Text

Application for Renewal of License SNM-942
	ML20155K131
Person / Time
Site:	07000984
Issue date:	04/30/1986
From:	; Battelle Memorial Institute, PACIFIC NORTHWEST NATION
To:	;
Shared Package
ML20155K129	List: ML20155K124; ML20155K131;
References
	PNL-5848, NUDOCS 8605270377
	Download: ML20155K131 (136)
	v • d • e

{{#Wiki_filter:. -.. I i PNL-5848 ' O i i APPLICATION FOR RENEWAL OF I' NRC SPECIAL NUCLEAR MATERIALS LICENSE SNM-942 i i Prepared by Laboratory Safety } l l 1iO j April 1986 i i j Prepared for the U.S. Nuclear Regulatory Comission i I I Battelle, Pacific Northwest Laboratories Richland, Washington l 1 i O PM C

l TABLE OF CONTENTS 4 em PART I - LICENSE CONDITIONS Chapter 1 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS..... 1 1.1 Name.......................... 1 1.2 Location........................ 1 1.3 License Number and Period of Time the License Is Requested For...................... 1 1.4 Possession Limits.................... 1 1.5 Location Where Material Will Be Used.......... 1 1.6 De fi n i ti ons....................... 1 1.7 Authorized Activities.................. 2 1 1.8 Exemptions and Special Authorizations.......... 2 i 1.8.1 Occupational Dose Limits............. 2 2 1.8.2 Calendar Quarter................. 2 1.8.3 Exposure Records and Reports for Current Exposure Year.................. 3 1.8.4 Records of Liquid Waste Disposals........ 3 l 1.8.5 Criticality Detection System........... 3 Chapter 2 GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 1 0 2.1 Battelle-Northwest's Policy............... 1 2.2 Organizational Responsibilities and Authorities..... 1 2.3 Safety Review Committees................ 3 2.3.1 Safety Review Council.............. 3 2.3.2 Triennial Safety Review Board.......... 3 i 2.3.3 Operational Readiness Review Boards....... 3 i 2.3.4 Laboratory Safety Organization.......... 3 l 2.4 Approval Authority for Personnel Selections....... 4 2.5 Personnel Education and Experience Requirements..... 4 2.6 Training........................ 4 ) 2.7 Operating Procedures.................. 5 2.8 Internal Audits and Inspections............. 5 2.9 Investigations and Reporting of Off-Normal Occurrences. 6 2.10 Records......................... 8 l Chapter 3 RADIATION PROTECTION.................. I 1 3.1 Special Administrative Requirements........... 1 3.1.1 Radiation Work Permit Procedures......... 1 3.1.2 ALARA Policy................... 1 ,lO '2 '""'"' ""***" 111 l .=------,..------,--------------+-...n. ,---m-mn-y-.,,----g, .4.- -,g.--r ,w- -my e~---r+,

w-,

e+,

Page h Chapter 3 (contd) 3.2.1 Access Control.................. 2 3.2.2 Ventilation Requirements............. 2 3.2.3 Instrumentation................. 3 3.2.4 Internal and External Exposure.......... 4 Chapter 4 NUCLEAR CRITICALITY SAFETY............... 1 4.1 Special Administrative Requirements........... 1 4.2 Technical Requirements................. 3 4.2.1 Facility Classification............. 3 4.2.2 Safety Factors and Assumptions.......... 4 4.2.3 Neutron Reflection................ 4 4.2.4 Neutron Moderation................ 4 4.2.5 Neutron Interaction............... 4 4.2.6 Special Reflectors and Moderators........ 5 4.2.7 Other Administrative and Technical Controls... 5 Chapter 5 ENVIRONMENTAL PROTECTION................ 1 5.1 Effluent Control Systems................ 1 g 5.2 Envi ronmental Monitoring................ 2 Chapter 6 SPECIAL PROCESS COMMITMENTS.............. 1 Chapter 7 DECOMMISSIONING PLAN.................. 1 Chapter 8 RADIOLOGICAL CONTINGENCY PLAN............. 1 PART II - SAFETY DEMONSTRATION Chapter 9 OVERVIEW OF OPERATION................. 1 9.1 Corporate Information............. 1 9.2 Financial Qualifications................ 1 9.3 Summary of Operating Objective and Process....... 1 9.4 Si te Descri ption.................... 1 9.5 Location of Buildings Onsite.............. 5 9.6 Maps and Plot Plans................... 5 9.7 License History..................... 5 9.7.1 H i s t o ry..................... 5 9.7.2 Amendments Since Latest Renewal......... 5 9.7.3 Organizational Changes.............. 5 9.8 Changes in Procedures, Facilities and Equipment..... 7 1 l iv 1 l

O fage Chapter 9 (contd) 9.8.1 Safety Review System............... 7 9.8.2 Responsibilities................. 8 Chapter 10 FACILITY DESCRIPTION................. 1 10.1 Plant Layout...................... 1 10.2 General Description of Facilities........... 1 10.2.1 30GW Facility.................. 1 10.2.2 Physical Sciences Laboratory.......... 6 10.3 Waste Handling..................... 6 10.3.1 Liquid Wastes.................. 6 10.3.2 Justification for Exemption from Liquid Waste Records Requirement............ 9 10.3.3 Solid Wastes.................. 9 1 10.4 Fire Protection.................... 9 Chapter 11 ORGANIZATION AND PERSONNEL.............. 1 11.1 Organizational Responsibilities............. I 11.1.1 Laboratory Director............... I 11.1.2 Director of Facilities and Operations...... 1 11.1.3 Manager of the Laboratory Safety Department... 1 11.1.4 Manager of the Emergency Planning Office.... 4 11.1.5 Manager of the Safeguards and Security Department................... 5 11.1.6 Line Management................. 6 11.1.7 Manager of the Health Physics Department.... 7 11.1.8 Senior Specialist, Criticality Analysis..... 8 11.1.9 Manager of the Earth Sciences Department.... 9' 11.2 Organization Charts................... 9 11.3 Organizational Procedures................ 12 11.4 Functions of Key Personnel............... 13 11.5 Education and Experience of Ke 14 11.6 Training...........y Personnel........ 23 Chapter 12 RADIATION PROTECTION fROCEDURES AND EQUIPMENT..... 1 1 1 12.1 Procedures....................... 1 ) 12.2 Posting and L'abeling........... -....... 3 l 12.3 Personnel Moni toring.................. 4 12.3.1 Justification for Substitution of' DOE 5480.1 Expos u re Li mi ts................. 5 y 4 n n* m

Page Chapter 12 (contd) 12.3.2 Justification for Use of Calendar Quarter Beginning on the Last Saturday of December... 6 12.4 Surveys......................... 6 12.5 Reports and Records................... 7 12.6 Instrumentation..................... 8 12.6.1 Portable Survey Instruments........... 8 12.6.2 Cri ti cal i ty Moni tors.............. 11 12.7 Protective Clothing................... 12 12.8 Administrative Control Levels.............. 12 12.8.1 Occupational Exposure.............. 12 12.8.2 Airborne Activity................ 13 12.8.3 Liquid Waste Activity.............. 14 12.8.4 Surface Contamination.............. 14 12.9 Respiratory Protection.................. 15 Chapter 13 OCCUPATIONAL RADIATION EXPOSURES............ I h 13.1 Occupational Exposure Analysis.............. I 13.2 Measures Taken to Implement ALARA............ I 13.3 Bioassay Program..................... 2 13.4 Air Sampling Program................... 3 13.4.1 Air Sampling Equipment.............. 3 13.4.2 Air Sample Counting Equipment.......... 4 13.4.3 Radiation Detection in Air............ 6 13.5 Surface Contamination.................. 7 13.6 Shipping and Receiving.................. 8 Chapter 14 ENVIRONMENTAL SAFETY - RADIOLOGICAL AND NONRADI0 LOGICAL.................... 1 Chapter 15 NUCLEAR CRITICALITY SAFETY............... I 15.1 Administrative and Technical Procedures......... 1 15.1.1 Responsibilities and Authority.......... 1 15.1.2 Training..................... 2 15.1.3 Audits and Inspections.............. 3 15.1.4 Fissionable Material Limits and Administrative Controls............. 5 15.1.5 Limit Violation and Criticality Emergency.... 10 15.2 Preferred Approach to Design............... 13 vi

/~N g U Chapter 15 (contd) 15.3 Basic Assumptions.................... 13 15.4 Analytical Methods and Validation References....... 16 15.4.1 Calculational Methods.............. 16 15.4.2 Neutron Interaction Calculations......... 16 15.5 Data Sources....................... 17 15.6 Fixed Poisons...................... 17 15.7 Structural Integrity Policy and Review Requirements... 17 15.8 Special Controls..................... 18 15.8.1 Fire Fighting Symbol............... 18 15.8.2 Additional Posting................ 18 15.8.3 Posting of Exterior Walls and Entry Points in Isolated Facilities 18 15.8.4 Posting of Walls in Adjacent Rooms of Isolated Facilities............... 18 Chapter 16 PROCESS DESCRIPTION AND SAFETY ANALYSES........ I 16.1 Physical Sciences Laboratory.............. 1 16.2 306W Facility...................... 1 16.2.1 Diversified Metal-Working Facility........ 1 16.2.2 Ceramics Laboratory............... 3 16.2.3 Specialty Machine Shop.............. 7 Chapter 17 ACCIDENT ANALYSIS.. '................. 1 O vii

w-, -- O PART I LICENSE CONDITIONS O l O I i l

Q Chapter 1 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1.1 Name Battelle, Pacific Northwest Laboratories of the Pacific Northwest Division of Battelle Memorial Institute (hereinafter referred to as Battelle-Northwest orBNW). 1.2 Location Post Office Box 999, Battelle Boulevard, Richland, Washington 99352. 1.3 License Number and Period of Time the License is Requested for This document is an application for renewal of license SNM-942 for a period of five (5) years. 1.4 Possession Limits License coverage is sought for enriched uranium and all isotopes of plu-tonium. These materials may be handled in any physical or chemical form. The maximum quantity of licensed materials that will be in inventory under the control of BNW at any time will be less than one (1) effective kilogram [as defined in 10 CFR 70.4(t)] of uranium-233, uranium-235 and plutonium, and s less than 5,000 grams of contained uranium-235, uranium-233, and plutonium, 1 CJ except that the quantity of plutonium shall be no greater than 1.5 grams, unless BNW possesses an approved radiological contingency plan. If BNW pos-sesses an approved radiological contingency plan, the maximum quantity of plutonium shall be no greater than 200 grams. 1.5 LocationWhereMaterTalWillBeUsed The primary work locations are the 306W facility located in the 300 Area of the Department of Energy's (DOE) Hanford Site near Richland, Washington, and BNW's privately owned Physical Sciences Laboratory (PSL) located on Battelle Boulevard, which is approximately one mile south of the 300 Area. Other future work locations may include BNW-controlled, but DOE-owned, facilities located on or adjacent to the Hanford Site, and facilities privately owned by BNW located in Richland, Washington. Additional temporary work locations may include sponsor's laboratories and facilities at locations remote from the Hanford Site and Richland, Washington. Any facilities other than 306W or PSL where licensed work is to be performed will have at least the equivalent of the safety systems and programs described in this application for 306W and PSL. 1.6 Definitions Definitions used in this application correspond to those in standard references. I.1-1

h 1.7 Authorized Activities Battelle-Northwest performs contract research and development activities for many sponsors, both government and industrial, in practically all areas of the physical and life sciences except human medicine. Small amounts of special nuclear materials are used in support of research and development work related to the production and processing of nuclear fuels and fuel mate-rial. In addition, special nuclear materials are used in a wide variety of nonfuel research and development programs, including but not limited to the following areas: determining the effects of ionizing radiation on biological systems developing improved methods for dosimetry of ionizing radiation e measuring, minimizing, and controlling radioactivity released to the environment developing reactor systems, materials and components studying irradiation effects e developing improved activation analysis techniques reprocessing of irradiated fuels and neutron target materials for recovery of products and radionuclides g developing radioactive waste processing procedures. No special nuclear materials will be produced under this license because it is not intended to cover the operation of a nuclear reactor or insertion of any licensed material into a nuclear reactor. 1.8 Exemptions and Special Authorizations Pursuant to 10 CFR 20.501, BNW requests the following exemptions from the requirements of 10 CFR 20 and 10 CFR 70. Justifications are provided in the sections of Part II indicated in parentheses. 1.8.1 Occupational Dose Limits (Part II, Chapter 12, Section 12.3) It is requested that BNW be allowed to substitute the occupational dose limits specified by the DOE Orders for those listed in 10 CFR 20.101(a). 1.8.2 Calendar Quarter (Part II, Chapter 12, Section 12.3) Battelle-Northwest requests exemption from the requirement of 10 CFR 20.3(a)(4) that specifies, "The first calendar quarter of each year shall begin in January...". For purposes of personnel dosimetry, BNW begins the first calendar quarter of each year with the last Saturday of December. O I.1-2

Q 1.8.3 Exposure Records and Reports for Current Exposure Year (Part II, Chapter 12, Section 12.5) Battelle-Northwest requests exemption from the requirement of 10 CFR 20.401(a) which states that employee exposure records be maintained on NRC Form 5 or equivalent. Battelle-Northwest maintains exposure records that contain all of the required information with the exception of items 13 (running total for calendar quarter) and 18 (unused part of permissible accumulated dose). 1.8.4 Records of Liquid Oaste Disposals (Part II, Chapter 10, Section 10.4.1) Battelle-Northwest requests exemption to the requirement of 10 CFR 20.401(b) for maintaining records of disposal of licensed materials to the 300 Area liquid waste systems. 1.8.5 Criticality Detection System (Part II, Chapter 15, Section 15.1) Battelle-Northwest requests that installation of criticality detection systems only in facilities containing more than 45% of a minimum critical mass be accepted as an alternate to the criteria described in 10 CFR 70.24(a). 4 e a I.1-3

