached so as to allow internal moderation the co.1-DATE 2-10-36 REVISIO1 NO.
2 PAGE 44 CURRENT REVISION:
SUPERSEDES: PAGE USNRC APPROVAL REFERENCE 5-04-84 DATE REVISIQ1 1
f MBC00( & WILG)X C&P#ff, 00WERCIAL NVQEAR REL PlMr USNRC LICENSE Snit-ll68 DOCKET & l201 III NUCLEAR SAFETY ANALYSIS SECTIOl 7.4 Pelletizing 7.4.4.4 Transfers Between Moderation Controlled Units (cont'd) ports, etc. Additionally, blind flanges, screw type caps, or other equally effective measures are utilized to provide secondary protection of penetrations into the blender and transport container at all times when such penetrations are not in use.
When empty, process equipment normally operated under moderation control limitations is maintained in a closed and sealed condition and is inspected prior to returning to use.
Gloveboxes or other effective enclosures are utilized as necessary to preclude external moderation of SNM where the unit itself does not provide the necessary protection (slug press) or where, such as in blender loading, the use of positive connections is not feasible. Where practicable, such e1 closures shall be of metal. When visibility or other operating requirements dictate their use, plastics or other hood materials are of fire resistant construction (chlorinated PVC or equivalent).
7.4.4.5 Admininistrative Controls and Procedures Approved Health-Safety and process procedures DATE 2-10-36 REVISIQ1 NO.
2 PAGE 110 CURRENT REVISION:
SUPERSEDES: PAGE 110 USNRC APPROVAL REFERENCE 5-04-84 1
MTE REVISIQ1
BAB000( & WILG)X C&PANY, COPPERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET & l201 III NUCLEAR SAFETY ANALYSIS SECTION 7.k Pelletizing 7.4.4.6 Moderation Control Measurements (continued)
OPERATOR QUALIFICATION Personnel responsible for measuring moisture content of UO will be trained in equipment operation and 2
result interpretation.
Such training will include practical use of the instrumentation and satisfactory analysis of unknown samples. Operation of moisture analysis units will be limited to authorized personnel. Authorized operators will be determined by the area supervisor.
PROCEDURES AND CHECK LISTS Specific procedures covering the use of moisture analysis equipment, approved by Health-Safety, will be maintained at the work station.
Additionally, the actual process is conducted in accord with a
" check-list" indicating the operational sequence, development of analytical data, and the operator performing the analysis.
Points where " standard samples" are analyzed and the action to be taken in the event of an unsatisfactory standard result are indicated.
2-10-86 112 DATE REVISION NO.
2 PAGE j
CURRENT REVISION:
l SUPERSEDES: PAGE 112 (ENRC APPROVAL REFERENCE 5-04-84 DATE REVISION
BABOXX & WIL(DX C&PANY, 00lfERCIAL NUCLEAR REL PLAY USNRC LICENSE St#t-ll68 DOCKET 70-1201 III NUCLEAR SAFETY ANALYSIS SECTION 7.4 Pelletizing 7.4.4.7 Administrative Controls (continued) 1.
those in the process which require dual signature:
- Initial moisture analysis of as-received powder
- Prior to oddition of powder lubricant to blender or transport container
- Prior to addition of re-cycle material to a moderation controlled unit, if the ma-terial has been exposed to an uncontrolled environment.
Adherence to the above procedure will be audited by Health-Safety at least monthly.
2.
The addition of powder lubricants to the blender or transport container has been shown to be safe under credible accident conditions.
However, in order to further preclude the potential for double batening of lubricant, or of adding lubricant to a system where the existing H/V is such that the additional rroderator would cause the system to exceed the 0.45 H/U license specification, administrative controls are established for the receipt, storage, and DATE 2-10-2 2
REVISION NO.
PAGE 115 CURRENT REVISION:
SUPERSEDES: PAGE 115 USNRC APPROVAL REFERENCE DATE 5-04-84 1
REVISIQ1
BABOXX & WIL(DX CGPANY, CutERCIAL NUGEAR REL PLM WNRC LICENSE SNPt-ll68 DOCKET A1201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing
.7.4.4.8 General Area Moderation Control Criteria (continued)
In the event it becomes necessary to utilize " wet" decontamination techniques on a moderation controlled uni ts, Health-Safety shall inspect and certify that visible moisture is not present before the unit is returned to service.
FIRE FIGHTING Specific procedures relative to fire fighting will be instituted and will include, as a minimum, the following considerations:
A.
Fire fighting capability will be based on the use of C0, "Halon" or other non-hydrogeneous 2
agents.
B.
The CNFP Fire Brigade will be informed of area restrictions and will receive training in the techniques to be utilized.
C.
All fire fighting efforts will be conducted under the direction of qualified members of the plant management.
D.
Accumulation of flammables will be limited to the greatest practical extent.
2-10-36 DATE REVISIO4 NO.
2 PAGE 119 CURRENT REVISIQ4:
SUPERSEDES: PAGE ll9 WNRC APPROVAL REFERENCE DATE 5-04-84 I
REVISIQ4 l
I BABC00( & WILG)X C&PANY, QMERCIAL NUCLEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET E 1201 SECTIOg III NUCLEAR SAFETY ANALYSIS 7.4 Pelletizing 7.4.4.8 General Area Moderation Control (continued)
FIRE FIGHTING E.
The area contains no source of generalized mo-deration such as sprinkler systems, or steam lines.
Flammable wastes will be stored only in metal containers approved by Health-Safety.
WATER LINES Figure l shows the placement of water lines in the p'elletizing area relative to moderation-controlled and other major equipment positions. Water lines are, except where necessary to service equipment, located against (e.g., m 1 foot) the outer building walls approximately 20 feet above the floor and are secured in place by means of steel brackets.
For purposes of industrial safety, and to limit the potential for accidental damage, the water lines necessary for furnace and grinder operation are po-sitioned above head height until the unit to be serviced is reached.
The typical baffling technique for service lines positioned along the plant walls is represented DATE 2-10-86 REVISIO1 NO.
2 PAGE 120 CURRENT REVISION:
SUPERSEmS: PAGE 120 USNRC APPROVAL REFERENCE DATE 5-04-84 1
REVISIQ1
BABC00( & WILWX C&PANY, CultERCIAL NUClfAR REL PLAE
~ t USNRC LICENSE SNPt-ll68 DOCKET 70-1201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing 7.4.4.8 Unit Area Moderation Control (continued)
WATER LINES directly over moderation controlled units or arrays, the overhead shielding essentially serves as a tech-nique for providing "second order" protection.
The shielding is not required to protect the array from accidental moderation due to pipe rupture since that contingency has been provided for through baffling and double containment.
PERIODIC EVALUATION OF MODERATION CONTROL l
EQUIPMENT The routine calibration and standards analysis pro-gram for moderation control instrumentation has been described previously. While safety within an operational area is the responsibility of the area supervisor, Health-Safety conducts routine system audits to verify that all activities are conducted safely and in accord with license conditions.
Additional nuclear s&fety and health physics audits are conducted by qualified B&W personnel, from outside the CNFP, at least quarterly.
At least monthly, a detailed inspection will be con-ducted by Heal th-Safety, DATE 2-10-86 REVISIO4 NO.
2 PAGE 124 CURRENT REVISION:
SUPERSEDES: PAGE 124 USNRC APPROVAL REFERENCE DATE 5-04-84 I
REVISlai
A BAB000( & WIL(DX C&P#ff, CufERCIAL NUQEAR REL PLAR USNRC LI NSE SNM-ll68 DOCKET E1201 III NUCLEAR SAFETY ANALYSIS SECTICN 7.4 Pelletizing 7.4.5.1 FIRE. The following measures are applied to minimize the fire potential and to assure localized containment in the event a fire does occur.
1.
Hoods, gloveboxes, and other containment devices are constructed of fire resistant materials ("Self-extinguishing " Plexiglas" conforming to ASTMD 635,"
or equivalent) with metal supporting members.
2.
Pre-filters and HEPA units are the fire resistant metal case type.
Additionally, supporting units and manifolds are of flame resistant construction.
Breaching of the ventilation system is not credible due to the limited flammable material available.
3.
Accumulations of flammable wastes and scrap are removed from the area promptly when containers are filled.
Only co/ered fire-safe containers approved by Health-Safety are utilized for tile accumulation of flammable wastes in the pelletizing area.
4.
Limited quantities of flammable solvents may be required for operation.
These materials are DATE 2-10-86 REVISION NO.
2 PAGE 129 CURRENT REVISION:
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DATE 5-04-84 REVISIQi
BABOXX & WIL(DX CTPANY, (INERCIAL NUCifAR REL PlM USNRC LICENSE SNM-ll68 DOCKET & l201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing 7.4.5.1 FIRE.
6.
While Brigade members are cognizant of the radiological and nuclear safety limitations that may be imposed, any major fire fighting activity would be conducted under the direction of responsi-ble plant management (e.g., except 1st aid measures).
Brigade members receive semi-annual training by representatives of Health-Safety as appropriate to the subject matter.
7.
Formal weekly inspections are conducted by Heal th- ***
Safety to monitor the effectiveness of, and ad-herence to, the fire prevention program.
8.
Response arrangements have been made with the Con-cord Volunteer Fire Department.
The Lynchburg Fire Department and the Concord Volunteer Fire Department have toured the CNFP facilities and have been made aware of special hazards that may be encountered.
Retraining is conducted on an annual basis.
Based on the above considerations, as well as the limited potential for fire within the process itself, it is felt that fires represent only a limited accident potential.
The most likely hazard will consist of DATE 2-10-E6 REVISIOJ NO.
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DATE 5-04-84 REVISIQ1
BAB000( & WIL(DX C&PANY, CutERCIAL NU0fAR REL PIM USNRC UCENSE Stet-ll68 DOCKER 70-1201 SECTIOi 7.14 Waste Storage 7.14.2 Nuclear Safety Parameters The safety of both 850 grams of U-235, and the 4.0" slab has been demonstrated elsewhere.
7.15 Self-Explanatory.
7.16 Transport 7.16.1 Such transport occurs only during the course of manufacturing activities, at which times abnormal levels of moderation are not present, interaction with other materials need not be considered.
7.17 1JF Storage 6
7.17.1 Storage Parameters - Source and Special fluclear Material The UF, as received for storage only, will be in solid form 6
and stored in cylinders that are approved for shipment.
The cylinders will be stored outside, in an area designated for UF storage within the CNFP security ' fence. The cylinders will 6
be stored on timbers designed to cradle and give support, in an area prepared and maintained under weed control, and located a minimum of 100 ft. from the paved driveway which circles the CNFP.
The cylinders will be equipped with valve protectors, and wii1 be routinely monitored by Health-Safety personnel to detect leakaga and to assure the continued adequacy of storage conditions.
Outside storage of enriched UF cylinders has been 6
previously determined to have no adverse environmental impact (Reference 1).
Reference 1: BAW-1412, Annex 1; UF to UO Conversion Facility.
6 2
DATE 2-10-86 REVISIO4 NO.
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BABC00( & WILOR COPANY, CutERCIAL NUCLEAR REL PLM USNRC LICENSE SNPt-ll68 DOC!ET D1201 IV HEALTH PHYSICS SECTIO 4
- 1. '
INTRODUCTION This section presents the health physics program which is adminstered at the Conmercial Nuclear Fuel Plant of the Babcock & Wilcox Company to assure safe operating conditions.
The information provided in this section is intended to demonstrate typical inethods utilized in the health physics and, to some extent, in the industrial safety programs and, as such, is subject to change in detail, or in the application of alternate methods.
Program effectiveness will not be reduced as a result of changes instituted by plant management. Technical specifica-tions defining the parameters which the health physics program must meet are contained in Section V.
2.
POLICY Operations involving exposure, or potential exposure, to radioactive materials will be performed in a manner which will assure the radiation safety of employees and the general public.
This policy is implemented by maintaining a staff of qualified personnel and appropriate equip-ment, procedures, and records.
Operations will be conducted in accordance with applicable Federal, State, and Local requirements.
Exposures to radioactive materials, or other hazards, will be maintained as low as reasonably achieva' le. The Health-Safety component has authority o
to stop hazardous or potentially hazardous operations until correction or resolution by plant management is obtained.
DATE 2-10-86 REVISIO4 NO.
2 PAGE 1 CURRENT REVISION:
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USNRC APPROVAL REFERENCE 5-04-84 1
DATE REVISIQ1
i BAB000( & WILGA COPANY, C0ltERCIAL NUCLEAR REL PIM USNRC LI NSE Snit-ll68 DOCKET D E l IV HEALTH PHYSICS SECTION 3.3 Detailed operating procedures are developed by Health-Safety to assure standardization, accuracy, and effectiveness of activities performed by Heal th-Safety.
Procedures are reviewed periodically and revised as required.
