ML20148L100
| ML20148L100 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 02/26/1988 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 29095, NUDOCS 8804010143 | |
| Download: ML20148L100 (8) | |
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Attention: Mr. L. C. Rouse, Chief b
Fuel Cycle Safety Branch DM j p}
Division of Industrial and Medical Nuc
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Washington, D.C.
20555 N
g License No. SNM-1227 Docket No. 70-1257
Dear Mr. Rouse:
Advanced Nuclear Fuels Corporation (ANF) hereby requests that License No. SNM-1227 be amended to update dosimetry requirements to place ANF in compliance with the revision to 10 CFR 20.202, to update the special nuclear materials safeguards references which were modified in compliance with 10 CFR 74.31(b),
to modify our treatment of HEPA filter systems, and to correct a typographical error in our in-vivo examination program.
Copies of the revised (Rev. 15) pages of the license application, document ANF-2, reflecting these changes are enclosed for your review.
A recent revision to 10 CFR 20.202 rquires, among other things, that all personnel dosimeters which are used to comply with conditions specified in a licensee's license must be processed and evaluated by a dosimetry processor accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Bureau of Standards'.
Section 3.2.5.2 of our license states, "All persons entering a radioactive materials area, of..the plant are required to wear S-y sensitive dosimeters."
It has been our policy in the past to i
require all employees to wear S-7 sensitive dostr.atws-arid all visitors who might leave the office area and visit ;the plant itself were also issued dosimeters.
It is our plan to continue that Spolicy; however, only those personnel who fall within the definition of. 20,202(a) will be required to wear the NVLAP accredited dosimeter.
Section 3.2.5.2 of,our license application has been modified to reflect the change in requimments'.
Section 1.6.6 of our license application addresses special nuclear material safeguards rquirements.
When this license application was submitted we weru in the process of modifying our safeguards control plan to conform to the new LEU reform rule.
The process is now complete and the appropriate section of our license application has been revised accordingly.
Section 5.1.1.1 of our licer.se application describes those instances when in-place testing of final HEPA filter installations are required.
One instance, c,
is following actuation of the sprinkler deluge system.
We propose to change that requirement to read, "Following actuation of the fog deluge system if determined necessary by Equipment and Maintenance Engineering following a visual / operational inspection."
The fog deluge system is located in the ductwork prior to the final filters and when activated the fog cools the gases 8804010143 880226 PDR ADOCK 07001257 C
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February 26, 1988 i
on their way to the filters.
The fog does not spray directly on the filters.
As a result, activation of the fog deluge system does not of itself necessarily affect the final filter system.
This fact has been confirmed on occasions when the deluge system has tripped inadvertently and followup inspectionand testing of the filter system has shown it to be within requirements.
This change in license requirements will allow returning a ventilation system to normal much more quickly then awaiting testing and at no compromise to safety.
Section 5.1.1.2 describes a specific system used to protect final HEPA filters.
Protection of filters from corrosive fumes is described as accomplished by liquid scrubbing followed by heating.
There are certain cases where small potentially corrosive gas flows are mixed with large non-corrosive gas flows and diluted to the point where filter system corrosion is not considered to be a problem.
In the same section of the license filter fire protection is described as being accomplished by liquid scrubbing, automatic fog deluge or cool air
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injection.
Cool air injection has not been used and is not planned to be used and is therefore eliminated as an option.
It was intended that this option be removed during license renewal but was inadvertently retained.
1 Section 3.2.7(5)(c) which is a part of the description of our bioassay program has a typographical error whereby it establishes an action level for females at 56 nanocuries rather than the real limit of 0.56 nanocuries.
This error has been corrected.
It is our judgment that the amendments to our license application described above in no way lessen the safety of the operation nor our commitment to maintain a strong ALARA policy.
The revised pages enclosed for your review will become Revision 15 and are redated to February 22, 1988.
The changes on each page are identified by a vertical line in the right hand margin.