O Chapter 2 GENERAL ORGANIZATION AND ADMINISTRATIVE REQUIREMENTS J 2.1 Battelle-Northwest's Policy Battelle-Northwest's policy for radiation protection is: " human exposure to ionizing radiation from both internal and external sources shall be kept as low as reasonably achievable through application of the best protective equipment, methods, and designs that are technically and economically feasible. The radiation protection program must meet the high professional standards of health physics and must remain responsive to all applicable requirements of DOE and other government regulatory agencies" (BNW Management Guide, 11.4 Radiation Protection). 2.2 Organizational Responsibilities and Authorities The BNW radiation protection program is administered by the facilities and operations support organization and the research organization. Within the support organization, the laboratory safety function is responsible for the establishment and conduct of the radiation protection and the nuclear safety programs. They also serve as the BNW contact with the Nuclear Regulatory Commission (NRC) for matters pertaining to this license renewal application. The support organization is also responsible for the emergency preparedness program and for safeguards and security. The broad responsibilities and functions of these organizations include the following: establishing the policies, standards and limits to be applied throughout BNW in nuclear safety and radiation protection providing review and approval on the design modification or development of facilities, equipment, and methods to be used in all work. Included in these approvals are project proposals, facility design criteria, facil-ity modification permits, radiation work permits, criticality safety specifications, and related documents. performing inspections, audits, and reviews of facilities and procedures and initiating changes necessary to assure a high level of criticality prevention measures and personnel radiation protection and compliance within all facilities and by all employees . measuring and recording radiological conditions in all work locations where sources of radiation are present and prescribing the protection methods to be employed in performing the work . administering an effective program to maintain exposure to radiation as low as reasonably achievable (ALARA) . conducting a surveillance progru to define the geographical and biological distribution of radioactive materials in the plant environs; determining the status of the plant environs with respect to applicable limits and I.2-1

1 guides; and establishing appropriate guides for the controlled release h of radioactive materials from facilities establishing procedures and maintaining records of the shipment of radio-active materials from BNW to other locations either on or off the Hanford Site reviewing safety analyses for reactors, critical facilities, and labora-tories containing fissile materials or significant quantities of radio-nuclides or other hazardous materials planning and coordinating programs designed to cope with off-normal events e within facilities participating in formal investigations of off-normal events maintaining records and providing necessary reports to meet all BNW, as well as state and federal, requirements in the areas described above. The research group is responsible for procuring and calibrating radiation instruments and dosimeters, maintaining dosimetry records and internal and external dose evaluations, monitoring and evaluating environmental conditions, and for providing the technical expertise to make the nuclear criticality safety calculations that establish nuclear safety conditions. A criticality analysis group within the research group is maintained g that is independent of the laboratory safety function. This group provides technical criteria on matters pertaining to criticality safety, establishes technical bases for criticality safety specifications, approves technical adequacy of criticality safety specifications, performs technical reviews of facilities and operations from a criticality safety standpoint, and parti-cipates along with the laboratory safety organization in the conduct of annual criticality safety appraisals of the operation of nuclear facilities. Individuals within this research group, who are designated as a specialist or senior specialist, approve criticality safety specifications and technical bases for criticality safety specifications. A criticality safety representative is appointed for each nuclear facility by operations management. The representative reports to the operating manager and is responsible for the facility's internal auditing, approved criticality safety specifications and for providing liaison with the laboratory safety organization. The representative is trained by the research criticality analysis group or by the laboratory safety organization in the instruction and procedures on criticality safety that are pertinent to the assignment as criticality safety representative. The appointment is subject to the concurrence of the laboratory safety management responsible for criticality safety. Battelle-Northwest maintains an organization that is responsible for nuclear materials management. This organization is separate from the operating departments of BNW and serves as the BNW official contact for all matters concerning security, safeguards and management of special nuclear materials as I.2-2

Q they pertain to this license renewal application. Responsibilities of the organization include the following: establishing the policies, standards and limits for security and nuclear material safeguards to be applied throughout BNW maintaining a system of control and management of nuclear materials that will optimize procurement cost, use and recovery providing the custodial care and special procedures to prevent diversion or unauthorized use providing audits to ensure compliance with appropriate security and safe-guards procedures establishing and maintaining an inventory, material transfer and forecast system for special nuclear materials. 2.3 Safety Review Committees 2.3.1 Safety Review Council The Safety Review Council is responsible for providing the Laboratory Director with expert safety review and advice on activities with significant safety impilca' ions. The council reviews and approves all safety analysis reports, techns 11 specifications and operational safety requirements. It meets pd as frequently as necessary to perform required reviews. Members of the council are persons recognized as authorities in their specific fields. Council members have sufficient knowledge of related fields so that the council, collectively, has the broad competence necessary to produce thorough safety reviews in all technical fields. 2.3.2 Triennial Safety Review Board The Triennial Safety Review Board reviews the overall adequacy of the BNW safety program at least every three years. This board consists of senior management and technical staff outside of the laboratory safety organization. I 2.3.3 Operational Readiness Review Boards An operational readiness review board defines and ensures completion of all factors necessary for appropriate projects with significant safety risks to be considered operationally ready to start up safely and efficiently. 2.3.4 Laboratory Safety Organization The laboratory safety organization provides guidance to management on the need for safety reviews and operational readiness reviews; conducts compre-hensive safety audit and appraisal program for all BNW operations and facili-tias; and provides review of facility modification permits, risk assessments, safety specifications, and fire protection systems. O I.2-3

2.4 Approval Authority for Personnel Selections g Battelle-Northwest exercises a one-over-one approval review for all trans-fers, promotions, and new hires. Hence, technical staff selections for safety-related positions are proposed by the immediate manager or supervisor but must be approved by one higher level before actions can take place. Careful attention is paid to professional training, work experience, growth potential, and soundness of character for all personnel moves or new hires. 2.5 Personnel Education and Experience Requirements Management and technical leadership positions require appropriate training and experience. Key radiation protection positions are staffed by certified health physicists or staff with varied and broad proven experience or training in health physics. The highly technical nature of BNW's research work, as well as the need for an excellent radiation protection program, require highly trained and capable staff members. In addition to the operational health physics programs, BNW has a substantial health physics research program. This activity attracts very capable staff, affords the opportunity to transfer staff between various kinds of work depending on the current demand, and, in addition, ensures a pool of highly trained health physics staff to meet any particular operational needs. 2.6 Training The primary purpose of BNW's radiation safety training program is to provide staff members with the knowledge and skill to perform their radiation work responsibilities and assignments safely. All training is documented in sufficient detail to evaluate the adequacy of the training. This documentation includes, but is not limited to: specific radiation training criteria describing the needs of each staff member, identi-fication of applicable radiation control requirements for the staff member's work, location of training / retraining, evaluation of the effectiveness of the training (written examination, oral examination, or observation of performance), and the trainer's signature and date. A staff member receiving training in basic radiation principles and pro-tection practices is designated a radiation worker. Radiation workers are permitted unescorted access to BNW-controlled radiation areas. Staff members who have not received this training arc escorted and supervised by a qualified radiation worker when in a radiation area. Biennial retraining is required to maintain qualification as a radiation worker. Job-specific radiation safety training and retraining is given in addition to the General Radiation Safety Training course. It includes, but is not limited to, discussion of the applicable specific control procedures, safe operating procedures for working with radioactive materials or radiation gen-erating devices, location of radioactive sources within the radiation area, specific or unusual hazards associated with the job assignment, and job-specific emergency procedures. The frequency of retraining is at least biennial. 9 I.2-4

(] 2.7 Operating Procedures Basic radiation protection standards and practices applicable to all BNW private and government operations in the Richland-Hanford area, as well as to offsite operations, are established in the BNW Radiation Protection manual (PNL-MA-6). The manual specifies that all staff members involved in the hand-ling or processing of radioactive materials or in the operation of radiation generating devices shall have a knowledge of radiation protection procedures. All BNW staff members are required to adhere to requirements stated in the manual. Line management must be familiar with the contents of the manual and ensure that their staff members understand the portions of the manual that apply to their job assignments. Any deviation from the intent of the manual requires the approval of the manager of the laboratory safety organization, who is also responsible for interpreting the requirements. Facilities managed by BNW that contain radioactive materials in such quantity or form that a significant risk is possible to the health and safety of staff members or the public are required to have documented safety evalua-tions. These evaluations are in the form of analyses that define risks and establish the basis for controls for the safe operation of the facilities. For DOE-owned nonreactor nuclear facilities containing radionuclides in quantities and forms that pose a significant risk, the safety evaluation is documented as a safety analysis report (SAR) prepared by line management of the facility or project and submitted to the DOE Richland Operations Office /7 for review before the involved facility operation or equipment is started. U The SAR must show that the nuclear facility and its safety-related systems can, with reasonable assurances, be operated with adequate provisions for the protection of onsite personnel, the public, property, and the environment. The safety requirements that define the controls required to ensure the safe operation of a nuclear facility managed by BNW are identified in the SAR as operational safety requirements. These requirements present, in detail, the conditions, safety boundaries, and management controls required to control to an acceptable level all identified environmental, safety, and health risks associated with the operation. The operational safety requirements are binding on the facility and can only be changed by revising or supplementing the SAR. A facility that may contain more than 3% of the minimum critical mass of fissionable material is assigned special design requirements and administrative controls. Fissile material processing is only conducted in accordance with approved written procedures. 2.8 Internal Audits and Inspections In accordance with written policy and procedures, BNW's safety appraisal program is composed of appraisals, audits, inspections, and the triennial review, all of which evaluate conformance with applicable regulations, license conditions, and department or facility safety programs. An appraisal is a multidisciplinary review of the safety program within a department or facility. An appraisal normally includes the safety disciplines of radiation protection, I.2-5 i _n ~

nuclear safety, emergency preparedness, industrial safety, industrial hygiene, g fire protection, waste management, training, and hazardous naterial shipping. Environmental protection considerations are covered in the operational safety requirements for the facility and are also evaluated during the appraisal. Audits are scheduled checks for compliance with BNW manuals or other require-ments. Most audits are integrated into the appraisal. Inspections are field checks of a facility for safety hazards. Inspections may either be conducted unannounced or informally as walkthroughs. The triennial review is an appraisal of BNW's safety program made every three years by senior management and tech-nical staff outside of the laboratory safety organization. Appraisals, audits, and inspections are conducted by safety professionals. The baseline building inspection frequency is determined by using written facility risk evaluation criteria. Facilities are reevaluated every two years for their baseline inspection frequency. The baseline inspection frequency is then increased as warranted by the hazardous material inventory or by other applicable regulations. Nonreactor nuclear facilities and reactor facilitie 1 are given an annual appraisal. Low-inventory nonreactor nuclear facilities are on a biennial appraisal frequency. Chemical hazards are also taken into account in deter-mining appraisal schedules. As with radioactive materials, the nature and the amounts of the chemicals provide quantitative guidance in determining the frequency of inspections. Appraisal reports are distributed to the appraisal coordinator, team g members, and members of the appraised organization. Responses to the findings w and observations of the report are required. The appraisal team leader is responsible for an appraisal until it is closed out with a formal written notice. To close out an appraisal, the i.eam must accept the responses to all items, findings and observations of the report. Items that have been assigned engineering requests and other long-term action items are followed up during the next appraisal. Audit and inspection reports are distributed to section managers, depart-ment managers, building managers, and other responsible individuals in the audited organization. A written reply to the report is required from the audited organization's management only for any items of noncompliance or defi-ciency. If the response is not acceptable, the auditor or inspector works with the audited organization's or facility's representatives to clarify and resolve the issue until an acceptable response is achieved. Follow-up on corrective action items is made during the next audit, inspection, or appraisal. 2.9 Investigations and Reporting of Otf-Normal Occurrences Battelle-Northwest defines an off-normal event as an unplanned or unexpected event, or the discovery of a deficiency in a procedure, plan, or system that has real or potentially undesirable consequences to personnel, equipment, facilities, and/or programs. This includes damage, loss, failure, or delays that can reasonably be expected to have undesirable consequences. G I.2-6

O Battelle-Northwest has an integrated system that provides an appropriate d level of notification and evaluation for all off-normal events. The objectives of this system are to: ensure that notification is made to the appropriate level of management in a timely manner in order to apply all resources necessary towards the mitigation and stabilization of any off-normal event . ensure the gathering and documentation of adequate information on which to base management action obtain early, complete, and factual information on events as a basis for reports to DOE, other government agencies, and sponsors investigate and evaluate events to determine their causes and appropriate measures to prevent recurrence and improve performance, reliability and safety of operations provide information on events, causes and corrective actions that can be used by others to avoid similar occurrences . gather data useful in trend analysis, personnel training, procedure revi-sions and other improvements. An off-normal event reportable to the NRC is defined as any defect, devia-A tion or failure to comply with 10 CFR 21 requirements for facilities or activ-V ities licensed by the NRC that would present or lead to a substantial safety hazard. Specific definitions are as follows: defect -- deviation in a basic component delivered, installed, used, or operated in a facility or in an activity subject to 10 CFR 21 regulation, or in a portion of a facility subject to the construction permit or manu-facturing licensing requirements of 10 CFR 50 deviation -- departure from the technical requirements included in a pro-curement document noncompliance -- a failure to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order, or license of the NRC relating to substantial safety hazards. An off-normal event that is formally reportable is termed an unusual occurrence. An unusual occurrence is any unusual or unplanned event having programmatic significance such that it adversely affects or potentially affects the performance, reliability, or safety of a facility. Unusual occurrences include but are not limited to the items specified in the applicable DOE Orders. Other off-normal events are reported and inves-tigated according to other internal procedures, i I.2-7 -.. ~. - . - -., - - - - + - 1

After the appropriate notifications have been made for an off-normal a event, the event is evaluated or investigated to determine the cause and appro-W priate measures to prevent recurrence. The level of the investigation depends on the severity and classification of the event. For example, an off-normal event not meeting the criteria of an unusual occurrence will normally require a simple evaluation, whereas an unusual occurrence requires a more in-depth investigation. The information obtained is used as a basis for reports to appropriate agencies. Investigations of severe unusual occurrences are conducted by internal investigation boards. These boards report directly to the cognizant Director (or his delegate) and are responsible for gathering adequate information on which to base subsequent management actions. Boards normally consist of three to five members, one of whom is appointed as chairperson. At least one member is a trained accident investigator, and all areas of expertise are considered including managerial, scientific, professional and investigative. Staff members directly related to the operation or activity involved in the occurrence do not serve on a board, but are available to the board to provide information as requested. Less severe unusual occurrences and other off-normal events are investigated by responsible managers. In all cases the information obtained is documented to allow trend analyses and other comparison of data. 2.10 Records Specific records and the retention periods are shown below. The respon-sibility for retention of each of these record categories is assigned to a specific organization. Record Retention Period Facilities modifications 10 to 20 years Off-normal event and unusual occurrence records permanent Criticality safety specifications permanent Audits and inspections 3 years Instrument calibrations permanent Safety training permanent Personnel exposure records permanent Radiation surveys 1 year locally, then to archives Environmental surveys permanent 9l I.2-8