As a minimum, Health-Safety procedures shall be approved in writing i*j cy the Manager, Quality Assurance as well as approval by affected l
members of plant management.
~
4.
RESPONSIBILITIES The Health-Safety component reports airectly to tne Nanager, Quality
- \\ssurance who reports directly to the Plant fianager of the Commerci:1 Nuclear Fuel Plant.
4.1 Health-Safety Function Health-Safety personnel are responsible for the general surveil-lance of all activities involving radioactive materials, distributing and processing personnel monitoring equipment, maintaining in-dividual exposure records, notifying supervisors of significant exposure levels, and recommending appropriate restrictions.
Other responsibilities are represented by, but not limited to, the following:
a.
Maintaining appropriate radiological and regulatory control of radioactive material, shipments, and receipts.
b.
Supervising and coordinating the contaminated waste disposal program.
c.
Assisting in personnel and equipment decontamination.
2 DATE 2-10-86 REVISIO4 NO.
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DATE REVISIQ1
BAB000( & WILCDX COPANY, CRPERCIAL NUCLEAR REL PIAT USNRC LICENSE SNPt-ll68 DOCKET E 1201 SECTION 4.1 d.
Orienting and training CNFP personnel in radiological and nuclear safety.
e.
Furnishing consulting services and advice on radiation protection to plant supervi:: ion and management.
f.
Generating or acquiring, maintaining, and appropriately distributing all records and reports required by appli-cable regulations or procedures.
g.
Leak testing on sealed radioactive sources.
h.
Developing and disseminating procedures related to radiation safety and reviewing procedures prepared by other operating sections for regulatory compliance and the adequacy of safety considerations.
4.2 Employees Since every unnecessary exposure to radiation violates sound Health Physics practice, each CNFP employee is responsible for the following:
a.
Following all established Health-Safety procedures.
b.
Seeing that any visitor in his company or custody observes all established Health-Safety procedures.
c.
Reporting any radiation hazard or potential hazard to his super-v!sor or to a Health-Safety representative.
d.
Minimizing radiation exposure, and assisting in the evaluation of exposure of himself and others to the DATE 2-10-86 RWISION NO.
2 4
PAGE CURRENT REVIS104:
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USNRC APPROVAL REFERENCE 5-04-84 1
DATE pggggg;
BABQXX & WIIEX QNANY, C0tERCIAL NVQEAR REL PLM
~
USNRC LICENSE Snit-ll68 DOCKET M-1201 IV HEALTH PHYSICS SECTICN 4.2 d.
extent possible by:
- Wearing prescribed monitoring and protective equipment.
- Surveying hands, shoes, and body for radioactivity and removing loose contamination to prescribed tolerance levels to comply with approved decontamination procedures.
- Wearing appropriate protective clothing whenever contami-nation of clothing is possible, and not wearing such clothing outside prescribed areas.
- Using recommended safety equipment; using proper techniques and facilities in operations.
- Observing regulations governing eating and smoking in contaminated areas.
- Promptly reporting injuries and suspected or known in-gestion or inhalation incidents to Heal th-Safety.
- Cooperating in all attempts to evaluate exposures.
- Roping off hazardous areas, controlling potential hazards, and reporting contamination to his supervisor.
- Cleaning up contamination for which he is responsible.
- Properly storing and labeling radioactive materials for which he is responsible.
- Being familiar with the evacuation plan and evacuation route.
4.3 Supervisors Each supervisor is responsible for ensuring that the individual 5
DATE 2-10-86 REVISION NO.
PAGE CURRENT REVISION:
SUPERSEDES: PAGE USNRC APPROVAL REFERENCE 5-04-84 DATE REVISION
BABC00( & WIUDX C&PANY, C0ltERCIAL NUCLEAR REL PLMT USNRC LICENSE SNM-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTIOi 4.3 responsibilities listed previously are discharged by persons under his control and is also responsible for the following:
1.
Acting in conjunction with Health-Safety to keep his em-ployees' exposure below 300 mrem in 1 week and keeping the average weekly exposure below 1.25 Rem /13 weeks (See 10 CFR, Part 20).
2.
Furnishing information to Health-Safety on individuals and activities in his area, particularly additions to or deletions from, his personnel roster.
3.
Contacting Health-Safety whenever major changes in operational procedures, new techniques, or new operations are anticipated.
5.
OPERATIONAL EVALUATION Radiation safety evaluations will be made for new operations, or those
. operations undergoing significant revisions or redesign.
These evalua-tions will also consider industrial and nuclear safety as appropriate.
Pre-operational evaluation may consider, but is not limited to, such items as%entilation control, external exposure potential, license compliance, contaminated waste generation and control, and special protective measures that may be required.
Results of the evaluation will be reviewed with cognizant area supervision and any necessary changes will be made prior to approval for operational startup.
In addition, the evaluation results will be documented and maintained i
on file in the Health Physics Office for at least six months after termination of the operation.
DATE 2-10-06 REVISION NO.
2 PAGE 6
CURREt(T REVISION:
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l
BABC0(X & WIL(DX C&PANY, COMERCIAL NUClfAR REL PLAVf USNRC LICENSE SNPt-ll68 DOCKET D E l SECTION IV HEALTH PHYSICS 6.
RADIATION SAFETY EQUIPMENT Instrumentation, appropriate to the detection, monitoring, and measure-ment of industrial and radiological safety hazards potentially encountered in a nuclear fuel plant, will be maintained by Heal th-Safety.
6.1 A list of radiation detection and miscellaneous instrumentation is given below.
These instruments are typical of those which are available for use at the CNFP.
Equivalent substitutes, or additions, will be accuired as necessary.
a.
Alpha survey and monitoring
- PAC-4G (0 - 500K CPM 2x)
- Alarming Hand Monitor (50 CPM 2n) b.
Low Range s/y survey - Eberline E-120 (0 - 50 mR/hr.)
- Eberline E-530 (0 - 200 mR/hr.)
c.
Intermediate Range y survey - Eberline " Red Owl" R0-2A (0 - 50 R/hr.)
d.
High Range y - Victoreen Radector II (0 - 1000 R/hr.)
e.
Laboratory =/8/y Measurement - NMC Proportional system, DSIT/
PC11T
- Ludlum scintallation system, Model 20-A
- Multi-channel analysis capabilities, alpha spectrometers, etc., are available at other B&W facilities.
f.
Miscellaneous
- Positive displacement, low flow rate sampling pumps
- HG-70 and " Glass fiber" filter papers
- Sound level meter, Pulsar, Model 85 DATE 2-10-86 REVISIQ1 NO, PAGE 7 CURRENT REVISION:
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USNRC APPROVAL REFERENCE DATE 5-04-84 1
REVISIQ1
BAB000( & WILCDX C&PANY, C0lfERCIAL NUCifAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTION 7.1 CNFP procedures require that Health-Safety be notified before maintenance or other non-routine operations are undertaken if significant airborne activity may result.
Data collected by work station or other fixed samples is supported, and modified if necessary, based on lapel sample results.
Lapel sample collection frequency is determined by Health-Safety based on verification requirements and the nature of the operation being conducted.
7.2 Smear surveys to evaluate surface contamination levels are con-ducted throughout the plant on a regular schedule.
Routine survey frequency varies from daily to monthly depending on contamination potential or potential hazard category.
Portable instruments used concurrently with smear surveys provide a means of assessing total surface contamination.
In addition, special smear programs are instituted as considered necessary by Health-Safety to provide in-depth coverage of special or unusual activities and to evaluate the effectiveness of decontamination.
Material being transferred from a " contaminated" to a " clean" area is routinely monitored for surface contamination.
7.3 External (" penetrating") radiation levels throughout the plant are monitored using a combination of portable instruments and TLD area dosimeters.
DATE 2-10-86 REVISION NO.
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BABC00( & WIL(DX CTPANY, CTPERCIAL NUCLEAR REL PLKK USNRC LICENSE SNM-ll68 DOCKER E3201 SECTIG4 IV HEALTH PHYSICS 8.
PERSONNEL DOSIMETRY AND EXp0SURE CONTROL 8.1 Personnel monitoring devices are selected by Health-Safety on the basis of radiation type and sensitivity requirements, and' may include film, TLD, or pocket chambers.
Rapid dosimetric evalua-tion of neutron exposure in the event of accidental criticality is provided by indium foil issued to personnel as part of their standard dosimetric package.
Dosimeters are issued to all plant employees and selected visitors based on the requirements of 10 CFR 20, with routine monthly or quarterly exchanges.
Use of special dosimeters may be required by Health-Safety where unusual exposure levels may be encountered, as in source manipulation. An indica-tion of 100 mR/or more on a pocket chamber requires the expeditious evaluation of the employee's TLD or film.
Extremity exposure is monitored using TLD's as determined necessary by the Health Physicist.**-
TLD and film dosimeters are oro-cessed by a veno)r with monthly or quarterly printout forwarded to CNFP.
More rapid notification is available by teleptione if needed.
Personnel involved in activities where exposure to airborne activity is possible participate in a bio-assay program con-ducted in accord with Regulatory Guide 8.11 (" Applications of Bioassay for Urar.ium").
Operating philosophy is that the air sampling program, supported by the smear surveys, provides 2-10-86 2
DATE REVISIG1 NO.
PAGE 11 CURREfff REVISIG4:
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BABC0CK & WILGR C&PANY, CutERCIAL NUCLEAR REL PLANT USNRC LICENSE SNPt-ll68 DOCKET h l201 SECTIQ4 8.1 definitive indications of personnel exposure.
Bioassay techniques, including urinalysis and in-vivo counting serve to validate the effectiveness of existing exposure controls. A " Base-Line" bioassay (urine) sample is collected from all new hires and from terminating personnel with an exposure history.
In addition, newly hired employees whose job assignments involve handling of significant quantities of unclad SNM are scheduled for in-vivo analysis as required.
In-vivo and urinalysis services are provided by a vendor.
Fecal sampling may be employeed, as considered necessary by the Health Physicist to evaluate the magnitude of suspected accidental or elevated exposure.
8.2 Radiation exposure and absorbed dose to employees are derived based on dosimetric results and in accord with 10 CFR 20.
Normal operational doses accrued by CNFP employees are limited to the following (10 CFR 20.101)
- Whole Body, trunk and head, active blood forming organs, lens of eyes, and gonads 1.25 Rem / cal. qtr.
- Hands and forearms, feet and ankles 18.75 Rem / cal. qtr.
- Skin of whole body 7.50 Rem / cal. gtr.
However, NRC Form 4 documentation is provided for each permanent employee and in specific cases the Manager, Quality Assurance, Health Physicist, and the Plant Manager may autnorize ex-posures greater than the above provided 10 CFR 20.101 (b) and 20.102 l
requirements are satisfied. In *.hese cases, the " maximum permissible exposure" 2
DATE 2 M REVISIOJ NO.
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REVISIQ1
BABC00( & WIL(DX C&PANY, CutERCIAL NUQfAR REL PUNT USNRC LICENSE Snit-ll68 DOCKET $- E l SECTIQJ IV HEALTH PHYSICS 8.6 Eating and smoking are prohibited in controlled areas. Smoking may be permitted in change rooms if assurance of adequate radiological hygiene practices are maintained. At the discre-tion of the Health Physicist drinking fountains may be located within controlled areas where non-transportable materials are being processed.
Drinking facilities are provided in change areas.
8.7 Exposure histories at CNFP for the period 1977-1980 are shown in Figure 1 below.
Data show normal fluctuations from period to period, without significant discernable trends.
FIGURE 1 x
H urs/Qtr. for an InMoual E pres 1
wable 5 rem /yr., wnole body exposure, except as otherwise noted)
(Expressed as % of maximum allowable 520 MPC Hours /Qtr.)
N ar 1977 1978 1979 1980 Year 1979 1980 Area t
and 4.9%
3.7%
4.7%
4.2%
1st Qtr.
17.2%
20.3%
g
- Internal % of maximum 2080 4.9%
3.2%
4.3%
4.4%
2nd Qtr.
18.6%
17.6%
MPC hrs./yr.
Rod Processing 3rd Qtr.
14.0%
15.8%
Assembly Fabri-2.6%
2.3%
4.2%
4.4%
4th Qtr.
17.2%
11.2%
f "f'"g "py,' #Id' 3
O.5%
0.3%
1.1%
1.2%
p Office 0.1%
<0.1%
0.1%
0.1%
DATE 2-10-06 REVISIQ1 NO.
2 PAGE 14 CURRENT REVISIQ4:
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REVISIQ1 1
BAB000( & WILQX C&P#f(, CutERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET D E l SECTIO 4 IV HEALTH PHYSICS 9.1 filters (in series) before re-entering the area. Air recirculated to the pelletizing area is representatively sampled on a continuous basis to verify filter effectiveness.