Following your approval, these revisions will be officially distributed by ANF Document Control.
Enclosed is a check for $150 as a filing fee for this amendment application.
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ADVANCED NUCLEAR FUELS CORPORATION ANF-8 SPECIAL NUCLEAR MATERIAL LICENSE 'NO. SNM-1227, NRC DOCKET NO. 70-1257 REV.
PART I - LICENSE CONDITIONS 15 1.6.4 Postina Exemotion All areas in which radioactive materials are stored, handled or used shall be posted with signs meeting the requirements of Title 10 CFR Part 20.203, except that of 20.203(f).
In lieu of 20.203(f) requirements, a sign bearing the legend, "Every container or vessel in thi: area, unless otherwise identified, may contain radioactive material," may be posted at entrances to each building in which radioactive materials are used, stored or handled.
1.6.5 Waste Discosal Pursuant to 10 CFR 20.302, disposal of solid waste material con-taining 30 pCi/ gram oc less to other than a licensed waste disposal facility is authorized. The low enriched uranium shall not exceed 30 pCi/ gram of dry solid waste material.
The uranium shall be essentially uniformly distributed throughout the waste material.
1.6.6 Special Nuclear Material Safeauards Specific safeguards requirements for special nuclear material are given in Safeguards Amendment SG-2 issued pursuant to 10 CFR Parts 70, i
73, 74 and 75.
Those conditions are not affected by this licensing action.
1.6.6.1 Physical Security Advanced Nuclear fuels shall follow the special safeguards con-ditions given in the Safeguards Amendment SG-2 and the NRC approved i
security plan submitted in accordance with the provisions of 10 CFR Part 73.67(c)(1). The NRC approved security plan is:
1.
XN NF-538, "Physical Protection Plan for Material of Low Strategic Significance."
This document shall be maintained in a current and approved status and shall be properly imple-mented.
1.6.6.2 Material Control and Accountina Advanced Nuclear fuels shall fc flow the special safeguards con-ditions given in the Safeguards Amen bent SG-2 and the NRC approved Fundamental Nuclear Material Control Plan (FNMC) submitted in accordance with 10 CFR Part 74.31(b).
The NRC approved FNMC Plan is:
AMENDMENT APPLICATION DATE:
P AGE NO.:
XN NF FO1822 (6'87)
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DVANCED NUCLEAR FUELS CORPORATION ANF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 REV.
PART I - LICENSE CONDITIONS ly, 1.
ANF-12, "Nuclear Material Safeguards Procedures Description for the Fuels Fabrication Plant," (Revision 18).
This document shall be maintained in a current and approved status and shall be properly implemented.
1.6.7 Authorization at Reactor Sites Advanced Nuclear Fuels Corporation is authorized to possess fuel assemblies or fuel rods at reactor sites for the purpose of loading them into shipping containers and delivering them to a carrier for transport.
.i 1.6.8 Authorized Release Guidelines Advanced Nuclear Fuels Corporation is authorized to release equip-ment, scrap or facilities for unrestricted use, or for termination of license according to the "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Sourco, or Special Nuclear Material" as published by the U. S. Nuclear Regulatory Commission dated August 1987.
A copy of these guidelines is contained in Appendix A to Chapter 3.
I I
AMENDMENT APPLICATION DATE:
PAGE NO.:
XN44F-F01822 (6/87)
DVANCED NUCLEAR FUELS CORPORATION ANF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 REV.
PART I - L: CENSE CONDITIONS 15 In addition to the controls specified elsewhere, the following methods of external radiation exposure control are employed as applicable and reasonable:
1.
Automation of operations.
2.
Minimization of quantities of radioactive material and/or use of shielding.
3.
Time and distance control.
4.
Special handling tools.
5.
Exposure awareness, planning and scheduling.
3.2.5.1 Radiation Surv_e.y_s A detailed survey of radiation levels (S-7 and neutron, as applic-able) is performed for each specific operation and radioactive material storage area as activity in the area is initiated.