O Chapter 3 RADIATION PROTECTION 3.1 Special Administrative Requirements Radiation Work Permit Procedures (a) 3.1.1 No work with radioactive material is permitted unless authorized by a valid radiation work procedure or permit (RWP is used for both the procedure and the permit). The RWPs are obtained by line management completing a radiation control protocol (RCP) and sending this form to the radiation protec-tion organization. Radiation protection personnel review and evaluate the RCP and write the RWP. All RWPs are issued with dates showing how long the RWP is valid. Before the expiration date, radiation protection personnel review the RWP with the appropriate line organization for which the RWP applies. Valid RWPs are reissued with appropriate changes; RWPs, when no longer needed, are voided. This review is documented and, after an appropriate retention period, is sent to permanent records storage. 3.1.2 ALARA Policy The administrative policy for the ALARA program is contained in BNW Manage-ment Guide 11.4, which states: " Human exposure to ionizing radiation from both internal and external sources shall be kept as low as practicable through application of the best protective equipment, methods, and designs technically and economic- ^ r ally feasible." The application of the ALARA policy to the BNW radiation safety program is stated in Radiation Protection, PNL-MA-6: "The basic radiation protection policy of Battelle is destyned to maintain radiation exposures of personnel and the environment to the lowest levels practicable, consnensurate with sound economics and g)ood operating prac-tices. The "as low as reasonably achievable" (ALARA concept should be interpreted as an intent to implement practices that minimize total per-sonnel exposures to radiation from all Battelle operations. The procedures and practices presented in this manual are intended to achieve this objec-tive." The laboratory safety organization is responsible for coordinating the ALARA program. This involves ongoing review and trend analysis of external exposure and internal deposition data, disseminaticn of ALARA information to staff and management, and review of all RWPs. (a) Radiation work permit procedures used by BNW includa the radiation work permit, the radiation work procedure, and the radiation work specification. These procedure forms are equivalent for specifying(The initialism, RWP, as radiation protection requirements for work with radioactive materials. used in this document, refers to both the radiation work procedure and the O radiationworkpermit.) I.3-1 ... _ -., _ -,, _ ~ _ _ _, r

3.2 Technical Requirements g 3.2.1 Access Control Control of access to radioactive materials is provided by posting all places where significant radiation exposure can be received as required by 10 CFR 20 and by establishing an RWP for the area. The radiation protection organization establishes the requirements for protective clothing, step-off pads, and personnel contamination monitoring, depending on the potential for contamination. Portable radiation detection instruments or hand and shoe counters are provided whenever personnel are required to monitor themselves before exiting a potentially contaminated radiation area. 3.2.2 Ventilation Requirements Particulate radioactivity in airborne effluents are minimized by equipping ventilation systems with one or more stages high-efficiency particulate air (HEPA) filters. The specific HEPA filtration requirements for each radio-nuclide depend on its relative toxicity, quantity, dispersibility, and nature of work to be performed. These requirements are determined by the laboratory safety organization. HEPA filters are aerosol tested individually before they are installed. An individual HEPA filter is not accepted for installation if the particulate removal efficiency is less than 99.97% for 0.3-micron-diameter dust particles. With the exception of HEPA filters located directly in shielded hot cells, h hoods, or glove boxes, all HEPA filters are aerosol tested immediately after placement and at least annually thereafter using the standard aerosol-testing procedure. Differential pressure measurements are included as part of this test. HEPA filter banks must be at least 99.95% efficient using the standard aerosol test. The operating pressure drop range is established for each filter bank installation. An unplanned decrease in pressure drop must be reported to the laboratory safety organization. The filter is replaced when the pressure drop exceeds the manufacturer's recommendations or when leakage is indicated. Release of other hazardous materials present in the effluent stream as gases or vapors is minimized. If required, special absorbers or other treat-ments are used. Cleanup systems are used that are adequate to ensure that the discharges of radioactive materials to the environment do not result in staff member or public exposure to radiation concentrations in excess of values specified in 00E Orders. Experimental equipment, vacuum systems, and process air systems having a potential to exhaust radioactive contamination are HEPA filtered. Each new gaseous effluent cleanup is tested in-place for efficiency before O I.3-2

(] use. The test results are reviewed and the system approved by the laboratory safety organization before routine use. 3.2.3 Instrunantation (Survey, Counting, Criticality Monitors) The instruunts currently used at BNW are listed in Tables 3.1 through 3.4. Instruments are maintained and calibrated with standards traceable to the National Bureau of Standards. Electronic signal pulsers, which are used in conjunction with radioactive standards, are calibrated at the HEDL Standards Laboratory which maintains traceability to the National Bureau of Standards. TABLE 3.1 Portable Instruments Used for Contamination Surveys Range Calibration Calibration Model/Name of Units Method Frequency Alpha PAM 0-100,000 cpm 23sTh fixture / 3 mo pulser Alpha Pac-6 0-500,000 cpm 23sTh fixture / 3 mo pulser Beta Gamma 0-100,000 cpm beta calibra-6 mo on probe; Thin-Wall tion fixture / 6 wk for count rate meter GM pulser { TABLE 3.2 Portable Instruments Used For Exposure Rate and Dose Rate Surveys Range Calibration Calibration Model/Name of Units Method Frequency CP Ion Chamber 0-5000 mR/h 137Cs cali-3 mo R0-3B 4 ranges bration well LPC Ion Chamber 0-50 R/h high-exposure 6 mo max. (3 mo usual) facility TPC Ion Chamber 0-500 R/h high-exposure 6 mo max. (3 mo usual) facility HPC Ion Chamber 0-6000 R/h high-exposure 6 mo max. (3 mo usual) facility Model 325 0-50000 R/h high-exposure 3 mo linear and facility 0-10,000 R/h I logarithmic Snoopy Neutron 0-2000 mrem /h neutron well 2 mo Q 1 BF Detector 4 ranges 3 I.3-3 4 e n, ,y

TABLE 3.3 Semiportable Air Particulate Monitors h Range Calibration Calibration Model/Name of Units Method Frequency Alpha 3 0-5000 cpm 23sPu standard / 1 yr Particulate 3 ranges pulser Alpha 5 0-10000 cpm 239Pu standard / 1 yr Particulate logarithmic pulser Beta Par-0-50000 cpm 14C, 99Tc, 1 yr ticulate 3 ranges 38Ce, 21sB1, AMS 2 231Pa / pulser Beta Par-0-10000 cpm C, 99Tc, 1 yr 14 ticulate logarithmic 38Ce, 21sB1, AMS 3 231Pa / pulser TABLE 3.4 Fixed Criticality Monitors Range Calibration Calibration Model/Name of Units Method Frequency BFa Neutron set to alarm Pu-Be in 1 yr g~ Detector at 80 mrem /h calibration in 1 sec fixture 3.2.4 Internal and External Exposure The following subsections describe the programs and engineered systems used to protect personnel from excessive internal and external exposures. Ventilation Building ventilation systems are designed to meet the performance criteria of PNL-MA-3, Radiological Design Criteria. In general, ventilation systems are designed to remove from routinely occupied areas airborne radioactive materials resulting from normal and abnormal conditions, and to limit releases to the environment from expected operations to less than 1% of the values in the DOE Orders. Ventilation systems also are designed to produce airflow patterns from the environment into buildings containing radioactive materials. Within buildings, air flows from uncontaminated areas into areas of succes-sively higher potential for contamination. Airflow between areas is maintained ) by establishing pressure differentials and results in between 4 and 8 air changes per hour. i G' I.3-4

Air Sampling and Analysis Administrative control limits for fixed air samplers for room air and effluent air are as follows: Room Air Effluent Air Alpha 1.0 X 10-12 pCi/cc 3.0 X 10-12 pC1/cc Beta-Gamma 5.0 X 10-18 pCi/cc 5.0 X 10-12 pC1/cc These values represent one-half of the maximum permissible concentration for occupational exposure for room air for plutonium-239 (alpha) and strontium-39 (beta-gamma), and one-sixth of the maximum permissible concentration for the satne radionuclides for nonoccupational exposure for effluent air. An inves-tigation by radiation protection personnel is required if these values are exceeded. Alpha alarm levels for continuous air monitors are generally set at 40 cpm, corresponding to approximately 26 mpc-hours for occupational exposure to 23'Pu. Airflow calibration for fixed air sampling apparatus is performed after any design change, modification, or major repair to the building vacuum system. l The calibration is checked visually whenever samples are exchanged. Continuous air monitors are calibrated annually to applicable ANSI standards. q Bioassay NJ All employees who are routinely exposed to enriched uranium are sched-uled for an annual urinalysis for elemental uranium. The minimum detectable limit for this analysis is 0.03 micrograms per 500 milliliter sample, at the 95% confidence level. Accuracy is +20% at 20 times the detection limit. Inves-tigation and derived investigation Tevels are established at 1% of the radiation protection standards in DOE Orders. Protective Clothing Protective clothing is used to protect personnel from direct contact with radioactive material and secondarily as a contamination control technique. Requirements for protective clothing are prescribed by the radiation protection organization on the applicable RWP. Protective clothing may include coveralls, lab coats, rubber and fabric shoe covers, rubber and fabric gloves, and head covers. Worn or damaged protective clothing is returned to the laundry for disposal. Excessively contaminated protective clothing is disposed of as radioactive waste. Respiratory Protection Respiratory protection requirements are prescribed by radiation protection on the applicable RWP. Respiratory protection equipment is required whenever the airborne concentration exceeds the limits specified in DOE Orders, or when radiation protection detects conditions in which these airborne radio-Q activity concentration limits may be exceeded. Respiratory protection equipment I.3-5 .p .nn, --,-.,_--n ,w.- ,.---,--.n

must be approved by the laboratory safety organization. Only individuals who g have been trained and who have been fitted for a respirator are permitted to use respiratory protective equipment. Surface Contamination Monitoring Frequency of routine contamination monitoring for laboratories, offices, and other areas is prescribed by radiation protection personnel depending on the potential for contamination. Items or materials in a radiation area are considered radioactive or contaminated until released by radiation protection personnel. Exceptions may be allowed if they are specified in the applicable RWP. Decontamination Unconditional release limits for the unrestricted release of radioactively contaminated property are stated in Table 3.5. TABLE 3.5 Unconditional Release Limits for the Unrestricted Release of Radio-actively Contaminated Property Release Limit, dpm/100cm2 Radionuclides Removable (smearable) Total (fixed plus removable) Transuranics, 22 era, 20 300 22sRa, 23sTh, 231Pa, 227Ac, 1251, 129 1 Th-natural, 232 h, 200 3000 T S8Sr, 223Ra, 224Ra, 2320, 12e1, 131y, 1331 U-natural, 23s, 1000 15,000 u and associated decay products Beta-gamma emitters 1000 15,000 (nuclides with decay modes other than alpha emission or spontaneous fission) except S8Sr and others noted above 9 I.3-6

Personnel Monitoring (External Radiation) The work environment of all employees is reviewed to determine the type and processing frequency of the dosimeter (s) to be worn. An individual's assigned dostmeter may be either a basic or multipurpose dosimeter based on the potential for the individual's exposure. Routine processing frequency may vary from annual to monthly depending on the potential for exposure. Ring dosimeters are assigned to individuals if exposure conditions warrant. i 4 l l i !O i, i i i t lO l I.3-7 f I

t CHAPTER 4 NUCLEAR CRITICALITY SAFETY 4.1 Special Administrative Requirements Battelle-Northwest uses a two-contingency policy which states that at least two unlikely, independent and concurrent errors or accidents must occur before a criticality accident is possible. To implement this two-contingency l policy, formal procedures for the control of fissionable materials are main-l tained. The principal procedure for control of fissionable materials is the cri-ticality safety specification (CSS), a written procedure which gives limits. to ensure criticality safety in facilities processing, storing, or otherwise handling significant quantities of fissionable material. Any work involving more than 45% of the minimum critical mass of fissionable materials is conducted l in a nuclear facility under an approved. CSS. An approved CSS is required for i any work involving fissionable materials, with the following exceptions: l natural and depleted uranium and thorium . work in a facility where only exempt quantities, i.e., less than 3% of the minimum critical mass, are present I work in an isolated facility where the amount of fissionable material j does not exceed one of the limits in Table 4.1 or Table 4.2. If more than one type of fissionable material is involved in an isolated facil-j 'J ity, the sum of the fractions of the allowed masses shall not exceed one. Also, fissionable material in the form of encapsulated sources j containing more than Table 4.1 or Table.4.2 values may be handled under j isolation control upon written agreement with the Richland Operations Office of DOE. l Facility criticality safety representatives or their appointed delegates { are responsible for obtaining new or revised CSSs. The senior specialist, i criticality safety, is available to provide technical bases for establishing criticality safety limits. The nuclear safety group within the laboratory safety organization provides assistance in preparing and distributing the CSSs. Each CSS is approved or concurred with by the following or their authorized j representative: j specialist, criticality safety senior specialist, criticality safety senior engineer, nuclear safety technical leader, nuclear safety building manager cf the building in which the CSS will be used j . criticality safety representative of the building i . manager of the operating component in the affected facility, i !O l I.4-1 j s