Existing procedures require notification of Health-Safety prior to servicing or maintenance on those portions of the fans or HEPA systems that may be contaminated.
Flow sensing elements are installed within ductwork at appropriate locations to provide an audible and visual alarm if flow is interrupted.
If flow loss is other than a momentary disrup' tion, operations may be terminated until proper ventilation is restored.
Additionally, pressure sensing devices are routinely monitored to assure that the controlled area remains negative with respect to the remainder of the plant.
10.
LIOUID EFFLUENT CONTROL Potentially contaminated liquids generated at the CNFP are controlled by means of a dedicated drain and retention tank system.
Sani tary wastes, and waste originating in areas where there is no potential for radiological or chemical contamination, are routed to a sewage treat-ment plant through separate piping.
Liquids originating in the con-trolled area, analytical labs, de-ionizer area and " cleaning room" are part of the retention tank system.
Liquids accumulated in the retention tanks are sampled, radiometrically 21 DATE 2-10-E6 REVISIQ1 NO.
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BABC00( & WII.fDX CTPANY, C&PERCIAL NUCifAR REL PLM USNRC LICENSE SNrt-ll68 DOCKET M - E l SECTIQ4 10'.
LIQUID EFFLUENT CONTROL analyzed, and treated as necessary, prior to release. The retention tank system incorporates capacity alarms, and air agitation capability.
Analytical sensitivity is 1% of the applicable 10 CFR 20, Appendix B, Table II limit. The sampling program is under the control of Health-Safety and no releases are made without the. prior approval of that component *.**
T.he retention tanks are housed in the Rad Waste Retention Building.
11.
SOLID WASTE DISPOSAL Non-contaminated solid wastes are disposed of through a contract hauler.
Contaminated solid wastes are sent to another licensed facility for processing or to a licensed burial facility.
Uncontrolled disposal of solid wastes or equipment is authorized when 2
contamination levels do not exceed an average of 2500 dpm/50 cm and a 2
2 maximum of 7500 dpm/50 cm for total alpha; 1000 dpm/100 cm maximum for removable alpha; or an average of 0.2 mradAr. and a maximum of 1 mr/hr.
(6/y) at 1 cm.
Establishment of the above contamination limits to permit disposal in accord with routine industrial practice does not present a hazard to the general public and the limits are generally accepted, within the nuclear industry, as not presenting any significant radiolo-gical or nuclear safety hazard. 49 CFR 173.397(a) cites removable contamination levels below 2,200 CPM /100 cm as being insignificant when applied to natural or depleted uranium. Although uranium enriched 235 up to 4.05% will be the contaminant of interest, the low U content DATE 2-10-86 REVISIQ1 NO.
2 PAGE 22 CURRENT REVISIQl:
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BABOXX & WIL(DX C&PANY, CutERCIAL NUCEAR REL PIM USNRC LICENSE SNWll68 DOCKET E1201 SECTIQ4 IV HEALTH PHYSICS
- 11. SOLID WASTE DISPOSAL is not significant in the present case for radiological safety purposes and is treated as natural uranium.
Additionally, 49 CFR 173.391(a) notes that the allowable sh exposure rate is 0.5 mrem / hour for exempt shipments.
Solid waste material, when the radioactive component is distributed throughout the non-radioactive matrix, is not considered radioactive when the specific activity does not exceed 0.002 microcuries per gram (49 CFR 173.389).
Routine sampling and monitoring programs are conducted by Heal th-Safety to assure that material, contaminated in excess of specification limits, is not released for uncontrolled disposal and to detect and alleviate increasing contamination trends.
11.2 Contaminated solid wastes consist primarily of low specific activity material and are disposed of a by a licensed contractor by land burial on an NRC or state licensed site.
LSA wastes are packaged in containers designed to retain loose contamination.
SNM content for each package is estimated using gamma scan or sampling technique.
12.
RESPIRATORY PROTECTION A supply of respirators, equipped with high efficiency filters, is maintained for use in unusual conditions where airborne concentrations are such that personnel may receive exposures in excess of acceptable DATE REVISIQ1 NO.
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A BABC00( & WILCDX CTPANY, COMERCIAL NUCLEAR REL PLAU USNRC LICENSE SNPt-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTION 12.
RESPIRATORY PROTECTION limits.
All respiratory devices for protection against radioactive materials are approved by the NIOSH or other authorized governmental authority.
Respiratory devices giving effective protection against acid gases, chlorine, ammonia, and other toxic substances as well as particulate are available, based on the specific requirement; imposed by plant activities. Self-contained breathing units of the "back pack",
pressure demand type, are provided for emergency use.
Examples of operations for which respiratory protection may be determined to be necessary by Health-Safety include certain mainte-
- *v nance activities such as filter changes and to provide an additional safety factor during the initial start-up of operations where the extent of airborne contamination cannot be evaluated accurately during the pre-operational check.
Respirators are not used as a routine protective measure or as a substitute for engineered controls..
12.1 All respiratory devices, used for protection against toxic substances, as opposed to those used for " nuisance control" (paint spraying, etc.) are maintained, issued, and use-monitored by Heal th-Safety.
Healtn-5atety also determines the type of respirator to be used in a particular situation.
Each individual who is required to wear a respirator, for toxic substance protection, is trained by Health-Safety in proper use and fitting including:
DATE 2-10-86 REVISIOJ NO.
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DATE 5-04-84 REVISIQ1
BABC00( a WILG)X C&P#ff, COMERCIAL NUCLEAR REL PLM USNRC UCENSE SNPt-ll68 DOCKET h.1201 SECTim IV HEALTH PHYSICS 12.1 a.
Advise that the user may leave the area in case of malfunction and psychological or significant physical discomfort.
b.
Proper method of fitting and use (wearing) of the respirator.
The initial fitting of a respirator on an individual will be conducted by Health-Safety during the training program and the fit checked by. smoke or an equivalent method.
Procedures relating to respirator use, training, and maintenance are in effect.
Respirator maintenance is performed by Health-Safety based on manufacturer's recommendations.
Routine inspections are conducted by Health-Safety to evaluate operability, check for deteriora-tion, and to remove outdated components from stock.
Outdated can-nisters, etc., may be used for training purposes; however, they will be identified so as to prevent use in a situation where protection is required.
Air sample coverage is provided during all activities where the use of respirators is required.
Special bioassay evaluations are undertaken if justified in the opinion of the Health Physicist in order to define the respirator effectiveness.
12.2 Protection factors for respirators currently available at the DATE 2-10-86 REVISION NO.
2 PAGE 25 CLERENT REVISION:
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DATE 5-04-84 REVISION
BABOXX & WILQ)X C0HNY, CatERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET &l201 IV HEALTH PHYSICS SECTICN 12.2 CNFP, are defined below:
a.
Half-mask facepiece, negative pressure - 10 b.
Full face piece, negative pressure 50 Full face powered air purifier - 1000 c.
Self-contained breathing apparatus full face (pressure demand) -
d.
1000 13.
ANTICONTAMINATION PROGRAM Means for the limitation of personnel contamination in controlled areas and the spread, by personnel, of contamination from controlled areas are defined by Health-Safety procedures and plant design criteria.
All persons entering contaminated areas are required to wear pro-tective clothing.
Minimum protective clothing consists of shoe cover *:
and lab coats. Additional protection in the form of coveralls, hair covers, etc., is required, where necessary, (e.g., pelletizing area).
Anti-contamination clothing is identified to assure that is not worn in " clean" areas without. Heal th-Safety approval.
~
Change room facilities are provided at all entrances to controlled areas, the sole exception being emergency exits, and controlled access points, not used on a routine basis.
The change rooms contain facilities for protective and personal clothing storage and decontamination.
" Controlled" showers are available for whole body decontamination.
Fixed alpha monitors are installed in all change rooms.
Instructions for the use of these monitors and the decontami-nation procedures to be followed are posted with the instrument.
DATE 7-10-86 REVIS!O1 NO.
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BABC00( & WILCDX C&PANY, C0ltERCIAL NtX1 EAR REL PIM USNRC LICENSE SNft-ll68 DOCKER 70-1201 IV HEALTH PHYSICS SECTIQ4
- 13. ANTICONTAMINATION PROGRAM In the event an employee cannot reach satisfactorily low contamination levels after two attempts he is instructed to contact Health-Safety for further evaluation. A personnel decontamination kit is maintained in the First Aid Room.
Section V, Part 8.4 specifies action levels for surface alpha contamina-tion on personnel and equipment.
Entrance to the controlled area is demarcated by means of easily visible stepoff lines.
Instructions for proper use of the change room facility are posted by Health-Safety as appropriate. Normal access to the con-trolled area is limited to the change room, and the layout of the change room itself is such that individuals exiting the contaminated area must pass the decontamination and monitoring points.
Tools and other equipment routinely used within the controlled area are conspicuously marked and are not normally removed from the area. If removal is necessary, decontamination to the levels specified in-Section V, Part 8.4 is undertaken.
If decontamination attempts are not successful, specific Health-Safety approval must be obtained prior to removal, and additional controls instituted as necessary.
Where tools or equipment have been exposed to high contamination levels such as may be found inside process units, the items will be decontani-nated as soon as practicable, or will be packaged and labeled if prompt cleanup is not feasible.
All such equipment will be decontaminated prior DATE 2-10-86 REVISIQ1 NO.
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BAB000( & WILG)X COMNY, CatERCIAL NUCLEAR REL PLAVf USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECT!ad IV HEALTH PHYSICS
- 13. ANTICONTAMINATION PROGRAM to removal from the controlled area unless the item is intended for disposal as radioactive waste and is properly packaged to prevent contamination spread.
- 14. MEDICAL AND FIRST AID PROGRAM Medical examinations of employees are performed as consistent with good industrial practice.
All employees receive a thorough pre-employment physical including kidney function, hematological evaluation, and chest x-ray.
Examinations upon termination of employment will be made when considered appropriate by plant management.
Babcock & Wilcox has retained the services.of a number of area physicians to assure adequate representation of various medical specialties as appropriate.
The CNFP maintains a fully equipped First Aid Room staffed by oersonnel qualified in first aid.
Additional plant
~
~
personnel receive Red Cross (or equivalent) training to assure that first aid capability is always available.
Registered nurse and ambulance services are available on site from another B&W facility.
15.
PERSONNEL TRAINING All personnel receive basic training in radiological, industrial, and nuclear safety upon being hired.
This initial training is a coopera-tive effort involving Personnel, Health-Safety, and the employee's supervisor and is designed to satisfy the requirements of 10 CFR 19.12.
DATE 2 36 REVISIO1 NO.
2 PAGE 28 CURREf6 REVISION:
SUPERSEDES: PAGE 28 Pm Emn 5-04-84 DATE REVIStal
BABOXX & WILCOX C&PANY, COWERCIAL NUCLEAR REL PLAT USNRC LICENSE SNft-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTICN 15.
PERSONNEL TRAINING Particular emphasis is placed on the nature of the materials handled, plant safety program and rules,10 CFR 19 requirements, and the emergency evacuation system.
Tne training is documented in Health-Safety records. Additional training sessions, of a general or specialized
= " '
nature, are conducted by Health-Safety as required.
Postings are maae as required by 10 CFR 19 and 20 specifications.
Radiation workers are re-trained annually.
15.1 Employees are referred to Health-Safety by the Personnel Department for initial training in safety. At this time, the entire plant safety program is reviewed in some detail with par-ticular emphasis being placed on specific areas according to the employee's job assignment.
A brief discussion of, and familiari-zation with, the general principles of health physics and nuclear j
safety is included.
The employee is informed of his rights and responsibilities under CFR 19, and OSHA.
Training sessions are documented and filed as part of the employee's Health-Safety record.
Following the initial indoctrination, the employee receives additional safety training from his immediate supervisor. The employee's i
immediate supervisor shall complete a new employee training verifica-tion form (App. 3, Exhibit A) prior to allowing the employee to operate independently.
15.2 Continuing training of a general nature is provided as necessary by Health-Safety and supervision. This training may be formalized (i.e., " classes") or informal and conducted as a part of routine 2-10-06 DATE REVISIQ1 NO.
2 PAGE 29 CURRENT REVISIO4:
SUPERSEDES: PAGE LENRC APPROVAL REFERENCE DATE 5-04-84 REVISIO1 1
l
BAB00CK & WIL(DX C&PANY, QMERCIAL NUClfAR REL PIM USNRC LICENSE StM-ll68 DOCKET h.1201 IV HEALTH PHYSICS SECTIOd 15.2 Heal th-Safety audits.
Formalized retraining may be utilized to explain operational changes affecting safety, control of special problems such as increased airborne activity, or changes in license specifications.
The responsibility for determining the necessity for retraining or special training rests with Health-
- =
Safety based on plant conditions or the request of supervision.