Routine radiation surveys are performed at least monthly in all areas where radioactive materials are stored or processed, and where personnel have access.
Radiation surveys are performed on all incoming and outgoing shipments of radioactive materials per 10 CFR 20.
3.2.5.2 Dosimetry Persons requiring radiation exposure monitoring per 10 CFR 20.202(a) wear B-y sensitive dosimeters which are processed and evaluated by a processor holding current accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Bureau of Standards.
For these personnel, exposure monitoring dosimeters are exchanged and analyzed quarterly.
The #-y dosimeters are supplemented, as appropriate, by other types of dosimeters (i.e.,
finger rings, direct-reading dosimeters, and neutron dosimeters), and by radiation measurements made with radiation survey instruments.
Film badge dosimeters, if used, shall be exchanged and analyzed monthly.
Personnel dosimeters shall be capable of measuring the following radiation exposure ranges: beta / gamma dosimeters: 10 mrem - 1000 rem.
AMENDMENT APPLIC ATION DATE:
February 22, 1988 3-7 XN-NFJ01822 (6/87)
ADVANCED NUCLEAR FUELS CORPORATION Ane-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 R EV.
PART I - LICEtiSE CONDITI0t4S 15 b.
Should the future 12 month dose commitment exceed 8 rems (approximately 200 micrograms, 0.43 nanocuries U-235) the actions of "a" above shall apply and the workers shall be considered for exclusion from work in a contamination control area, Should the future 12 month dose commitment exceed 12 rem c.
(approximately 300 micrograms, 0.64 nanocuries (male) 260 micrograms, 0.56 nanocuries (female) U-235), the actions in "a"
above will apply and the worker shall not be allowed to work in a contamination control area until the time when his future dose commitment for the subsequent 12 month period to the lung is less than 8 rem.
PAGE NO.:
3-12 AMENDMENT APPLICATION DATE:
February 22, 1988 XN-NF F01422 ( 6.11 7)
ADVANCED NUCLEAR FUELS CORPORATION AllF-2
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SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 REV.
PART I - LICENSE CONDITIONS 15 Only HEPA filters which are certified by the manufacturer to be at least 99.97 percent efficient for the removal of 0.3 micron particles shall be used. The adequacy of final HEPA filter installations shall be determined by in-place testing to assure that they are at least 99.95 I
percent efficient for the removal of 0.8 micron particles prior to initiating operations with radioactive materfals in the following in.:tances:
a.
Startup of a new facility; b.
Following maintenance work on the filter bank and/or i
replacement filters; or c.
Following actuation of the fog deluge system if determined necessary by Equipment and Maintenance Engineering following a visual / operational inspection.
5.1.1.2 Final HEPA Filter Protection Air exhausted from process equipment containing potentially corrosive fumes may be liquid scrubbed, heated and/or diluted prior to final HEPA filtration.
Final HEPA filters potentially exposed to i
corrosive fumes are visually inspected at least quarterly.
Final HEPA filters in the fuel fabrication ' buildings are protected from damage in the event of fire by one of the following design features:
1.
A liquid scrubber in the exhaust air stream upstream of the filters.
2.
An automatic (actuated by neat detectors located in the exhaust air ducts) fog deluge system in the exhaust air stream upstream of the filters.
Final HEPA filter installations are equipped with continuous pressure differential measuring / indicating devices, which are read and the readings recorded at least monthly.
The Ap across final HEPA filters is not allowed to exceed four inches of water gage.
5.1.2 Liauid Effluent Controls Advanced Nuclear Fuels shall maintain and use liquid effluent treatment systems to maintain releases of radioactive material in liquid effluents to unrestricted areas as far below the limits specified in 10 CFR 20.106 as is reasonably achievable, and in accordance with 10 CFR 20.303.
Procedures have AMENDMENT APPLIC ATION DATE:
P AGE NO.:
gg XNhF401-822 $17)
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