TABLE 4.123s0 Limits for an Isolated Facility (a) Allowable Weight 23sU, wt% for U, kg 23sy, q 0.71 No Limit No Limit 1.0 900 9000 1.5 168.8 2532 1.7 121.4 2065 2.0 81.1 1622 2.5 49.1 1228 3.0 35.1 1053 3.5 27.9 977 4.0 22.0 880 4.5 18.3 823 5.0 15.6 783 8.0 7.9 632 10.0 5.85 585 20.0 2.48 496 25.0 1.88 472 30.0 1.5 450 40.0 1.07 428 50.0 0.826 413 75.0 0.501 376 93.0 0.396 369 96.0 0.384 369 h 97.0 0.380 369 100.0 0.369 369 (a)Although these quantities may exceed license limits, they are meant to show controls for material which may also be present under DOE programs. Pu and 233U Limits for an Isolated Facility (a) TABLE 4.2 Isotope Limit, a Less than 50% 23sPu 230 (total Pu) More than 50% 23aPu 1500 (total Pu) 2330 256 (a) Although these quantities may exceed license limits they are meant to show controls for material that may also be present under DOE programs. Approval by the responsible manager formally establishes the specification as a written instruction to all members of the organization. Approval by the manager of the nuclear safety group shows that the specification is consistent with DOE and BNW policies and regulations and consistent with good safety g I.4-2

a .F L,4_-. 4- -ea

M-

....6

i.e+>ea u

e a m uy -a# we -g ._.A.m .-,+. -.4 i i practices. The signature of the senior specialist, criticality safety,. estab-lishes that the technical bases for the specification are correct. Fissionable material, including fuel rods, vials, capsules, devices, etc., is marked or labeled as prescribed in DOE Orders concerning nuclear materials management and safeguards. Moderated fissionable materials are identified by a yellow label with magenta border. Unmoderated fissionable materials are identified by a yellow label. A criticality safety limit. sign is conspicuously posted on the exterior l of all enclosures (glove boxes, hoods, refrigerators, etc.) or in the immediate vicinity of each work or storage location for fissionable material. The limit signs include (as applicable) the following information: type and fom of material permitted (e.g., Pu-oxide 2 wt% Pu0 ) 2 allowable quantity (grams, pounds or number of pieces) or geometry limit { restrictions on moderators t i required spacing to other fissionable materials appitcable CSS number (s). j When the complexity or variety of fissionable material warrants, the following sign and the applicable CSS may be substituted. CRITICALITY SAFETY LIMITS l ONLY (list types of fissionable material) PERMITTED. ALL PROCESSING (or " storage") SHALL BE CONDUCTED IN ACCORDANCE WITH CSS NUMBER 4.2 Technical Requirements 4 The mandatory criticality safety limits are identified through a technical analysis of the specified work involving fissionable material. The analysis is made by a criticality safety specialist and is documented by issuing a basis memo. These technical bases are reviewed and approved by the senior i specialist, criticality safety'. The basis memo is maintained in a permanent file by the nuclear safety group. 4.2.1 Facility Classifications a l A BNW-controlled facility is classified as either an exempt, isolated or fissionable material facility. An exempt facility is one that contains less than 3% of a minimum critical mass. An isolated facility may contain up to l 45% of a minimum critical mass while a fissionable material facility may contain j more than 45% of a minimum critical mass. Before a building can be designated j as a fissionable material facility in which greater than 45% of a minimum l I.4-3 i i

critical mass of fissionable material may be handled, a safety analysis report (SAR) is required. Also, any significant modification or additional work not previously covered in an SAR requires a safety analysis in a supplemental SAR. An SAR is the result of a thorough study that is performed to ensure that potential major nuclear hazards have been analyzed and appropriate action taken to reduce the probability of major accidents and to minimize the conse-quences in the unlikely event of their occurrence. The safety analysis consid-ers foreseeable nuclear accidents that would substantially threaten the safety of personnel or the public, the use of or damage to property, and the con-tinuity of operation of facilities. Each SAR, and each revision, requires the approval of the responsible department manager and the Safety Review Council and review by the Richland Operations Office of DOE. 4.2.2 Safety Factors and Assumptions Criticality safety limits used in establishing a CSS are based on data from experimental measurements or, if direct experimental data are not avail-able, on limits obtained from a calculational method that can be shown to be accurate or conservative when compared to experimental measurements. The maximum fractions that independently satisfy the two-contingency criteria for criticality safety are: 0.45 of critical mass 0.75 of critical volume W 0.7S of critical mass per unit area 0.85 of critical slab thickness 0.85 of critical cylinder diameter 0.95 k,gg. 4.2.3 Neutron Reflection Safe limits are based on full water reflection except when less reflec-tion can be ensured by the two-contingency policy. 4.2.4 Neutron Moderation Safe Ifmits are based on optimum water moderation, unless other than optimum moderation can be ensured by the two-contingency policy. 4.2.5 Neutron Interaction For vessels or units in arrays in which neutron interaction contributes to reactivity, allowance factors to obtain safety margins depends on the method used to calculate the critical number of units in the array and on how well the method predicts criticality for arrays that have been measured experimen-tally. O I.4-4

[ ({]) 4.2.6 Special Reflectors and Moderators For instances where fissionable material processing or handling involves special reflectors or moderators, such as D 0, carbon, beryllium or heavy 2 metal reflectors, criticality safety is assessed on an individual basis. 4.2.7 Other Administrative and Technical Controls Geometry control of fissionable material is the preferred means of criti-cality safety control and is used wherever feasible. Criticality safety dimen-2 sions are attributed to spherical geometry, unless equipment design ensures a geometry less favorable to criticality than spherical (e.g., cylinder or slab). In processes conducted behind massive shielding, soluble and fixed neutron poisons such as boron in solution, Pyrex Raschig rings, and steel plates con-taining boron or gadolinium may be used as a primary means of criticality safety control. In processes not conducted behind massive shielding, fixed poisons may be used as a primary means of criticality control, if the positive design measures and maintenance controls ensure that the poison is always present and that leaching of the poison away from the matrix does not occur. Battelle-Northwest's nuclear safety program is described in PNL-MA-25, Criticality Safety. Operations with fissionable materials are conducted in accordance with this manual and, where applicable, ANSI /ANS-8.3-1979, "Criti-cality Accident Alarm System," ANSI N16-1-1975, " Safety Standards for Operations With Fissionable Materials Outside Reactors," and ANSI /ANS-8.5-1979, "Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber.in Solutions of Fissile Materials." \\ ) l 1 i I 4 ' O I.4-5

h 4 i O Chapter 5 ENVIRONMENTAL PROTECTION i 5.1 Effluent Control Systems Licensed work is performed in the same facilities using the same equipment i as work under the operating contract with DOE. It is, therefore, not normally possible to distinguish between the quantities of gaseous and liquid wastes from license and contract work. In general, only a small fraction of the radioactive materials in these effluents results from work performed under i the license. Waste handling and disposal requirements are documented in j PNL-MA-8, Waste Management. All radioactive materials in liquid and gaseous i effluents are controlled at or below the values shown in Appendix B of 10 CFR 20 at the release point. Radioactive gaseous waste streams are released to the atmosphere only after high-efficiency filtration and, in some cases, cnemical treatment. All radioactive waste that is disposed of as a liquid is disposed to systems operated by the Westinghouse Hanford Company, who has an operating contract j with DOE. See subsection 10.3 for discussion of these systems. 1 The liquid waste created by license work that can be segregated is con-verted by evaporation or absorption td a solid and disposed as solid waste. All solid wastes created by license work that can be segregated is packaged i according to the document PNL-MA-8, Waste Management. It is shipped to the [CD commercial waste facility on the Hanford Site for disposal. Management of l the laboratory safety organization is responsible for issuing controls and for appraisals determining compliance with the controls. If the concentrations of radioactive and other hazardous materials in a gaseous or liquid effluent stream exceed the concentration guide (s) in the DOE Orders, the building manager or other responsible line manager, upon being notified, promptly initiates the necessary actions to reduce the abnormal release to below the concentration guide. These actions are taken according to the following schedule: i 1 to 10 times the concentration guide -- within 1 week e 10 to 100 times the concentration guide -- within 1 day 100 times the concentration guide -- within 2 hours. l In addition, the laboratory safety organization is notified in the event that: ] effluent release guides are known to or suspected to have been exceeded effluent samples are lost or not exchanged as required i e f a transient, accidental or unusual release of significant quantities of J nonradioactive hazardous material to the environment is known to or may J have occurred 1 the concentration of radioactivity in a gaseous effluent stream exceeds e !O 1.0 x 10-" pC1/ml alpha and/or 5.0 x 10- pC1/ml beta gamma I.5-1 - =

t ,a s' there has been an advertent release of radioactive material to a disposal h site the disposal of a specific waste results in an established operating ' limit being exceeded l a waste is dispesed of without required approval or concurrence, or otherwise not in conformance with the disposal procedure waste storage facilities or associated measurementisystems fail or are modified without authorization.- ~ ST5 Environmental Monitoring The Hanford 'envirormental surveillance program, which is conducted by BNW, provl des for. the measurement, interpretation, and evaluation of environ-mental samples and other^ measurements to assess environmental impact, determine compliance with pertinent regulations, and evaluate the adequacy of onsite waste management practices. The program is designed to evaluate all significant path >vays of potential environmental impact, with emphasis on those that are most significant. Summaries and evaluations of the data generated during the performance of environmental surveillance activities are published annually. Samples of air, surface water, soil, vegetation, wildlife, and ground water are collected, and external penetrating radiation dose measurements are made both on and off the Hanford Site. Samples are analyzed for radioactive h constituents including tritium, strontium-90, plutonium, and gamma-emitting radionuclides. In addition, site roads, railroad tracks, and burial grounds are surveyed periodically to detect any abnormal levels of radioactivity. Radioactive and nonradioactive waste discharges and environmental related unusual occurrences reported for the major operating areas are reviewed and summarized. . The Hanford environmental surveillance program is designed to assess the environmental impact of all Hanford operations. The environmental impact of work performed under license SNM 942 represents an extremely small fraction of the total of all Hanford operations. The quantities of material authorized under license SNM 942 are extremely small in comparison to the quantities routinely handled by BNW and other Hanford Contractors under DOE programs. In addition,' no significant operations have taken place with NRC-licensed material since the last renewal in 1980. The licensed material has been in storage since that time. Even if any operations had taken place under the license, it would be impossible to differentiate their impact from that of ther rest of Hanford operatLions. 4 I.5-2

O Chapter 6 SPECIAL PROCESS COMMITMENTS Because of the highly variable nature of the research and development Work that may be u'idertaken by BNW, it is not possible to predict at this time special procedures or actions which may be required for unique processes or operations to ensure radiological safety, nuclear criticality safety, or fire protection. All new projects undertaken by BNW will be subjected to tae applicable safety reviews described in Chapter 9, subsection 9.7, which may include safety analysis review, operational readiness review, design review, and any other reviews specified by the laboratory safety organization. O i l l l O I.6-1 n

Q Chapter 7 DECOMMISSIONING PLAN Work performed under license SNM 942 in DOE facilities (306W, for example) represents an extremely small fraction of the total work with radioactive materials performed under DOE programs. Thus, the additional considerations for decomissioning and decontamination caused by licensed work in DOE facilities are insignificant. In general, decomissioning and decontamination of DOE facilities will be accomplished within the framework of approved DOE policy, including reducing levels of radioactive contamination to levels that are comensurate with protection of the health and safety of the public. The majority of licensed work performed in BNW private facilities consists of laboratory analysis of small samples of radioactive material. In general, these samples are in a nondispersible form, and do not represent a source of radioactive contamination. It is not expected, therefore, that decontamination of BNW private facilities prior to decomissioning will require extensive efforts. Nevertheless, radioactive contaminattor, in all BNW private facilities and equipment will be reduced to the levels stated in subsection 3.2.4 prior to unrestricted release. O O I.7-1

Chapter 8 RADIOLOGICAL CONTINGENCY PLAN Battelle-Northwest will prepare a radiological contingency plan, in accor-dance with NUREG-0762, at such time that BNW has need to increase the licensed amount of plutonium above 1.5 grams. O C I.8-1

9 O PART II SAFETY DEMONSTRATION l l

o

Chapter 9 OVERVIEW OF OPERATION 9.1 Corporate Information The applicant is the Battelle, Pacific Northwest Laboratories of the Pacific Northwest Division of Battelle Memorial ~ Institute (BMI), Battelle Boulevard, Richland, Washington. Corporate offices of BMI are located at 505 King Avenue, Columbus, Ohio. Battelle Memorial Institute is incorporated in the state of Ohio. The principal officers of BMI are: t

l' Dr. Ronald S. Paul, President and Chief Executive Officer l

Dr. Douglas E. Oleson, Executive Vice President and Chief Operating Officer j Paul T. Santilli, Vice President, General Council, and Secretary Maurice G. Stark, Vice President, Treasurer, and Corporate Director, Finance Dr. William R. Wiley, Vice President and Director, Pacific Northwest Division i All of the above officers are United States citizens. No control or i ownership is exercised over the applicant by any alien, foreign corporation, or foreign government. 4 9.2 Financial Qualifications i Total assets of BMI were reported as $249,612,000 in the 1984 BMI annual ] report. 9.3 Summary of Operatina Objective and Process Battelle Memorial Institute operates the DOE's Pacific Northwest Laboratory (PNL) in Richland, Washington, under contract DE-AC06-76RLO 1830. Under this j contract, BNW carries out assigned DOE research and development programs. Areas of research include materials reliability, hazardous materials research, manufacturing technology, energy technology, health, safety and environmental research, and biotechnology. Battelle-Northwest also conducts contract research for its own account in DOE-owned and BNW-owned facilities under a use permit -7 contract, DE-AC06-76RLO 1831. This license is intended to cover the work conducted under the use pennit contract, plus any other work conducted by BNW that requires a special nuclear materials license. 9.4 Site Description The DOE's Hanford Site, shown in Figure 9.1, is located in the southeastern i part of the state of Washington just north of where the Yakima and Snake Rivers i flow into the Columbia River and occupies an area of 1500 km2 (560 square l miles). J Geologically the area encompassing the site is an irregular structural j and topographical basin underlain by basalt flows that have been depressed below sea level in some areas and upward in others. Fluvial, lacustrine, i aeolian, and glacial sediments overlie much of the basalt and form terraces !O II.9-1 ^

WASHINGTON Columbia () Seattle Spokane O l Tacoma b U Olympia Hanford S te Lewiston Richland Pasco Kennewick O Pendleton g,, f IDAHO' O Eugene OREGON O Boise k FIGURE 9.1 Location of the Hanford Site Within the Pacific Northwest of other subordinate physiographic features. Dominate features are the anti-clinal ridges forming the Saddle Mountains to the north of the site, the Rattle-snake Hills to the south, and Yakima and Ahtanum Ridges to the west, and Gable Mountains in the center of the site. The crests of these surrounding ridges rise to 762 m (2500 ft) and 914 m (3000 ft). Those areas occupied by site facilities are located at elevations between 122 m (400 ft) and 213 m (700 ft). Hanford's climate is mild and dry with moderate winters and warm summers. Light cloud cover and light precipitation are characteristic of the region. The average annual precipitation is approximately 16 cm (6.3 in.), of which more than half occurs between Octob r and February.g Thegveragemaximumand g minimum temperatures in July gre 33 C (92 F) gnd 16 C (61 F). For January, g the respective averages are 3 C (37 F) and -6 C (22 F). O II.9-2