15.3 Training and retraining in the use of respiratory protection devices is provided by Health-Satety as required.
Points relating to proper use are covered as the unit is issued and fitted by Heal th-Sa fe ty.
This approach provices continu1ng review or respiratory protection requirements.
Should situations arise where frequent use of a respirator is necessary, frequent Heal tn-Saf ety surveillance will assure continued proper application.
15.4 Specialized training for speqial and emergency r'esponse units such as the Fire Brigade, Radiation Monitoring Team and First Aid personnel is coordinated by icaltn-Safety.
Fire ur1gaae
- +*
training is conducted by representatives of Health-Safety and/or local Fire Departnents and covers the use of equipment and agents available at CNFP including high pressure water, CO, dry chemical, 2
and Met'L-X.
Radiation Monitoring Team members receive periodic training from Heal th-Safety in emergency response techniques (emergency plan), instrument use and maintenance, health physics and nuclear safety fundamentals, respiratory protection and 2
DATE 2-10-36 REVIS101 NO.
PAGE 30 CURRENT REVISION:
SUPERSEDES: PAGE 30 lENRC APPROVAL REFERENCE DATE 5-04-84 REVIS!01
BABC00( & WILOX C&PANY, QMERCIAL NlX1 EAR REL PLM USNRC LICENSE SNM-ll68 DOCKET &l201 IV HEALTH PHYSICS SECTIOl 15.4 contamination control. Annual evacuation drills are utilized as a training period for the emergency teams.
First aid training is given by a qualified instructor and is the standard Red Cross program or equivalent.
Efforts are made to recruit individuals who have had previous training such as military damage control or Civil Defense radiation monitoring.
16.
RECORDS AND REPORTS Records and reports pertaining to Health-Safety activities requiring formal documentation are maintained and stored in accord with Regulatory Guide 8.7, Occupational Radiation Exposure Records Systems. Supporting documentation and material not appropriately part of Regulatory Guide 8.7 is prepared and stored in a manner, and for a period of time, consistent with good industrial practice. The provisions for records reten+. ion and report submittal are governed by 10 CFR 19, 20, 70, and 71 specifications.
All documentation directly relating to Health-Safety activities is pre-pared by, or is under the administrative control of, the Health-Safety Section.
Vendor generated and supplied data (bioassay, TLD) is incor-parated as part of the Health-Safety record system based on contractual assurance of quality, precision, and adequacy of supporting information.
Information generated by other plant or company components is utilized as appropriate in the Health-Safety documentation program.
This type of material may be characterized as " supportive" and may include selected DATE 2-10-06 REVISIO1 NO.
2 PAGE 31 CURREffT REVISION:
SUPERSEDES: PAGE 31 MPRR mm DATE 5-04-84 REVIS!Q1 1
BABC00( & WIUDX QNANY, QMERCIAL NUQfAR REL PLM USNRC LICENSE SNft-ll68 DOCKET E1201 SECTIQ1 16.3 reviewed periodically by the Manager, Quality Assurance and in the course of routine audits provided by other B&W com-ponents.
Record retention requirements are in accord with 10 CFR 20.
16.4 Where applicable, all records are maintained using terminology equivalent to 10 CFR 20.
Where because of type of sample or the analytical technique employed, other units are more descrip-tive or useful, Health-Safety may maintain records in the units most appropriate.
Typically, unit terminology will be as noted below:
- All air samples - pCi/ml 2
- Removable surface contamination - DPM/100 cm 2
- Fixed surface contamination - DPM/50 cm 1
- Effluent water samples - Ci/ml
- Enviror.me7tal water samples - pCi/ml
- Soil / vegetation samples - pCi/g
- Bioassay samples in-vivo counting - pgU-235 urinalysis - DPM/t pgU/2 fecal - ugU/ sample nasal smears - DPM/ sample
- Exposure records - Rem, mrem, MPC h
- Penetrating radiation surveys - R, mR, mrem j
- Source leak test - uCi 35
- Solid waste disposal - gU, g U
2-1 M DATE REVIS!Q1 NO.
PAGE 33 CURRENT REVIS101:
SUPERSEDES: PAGE 33 USNRC APPROVAL REFERENCE 5-04-84 DATE REVIS!Q1
MBC00( & WilGX Cuf##, C0WERCIAL NUCLEAR REL PLM USNRC LICENSE SNft-ll68 DOCKET M-E l IV HEALTH PHYSICS SE N 17'.
CAUTION SIGNS, LABELS, AND AREA CONTROL A continued exemption is requested from the labeling and posting require-ments of'10 CFR 20.203(e)(1) and 20.203(f)(1) because of the nature of our operation.
The intent of these section is met by posting plant entrances with signs incorporating the radiation symbol and the following warning:
CAUTION RADI0 ACTIVE MATERIALS ANY AREA OR CONTAINER WITHIN THIS PLANT MAY CONTAIN RADI0 ACTIVE MATERIAL.
This system has been applied effectively at the CNFP for the past ten years.
17.1 Personnel access to the plant and supporting buildings is con-trolled through a guard station which is constantly manned.
The plant area is surrounded by a chainlink fence, and all access points, other than the main gate, are locked when not in use.
Key control is the responsibility of the Health-barety broup.
For purposes of plant and personnel protection and access control, the CNFP " restricted area" is considered to consist of all areas within the perimeter fence.
In specific instances, CNFP management may modify the restricted area as defined above in order to accom-modate unusual or temporary conditions.
17.2 " Controlled areas" within the CNFP are established as necessary to assist in the protection of personnel or in the control of contamination spread.
Criteria specified in 10 CFR 20.202 DATE 2-10-86 REVIS!Q1 NO.
2 PAGE 34 CURRENT REVISION:
SUPERSEDES: PAGE 34 USNRC APPROVAL REFERENCE DATE 5-04-84 1
REVIS!Q1
BABQXX & WIL(DX C&P#ff, CatERCIAL NVQfAR REL PLM USNRC LICENSE SNft-ll68 DOCKET 70-1201 SECTICN IV HEALTH PHYSICS 17.2 and 20.203 are applied to the determination for the necessity of establishing controlled areas.
Portions of the plant falling within one of the above categories are identified and controlled in accord with 10 CFR 20 requirements.
Postings utilized in accord with the above are placed so as to be visible from all access points.
Addi tionally, Health-Safety l
may require the use of barriers, tapes, etc., to further control access or deleniate the extent of the involved area.
Change areas, stepoff lines and appropriate monitoring equipment i
are used to control the spread of contamination to uncontrolled areas. Boundaries between controlled and uncontrolled areas are clearly identified and special requirements for access to the area are posted.
A radiation work permit program (RWP) may be instituted by Heal th-Safety ~ at any time in order to assure adequate protection, con-trol, and health physics coverage of personnel working under high, or potentially high, radiation exposure conditions.
Due to the routine nature of plant operations, the imposition of RWP controls is infrequent and generally relates to special mainte-nance or process development programs.
Safety rules (industrial, radiological, and nuclear) are pro-minently posted throughout the plant.
These postings are main-DATE 2-10-86 2
REVISIO1 NO.
PAGE 35 CURREf(T REVISION:
SUPERSEDES: PAGE 35 USNRC APPROVAL REFERENCE DATE 5-04-84 I
REVISIOJ
BAB000( & WIL(DX C&PANY, CufERCIAL NUCLEAR REL PLM USNRC LICENSE SNrt-ll68 DOCKET 70-1201 SECTIO 4 IV HEALTH PHYSICS 17.2 tained by Health-Safety based on license requirements and spec 1 tic plant operating criteria.
18.
EMERGENCY RESPONSE AND CONTROL PROGRAMS 18.1 Criticality Monitoring System A criticality monitoring system based on a series of GM detector.
units and a central control panel located in the Health-Safety Office is installed at the CNFP. GM detector spacing meets, or exceeds, the specifications of 10 CFR 70.
Integral with the detector system is an immediate evacuation alarm system composed of a modulated frequency generator and speakers or horns positioned throughout the plant. Alarm sound levels in all areas requiring immediate evacuation are distinctively audible above maximum ambient noise levels.
Selection of the alarm system was based on noise levels, frequencies, and modulation characteristics under plant operating conditions.
The system currently in use hcs been demonstrated in the course of drills to result in immediate personnel response.
Sound characteristics of the evacuation alarm are totally distinct from other audible alarms or signals in use at the plant (fire siren, time bells).
At the present time the monitoring system consists of six master detector units covering the plant in a manner consistent with the requirements in 10 CFR 70.24(a)(1) or (a)(2).
These detectors are located at appropriate distances where necessary to allow for %
DATE REVISIOl NO.
2 PAGE 36 CURREfff REVISION:
SUPERSEDES: PAGE 36 (ENRC APPROVAL REFEREtiCE DATE 5-04-84 REVIS!01 1
BABC0CK & WILG)X C&PANY, COWERCIAL NUClfAR REL PL/M USNRC LICENSE SNM-ll68 DOCKET E-1201 IV HEALTH PHYSICS SECTIQ4
- 19. BY-PRODUCT MATERIAL AND SEALED SOURCES 19.1 Encapsulated by-product material and neutron sources may be possessed at CNFP for use in instrument calibration, monitor training, and product evaluation devices such as scanners. Signi-ficant quantities of material are required in order to provide exposure or neutron flux rates of sufficient intensity to calibrate "high range" survey instruments and to penetrate high density materials for gauging purposes.
CNFP Health-Safety personnel have adequate training and experience in health physics and source handling to insure utilization of such sources (reference SNM-1168,Section V, minimum qualifications).
The following controls are in effect to insure adequate radiological safety:
a.
Authorized users of sources intended for training and instru-ment calibration are limited to qualified iealth-Safety and plant instrument technicians.
In' cases where other personnel may be involved in use of these sources, as in training exercises, the operation is directly supervised by a qualified representative of Health-Safety b.
Sources intended for use in manufacturing / quality control devices will be operated only by personnel designated by plant supervision and instructed in safe operating proce-dures by Health-Safety personnel.
DATE 2-10-86 REVISIQ1 NO.
2 PAGE 39 CURREfff REVISIO4:
SUPERSEDES: PAGE 39 USNRC APPROVAL REFERENCE 1
DATE 5-04-84 REVISIQ1 i
BABC00( & WILCDX CGPANY, C0WERCIAL NUCLEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET D E l SECTIa4 IV HEALTH PHYSICS 19.1 c.
When not in use, sources will be stored in approved, labeled and locked shields in a designated area.
Source container shielding shall be sufficient to minimize the exposure rate to personnel working in the vicinity of the container to less than 2 mrem /hr.
In general, storage requirements will be guided by the conditions outlined in " Safe Handling of Radio-isotopes" (IAEA Safety Series, No.1 Section 4,1962) and NBS Handbook 73 (1960).
d.
Adequate portable survey instrumentation is presently available on site.
e.
All employees of CNFP routinely wear personnel monitoring devices.
In addition, self-reading dosimeters, neutron dosimeters, and extremity dosimetry are required as deemed necessary by Health-Safety.
Routine use of remote handl1ng devices minimizes extremity exposure. Wherever practicable, automated handling and process equipment is utilized.
f.
Leak tests are conducted on all sources immediately upon receipt and at least semi-annually thereafter and are performed in accord with the guides outlined in NBS Handbook 73 (1960, Section 7.6, " Radioactive Source Leakage & Contami-nation") or by an equally effective method.
In the event that a leaking source is discovered it shall be packaged so as to prevent further contamination spread and arrangements DATE 2-10-86 REVISIQ1 NO.
2 PAGE 40 CURRENT REVISION:
SUPERSEDES: PAGE 40 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISIQ1 I
i
BAB000( & WILCDX COPANY, C0WERCIAL NUCLEAR REL PUNT USNRC LICENSE SNft-ll68 DOCKET & l201 SECTICN IV HEALTH PHYSICS 20.1 d.
Sampling media available at! selected site.
e.
Chemical and physical characteristics of potential con-taminants (insoluble uranium oxides, etc.).
f.
Potential impact from neighboring nuclear facilities.
The sample results are maintained on file by Health-Safety.
Figure 4 shows results of the environmental sampling program for the period 1977-1980.
flormal data fluctuations are noted with no discernable trends identified.
DATE 2-10-86 REVIS!Q1 NO.
2 PAGE 43 CURRENT REVISION:
SUPERSEDES: PAGE 43 MRC MPRR Mm DATE 5-04-84 1
REVISION
BABC00( & WILCDX C&PANY, CutERCIAL NUClfAR REL PLM t.6NRC LICENSE SNft-ll68 DOCKER 70-1201 IV HEALTH PHYSICS APPENDIX 1, PAGE 10 SECTIO 4 NEUTRON EMITTING SEALED SOURCES It is believed that neutron activation of scanned rods will result in 4
an insignificant increase in the penetrating radiation levels normally encountered with unexposed fuel rods.