9 Prevailing winds are westerly with an average monthly velocity ranging 9',- from about 14 km/h (9 mph) in the summer to 10 km/h (6 mph) in the winter. Normal wind conditions are occasionally perturbed by short periods of high winds. Peak gust velocities to 112 km/h (70 mph) have been recorded. However, winds of hurricane or tornado force have never been observed. The region is a typical desert area with frequent strong inversions that occur at night and break during the day, causing unstable and turbulent conditions. The Columbia River flows through the Hanford Site and forms part of the eastern boundary. The average monthly flow rate past the site ranges from about 1700 m /sec (60,000 fta/sec) during low water months to more than a ft /sec) during peak periods in the early summer. Barge 3 11,300 m /sec (400,000 3 transportation on the Columbia River is available from the Pacific Ocean to Hanford. The desert plain on which the Hanford Site-is located has a sparse covering of vegetation primarily suited for grazing. The most broadly distributed type of vegetation on the site is the sagebrush /cheatgrass/ bluegrass variety. The mule deer is the most abundant big game mammal on the site, while the most abundant small game animal is the cottontail rabbit. Approximately 250,000 people live within an 80 km (50 mile) radius of the Hanford Site. The principal urban center in the vicinity of the site is the Tri-Cities area (Richland, Pasco, and Kennewick) which is located along the Columbia River southeast of the site. These three communities have a combined population of approximately 100,000. . h l The land within the area is predominately agricultural. Wheat is grown on the high ground, and varied crops and orchards are found on the irrigated land of the Columbia Basin and lower Yakima Valley. Industrialization, though not extensive, is growing especially in the vicinity of Pasco and Kennewick. The potential of the area for future expansion is favored by the availability j of cheap electricity, water, and river transportation. Facilities on the Hanford Site, shown in Figure 9.2, include the historic reactor facilities for plutonium production located along the Columbia River, in what is known as the 100 Areas. In the middle of the site, on a plateau i about 11.2 km (7 miles) from the river are the 200 Areas where the fuel proces-sing and waste management facilities are located. The 300 Area, just north of the city of Richland, contains the reactor fuel manufacturing facilities and research and development laboratories. Privately owned facilities located within the Hanford Site boundaries are: the Washington Public Power Supply System (WPPSS) Hanford Generating Plant located within the 100 Areas, and one operating and two under-construction WPPSS nuclear power plants located about 16 km (10 miles) northwest of the 300 Area; a commercial radioactive waste burial site southwest of the 200 Areas; and the Exxon Fuel Fabrication Facility located immediately adjacent to the southern boundary of the site. BNW private facilities are also located just south of the southern boundary of the Hanford Site in the 3000 Area. O II.9-3 l 1

N i s s -N-1000 ~ 3"oT* [ t 100K AREA i WJ h S AR RICADE ,e . ""^ i ^ =psr w:H~ x l \\ N l h e x 0 s N O i 10 g onscRvATORY '(# ) ADQUARTERS \\ 5 4 ./ I 9 g, EA D 'v} = / ,*;s di.sk A b!!

AREA

~ FIGURE 9.2 Location of the Operations Areas on the Hanford Site h II.9-4

G Detailed descriptions of the Hanford Site are found in several government U documents. An example is ERDA-1538, Final Environmental Statement, Waste Management Operations, Hanford Reservation, Richland, Washington, Volumes 1 and 2. 9.5 Location of Buildings Onsite The location of the 306 facility within the 300 Area of the Hanford Site is shown in Figure 9.3. Battelle-Northwest operates the west portion of the facility (referred to as 306W). Figure 9.4 shows the location of the BNW private facilities (including the PSL) with respect to the Hanford Site. 9.6 Maps and Plot Plans See Figures 9.1 through 9.4. 9.7 License History j 9.7.1 History Battelle-Northwest has been licensed for the possession of special nuclear materials since 1966. The history of the license is as follows: Original License Issue Date: February 10, 1966 First Renc,ial: June 26, 1974 Second Renewal: May 15, 1981 9.7.2 Amendments Since Latest Renewal No amendments have been requested or granted since the last renewal. 9.7.3 Organizational Changes The Occupational and Environmental Protection Department of BNW, as des-cribed in the previous application for renewal of license number SNM-942, was reorganized in 1982. As a result of the reorganization a new department, Laboratory Safety, was created. In a later reorganization, the Occupational and Environmental Protection Department was abolished, and its functions were split between a newly created Health Physics Department and the Earth Sciences Department. The Laboratory Safety Department of BNW, as described in Chapters 2 and 11 of this application, is responsible for all aspects of the radiation safety, nuclear safety, and industrial safety programs at BNW previously administered by the Occupational and Environmental Protection Department, with the exceptions of the environmental monitoring, personnel dosimetry, and radiological instrument calibration programs. These services are provided by components of the Earth Sciences Department (environmental monitoring) and the Health Physics Department (personnel dosimetry and radiological instrument calibration) which also provide the same services 'to all other Hanford Contractors, as prescribed by contract with the DOE. The Laboratory Safety Department is II.9-5

4 <iMg '\\ 7 North Gate Rs-sd pt-0, g 306 z} E 0 0@C '] 'ou" 1 West Gate-- 0 C a g-I a D Ea.a_ a o a f R. P l. h.,--., ^ W(' cs O a &l \\ a _1 a Cypress St. Gate, 7_g g 7 3 I a r ~ [ I i I I a J L.i--,-,-,,-LI,-,-- George [j I Washington Life Sciences Way Gate h Laboratory I { E i k -,_,_,_,_,= 5 l 'd I E 8 o i 5 Y a K FIGURE 9.3 Location of the 306 Building Within the 300 Area g II.9-6

i n i V l l kk i r, = Jl i EDL ms+ Trailers S WM LSL-il o M Main Lobby jPSL/ Math ROB i I Battelle Blvd. l ~ FIGURE 9.4 Location of the PSL Building Within the BNW Research Complex responsible for review and approval of these programs as they pertain to BNW operations under license SNM-942. 9.8 Changes in Procedures, Facilities, and Equipment Battelle-Northwest has established a safety review system to provide a high degree of confidence that 1) risks associated with proposed work have been adequately evaluated and identified to appropriate management; 2) work changes or modifications to facilities or equipment receive appropriate safety review;

3) ongoing work is being conducted safely and within applicable requirements; and 4) appropriate management attention is given to safety concerns in perform-ing work and in operating facilities and equipment.

9.8.1 Safety Review System The safety review system of BNW consists of the following elements: a Safety Review Council that provides the Laboratory Director with expert i O II.9-7

safety reviews and advice on activities with significant safety implica-tions risk assessments of research proposals to determine the potential risks associated with the work environmental evaluation for all activities having potent:al environmental impact for appropriate facilities, an operational readiness review system to define and ensure completion of all factors necessary for a project to be considered operationally ready to start up safely and efficiently . modification permits to provide appropriate reviews of proposed changes of utilities and facilities that may have safety significance . design reviews to ensure that engineered safety features are adequately considered in the design of new facilities and that facilities will be constructed in compliance with appropriate safety codes . an independent review of safety specifications to provide, when appro-priate, a high level of confidence that limits and controls placed on a work task or operations are adequate and appropriate for the safe and efficient conduct of the work . an independent review of off-normal event procedures, reports, and veri-g fication of equipment operability, i.e., unusual occurrence reports, y facility emergency procedures, prefire plans, outage permits, and accep-tance test procedures for fire protection systems and emergency alarms. . an audit and appraisal system that 1) evaluates ongoing work for compliance with safety requirements and practices: 2) may detect safet in facilities, operations, and performance of work; and 3) y deficiencies provides a stimulus to line organizations to comply with safety requirements and to be alert to detect and correct safety deficiencies an appraisal of BNW's safety program made by senior management and tech-e nical staff every three years routine facility walkthrough inspections by line management and Laboratory Safety to detect and identify potential safety hazards and items needing correction. 9.8.2 Responsibilities Laboratory Director Appoint the chairman and members of the Safety Review Council Appoint members and chairman of the triennial safety review board for reviewing the adequacy of the BNW safety program. 9 II.9-8

Cognizant Director Appoint operational readiness review boards. Department Managers Review line management's response to safety appraisals for adequacy of proposed corrective action. Perform routine reviews and inspections of assigned operations and facilities. Line Managers Ensure preparation of applicable safety documentation and submit to appropriate review functions as outlined in Figure 9.5. Perform routine reviews and inspections of assigned operations and facilities. Chairperson, Safety Review Council Review and approve all safety analysis reports includ-l ing technical specifications and operational safety requirements. Call for a review of an activity by the Council or a subcouncil whenever the potential consequences of an accident could be substantial. 1 Advise the Laboratory Director when work by line organizations should receive special safety consider-O atioas-f Manager, Laboratory Safety Provide guidance to management on the need for safety reviews and operational readiness reviews. i i Audit and appraise BNW operations and facilities for compliance with safety requirements. Conduct walkthrough inspections by Laboratory Safety staff. Provide review of the following: modification permits, risk assessments, safety specificaticos, occurrence reports, fire plans, acceptance test procedures for 1 emergency alarms and fire protection systems, design documents, reactor experimental plans, and environ-1. mental evaluations. Facilities Engineering Prepare design documents and submit to appropriate 4 Manager review functions identified in Figure 9.5. II.9-9

~. s c.os pa. i .em l s.s jw,. ij o..oi. I. < i

o. o...

~ o i ca= L c c [w. o. o. ..a s c I< ! l. I, e c .s I I I I l l >~ ~.

~..~-.

ir ,,i i l l l l l l

m..c

.e.! .c s... ,.. t i i 1 . o cs. .,I...

i.,

i i i i i i.c i i Si a l i m. 3 Ie. l I, l I l. i i I l l e L.in g . _4,. c 1 2 css. .c...

c-i

~.

1. a i

,..c 4 i, m. c- ; .c r n-c. 'w a. u.. sawa. .cj.. j l l . l l l l l

_ L_ t._L_ l g

i l i I. l i i~...~- 4-}- fu _ 4 - f- } -- - r 4 - L-+--& 2',"***"',',;*',,,",,,,,,,, t i I I.l.I I i I I l 4 i i 1 i . ~.. ,.i . L. t_ L!__ a.4 -,!,L _t J _ L L L _ L.L !

u~. ~e ~ --. :

1 i ..w_ s 1 i i i i 1., 1, I i i !.I. 1 1 t-3 .. _.~ i i. [. i. [_. i. i. j._I l.1 I l l l 1 o 4 i .1

. 1, 4.,;

,_~c.. .+ .c,,,,. rri. : .....;. WMt-ty t-+~g+ -+--t-- - - --t - + - t - ~ & - f -- & - - - +- -.- gp,,3,...,,,,,,,, l..'cl l ' l l I I l l

l., l l

l. l l l l

* ~ " ' ' " "

'",i'o."~" ! ! Ll L._! I, j l l 1 .~ P. t.'---~' - ~ M 3 os.. som i ,[ r I j j j - j ] .M "-t + 1 +- --+ + t, - i. ~.. r. l l l l I i i mt ; ..j j j 1 ._I L, I i i t m._,..- .i 8t c c ~.. FIGURE 9.5 BNW Approval Matrix 0 II.9-10

Chapter 10 FACILITY DESCRIPTION 10.1 Plant layout Engineering drawings of the 306W and PSL facilities are shown in Figures 10.1 through 10.3. 10.2 General Description of Facilities 10.2.1 306W Facility The west portion of the 306 Building (designated as 306W) is a PNL facility belonging to DOE but operated by BNW. The east portion of the facility is operated by Westinghouse Hanford Company for DOE. The BNW-occupied portion of the facility contains: a diversified metal working factitty for performing a variety of nonrepet-itive fabrication development jobs i a specialty shop that provides machining services for uranium, thorium e and other materials of equivalent radiological consequence i a thorium oxide fuel development laboratory for fabrication of uranium i e l and thorium dioxide nuclear fuel pellets a special nuclear materials storage area ' O support laboratories. 1 The 306 Building is of steel construction with a tar and gravel roof over steel decking. Exterior walls are 8-in. concrete brick. The 306W portion of the building is 193 ft in the east-west direction and 160 ft in the north-2 of floor south direction. A 25-ft high-bay area provides about 30,000 ft j space; the remaining 2000 ft2 of the first floor is office space having a ceiling height of 8 ft. Additional office space and an equipment room are located above the first floor office area. A 12-in.-thick concrete fire wall divides the building into approximately equal 306E and 306W portions. This i wall has a sealed personnel door and a large, steel, sealed equipment door; Both doors have a 1-1/2 hour Underwriters Laboratory fire rating. The 306W facility is occupied by approximately 50 persons. The manager of the Materials Science and Technology Department of BNW has overall respon-sibility for the safe and effective use of the 306W Building. Engineered safety features of the 306W Building include an independent ventilation system for contamination control, hoods for processing oxide pow-ders, safety interlocks on the hydrogen furnace system to prevent an accumu-lation and ignition of explosive gas mixtures, an emergency power system for emergency lighting and the alarm systems, and a comprehensive fire protection system. 4 O II.10-1

e-l l i t 6 I I f f i t 1 en (h s, se. na s sk. Gr e, s. ier s lQ I i J l T I l 1 I -I_...'L, 11 I

l Fl ll -

= [; <rr ~ Q ~ ~ g :) [-. -.*] m. _] I _.. t] -l 1111 g r. IllII -_1 I.sq.4.t: -} ~I - _J L '. ---.J. - j F -- 1 1 1 1:~ 1 '~ ~ u jt- _1l { _1 i _. --u _iI ,i i u-i-p go,- .l .s II_5-. -- - - ti) ? _J N ._..,3 g _. 1- ._J

c. -

-+ + - ~ rme #Lw Lu un rim n o w - -.g 7 --=r.~~-

.W.-

. b_ m hsae : , L ~.- ~2*~ T '4-& a e avee r ,se e ee e }_. m w =- = ,,. 3. uso p y-g = i i e 6 6 i i i 6 i l-FIGURE 10.1 Diagram of the 306W Facility 0 0 0

l O, O (o~~') o u _ l l l l l l l, l t.-_.-._ -t,' p p - a ---_.7--..- in ~! -II !{__jg_._j j --j _l}_ ,__;..pm . _; ;_ p _g. t-s _g ,,; _iL _ y.;_+ i_ _g.? r. ([ p l 7 ;_ t._. ; _._ _; ._.y _m__3_, f........., o, l c ,d[ (g g M}- p' ~ ~irggg~.L g ~ 3 'g i TIT 1i,,! i T 4-{ } '{ ~ ] ;L-- [ 1 _I }.--.'- i L.{ l_1 5) ,1 '}- a u L-[ }- f,i L{ g D } I j -f;L[ } { h-{ i' l _b f y k -f 'q' ; =m f.~ _.-f -f I ,e -} ,l I -- ( i } ;r