During the initial phase of scanning, however, a confirming measurement program will be undertaken. Sources are leak tested upon receipt at CNFP and at least every six months thereafter (unless the source is in storage).
Leak tests will be conducted by Health-Safety using remote handling techniques and will be compatible with NBS Handbook 73, Section 7.6, or by an equally effective method. Measurement techniques are capable of detecting 0.005 microcurie on the test sample.
When practicable, leak tests will be conducted without removing the source from its shielding unit.
Neutron survey instrumentation is available on-site.
Personnel dosimetric devices, such as film and self-reading chambers, appro-priate for evaluating neutron exposure are utilized as determined to be necessary by Health-Safety.
Operating personnel are trained in safe practices and health physics requirements prior to operating the scanner.
Documentation of such training is maintained in the Health-Safety Office.
In-plant operating procedures require that Health-Safety be notitied prior to undertaking any maintenance or other activities that may involve access to, or modification of the source shield.
In addition, all source handling is under the supervision of qualified Health-Safety personnel.
Written procedures provide guidance for normal use of the sources and define the controls to be applied in the event of leakace or other non-routine condition.
Appendix i DATE 2-10-36 REVISIOJ NO.
2 PAGE 10 CURRENT REVISIO1:
SUPERSEDES: PAGE Appendix 1, Page 10
@PRR REFERM DATE S-04-84 1
REVISIQ1
i BABC00( & WILIDX C&PANY, CufERCIAL NUCLEAR REL PLM USNRC UCENSE SNWil68 DOCKET &l201 V CONDITIONS SECTICH 5.0 Administrative The following feature of administration provide control to assure nuclear and radiation safety.
5.1 Management shall be responsible to assure the safety of the operation and compliance with license conditions. Control shall be established by designation of responsibilities to qualified individuals, review ***
and approval of_ Health-Safety proce.dures designed'to assure continuing safety and compliance, review of ~ rogram e'ffectiveT p
ness and assuring correction of non-conforming conditions.
~
~ '
ORGANIZATION QLART Plant Manager Safety Production Quality Assurance Administrative Review ttanagers Manager
- Managers
- not directly responsible
"**[' ;UN*l j
for production functions 5.2 Operational Area Supervision Operational area supervision is that supervision directly responsible for the control of materials, personnel, equipment, and activities in specific areas.
Those responsibilities include assuring that approved control procedures developed with Health-Safety shall be available in writing to operators and other concerned personnel and shall be adhered to.
5.2.1 Minimum qualifications of operational area supervision shall include:
(a) A high school education or equivalent and a minimum of 6 months experience in the nuclear industry.
Experience shall include the practical DATE 2-10-06 REVISION NO.
2 PAGE 6
CURRENT REVISION:
SUPERSEDES: PAGE 6
USNRC APPROVAL REFERENCE DATE REVISION
BABC00( & WILCDX QWW, QWERCIN. NUCLEAR REL PLM USNRC UCENSE SNft-ll68 DOCKET E1201 SECTIO 4 V CONDITIONS 5.0 Administrative (continued) 5.2.1 (a) application of criticality control techniques and a familiarity with the applicable specific limitations imposed on CNFP operations.
(b) Sufficient experience of industrial supervisory nature for recognition of the responsibilities of the position and achievement of the required control.
5.3 The Health-Safety tiroup 'shall De responsible to in-terpret the license conditions, provide monitoring facilities, develop safe operation guidelines, maintain training programs, and review and approve operating procedures to assure safe opera-tion and license compliance.
These respcnsibilities include nuclear safety and radiation safety with the approval authority limited to authorized specific or general license conditions.
The Health-Safety function shall be responsible to pro-vide management with assurance of the effectiveness of the safety program by maintaining an audit program that includes periodic inspection of controls and operations, reports to management, follow-up of non-conforming conditions and necessary documentation.
(See Audits, Part 6,6,Section V),
7 DATE 2-10-86 REVISIQ1 No.
2 PAGE CURRENT REVISION:
SUPERSEDES: PAGE 7
WNRC APPROVAL REFERENCE S-04-84 1
DATE REVISlal
BABC0CK a WILC0X C0ff%'iY, C0ffERCIAL NUCLEAR FUEL PLM
)
USNRC LICENSE SNfi-ll68 DOCKET 70.1201-l SECTION V CONDITIONS i
~
5.0 Administrative _ (continued) 5.3 The section shall not be directly responsible for the performance of manufacturing operations.
5.3.1 The section shall include a person trained in. health physics with a Bachelor's Degree in-Science or Engineer-i ing, or equivalent, and a minimum of three years experi-I ence shall be of a nature that would provide an under-standing of the health physics and nuclear safety hazards i
involved, and the ability to evaluate the potential for f
exceeding authorized control limits.
5.3.2 The manager to whom the section reports shall have a bachelor's degree, or equivalent, and a minimum of five years experience in i
responsible positions which would develop an understanding I
of nuclear and radiation safety. Such experience shall be of a nature which demonstrates to the Plant Manager sufficient judgement and capability to establish and maintain an effective nuclear criticality and radiation safety program for the activities authorized by license.
5.4 Independent Auditors shall be responsible to ascertain the over-l all performance of the plant functions in providing adequate con-trols, surveillance, and followup to assure safety and license
}
compliance.
This shall be accomplished'by periodic inspection
{
of the facilities and records resulting in a written report to l
the Plant Manager, l
{
5.LL Oualifications of the independen_t auditors shall include l
1 DATE 2-10-86 REVISICtl NO.
1 PAGE 8
CURRENT REVIS!CN:
SUPERSEDES: PAGE 8
USNRC APPROVAL REFEREilCE O
DATE 12-6-82 REV!SICt;
BABC0CK a WILCOX C0iPKN, C0itERCIAL NUCLEAR FUEL PLAllT USNRC LICENSE SNti-ll68' DOCKET 70-1201 SECTION V CONDITIONS 6.0 General Specifications - Implementation of the technical specifications will be accomplished through application of,the following general specifications.
6.1 Control Program Specifications and design criteria for purchased or locally fabricated equipment where nuclear and radiological safety considerations are involved shall be approved by a knowledgeable representative of Health-Safety.
Before being releared for production operation, new equipment shall be tested to assure that safety specifications are satisfied.
Safe geometry equipment shall be measured by a knowledgeable perron to ascertain that it is of proper dimensions before it is put into service. Where operational safety is based wholly or in part on the use of electrical or mechanical interlocks, the proper functioning of interlocks shall be verified upon installation and on an annual basis thereafter.
Routine plant inspections place added emphasis on new operations. No equipment is used after being removed from service until an equipment checkout for continued effectiveness of safety related para-meters is performed.
Radiation instruments shall be calibrated at the frequency indicated in Section V, Part 8.3.4.
Calibration shall be performed by Healtb-Safety personnel or other NKC licensec facilitias.
DATE 2-10-86 REVISICN NO.
3 PAGE 11 CURRENT REVISION:
SUPERSEDES: PAGE 11 USNRC APPROVAL REFERENCE DATE 2-04-85 REVISION 2
BABC00( & WILQM CTPANY, COMUCIAL NUClfAR REL PINT USNRC LICENSE SNPt-ll68 DOCKET M-1201 V CONDITIONS SECTION 6.0 General Specifications (continued) 6.1 Ventilation, containment, and air cleaning equipment shall be routinely inspected by Health-Safety personnel to assure continued effectiveness and c.omplience with. license specifications.
These inspections shall be recorded and a periodic review shall be per-formed by Health-Safety. Any unusual circu.nstance.i
.===
shall be brought to the attention of the Health Physicist and/or the 0.uality Assurance Manaaer.
The Health Physicist or qualified designee as appointed by Manager, Quality Assurance shall be responsible for the control of the air sampling and contamination survey program, and evaluates daily sample results.
Quarterly air sample program records shall be reviewed by the Health Physicist and/or the Manacor, Ouality Assurance.
Instances of inadequata control of contamination or air effluent levels, and of equipment operation not in accordance with established nuclear and radiation safety and license parameters shall be reviewed by either the Health Physicist, and/or the Manager, Quality Assurance wno may oraer the operation suspended if timely compliance cannot be assured.
Disciplinary action can be recomended if warranted.
6.1.1 Safety Review Board A Safety Review Board shall be established to review the following as a minimum on a quarterly basis:
3 12 DATE 2 M REVISION No.
PAGE CURRENT REVISION:
SUPERSEDES: PAGE 12 lENRC APPROVAL REFERENCE 2-04-85 2
MTE REVISION
FAC0CK & WILCOX C&PAiff, C0tERCIAL NUCLEAR FEL PLAIT USNRC LICENSE SNM-ll68 DOCKET 10-1201 SECTIOd V CONDITIONS 6.0 General Specifications (continued) 6.1.1 Safety Review Board
'new or revised facilities
' analysis of equipment and processes involving radioactive materials
'the continuing effectiveness of established controls and safeguards
' maintenance of ALARA criteria (review of quarterly air sample averages, review of surface contamination surveys)
' safety-related audit findings
'other items (such as abnormal occurrences) that Safety Review Board members wish to discuss The Safety Review Board Chairman or his qualified designee shall be directly responsible to the Plant Manager for the pro-per conduct of the Safety Review Board. The Plant Manager shall be kept informed in writing of Safety Review Board action.
The Board shall be chaired by the Manager, Operations Support, and the permanent membership of the Board shall consist of representativesof CNFP operational and technical management, specified by procedure, which is approved by Plant Management personnel. Technical representatives of consulting organizations shall be included as necessary (LRC, Nuclear Criticality Safety Group).
Board meetings may be convened at the discretion of the Safety Review Board Chairman or his qualified designee or the Manager, Quality Assurance, but shall be held at least quarterly. The Safety Review Board Chairman or his qualified designee shall decide whether or not the necessary disciplines are present during a toard meeting to evaluate the item (s) under consideration.
There shall be a minimum of 4 Safety Review Board members present durino a board meeting.
13 DATE 2-10-86 REVISIGi No.
3 PA:d CURRENT REVISICN:
I.
SUPERSEEES: PAC-E 13 USNRC APFROVAL PEFERENCE 2-04-85 2
EATE gggggg.
BABC00( & WILCDX C&PAi#, C&fERCIAL NLX1 EAR REL PLM USNRC LICENSE SNft-ll68 DOCKET L 1201 V CONDITIONS SECTICN 6.0 General Specifications (continued) 6.1.1 Safety Review Board The Safety Review Board Chairman or his qualified designee reviews all requests for changes in process and equipment which involve radioactive material and determines if Board review is necessary.
In the case of minor change where existing safety practice remains the same, the Safety Review Board Chairman or his qualified designee may determine that Board review is not necessary.
Safety Review Board members shall be kept appraised of actions
~
taken by the Safety Review Board Chairman or his qualified designee on such minor changes.
]
Where other than minor changes are involved, the Safety Review Board review and approval process shall be con-ducted in accord with Part. 7.1.4 of this section.
Records of Safety Review Board proceedings, including supporting calculations and approvals, shall be retained l
for at least six months after the completion or termina-tion of the subject activity.
6.1.2 Records Plant alterations or additions, abnormal cccurrences, events associated with radioactive releases, criticality analyses, aedits, inspections, instrument calibration, ALARA findings, employee training and retraining, personnel exposures, routine radiation surveys, and environmental surveys shall be maintained on file for a minimum of 2 years or as other-wise required by federal regulation or other license con-dition, for review by B&W management and regulatory agencies.
6.2 Personnel Training Initial indoctrination of employees into nuclear and radioh gical safety shall be the responsibility of Health-Safety and shall j
DATE 2-10-86 REVISION NO.
2 PAGE 14 CURRENT REVISION:
SUPERSEDES: PAes 14 USNRC APPROVAL REFERENCE 5-04-84 1
DATE REVISICf!
BABOXX & WILCDX C0FPMY, C0ftMIAL.1UCLEAR REL PLATT USNRC LICENSE Snit-ll68 DOCKET 70-1201 SECTIO 4 V CONDITIONS 6.0 General Specifications (continued) 6.2 Personnel Training conform with 10 CFR 19.
Initial indoctrination training shall, as a minimum, include the following topics:
' license conditions
' federal regulations
' operating procedures
, radiation safety
, nuclear safety emergency procedure The extent and depth of the training, relative to the detailed aspects of the health physics and nuclear safety programs, is dependent on the employee's job assignment and potential exposure to radioactive materials as determined by Health-Safety.
The initial indoctrination training shall be reinforced (as appro-priate to the individual's job assignment) by the employee': imme-diate supervisor or his designee with respect to individual unit safety requirements, location of emergency exits, contamination control techniques, specific local controls, and operating proce-dures, prior to the employee being released to operate independently.
The employee's immediate supervisor shall complete a new employee training verification form prior to allowing tne employee to operate independently.
A continuing safety training program shall be conducted by Health-Safety to the extent necessary to assure the maintenance of acceptable safety practices.
Such training may be conducted on an individual or group basis. The content of retraining programs may be varied by Health-Safety with emphasis placed on new or revised safety criteria or areas in need of re-inforcement. A formal retraining of radiation workers shall be conducted at least annually.
Documentation of formal training and retraining shall be maintained by Health-Safety.
DATE 2-10-86 REVISIOJ NO.
2 PAGE 15 CURREtiT REVISICN:
SUPERSEDES: PACE is ustlRC APPROVAL REFEFElCE 1
DATE 5-04-84 pgy;3;g;
BABC00( & WIl.G)X QWANY, CTPERCIAL. NUQEAR REL PIM USNRC U NSE SNPt-ll68 DOCKET M-1201 SECTICH 6.0 General Specifications (continued) 6.2 The Manager, Quality Assurance shall be responsible to assure that personnel. assigned.to the_ Health-Safety function are properiy trained. The extent and depth of the training is based on the specific job assignment involved.
Health-Safety monitoring personnel shall receive a combination of formal and "on-the-job" training such that they can successfully demonstrate their proficiency in basic nuclear and radiation physics monitoring and control techniques.
and regulatory requirements before being allowed to function with-out direct oversight.
Members of the CNFP emergency monitoring team shall be trained by Health-Safety in the proper technique of accident control.
6.3 Postings Nuclear safety postings approved by Health-Safety shall be maintained specifying nuclear safety parameters that are subject to procedural controls.
Area postings may be used for those parts of the process where nuclear safety is maintained by means of " area-wide" require-ments.
Operations for which specific (dedicated) controls are applicable shall be individually posted.
Local safety rules approved by Health-Safety providing personnel and supervision with specific directions essential to assuring DATE 2-10-86 REVISION NO.
2 PAGE 16 CtRRENT REVISION:
SUPERSEDES: PAGE 16 (ENRC APPROVAL REFERENCE DATE 5-04-84 REVISICN 1
BABC00( & WIL(DX C&PANY, CatERCIAL NUCLEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET &l201 V CONDITIONS SECTim 6.0 General Specifications (continued) 6.5 consideration involves SNM or radioactive materials, specific written approval by the Manager, Quality Assurance or his designee shall be required prior to implementation of the procedure. Applicable procedures shall be available in the work area and adherence to procedure shall be required of all personnel.
Procedures for operations where nuclear and radiological safety are involved shall include specific reference to applicable safety re-quirements. Procedure and format shall be such that operations are clearly detailed and specific directions Are provided for operaticn under both normal and abnormal conditions. Deviation from written procedures for the handling of SNf1 shall be approved by the Manager, Quality Assurance, or his qualified designee.
Procedural control of activities at the CHFP are catacorized as follows:
- Procedures developed by Health-Safety specifying the method by which safety related functions are to be accom-plished.
Such procedures may be for internal Health-Safety use or may be intended for general distribution to affected indivi-duals within other components. As a minimum, Health-Safety Proce-dures shall be approved in writing by the fianager, quality Assurance as well as approved by affected members of plant management.
DATE 2-10 M REVISION NO.
3 PAGE 18 CURRENT REVISION:
18 SUPERSEDES: PAGE USNRC APPROVAL REFERENCE 2
DATE 2-04-85 REVISIm
_.,mm.;_
m-
_.m_
i BABCDO( & WILG)X QPPANY, CutERCIAL NUCLEAR REL PIM USNRC UCENSE SNM-ll68 DOCKET &l201 V CONDITIONS i
SECTICN 6.0 General Specifications (continued) 6.5
- Nuclear Materials Control procedures provide techniques for the accountability and measurement of SNM. As a minimum, sucn pro-cedures shall be approved in writing by the Manager,. Quality Assurance and the Manager, Production & Materials Control.
- Procedures from other plant groups where nuclear or radio-logical safety, license conditions, or regulatory require-ments are involved require prior approval by the Manager, Quality Assurance as well as approval by affected members of plant management.
Revised procedures shall be subject to approval in the same manner as new procedures. Health-Safety procedures shall be
~
reviewed at least annually for technical correctness and applicability.
Procedure distribution and control shall be the responsibility of plant supervision.
6.6 Audits An internal audit program shall be maintained to provide assurance that plant activities are conducted safely and in accord with license specifications.
The Manager, Quality Assurance shall be~res;56nsible to '
assure that the audit program is conducted effectively.
3 DATE 2-10-R6 REVISION NO.
PAGE 19 CURRENT REVISION:
SUPERSEDES: PAGE 19 USNRC APPROVAL REFERENCE 2-04-85 DATE REVISION
MBOXX & WILQX CDPANY, CatElEIAL NUCLEAR REL PIM USNRC UCENSE SNPt-ll68 DOCKER F1201 SECTION V.
CONDITIONS 6.0 General Specifications (continued) 6.6 Health-Safety personnel shall conduct, at least weekly.
a formal audit of plant status relative to nuclear and radiolo-gical safety, except during plant shutdown of a week or longer.
At the discretion of Health-Safety, the audit may consist of an indepth, evaluation of a specific area or may be of a generalized nature providing an over-view of total plant activities. Audit results shall be documented, reported to plant management and supervision as appropriate, and will be maintained on file by Healtn-Safety for at least 2 years.
Mealth-Safety audits shall be conducted by personnel technically qualified in operational nuclear and radiological safety and in the application of license specifications.
Health-Safety personnel shall, as part of their routine duties, conduct informal daily audits of plant activities.
Independent auditors shall conduct inspections as follows
- nuclear safety
- quarterly
- health physics
- quarterly All formal (quarterly) nuclear safety and health physics audits shall be conducted in accordance with written instructions or procedures.
The audit program shall include physical inspections and records reviews for the industrial, nuclear, and radiological safety elements of plant activities including:
- Effectiveness of procedural controls impacting on operational safety parameters.
DATE 2-10-36 REVISION NO.
3 PAGE 20 CURRENT REVISION:
SUPERSEDES: PAGE 20 USNRC APPROVAL REFERENCE DATE 2-04-85 2
REVISION
BABC00( & WILG)X CDPANY, 00MUCIAL. NUCIIAR REL PLMT USNRC LICENSE Snit-ll68 DOCKET D E l SECTICN V
CONDITIONS 6.0 General Specifications (continued) 6.6
- Audit of operating records, where such records provide a means of verifying procedural compliance with safety specifications.
- Periodic review and evaluation of contamination survey data.
An annual ALARA report shall be submitted to the Safety Review Board on employee exposures and effluent release data.
A copy of the report shall be sent to the Plant Manager.
Independent auditors' reports shall be submitted to the Plant Manager.
The Manager, Quality Assurance shall review the audit reports as they "
are submitted. The audit report shall include any audit findings or recommendations. Actions taken as a result of audit findings shall be documented.
Safety-related audit findings are reviewed by the Safety Review Board.
6.7 Reporting Unusual events requiring reporting under 10 CFR shall be investi-gated, with results reported to plant management and NRC.
Events not otherwise requiring a report may be reported to NRC based on potential public or media involvement, etc., in order to keep NRC appraised of the situation.
2 DATE 2-10-86 REVISION NO.
PAGE 21 CURRENT REVISION:
SUPERSEDES: PAGE 2I USNRC APPROVAL REFERENCE 5-04-84 1
DATE REVISICN
BABC00( & WILG)X C&PANY, 00ltERCIAL NUDIAR REL PLAVT USNRC LICENSE SNPt-3168 DOCKET E1201 V CONDITIONS SECTIO 4 7.U Nuclear Safety - Technical Specifications (continued) 7.1.2 e.
The solid angle criteria applied in accord with TID-7016 (Rev. 2) for accumulations having k-eff
< 0.8.
7.1.2.1 The Safety Review Board Chairman or his qualifier'.
designee, with the concurrence of the LRC Nuclear Criticality Safety Group, shall determine which arrays are more reactive than those used as a basis for a, b, and c or are best represented as slabs for nuclear interaction purposes.
In these cases, the interaction acceptance cri-l teria shall be evaluated on an individual i
basis by the LRC Nuclear Criticality Safety Group or itshall be the equivalent of eight inches (20.3 cm) of water or as defined in 7.1.2(d) or (e).
7.1.3 Isotopic enrichment of SNMshall be verified by shipper's docume. *s with added assurance by Quality Assurance overchecks.
7.1.4 Modification of product or process involving SNM may be made without license amendment provided such changes are controlled as described in this section and where the license conditions specified in this part are not vinl a to t DATE 2-10-86 REVISION NO.
2 PAGE 23 CURRENT REVISION:
SUPERSEDES: PAGE 23 USNRC APPROVAL REFERENCE 1
DATE 2-04-85 REVISIQ1
BAB000( & WIL(DX CTPANY, CatERCIAL NUCifAR REL PLAT USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTIO 4 7.0 Nuclear Safety - Technical Specifications (continued) 7.2 discussed in Section III and may be considered typical of material pr'ocessed.
7.2.1 Fuel Pellets Composition: Uranium Oxide Size:
.300" to.600" diameter inclusive 235 Enrichment: Maximum 4.05%
U NOTE: An increase from 4.00 to 4.05 w/o does not significantly affect nuclear safety _ calculations based on 4 w/o material.
7.3 Fuel Pellet Receiving and Temporary Storage A single shipment of pellets may be stored in the shipping containers s
in an array no more reactive than as received pending transfer to planned storage facilities.
Nuclear interaction between the shipment and other SNM will be as specified in 7.1.2.
7.3.1 The containers shall be examined for transit damage, and 5*
Health-Safety notified if damage is found.
Health-Safety shall examine the damaged containers for evidence of water entrainment and other conditions that might constitute a hazard.
Damaged containers shall be opened one at a time and as the material is removed, itshall be immediately placed into storage within safe geometry slabs or 850 grams U235 accumulations in accord with appropriate license con-ditions for storage.
DATE 2-10-86 REVISIQ1 NO.
2 PAGE 28 CURRENT REVISION:
SUPERSEDES: PAGE 28 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISIOJ l
BAB000( & WIL(DX COPANY, CGtERCIAL NUCLEAR FLEL PLM USNRC LICENSE SNM-ll68 DOCKET D E l SECTIOi V CONDITIONS 7.0 Nuclear Safety - Technical Specifications (continued) 7.5.2 Only a single slab thickness will be permitted on any one shelf.
7.5.3 The vault is separated from other SNM storage and pro-cessing areas by eight inch thick concrete walls.
7.5.4 Storage and handling of materials in the vault shall be controlled based on criteria specified by Health-Safety per ***
sonnel. Enrichment determination and selection of proper slab **'
thickness shall be made utilizing appropriate records or test data.
7.6 Fuel Pellet Handling and Storage Fuel pellet handling (following release from the pellet handling area) may involve such operations as fuel rod loading, and storage of packaged but unciad fuel pellets in areas other than the vault.
Fuel pellets shall be handled in accumulations limited to thickness by enrichment as follows:
235U Enrichment Maximum Thickness (5)
(in.)
< 2.5 5.4
> 2.5 1 3.0 4.8
> 3.0 1 3.5 4.4
> 3.5 5 4.05 4.0,
DATE 2-10-86 REVISIQ1 NO.
2 PAGE 31 CURRENT REVISION:
SUPERSEDES: PAGE 51 USNRC APPROVAL REFERENCE DATE 2-04-85 1
REVISIO1
BABCOC< & WILCDX CGPMY, C0ltERCIAL NUClfAR REL PLMT USNRC LICENSE Snot-llb8 DOCKET &l201 V CONDITIONS SECTICN 8.'0 Technical Specifications - Radiation Safety (continued) 8.1.1 c.
The following program shall be instituted to assure that airborne releases to uncontrolled areas are maintained as low as. reasonably achievable.
AIR EFFLUENTS Quarterly A.verage - % of 10 CFR 20 Appendix B, Table 2 LIMIT ACTION
< 10% of "MPC" None required.
11 - 20%
Conduct investigation of system and correct if possible.*
21 - 75%
Visually inspect system. As soon as practicable, conduct efficiency test.
Determine and correct cause.**
> 75%
Conduct immediate investigation to determine and correct problem in ventilation system. Maintain addi-tional Health-Safety surveillance of system to monitor contamination levels until problem is corrected.
, end weld operation area - none_ required
,,end weld operation area - none required at < 50% fiPC end cap removal area - none required at < SD% f1PC Health-Safety shall maintain records of investiga-tions and actions resulting therefrom, d.
If the gross alpha radioactivity (excluding radon and its daughters) in planned gaseous effluents discharges exceeds 10 uCi/ cal. qtr., a written report shall be submitted to NMSS and the Regional Office of the Com-mission within 30 days, identifying the cause for exceed-ing the limit, and corrective actions to reduce release rates.