---{

3 e !i 8 : v is_ I+ e m ;; i n rI 1 . -I c t I t a_ 'p q.,

1. {

} l; {[ } l p-( o ~ e e j g a g t'- t t W d '{ I__ ? g g_. }%; J-l l -[l c n l [:-{ '5 .1-1 / , ;r-l 1 3I l-]l.i Ml-I l i'c .r-l i -l w e._ l r; J _ aD' - -I le y =' DRAWER 51 .Q ( or !" oswt F-as-as li - i _,3,i 4 1 - i-t' . i-j-n e; i i. .F-[ 3$ -i Er-i-I- --J t -i-it -ij-t -1 1-SIMPLIF/ED j?~ ~~ l .D BU/LDING LAYOUT w --. 7-...,, 7 e 6 I L"" '1 l f J PSL 90f_QN LyQ @_I LJ q)w w mw @ -- g. A -427 lg lTl* i l l l l l l FIGURE 10.2 Diagram of the PSL Building's First Floor

1 l l l I l f i l e e l'i O e t 3 = i b,i I 4 .j. .p p l 4 ll L_ i +) i - ._._11 = i t f,,,t t s E #. ( f- ~~ ~ ~ '3,>l I ( ,1) gq 3 ] i 5 J n 3 f: Isl i 5 (. l e i [= -I lJti -w i- ,-i ,e e. .f 1.;] x s-1:: R -:,r - I m i r-e a - [ i._-. - v, -. ),t. g 7 3I f: l- - a. a- = . _.{ _1 5 4 ( 3 [ i 1, 1 5[_ m - f 'l !5 5- .t 5 ,_1 3_ g __.. _q ~.t Ial.t_ '.L = oam... _.a, lij ll m-T. _= g ~ i 4 . _-g,-[, i. m.j - t b . u i, i, ll w. iim, s. m-m. -e .c, e l4, e, - '!= I dl i ! i

_?

? i =' 1 SIMPLIFIED t lI I BUILDING L AYOUT \\ ^^ kst eos eTvw at vo l L \\ \\. q) a) q) <0 mr; mu (wo

)

(:) :' g.a.gg7 JpJgfy l l l l i l l FIGURE 10.3 Diagram of the PSL Building's Basement 6 O O

(VO Independent ventilation systems serve four distinct areas within the 306W Building. The first floor section is served by two roof-top units that provide ventilation, heating and refrigerated cooling. The main high-bay area single-pass supply air is provided through independent roof-mounted H&V units consisting of prefilters, steam heating coils, and an evaporative cooling section. Exhaust from this section is discharged through three roof-mounted exhaust systems, which include medium efficiency pref 11ters and one-stage HEPA filtration. Vacuu;n air samplers are installed in the exhaust ducts to sample air released to the atmosphere. Airflow through the thorium oxide fuel development laboratory is partly supplied by a single-pass, refrigerated, heating-ventilation-air-conditioning (HVAC) system. In addition, supplied-air hoods are used to reduce the amount of tempered air needed. The exhaust air is discharged through two stages of HEPA filters by an externally mounted fan. A vacuun air sampler is installed in the exhaust duct to sample air released to the atmosphere. Continuous operation of the 306W ventilation system provides a differential negative pressure (at least 0.05 in WG) with reference to atmospheric pressure for control of potential airborne contamination in the north high-bay area. Processing operations with materials in powder form are conducted in hoods or glove boxes. A minimum airflow of 125 ft/ min is provided at the hood face to give adequate control for airborne contamination in the hoods. Furnace systems for the processing of nuclear fuel pellets and powders, n using hydrogen mixtures greater than 5% hydrogen, are equipped with safety () features to preclude an accumulation and ignition of an explosive mixture. The manifold for the hydrogen mixture supply is equipped with a double pressure reducing station and a pressure-relief pop valve set less than 75 psig. When-ever a flowing explosive mixture is being used, a source of inert gas is always available to the furnace system to purge the furnaces manually before a hydrogen mixture is introduced and at the completion of a process cycle. A second inert gas safety system is on standby to purge a furnace automatically in the event of a furnace power failure or hydrogen mixture supply failure. In addt-tion, a burn-off system is provided to burn any potentially explosive mixture flowing from the furnace. A safety interlock system prevents the flow of the hydrogen mixture to the furnace in the event of burn-off failure, gas pressure drop, or power failure. The building is covered by an automatic wet-pipe sprinkler system. Fire alarm pull boxes and fire extinguishers of the appropriate types are located throughout the building. Fire alarms in the building are connected with the 300 Area fire alarm system. The activation of any sprinkler head sounds an alarm in the 300 Area Fire Station and the 306 Building. Radiation protection l'istruments include hand and shoe counters, exhaust air samplers, and criticality detectors. The building is served by evacuation sirens and an emergency telephone system. II.10-5

10.2.2 Physical Sciences Laboratory g The PSL is a BNW-owned facility located in the BNW Richland Research Complex adjacent to the Hanford Site. Specific laboratories in the PSL are equipped for work with small quantities of radioactive materials. Supply air is provided to these laboratories through overhead diffusers, and air from these rooms is exhausted through hoods. The air passes through two HEPA filter banks before being exhausted to the atmosphere. The hoods automatically com-pensate when they are closed to exhaust the room via a bypass. The exhaust system has two exhaust fans, either of which can accommodate the entire exhaust capacity. The electrical load from these fans is automatically transferred to an emergency power system in the event of a power failure. Solid and liquid radioactive wastes are collected, and disposed of to the commercial waste disposal site located on the Hanford Site. The laboratories in wSich work with radioactive material is performed are equipped with an air sampling vacuum system. The building is covered by an automatic wet-pipe sprinkler system. Fire alann pull boxes and fire extinguishers of the appropriate type are located throughout the building. 10.3 Waste Handling 10.3.1 Liquid Wastes Licensed work is performed in the same facilities using the same equipment as work under the operating contract. Thus, it is not possible to distinguish between the quantities of gaseous and liquid wastes deriving from license and contract work. In general, only a small fraction of the radioactivity in h these streams results from work under the license. In all cases, waste handling and disposal must comply with the requirements contained in PNL-MA-8, Waste Management. The 306W facility is connected to liquid radioactive waste systems which serve many buildings within the 300 Area. These systems are operated by the Westinghouse Hanford Company. In some cases, it is not possible to identify the contributions to the system from a given building, or those arising from the activities of a given contractor. The systems are shown in Figure 10.4. The waste systems that are provided for the Hanford 300 Area are as fol-lows: The 300 Area Sanitary Sewer System No potentially contaminated liquid wastes are disposed to the 300 Area sanitary sewer system. The 300 Area Process Sewer System Waste management procedures do not allow releases of liquid radioactive materials to the process sewer system. Releases to this system are limited to dilute aqueous wastes of miscible nonradioactive chemicals, drain overflows, 61 11.10-6

Columbia 315 Pumping Chlorinated I River Station Water I t t Filter Process Sanitary ~ Backwash Water Water 4 Retention Radioactive Process RLWS Check Yes Contamination Divert lNo ' t 1r 307 Retention Basins Check Yes Contamination / lNo O South Process Evaporation - 34o Bldg. Sanitary Pond Trench Trench l I I I Ground Water Ground Water 200 Area Ground Water FIGURE 10.4 300 Area Liquid Waste Disposal System aquaculture overflows and'small amounts of dilute thermal discharges. The process sewer system discharges directly to the process waste trenches for percolation into the ground. Typical releases to the system for all contractors in the 300 Area in 1985 were: Total Releases 1.3 x 10-1 Ci 2 40 7.0 x 10-3 C1 2ssU 1.0 x 101 C1 racy 1.1 x 10 2 C1 unidentified beta-gamma Minimum Concentration 28 parts per billion Maximum Concentration 200 parts per billion Total Volume 9.3 x 10s gallons. II.10-7

Diverter stations are installed in the process sewer system discharge lines from the 325-A and 324 buildings. These diverter stations consist of counting instruments and automatically operated valves that divert the liquid from the process sewer into the radioactive liquid waste system and initiate alarms if the radioactivity exceeds a preset level. If the radioactivity in the liquid is below the preset point, the liquid is discharged to the process waste trenches. When radioactivity levels in the liquid are above the preset point, the liquid is diverted to a holding tank, then into the radioactive liquid waste system. The 300 Area Radioactive Liquid Waste System This system is intended to handle those waste water streams which have a high potential for contamination or are actually contaminated with radioactive materials from laboratory operations. These waste solutions are accumulated through a system of double lined and monitored pipes and stainless steel tanks, adjusted to a pH of 11 and shipped by one of four 20,000-gallon, stainless steel railroad tank cars to another Hanford contractor for concentration prior to disposal. The condensates are trenched and the concentrates are transferred to the underground waste storage tanks used in support of manufacturing opera-tions. The following controls are in place for the radioactive liquid waste system to ensure safe operation: Only personnel trained in the use of the radioactive liquid waste system may dispose of liquids into the system. g Only liquids are placed in the system. Liquids with solids suspended are allowed to settle; then the liquid is decanted off or filtered and the solids disposed of as solid waste. Mixtures or solutions that may precipitate solids out when proper chemical conditions are reached are tested for precipitation in water before placing in the system. No liquids are placed in the system that have a possibility of solidifying in the line. Examples are paint, plastics, liquid rubber, epoxy, etc.

Water insoluble solvents are not placed in the system.

Strong acids or bases are washed down with copious amounts of water. Concentrations of beta-gamma emitters up to 10 sci /ml may be placed in the system, provided that the total activity discharged does not exceed 40 Cl within a 30-day period. Concentrations of fissile material up to 0.1 pC1/ml may be discharged into the system. Amounts of tritium up to 10 Ci within a 30-day period may be discharged. II.10-8

d C Waste systems operations is notified before making a transfer of 200 e gallons or more. The approval of waste systems operations is obtained before disposal of any quantity of liquid reading greater than 500 mR/h. A line manager is assigned responsibility for each opening into the radioactive liquid waste system. Prior concurrence with Westinghouse Hanford Company is needed before wastes exceeding the above conditions can be released to the system. In those facilities where radioactive liquid waste systems are not provided (the Battelle-owned facilities), radioactive liquid wastes are accumulated and transferred to the Westinghouse Hanford Company, or to the commercial waste disposal firm located on the Hanford Site, if the waste generated during work with licensed material can be separated from waste associated with DOE contract work. 10.3.2 Justification for Exemption from Liquid Waste Records Requirement Most of the buildings in the 300 Area where BNW performs licensed work are connected to the 300 Area liquid waste system which is operated by the Westinghouse Hanford Company for DOE. It is not possible to distinguish liquid wastes generated in licensed activities from those generated in DOE contract f'T activities, and in some cases, it not possible to identify the contributions (/ to the system from a given building or those arising from the activities of a given contractor. Measurements are made and records are kept by the Westing-house Hanford Company of the total radioactivity disposed to these systems. 10.3.3 Solid Wastes Solid radioactive waste generated in PNL facilities from work under the operating contract is disposed to burial sites established by and operated in accordance with criteria established by the Richland Operations Office of DOE. The type of disposal is dependent primarily upon the radionuclide or other hazardous material contained and the level of the contaminant. For example, wastes containing significant quantities of long-lived highly radio-toxic materials, including plutonium, are placed in 20-year retrievable storage. Low-radiotoxic materials are packaged for direct burial. The solid radioactive wastes generated by-BNW from work done under license are kept separate, to the extent possible, for disposal to U.S. Ecology in approved containers. 10.4 Fire Protection l The 306W facility is a noncombustible structure designed to meet the 4 i requirements of the Uniform Building Code (construction type II-N). The facil-ity is shared with Westinghouse Hanford Company, another DOE contractor. How-ever, the two parts of the building are separated by a 4-hour-rated fire wall. ! Q The building is fully protected by automatic sprinkler systems and complies II.10-9

g with National Fire Protection Association (NFPA) 13, " SPRINKLER SYSTEMS." The sprinkler system is connected to a fire alarm system designed to meet the requirements of NFPA 728, " AUXILIARY PROTECTIVE SIGNALING SYSTEMS." Fire alarm signals are automatically transmitted to the 300 Area fire station which is manned 24 hours a day by full-time, professional fire fighters. The fire station is less than 1/2 mile away from the 306W Building. The PSL Building is a noncombustible structure, designed to meet the requirements of the Uniform duilding Code (construction type II-N). The building is protected by automatic sprinkler systems that meet the requirements of NFPA 13. The sprinkler system is connected to a fire alarm system designed to meet the requirements of NFPA 728. Fire alarm signals are automatically transmitted to the Richland Fire Department via the municipal radio fire alarm system. The nearest Richland fire station is approximately 3 miles away from the PSL Building. The 306W Building and its fire protection systems were designed under the management of General Electric and DOE. The PSL Building was designed by Naramore, Bain, Brady, and Johansen in two phases t,eginning in the late 1960's. Both buildings and their fire protection systems were designed and constructed in accordance with current Uniform Building Code and NFPA standards. All required fire protection devices are listed or approved by a national testing laboratory. Battelle-Northwest maintains an active fire protection program that includes periodic testing and maintenance of required fire pro-tection devices. g The fire protection program is administered by two professional fire protection engineers who both hold BS degrees in fire protection engineering technology from Oklahoma State University and are members of various fire protection and safety organizations (e.g., NFPA, the Society of Fire Protec-tion Engineers, and the Board of Certified Safety Professionals). Fire protec-tion policies are defined in PNL-MA-43, Health and Safety Management, the internal manual governing BNW's safety program. Fire fighting in BNW facil-ities, except for minor "first aid" fire fighting using portable fire extinguishers, is left to the professional fire fighters of the Richland Fire Department or the Hanford Fire Department. Detailed prefire plans for all BNW facilities have been developed through cooperation between BNW and the appropriate fire department. Maintenance and inspection of fire protection systems are done by BNW crafts services personnel under the direction of building managers assisted by the fire protection engineers. Storage of combustibles is kept to a minimum in accordance with the Health and Safety Management manual. Where NFPA addresses storage practices, those requirements are applied to BNW and are summarized in the Health and Safety Management manual. Combustible contaminated waste is stored (on a temporary basis) in covered metal containers. O II.10-10