If the parameters important to a dose assessment change such that the parameters no longer represent boundary conditions, report shall be submitted within 30 days which describes the changes in parameters and includes an estimate of the resultant change in dose conunitment.
(Ref:
Order to flodify License, Jan. 28, 1930).
DATE 2-10 R6 REVISIQ4 NO, 3
PAGE 42 CURFEffT REVISICN:
SUPERSEDES: PAGE 42 USNRC APPROVAL REFFJiENCE 2
DATE 2-04-85 p,3yI3;g;
~ _.
BAB000( & WILO)X C&PANY, CutERCIAL NtX1 EAR REL PIM USNRC LICENSE SNft-ll68 DOCKET D E l SECTIm V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.1.2 Po.tentially contaminated liquid effluents hall be s
controlled through a retention tank system with dilution and mixing capabilities and shall be evaluated for compliance with 10 CFR 20, Appendix B limits prior to release to unrestricted areas.
The following actions, at the contamination levels indicated, shall be undertaken in order to maintain contaminated liquid effluent re-leases as low as practicable:
LIQUID EFFLUENTS
% 10 CFR 20 App. B. "MPC" Action
< 20%
No action required.
21 - 75%
Individual releases authorized by Manager, Quality Assurance or his alternate.
> 75%
Discharge prohibited.
Effluent routed for further treatment or disposal.
Health-Safety shall maintain records of investiaations i
and actions resulting therefrom.
a.
Retention tanks shall be inspected monthly for sludge accumulation.
8.1.3 The following parameters are established for determining if waste or excess materials and equipment may be disposed of in routine industrial fashion.
Item (d) i 3
43 DATE 2-10-86 REVISION NO.
PAGE l
CURRENT REVISION:
SUPERSEDES: PAGE 64 USNRC APPROVAL REFERENCE DATE 2-04-85 REVISION 2
3 l
BABC00( & WIL(DX C&P#f(, COWERCIAL NUCLEAR REL PLM USNRC LICENSE SNPt-ll68 DOCKET b]201 V CONDITIONS SECTION 8.0 Technical Specifications - Radiation Safety (continued) 8.2.2 Pressure differential shall be monitored by manometers or equivalent devices. Minimum face velocities for hoods and similar enclosures shall be 100 LFM whenever hood w'ork in-volving dispersible licensed material is being performed.
Air velocity surveys shall be conducted using heated thermocouple anemometers or equivalent. Higher velocities may be required, based on Health-Safety survey data.
3, 1.
Glovebox negat.ive pressures shall be monitored weekly, except during plant shutdown of a week or longer.
- 2. Face velocities shall be measured weekly, except during plant shutdown of a week or longer.
" Elephant trunk" drops shall be used as required for maintenance or non-routine activities requiring ex-haust ventilation and where other, more permanent types of containment are not practicable.
Except as noted above, elephant trunks shall not be used as a routine control measure without the specific approval of Health-Safety.
ilinimum velocity at the point of entrance to " elephant trunk" drops t
in the pelletizing area shall be 1300 LFM, U
{
DATE 2-10-86 REVISICt1 NO.
3 PAGE 49 CURREllT REVISICH:
SUPERSELES: PACE 70 USMRC APPROVAL REFERENCE 2
DATE 2-04-85 ggyy3;q;
BABC00( & WILWX QPPANY, C0WERCIAL NUCLEAR REL PIM USNRC LICENSE SNWll68 DOCKET D E l SECTICN V CONDTTTON9 8.0 Technical Specifications - Radiation Safety (continued) 8.2.2 andshall be measured weekly when the area is in operation.
8.2.3 Air Sampling In order to verify the adequacy of the ventilation and containment systems, air sampling technique (s) shall be employed. Air samplers shall be positioned at work stations based on evaluation of smoke tests, special air samples, and operator working position. Based on operational status and/or exposure potential, air samples shall be collected after each shift. The air samples shall be analyzed to evaluate airborne levels and assign worker exposures.
General area air samples shall be collected and analyzed as stated in the preceding paragraph.
UPon initiation of new operations, non-repetitive opera-tions, or operations modified such that previous airborne contamination levels may be effected, Health-Safety sha'll verify that satisfactory control is being maintained by means of the air sampling techniques stated above. The scope and duration of such special programs shall be determined by Health-Safety based on good health physics practice.
DATE 2-10-86 REVISIOJ NO.
3 PAGE 50 CURRENT REVISIO4:
SUPERSEDES: PAGE 71 USNRC APPROVAL REFERENCE DATE 2-04-85 REVISICN 2
BABOXX & WILG)X CCWANY, ONElEIAL NlufAR REL PIM USNRC LICENSE Slet-ll68 DOCKET 70- E l V CONDITIONS SECTICN 8.0 Technical Specifications - Radiation Safety 8.2.3 The following action points shall apply to the routine work station air sampling program:
PERSONNEL EXPOSURE Quarterly % MPC Average Action
< 25%
No action required.
> 25%, < 50%
Report to Manager, Quality Assurance **'
or designee.
Evaluate operation and containment.
Increase air sample frequency if indicated.
> 50%, < 75%
Report to Manager, Quality Assurance. Take steps necessary to lower airborne activity to acceptable range.
> 75%
Notify Manager, Quality Assuranc6.' ***
Terminate operation if > 100 MPC. Modify or install air capture devices. Increase air sample frecuency If any one sample measures 100% MPC, the location and occurrence shall be investicated.
Health-Safety shall maintain records of investigations and corrective actions taken.
The action levels do not apply to non-routine operations con-1 ducted with the cognizance of Health-Safety, and in accord
.?*
with specific contamination control measures (for example, certain maintenance activities).
4 DATE 2-10-86 REVISICN NO.
PAGE 51 CURRENT REVISICN:
SUPERSEDES: PAGE 72 USNRC APPROVAL REFERENCE 3
DATE 2-04-85 REVISIW
BABC00( & WIL(DX COPANY, CutERCIAL NUCLEAR REL PLM USNRC LI NSE SNM-ll68 DOCKET &]201 V CONDITIONS SECTIO 4 8.0 Technical Specifications - Radiation Safety-(continued) 8.2.4 Respirators may be used in unusual conditions where air-borne concentrations of radioactive material may.cause personnel to receive exposures in excess of permissible levels. Typical unusual conditions may be certain maintenance operations, startup periods, short-tenn operations, etc.
Procedures for maintenance of the respirators and training of personnel using respirators shall be under the cognizance of Health-Safety.
Respira-tors shall not be applied as a routine control measure in situations where engineered or procedural controls are feasible.
SCBA is available at the plant.
Respiratory protection equipment shall be governed by 10 CFR 20.103(c).
8.3 Instrumentation 8.3.1 Portable instrumentation used to evaluate general area activity shall be capable of detecting contamination levels at or below license limits or action levels.
DATE 2-10-86 3
REVISIO1 NO, PAGE 52 CURRENT REVISIO4:
SUPERSEDES: PAGE 73 USNRC APPROVAL REFERENCE 2-04-85 2
UTE REVISIO1
MB000( & WILG)X CTPANY, COMMIAL NLUEAR REL PLAVT USNRC LICENSE SNM-ll68-DOCKET 70-1201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.3.2 Analytical capability for evaluation of effluent samples shall be such that instrument sensitivity and sample preparation techniques allow:
a.
1% of the appropriate MPC far liquid effluents b.
10.0% of the appropriate MPC for airborne effluents.
8.3.3 A criticality monitoring system shall De maintained in com-pliance with the appropriate sections of 10 CFR 70. Response time for the system shall be in accord with Regulatory Guide 8.5, " Criticality and Other Interior Evacuation Signals" dated March, 1981.
The criticality alarm system shall be function-tested at least quarterly, an d detector units calibrated annually.
Nuclear accident dosimeters incorpo-rating neutron activation foils shall be positioned in the plant at locations selected by Health-Safety to provide exposure estimating capability in the avent of a nuclear incident.
8.3.4 All instrumentation shall be calibrated upon initial installation, following major maintenance, and at other times as deemed necessary.
In any case, DATE 2-10-86 REVISIQ1 NO.
3 PAGE 53 CURRENT REVISION:
SUPERSEDES: PAGE 74 p
2 DATE _ _ 2-04-85 REVISIQi
BABC00( & WIL(DX QNANY, C0tERCIAL NtX1 EAR REL PLAff USNRC LICENSE SNM-1168 DOCKET h-1201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.3.4 calibration shall be performed at least semi-annually. Labora-tory counting instruments shall be calibration-checked daily when in use. Calibration records shall be maintained for a minimum of two years.
8.3.5 Field check sourcesshall be available for assuring functional response of instrumentation prior to use.
8.4 Personnel Monitoring and Contamination Control 8.4.1 Personnel monitoring equipment - film badges, thermo-luminescent dosimeters, detectors, etc., -shall be used by persons having access to restricted or radi-ation areas, as deemed necessary by Heal th-Safety,
~
and in accord with 10 CFR 20. The dosimeters shall be processed routinely to determine radiation dose. Heal th-Safety shall review and maintain the dose records and prepare such reports as are required by regulations.
Neutron dosimeters shall be used by operators and other persons as deemed necessary by Health-Safety when a potential for measurable neutron exposure exists.
8.4.2 An indium foil stripshall be worn by plant personnel to provide for identification of persons receiving high exposures in the event of an accidental criticality.
8.4.3 Persons who work routinely in areas where there is a potential for bodily intake of radioactive materials 3
DATE 2-10-36 REVISION NO.
PAGE 54 CURREffT REVISIOJ:
SUPERSEDES: PAGE 75 p
DATE 2-04-85 2
REVISIQ1
BAB000( & WILCDX C&PANY, CutERCIAL NUGEAR REL PUNT USNRC LICENSE SNM-ll68 DOCKET & l201 SECTI(N V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.4.3 shall be subject to determination of the extent of in-take and retention by analysis of excreta or body counting.
The bioassay program shall be conducted in accord with Regulatory Guide 8.11, " Application of Bioassay for Uranium".
Periodic " blank" or " spike" samples shall be included in the bioassay program.
8.4.4 Personnel Contamination
" Change room" facilities shall be provided for the control of contamination spread from areas where sig-nificant quantities of unclad SNM are handled.
Normal exit from controlled areas shall be through change room facilities.
The change room shall include personnel decontamination and monitoring capability.
External contamination of personnel entering controlled areas shall be limited by means of protective clothing.
The degree and type of protection required is determined by Health-Safety, depending on the contamination potential ***
in the area under consideration.
Required protection may range from a minimum of lab coats and shoe covers over street clothes to coveralls, haircaps, gloves, and special shoe for areas of higher contamination potential.
The use of anti-contamination clothing DATE 2-10-86 REVISION NO.
3 PAGE 55 CURRENT REVISION:
SUPERSEDES: PAGE 76 lENRC APPROVAL REFERENCE 2-04-85 DATE REVISION
BABC00( & WILCOX C0WANY, COMERCIAL NUCLEAR REL PLM USNRC LICENSE SNPt-ll68 DOCKET D E l V CONDITIONS SECTICN 8.0 Technical Specifications - Radiation Safety (continued) 8.4.4 within the plant is limited to the controlled area, except as specifically authorized and monitored by Heal th-Safety.
Radiation monitors, incorporating audible and/or visual alarms, shall be located at routine exit points from controlled areas.
The monitor alarm point shall be set as low as practicable taking into account the necessity for reducing spurious alarms induced by background fluctuations. Health-Safety shall be noti-fied when initial decontamination attempts fail to reduce skin contamination below the monitor alarm point. Health-Safety shall assist during further decontamination, as necessary, to levels as low as reasonably achievable, consistent with good health physics practice before releasing the employee.
8.4.5 Surface Contamination Control The following criteria shall be applied to monitoring -
and control of surface contamination.
The levels shown represent contamination levels which, when ex-ceeded, shall cause prompt clean-up activities of the affected area to be initiated.
DATE 2-10-06 REVISION NO.
3 PAGE 56 CURREt(T REVISION:
SUPERSEDES: PAGE 77 USNRC APPROVAL REFERENCE DATE 2-04-05 REVISION 2
BABC00( & WIUDX COPANY, CutERCIAL NUClfAR REL PUE USNRC UCENSE SNPt-ll68 DOCKET & l201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.4.5 Area Action Level Survey Frequency 2
1.
Controlled pellet Removable:
5,000 DPM/100 cm Weekly proiessing/ rod Total 50,000 DPM/ 50 cm loa 6ing, change room (hot area) 2 2.
Change Room Removable:
-500 DPM/100 cm Daily *
(Intermediate)
Total 2,000 DPM/ 50 cm 2
3.
Clean (Remainder of Removable:
200 DPM/100 cm Monthly plant and office Total 500 DPM/ 50 cm area)
- When pellet processing operations are being conducted.
In no case shall there be more than one week between surveys.
The levels established for Item "1" abcve are defined for the general area including floors and other exposed surfaces. The contamination levels in hoods and on equipment that directly contacts SNM cannot be effectively speci fied.
Control shall be maintained through frequent cleacup and limitation of powder accumulation.
Tools and equip 1ent removed from controlled areas for uncontrolled use elsewhere in the plant shall not exceed that specified for clean areas unless specified by Heal th-Sa fety.
In such cases, Health-Safety may impose limitations on use or require other controls to preclude con-i taminacion spread.
I DATE 2-10-86 REVISION No, 3
PAGE 57 1
CURREffr REVISION:
SUPERSEDES: PAGE 78 USNRC APPROVAL REFERENCE DATE 2-04-85 2
REVISICN j
B/GCOG( & WIL(DX CCFPMY, C0tERCIAL NUQIAR Fi A PIM USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTICN 8.D Technical Specifications - Radiation Safety (. continued) 8.4.6 Health-Safety may approve the performance of non-routine or temporary operations in the manufacturing area outside the controlled area when the operation may result in contamination provided the following controls are established and documented:
- The area involved is identified and access controlled.
- Necessary area and personnel contamination control and monitoring programs are implenented including use of anti-contamination clothing if needed and air sampling as required.
- During the course of the operation, decontamination shall be initiated when general contamination levels in excess of 1000 DPM/100 cm2 (removable) or 2,500 DPM/50 cm2 (total) are noted.
Following completion of the operation, decontamination to clean area levels specified in Paragraph 8.4.5 shall be accomplished.
8.4.7 Operations which are not covered by an operating procedure and are judged by cognizant supervision as being likely to exceed the concentration limits specified in Table I of Appendix B to 10 CFR Part 20, shall be covered by a Radiation Work Permit (RWP).
The RWP shall be issued by the Health-Safety group.
It ***
shall specify the safety requirements, protective clothing and equipment, and monitoring requirements necessary to assure the operation is conducted in a safe manner.
8.5 Receiving Inspection _
8.5.1 SNM receipts shall be inspected for damage, and surveys conducted to ascertain if the level of contamination is acceptable for CNFP handling and storage.
Results in excess of contamination limits specified by the Department of Transportation shall be reported to Health-Safety for DATE 2-10-86 REVISICH NO.
3 PAGE 58 CURRENT REV1SICN:
SUPERSEDES: PACE 79 USNRC APPROVAL REFERENCE 2-04-85 DATE REVISICU
BABC00( a WIL(DX CCNANY, GMERCIAL NlE:fAR REL PIM USNRC LICENSE SNPt-1168 DOCKET &l201 V CONDITIONS SECTIOl 8.0 Technical Specifications - Radiation Safety (continued) 8.5.1 notification of the shipper and evaluation of the need for decontamination.
8.6 Non-Exempt Sealed Source Control 8.6.1 Use of non-exempt sources for training and instrument calibration shall be limited to, or under the direct control of, qualified Health-Safety personnel.
8.6.2 Sources utilized as a functional component of devices designated for manufacturing and quality control purposes shall be operated only by approved personnel who have been instructed in safe practice by Health-Satety.
Health-Safety shall provide appropriate monitoring support """
during maintenance or other operations that may entail increased exposure levels. A register of approved operators shall be maintained in the Health-Safety Office.
8.6.3 Maximum whole body exposure rate,s in any constantly occupied area in the vicinity of operating manufacturing or quality control units utilizing by-product material sources shall be less than 2 mrem /hr.
8.6.4 In addition to dosimetric devices routinely worn by all CNFP employees, appropriate self-reading dosimeters shall be utilized by personnel involved in source DATE 2-10-f6 REVISIO1 NO.
3 PAGE 59 CURRENT REVISION:
SUPERSEDES: PACE 59 USNRC APPROVAL REFERENCE DATE 2-04-85 REVISIOg 2
BABC0CK a WILC0X C0WA'iY, C0t?ERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 l
SECTION V CONDITIONS 10.
Failed Fuel Rod Detection System 10.1 Description of Activities A Radiation Control Zone (RCZ) will be established for activities with the ECH0-330 when it is out of the storage configuration.
i Typical activities performed on the ECH0-330 equipment in the RCZ l
include decontamination, repair, testing, and packaging.
The ECH0-330 will be appropriately packaged and labeled to prevent contamination spread when in the storage configuration.
10.2 Radiation Control Zone (RCZ)
The following conditions apply to the establishment and maintenance of the RCZ.
10.2.1 The RCZ will be physically defined (rope and/or changeline tape) at tre CNFP plant site.
10.2.2 All maintenance of contaminated ECH0-330 equipment shall te performed within the RCZ.
10.2.3 The action levels used for radiological control within the RCZ are given in Table 1 of this part.
10.2.4 Access to the RCZ area shall require approval of Health-Safety.
+**
i b
4 DATE 2-10-86 REVISION NO.
1 PAGE 67 CURRENT REVISICtt:
SUPERSEDES: PAGE 67 USNRC APPROVAL REFERENCE 5-07-85 0
DATE REVISION
~
IMBC0CK a WILCOX C0WA% COWERCIAL NUCLEAR FIF1 PLM USNRC LICENSE SNft-ll68 DOCKET D E l SEM V
CONDITIONS -
10.
Failed Fuel Rod Detection' $ystem 10.2.5 Radiological surveys shall be performed as contaminated ECH0-330 equipment is unloaded.
10.2.6 Contaminated equipment that exceeds the Radiation Control Zone limits in Table 1 shall be decontaminated.
10.2.7 Radiological surveys shall be documented and maintained by Health-Safety personnel for a minimum of 2 years or longer if required by Federal Regulations.
10.2.8 During periods of maintenance.on the contaminated equip-ment, radiological surveys of the RCZ shall be performed at ***
least daily.
l DATE 2-10-86 REVISION NO, 1
FAGE 68 CURRENT REVISION:
SUPERSEDES: PAGE 68 USNRC APPROVAL REFERENCE DATE 5-07-85 REVISION 0
- - __-_~ -
BABC0CK a WILC0X C0WN#l C0ffERCIAL NUClfA REL PlNT USNRC LICENSE SNtt-ll68 DOCKET 70-1201 SECT. ION V
CONDITIONS'.
3 10.
Failed fuel-Rod Detection System 10.2.9 Removal of RCZ designation (including physical markings like ropes and changelines) shall require a documented survey that the RCZ area meets the Unrestricted Area Release Limits in Table 2 of this part.
10.2.10 All personnel entering the RCZ shall wear as a minimum pro-tective lab coats and shoe covers. All personnel handling contaminated equipment shall also wear protective gloves.
Upon exiting the RCZ, personnel shall survey to assure they meet unrestricted area release limits given in Table 2 of this part.
10.2.11 Radiation workers shall receive initial indoctrination training before they are allowed to work in the RCZ.
This training is as described in Paragraph 6.2 of Section V of SNM-1168.
DATE 2-10-86 REVISION NO, 1
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BABC0CK a WILC0X COWANYj C0fff_RCIAL NUCLEAR FLEL Pl#T USNRC LICENSE SNft-ll68 DOCKET & l201 SECTION V
CONDITIONS 10.
Failed Fuel Rod Detection System 10.2.12 Instrumentation shall be calibrated as indicated in Section 8.3.4.
- u*
10.2.13 Respirators may be used in unusual conditions where air-borne concentrations of radioactive material may cause personnel to receive exposures in excess of permissible levels.
Typical unusual conditions may be certain maintenance operations, short-term operations, etc. Pro-cedures for maintenance of the respirators and training of personnel using respirators shall be under the cognizance of Health-Safety.
i l
DATE 2-10-86 REVISION No, 1
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BABC0CK a WILCOX COM%1Y, C0i?ERCIAL NIELEAR FlEL PLAlT 4
USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTION
.V.
CONDITIONS 20.
Failed Fuel Rod Detection System 10.2.13 The Respiratory Protection Program shall be conducted in accord with 10 CFR 20.103.
10.2.14 Personnel and/or fixed air samplers shall be used to deter-mine exposure to airborne radioactivity during maintenance operations.
Health-Safety shall specify frequency of per-sonnel sampling based on operational experience and Health Physics judgement to keep exposures within 10 CFR 20.103(a) limits.
Gaseous effluents from the RCZ shall be used to determine compliance with 10 CFR 20.106(a).
Fixed boundary and RCZ air samples shall be run daily during maintenance operations.
HEPA filtered containment facili-ties such as disposable tents or enclosures, shall be used in accord with good Health Physics practice as required by Health-Safety to control airborne radioac-tivity. HEPA filters shall be changed when the differential pressure exceeds 4" of water.
Differential pressure shall be recorded weekly when containment facilities are in use.
2-10-86 DATE REVISION NO, 1
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DATE 5-07-85 REVISION 0
BABC0CK & WILC0X COWANY, GPERCIAL NUCLEAR FLEL PlM USNRC LICENSE SNti-ll68 DOCKET 70-1201 j
SECTION
.V CONDITIONS i
10.
Failed Fuel Rod Detection System 10.2.15 Personnel working directly in the RCZ shall be included in the bioassay program of at least one in vivo measurement per year, if they work in an area which is designated as an airborne radioactivity area as defined in 10 CFR 20.203(d).
Additional bioassays shall be performed when, in the judgement of Health-Safety that conditions during work were such that significant internal exposure may have occurred. Such conditions include but are not limited to:
1.
Nasal smear results indicating facial contamination in excess of 10,000 DPM.
2.
An internal exposure in excess of 40 MPC. Hr. in any seven consecutive days.
3.
Any accidental internal exposure, whether real or suspected.
Immediate followup bioassay (excreta) measurements shall be performed if any of the 3 conditions noted above exist. If the followup measurements confirm the presence of greater than 10% of the maximum permissible organ burden, the worker will be restricted from work in a contaminated airborne environment until the maximum permissible organ burden is under 10%.
DATE 2-10-86 REVISION NO, 1
PAGE 72 CURRENT REVISION:
l 1
SUPERSEDES: PAGE 72 USNRC APPROVAL REFERENCE 1
DATE 5-07-85 REVISION 0
_ _ _ -. ~ ___ _,,._ _ __.._-._, _
BABC0CK a WILC0X COWN4Y, C0tfERCIAL NUClfAR FUEL PLAT -
USNRC LICENSE SNft-ll68 DOCKET 70-E01 SECTION V CONDITIONS 10.
Failed Fuel Rod Detection System 10.2.15 Prior to Health-Safety approval of an individual to work in the RCZ, the individual's occupational radiation exposure history (both internal and external) shall be reviewed.
10.2.16 The reactor inspection equipment contain only contamination quantities of by-product material and there-fore does not require special handling with regard to nuclear criticality safety.
10.2.17 Contaminated wastes that cannot be disposed of under the current conditions in Section V will be transferred to a licensed facility for subsequent disposition.
s.
DATE 2-10-86 REVISION NO, 1
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BABC0CK & WILCOX C0WAW, C0ffERCIAL NUClfAR FUEL PLAlff USNRC LICENSE Snit-ll68 DOCKET 70.1201 SECTION V
CONDITIONS TABLE 1:
RADIATION CONTROL ZONE (RCZ) LIMITS
- 4 Beta-Gamma i
Total (Fixed & Removable)
Item External Radiation Removable Contamination 2,,
- 1. Protective Clothing
.5 mR/hr. at 1 cm 5,000 DPM/100 cm
- 2. Equipment Maintenance 2
and Storage 50 mR/hr. at 1 ft.
500,000 cpm /100 cm
- 3. Floors, Walls, and 2
other Surfaces 1.0 mR/hr. at 1 ft.
5,000 DPM/100 cm
.i 1
- Alpha contamination will be controlled as indicated in i
Part 8.4.5 of Section V.
- "As measured by direct survey.
DATE 2-10-86 REVISION NO, 1
PAGE 74 CURRENT REVISION:
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DATE REVISION
4 BABC0CK c, WILC0X sfAT(, C0fERCIAL NUClfAR FUEL PLAff USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTION V. CONDITIONS.
TABLE 2:
UNRESTRICTED AREA RELEASE LIMITS
- Beta-Gamma Item External Radiation '
Removable Contamination
^'
- 1. Skin, Hair, and
_ -~ - --
Personal Clothing -
~
Mi'n.' DbtEcfable Level.
Min. Detectable Level **
~
2
- 2. Equipment 0.5 mfi/hr.. at 1 cm 1,000 DPM/100 cm
- 3. Floors, Walls, and 2
Other Surfaces 0.2 mR/hr. at 1 cm' 1,000 DPM/100 cm
- Alpha contamination will be controlled as indicated in Part 8.4.5 of Section V.
- As measured by direct survey.
w.
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3 I
2-10-86 REVISION NO.
1 PAGE 75 DATE CURRENT REVISION:
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DATE REVISION
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