] Chapter 11 ORGANIZATION AND PERSONNEL The policy of BNW with respect to safety is to provide a safe and healthful working environment for all staff members and to operate to ensure a high degree of safety to the public and the environment. A safety program is estab-lished to prevent accidents, minimize the consequences should an accident occur, maintain exposures of staff members to all hazardous materials as low as reasonably achievable, and minimize release to the environment. The program meets the high professional standards established by the applicable safety disciplines. This chapter describes the organization and personnel who are responsible for implementing the BNW safety program. 11.1 Organizational Responsibilities Managerial responsibilities relative to the health and safety program at BNW are prescribed in Management Guide 11.2. Battelle-Northwest subscribes to the philosophy that authority for carrying out.the BNW safety program can be delegated downward, but that responsibility for the safe conduct of BNW operations ultimately lies with line management. Specific responsibilities of each position are provided below. 11.1.1 Laboratory Director i The Laboratory Director is responsible for the appointment of an ad hoc coinmittee to independently review, at least every three years, the adequacy and implementation of the BNW safety program, the independent review system, t and the adequacy of the safety staff. 11.1.2 Director of Facilities and Operations The Director of Facilities and Operations is responsible for the approval of BNW safety manuals and their revisions, all unusual occurrence reports, and responses to sponsors about safety-related items. 11.1.3 Manager of the Laboratory Safety Department The manager of the Laboratory Safety Department is responsible for: providing guidance on the overall adequacy of the BNW safety program maintaining awareness and informing management of new regulations and e regulatory changes applicable to BNW operations issuing and maintaining all BNW safety manuals e reviewing safety risk assessments on all BNW research proposals, providing guidance to operating components in evaluating hazards and in defining engineering features and administrative controls for reducing risks to an acceptable level (e.g., safety analysis reports and operational safety requirements) O l II.11-1 I

providing independent safety reviews of plans for new, or modifications h to, facilities or process operations conducting appraisals on operations having significant safety risk establishing a comprehensive audit system to comply with applicable safety requirements providing guidance on BNW's operational readiness reviews e shutting down or restricting operations that are considered unsafe or that do not comply with safety requirements managing the BNW off-normal event reporting system and its corresponding responsibilities of notifications to applicable authorities; informing line management of " lessons learned" from BNW and other unusual occurrences; determining the severity and classification of accidents; and providing technical experts for accident investigations evaluating, recording, and reporting occupational injuries and illnesses, and industrial accidents and occurrences administering the BNW regulatory licenses and permits necessary to acquire, work with, and dispose of hazardous materials coordinating with line management to determine the need for environmental g analyses and evaluations for research programs, proposals, and facilities; and providing guidance on preparing environmental documentation providing guidance to BNW staff and line management on maintaining staff exposure to ionizing radiation and nonradiological hazards ALARA. Manager of the Industrial Health and Safety Section The responsibilities of the manager of the industrial health and safety section are: providing assistance and guidance to line management in fulfilling their safety responsibilities providing an overview of safety performance through statistical analyses, audits, appraisals and frequent walkthrough inspections, trend analyses, and reporting to upper management on safety performance updating line management on current changes to safety standards and regula-tions using "stop work authority" in situations that present imminent danger to employees, the public, facilities or equipment providing training programs and an overview of job-specific training. II.11-2 4 0

] Manager of the Hazardous Materials Safety Section The manager of the hazardous material safety section is responsible for: auditing BNW operations and facilities to ensure adherence to established waste management procedures and practices establishing requirements and approving shipments of hazardous materials e coordinating BNW's waste disposal practices, which includes maintaining the waste disposal practices in conformance with DOE, state and other federal waste disposal and pollution control requirements ensuring that high standards of nuclear safety are maintained throughout all laboratory divisions, and to assure that these standards are responsive to government and other regulations per forming nuclear safety analyses for reactors, critical facilities, and laboratories containing large inventories of fissile materials or radio-nuclides performing periodic audits to ensure that written specifications are appropriate and that operations conform to these instructions providing consultation during the design of new or modified facilities to ensure that adequate nuclear safety features are included providing liaison with DOE in obtaining approval of operating safety limits and other administrative controls as described in DOE manual chap-ters. Manager of the Radiological Engineering Section j The manager of the radiological engineering section is responsible for: auditing BNW operations and facilities to ensure adherence to established radiation protection procedures and practices evaluating technological developments in the field of radiation protection e providing authoritative consultation to others with regard to the develop-ment or application of regulations, technical recommendations, and proce-dures for radiation protection providing liaison with DOE and other regulatory agencies with reference to the radiation protection program and radioactive materials license ensuring that the BNW radiation protection program as well as radiation e protection services provided by BNW to other contractors, meet applicable requirements providing field dosimetry services II.11-3

~ providing consultation during the design of new or modified facilities to ensure that adequate radiation protection criteria are included W investigating high personnel exposures and conditions and factors involved in radiation incidents and to issue reports including ' recommendations for corrective action participating in Yormal investigations of radiation exposure involving BNW employees developing meaningful ALARA inspections and audit functions.- Manager of th3 Radiation Protection Section The runager of the radiation proteccion section is responsible for: establishing the radiation monitoring program to meet BMW radiation pro-l tcction requirements l providing complete and effective radiation monitoring services for all BNW departments, as well as for the U.S. government and other Hanford contractors on request l providing authoritative counsel to customer managment regarding work with radioactive materials in order to minimize hazards to personnel, facili-ties, and the environment remaining in a state of preparedness to copeytth serious radiation events through a continuing program of education and training working with operational groups to develop effective ALARA programs for all radiation work activities. 11.1.4 Manager of the Emergency PJinning Office The manager of the Emergency Planning Office is responsible for developing, implementing, maintaining, and enhancing a program to provide a state of readi-nes? to deal successfully with emergency events or incidents that have safety and security implications to persons, facilities, programs and community. This function has the primary responsibility for:

1) training of emergency management personnel, 2) developing and maintulning a functional emerg'ency control center, 3) developing and conducting a program of exercises to test program and personnel readiness and efficiency, 4)-developing and maintaining an emergency preparedness manual, 5) providing technical support to the Laboratory Director, 6) maintaining a trained and knowledgeable emergency-preparedness staff, 7) coordinating emergency preparedness activities with other Hanford contractors, DOE, and the Washington Public Pcwer Supply System by means of the Hanford Emergency Preparedness Council, and 8) participating in emergency preparedness exercises with Hanford contractors, DOE, the Washing-ton Public Power Supply System, and the Federal Emergency Management Agency.

O II.11-4

w O Additional responsibilities include developing and maintaining the emer-gency management on-call system, providing technical support of the emergency response / notification system (375 2400), maintaining the inspection / audit 3 program for building eme,rgency procedures, and providing a duty officer.from the Emergency Planning Office for immediate availability. The Emergency Planning Office maintains an ongoing awareness of emergencies and off-normal events. In addition, at the discretion of the Director of Facil-ities and Operations, the personnel of the Emergency Planning Office may be assigned to task forces, committees, and other special assignments where their individual or collective expertise can serve BNW's needs. 11.1.5 Manager of the Safeguards and Security Department The manager of the Safeguards and Security Department is responsible for the functions described in the following paragraphs. The safeguards section is chartered with the administration of the overall nuclear material control and accountability (MCA) system. The safeguards section is functionally separated and independent from all organizational units involved with the use, production and research and development of nuclear material s. The MCA system imposes the same basic requirements on each type (DOE or NRC) of material on inventory. The formal reports that are prepared are spe-cifically designed to meet the unique reporting requirements of the cognizant j. authority. There are basically seven functions performed by the safeguards section to meet the objectives of the MCA system. Each function is briefly discussed below: nuclear material accounting -- Maintains a centralized records system, supported by appropriate documents, which provides sufficient information to maintain an accurate material balance by individual material balance area and a total BNW material balance for the three types of material. The system is the basis for the required formal reports for DOE, NRC, and BNW distribution. Nuclear material accounting also prepares and distri-butes transfer documentation between contractors; reconciles physical inventories, prepares and transmits the necessary data submissions (NMSS) and subsequent reconciliations, and identifies shipper / receiver differ-ences. safeguards audits -- Implements an audit program that ensures compliance with PNL-MA-5, Nuclear Materials Management and Safeguards Procedures, DOE Orders, and NRC requirements. The audit program includes: schedule development, working papers, detailed documentation, and follow-up on corrective actions covering all material balance areas and some areas of safeguards activities. radionuclide inventory -- Maintains a composite inventory record of the type and quantity of each radionuclide for each custodian and the total O type and quantity in possession of BNW. Provides for a physical inventory II.11-5

each calendar year and reconciliation of the inventories. Prepares monthly g; lists'of sealed and unsealed sources due for leak testing. l nuclear materials management -- Maintains a continuing review of nuclear material holdings.to maintain economic inventory levels. Periodically i reviews all major nuclear material holdings for any significant program change or variance to facilitate the completion of required reports (e.g., inventory assessment report, sixteen-year forecast, nuclear materials management plan), prepares and submits to the Richland Operations Office of DOE all required requests for nuclear material status changes,~ autho-rizes shipping and receiving of nuclear material, prepares import and export authorizations and scrap declarations. measurements -- Operates and maintains the mobile verification measurement facility (van) which is used for the nondestructive analysis of material at BNW and supports the DOE Richland Operations Office's inventcry veri-fication program of the other Hanford contractors. safeguards support -- Develops, revises and ensures compliance with PNL-MA-5, Nuclear Materials Management and Safeguards Procedures; provides training for material balance area custodians and material handlers; reviews for adequacy and accuracy the limits of error provided by the material balance area custodians; reviews inventory differences and con-ducts investigations if needed; administers the tamper-safing programs; administers the scheduling, witnessing and procedure approval of physical inventories; reviews new facility construction for safeguards and material a control requirements; reviews the design of advanced material control W and accountability systems for facilities; investigates significant shipper / receiver differences; investigates nonroutine incidents involving nuclear material, measurement control -- Monitors measurement performance throughout BNW and the issuance of reports demonstrating measurement performance; main-tains documentation supporting the selection and qualification of measure-ment systems; develops procedures to ensure that individuals performing measurements are sufficiently trained to perform the tasks; develops sampling procedures and determines the variability associated with the procedures; evaluates measurement control data to provide estimates of accuracy and precision for inventory control statements. 11.1.6 Line Management Line management within the research and service departments at BNW is responsible for: inplementing safety practices for projects to ensure that appropriate e safety standards, regulations, and procedures are enforced 1 shutting down or restricting operations that are considered unsafe or that do not comply with safety requirements ) O II.11-6

] promoting and maintaining a high level of health and safety awareness among staff members providing staff members with appropriate training to, accomplish their e work assignments safely and efficiently and documenting training activities preparing and implementing risk assessments, analyses, procedures, controls and engineered safety systems appropriate for the safe performance of ~ projects and tasks coordinating with Laboratory Safety to plan activities that may have significant safety implications; allowing sufficient time for evaluation and institution of necessary controls and protective devices informing the cognizant building manager of modifications and changes that may have significant safety implications or an impact on a facility, its occupants, equipment, and the environment providing regular inspections of facilities and equipment to detect unsafe conditions; initiating action to corrcct unsafe conditions, noncompliance with safety requirements, or conditions needing ir.provement coordinating with Laboratory Safety to determine the need for environmental documentation (environmental assessments, environmental evaluations) for research programs, proposals, and facilities reviewing work environments, procedures and equipment to ensure that staff exposure to ionizing radiation and nonradiological hazards is main-tained ALARA. 11.1.7 Manager of the Health Physics Department The manager of the Health Physics Department is responsible for providing certain health physics related services for the entire Hanford Site, including personnel dosimetry (external and internal), radiation exposure records, whole body counting, analytical support services (bioassay), and radiological instru-ment calibration and evaluation. These services are provided by the personnel dosimetry section and the instrumentation and external dostmetry section. Manager of the Personnel Dosimetry Section The manager of the personnel dosimetry section is responsible for: designing and establishing bioassay sampling and whole body counter exam-ination programs for varying degrees of potential for radiation exposure to Hanford employees from internal emitters providing professional evaluations of the extent of internally deposited radionuclides in project employees and visitors using the best available interpretive techniques O II.11-7

applying research findings to dosimetry programs, and conducting equipment 3 ' evaluation studies and field tests of prototypical and new commercial W equipment anticipating new needs for internal dosimetry services arising from process and function changes of customers and identifying areas of needed research and development leading to improved technology and methodology establishing, implementing, and auditing a functional, legally sound radiation protection records system preparing as required for administrative, professional or legal use, reports of radiation dose received by individuals establishing and maintaining a quick response system for dose evaluations to assure accurate and timely radiation dosimetry for emergencies conducting studies of dosimetry records to determine the incidence, dis-tribution and other pertinent parameters of exposure participating in formal investigations of incidents involving BNW person-nel or facilities and preparing the formal statement of the exposure received by personnel. Manager of the Instrumentation and External Dosimetry The manager of the instrumentation and external dosimetry section is h responsible for: procuring, maintaining, calibrating and providing portable personnel radiation monitoring instruments, and establishing portable instrument performance specifications and procurement standards for the Hanford Site providing a comprehensive radiation standards and calibration laboratory e providing external dosimetry to the Hanford contractors providing thermoluminescent dosimetry support to the Hanford environmental surveillance program providing technical support to evaluate external doses received by Hanford e personnel. 11.1.8 Senior Specialist, Criticality Analysis The senior specialist, criticality analysis is responsible for analyzing criticality factors for work with fissionable materials and preparing technical basis memos leading to the material inventory control limits and the operational parameters for handling fissionable materials. O II.11-8

11.1.9 Manager of the Earth Sciences Department The manager of the Earth Sciences Department is responsible for conducting the environmental surveillance program for the Hanford Site in compliance with DOE Order 5484.1, Chapter III, and for reviewing all environmental dose calcula-tion methods and assumptions used for Hanford specific environmental dose assessments. 11.2 Organization Charts Director Director's Staff W.R. Wiley J F Bagley. External Aftairs 4 J Mayer. Human Resources Legal and Contracts Finance S.J Farmer A.F. Johnston

== - Director Directe< E E ua Y AcNevement Develop ent Projects D B. Cearlock.

s. G Idsmith, TI CMsm Director

- 1. I '

Director Advanced Nuclear Biology and Health Physics Systems Chemistry -= = B J Kelman G W Hoenes R.C. Liikala, R D Widng Director Chemical Materials Science Systems hchnology and Technology Engineering J L. Straalsund J T A Roberts W D Rechmond Technology Transfer Earth Sciences Environment, Health Advanced Energy L.D. Williams, and Safety Research Concept =- D W Dragnich W J Bair L R Dodd Energy Systems Research Programs Engi ering Facilities R C. Adams W W Ballard R J Hall T.D. Chikalla. Engineering Physics National Secunty Director R A Stokes J M Davidson Management Systems Hanford Environmental and Technology Applications R.M. Fleischman, W W Laity Director FIGURE 11.1 BNW Organization Chart as of March 1986 OV II.11-9 l l.

Director Facilities and Operations Laboratory Emergency Planning Facilities Safety Office Administration Engineering and Security and Crafts Services Safeguards FIGURE 11.2 Organization Chart for Facilities and Operations l Laboratory Safety Department l l l Manager l I I I I industrial Health Hazardous Material Radiological Radiation and Safety Safety Engineering Protection I I I I l Manager l l Manager l l Manager l l Manager l l l l 1

D "

l Waste Management l Engineer Supervisors Engineer l I l Hazar us atenal eld Dosirnetry Senior Engineer l l Industrial Hygienist l Transportation Services l I I Ra sation Protection Radiation Protection l Safety Engineer l l Nuclear Safety l Instrumentation Specialists I Radiation Appraisal l Medical Scheduling l Protection l Training Coordinator l Coordinator y Technologists i I Safety Analysis ALARA Review Coordinator I Operational l Licensing l Readiness Review i I Environmental off-Normal Compliance Event Reporting FIGURE 11.3 Organization Chart for the Laboratory Safety Department h II.11-10

j 1 6 0 Health Physics Department 2 a Instmmentadon Personnel Health Physics Dosimetry Dosimety ec n I gy e n 9y Externa Dosimetry i Radiation Records FIGURE 11.4 Organization Chart for the Health Physics Department Energy Systems Department Technology Statistical Econom.ic an9 Performance Systems Safety Information Policy Analysis and Reliability Analysis Sciences i 1 i Nuclear Design UnM j Criticality Analysis FIGURE 11.5 Organization Chart for the Energy Systems Department O II.11-11

11'.3 ONanizational Procedures h Battelle-Northwest management'is guided by the policies set forth by BMI and communicated in the Management Guide. Battelle-Northwest has established a m'anagement guide system that implements, restates, and interprets BMI policy accounting for local operating options and government and BNW requirements. Administrative manuals, as authorized by the Management Guide, are developed and distributed as supplemental requirements and procedures that cover the detail to implement policy and spell out responsibilities. In addition, "Act Now Directives" are issued in bulletin form as necessary to inform BNW staff of new policies or requirements of immediate significance. Management guides state the primary responsibilities for implementing policy, identify the authoritative local contact and other sources for obtaining supporting information required to implement policy, and provide for examples of specifics that require consideration in implementing policy. Administrative manuals pertaining to the BNW safety program include: PNL-MA-3 Radiological Design Criteria PNL-MA-5 Nuclear Materials Management and Safeguards Procedures PNL-MA-6 Radiation Protection PNL-MA-7 Off-Normal Event Reporting System PNL-MA-8 Waste Management PNL-MA-11 Emergency Preparedness PNL-MA-25 Criticality Safety 5 PNL-MA-43 Health and Safety Management PNL-MA-81 Hazardous Materials Shipping Manual PNL-MA-97 Operational Readiness Review System. Supplementary manuals of procedures for carrying out specific tasks are issued by the cognizant departments or sections. Safe operating procedures are also issued by specific operating components whenever a project or operation has the potential for significant safety implications. Responsibilities of management per:onnel in the preparation, review and approval of management guides and administrative manuals are as follows: Director, Facilities Ensure the preparation for management review and and Operations the issuance and maintenance of administrative manuals pertaining to safety. Functional Directors Recommend for final BNW approval management guides in area of functional responsibility. Give final approval for administrative manuals in arca of functional responsibility. Laboratory Director Give final BNW approval of management guides and quality assurance monuals. Director, Legal and Obtain Corporate approval of policy prior to Contracts issuance of management guides. h II.11-12

{J } Line Managers Comply with policies and requirements set forth in the management guide system and ensure that staff.have appropriate knowledge of these policies and requirements. Responsibilities for audits and appraisals of the BNW safety program are provided.in subsections 11.1 and 9.8. 11.4 Functions of Key Personnel Responsibilities and authorities of key personnel positions have been identified in subsection 11.1. Written delegation of authority is required for all managers whenever they are absent from BNW. One-over-one approval is required if the absence is for more than two weeks. All managers are required to identify back-up personnel for their own and other key positions within their areas of responsibility. Key positions within BNW and the individuals currently occupying the positions are: Labo rato ry Di rector........................................W. R. Wi l ey Director, facilities and Operations.....................T.D. Chikalla Manager, Laboratory Safety Department...............J.T. Denovan Manager, Industrial Health and Safety........B.D. Robertson Manager, Hazardous Material s Safety.............S.C. Hawl ey Manager, Radiological Engineering................D.E. Lucas Manager, Radiation Protection....................J.R. Berry Manager, Emergency Pl anni ng 0ffice...................R.J. Kofoed Manager, Safeguards and Security Department........D.P. Carlisle

Manager, Safeguards........................... 0.P. Amacker Di rector, Research......................................D.B. Cea rl ock Manager, Health Physics Department...................G.R. Hoenes Manager, Personnel Dosimetry...................J.R. Houston Manager, Instrumentation and Ext. Dosimetry....D.M. Fleming Senior Speciali st, Criticali ty Analysis...............R. A. Libby Manager, Envi ronmental Eval uations.................. P.E. Bramson The qualifications of key individuals are provided in subsection 11.5 nU II.11-13 t

11.5 Education and Experience of Key Personnel Battelle-Northwest has an extensive staff of health physicists, many certified by the American Board of Health Physics. This staff and others from closely related fields have developed many research programs where original contributions are being advanced for many government and private industry sponsors. Some of the key staff responsible for the BNW radiation protection and safety programs are briefly described in the following resumes. W. R. Wiley, Laboratory Director Dr. Wiley earned a bachelor's degree in chemistry from Tougaloo College, Mississippi. He served 2 years with the U.S. Military Police Corps and later taught classes in electronics to servicemen. Studying under a Rockefeller Foundation scholarship, he earned a master's degree in microbiology in 1960 from the University of Illinois-Urbana. His doctorate degree in bacteriology was awarded in 1965 by Washington State University, Pullman. Dr. Wiley is a vice president of BMI, the world's largest independent research organization. As the principal BMI executive in the Northwest, he directs operations of the DOE's Pacific Northwest Laboratory. The BMI has operated this multiprogram national laboratory since 1965. Dr. Wiley is responsible for research and development activities at BNW's research complex in Richland, the Marine Research Laboratory at Sequim Bay on the Olympic Peninsula, and the Seattle Research Center located near the University of Washington campus in Seattle. A member of the BNW staff since 1965, Dr. Wiley previously served as Director of Research at the Richland laboratories, a position he held for 5 years. His earlier assignments included management positions with the Biology Department and the Cellular and Molecular Biology research section. Dr. Wiley is a member of the Board of Trustees at Gonzaga University in Spokane, Washington, and was appointed by the governor to the Washington State Higher Education Coordinating Board. He served on the advisory Committee for Advanced Studies in Biomedical Science at the University of Washington and is a former member of the Washington State Commission for the Humanities. T. D. Chikalla, Director of Facilities and Operations Dr. Chikalla received his Ph.D. in Metallurgy from the University of Wisconsin. Dr. Chikalla's area of specialty is nuclear materials with emphasis on high temperature behavior of ceramic materials. Work since 1958 has included active participation in, as well as direction of, work on light water reactor and fast breeder fuels, including process development and fabrication, characterization, physical properties, and fuel-clad compa-9 II.11-14

4 a O-tibility. Special interests include thermodynamics, phase equilibria, and defect behavior of nonstoichiometric rare earth and actinide oxides. i Dr. Chikalla served as manager of the Nuclear Waste Technology Program Office, with responsibility for direction of a $30 million DOE program i dealing with immobilization, characterization, and isolation of commercial and defense high-level, TRU, airborne, and low-level wastes. He has authored numerous reports and scientific literature publications dealing with fuels and nuclear waste materials and is co-editor of the book Ceramics in Nuclear Waste Management. Dr. Chikalla served as manager of the Chemical Technology Department. In this capacity, he was responsible for the direction of 250 scientists, engineers, and technicians dealing with analytical and radiochemistry research, chemical separations technology, and large-scale process engi-neering associated with nuclear waste immobilization and coal conversion. A principal responsibility was also techelogy transfer of output from Government R&D programs to the industrial-sector. In 1986, Dr. Chikalla was named the Director for Facilities and Operations. In this position, he is responsible for Laboratory Safety, Safeguards, Security, Facilities Administration and Engineering and Craft Services. i This involves a staff of 460 and management of 125 laboratory facilities. Professional society affiliations include: American Association for ^'"*""*"' ' '" ""' *' ^"*"" '' ' ' ""' """*" "' (J offices held at nationa'l and loca'l levels. Dr. J. T. Denovan, manager of the Laboratory Safety Department Dr. Denovan received his B.S. in Environmental Health from the University of Washington; his M.S. in Radiation Protection from Oregon State Univer-sity; and an M.S. and Ph.D. in Environmental Health Sciences from the University of Michigan. j Dr. Denovan has over 15 years of experience in the nuclear industry. He is currently the manager of Laboratory Safety at BNW. In this position, i i he is responsible for the safety program at BNW. The managers of radiation protection, radiological engineering, hazardous material safety and indus-trial health and safety sections report to Dr. Denovan. He was the manager of the radiation and nuclear safety section at BNW from 1982 through June 1985. i l From 1977 to 1982, he was manager of various safety groups at the Westing-house Hanford Company. He was responsible for such activities as non-reactor nuclear facility safety analyses, reactor safety analyses, core loading and reactivity surveillance reviews, technical specification i review, radiological codes and analyses, and criticality safety. l Before coming to Hanford, Dr. Denovan was the radiological safety group II.11-15

leader at a large utility and was responsible for designing health physics g programs for power reactors. Dr. Denovan is certified by.the American Board of Health Physics. B. D. Robertson, manager of the industrial health and safety section Mr. Robertson received his B.S. in Bacteriology and Public Health from Washington State University in 1969. His responsibilities include development of safety and health policy, budgeting and resolution of personnel problems. He chairs or participates in various committees such as health, safety, accident prevention, opera-tional readiness and management. He was responsible for environmental protection and managing hazardous wastes. In this capacity, he developed a good working knowledge of environmental regulations such as RCRA, NPDES, NIPDWR, TSCA, HMTA, FWPCA, CAA, and other state and local regulations. He handled, treated and disposed of laboratory generated wastes, planned and evaluated waste management systems, and implemented improved waste disposal techniques and also prepared environmental assessments, environ-mental evaluations, and co-authored the annual "Hanford Drinking Water Report," which summarizes the chemical, microbiological and radiological quality of drinking water on the Hanford Site. In performing that work, he was responsible for water sampling, analysis, and interpretation of analytical results. In this capacity, he also served as a consultant to other Hanford contractors in the area of hazardous waste management. He is a member of the Washington State Environmental Health Association and the National Environmental Health Association. S. C. Hawley, manager of the hazardous material safety section Mr. Hawley received his B.A. in Chemistry from Reed College in 1978. In 1985, Mr. Hawley became manager of the hazardous material safety section that is resp]nsible for hazardous material transportation, radioactive and nonradioactive waste management, environmental compliance, safety analysis and appraisals and nuclear safety. Mr. Hawley has 8 years of experience working with research reactors, 2 years of experience evaluating emergency preparedness at nuclear power plants, and 3 years experience as a nuclear safety engineer. Reactor Operation and Supervision. Mr. Hawley received his first senior operator's permit in 1973 for the Reed College reactor facility. In his 6 years there, he was a senior reactor operator, assistant health physi-cist, reactor supervisor, and training supervisor. In 1979, he received his second senior operator's permit for the Washington State University reactor. As reactor supervisor, he was responsible for the safe operation and maintenance of the reactor, and also advised and instructed researchers in the methodology of neutron activation analysis. O II.11-16

v 1 s i /~~ Accident Analysis and Emergency Preparedness. Since joining BNW, Mr. j Hawley has been analyzing credible accidents for research reactors and participating in emergency preparedness appraisals and exercise obser-i vations at nuclear power plants. He has also served as: task leader for reviewing emergency plans of NMSS-licensed facilities; task leader for non-power-reactor emergency preparedness; project manager for hearing support ~ for UCLA research reactor; and one of three principal investigators for technical assistance in implementing emergency preparedness require-ments. D. E. Lucas, manager of the radiological engineering section Ms. Lucas received her B.S. in Environmental Health from Purdue University in 1975 and her M.S. in Bionucleonics from Purdue University in 1977. In 1985, Ms. Lucas became manager of the radiological engineering section that is responsible for radiation protection engineering and standards, field dostmetry services, radiation protection instrumentation, medical scheduling, ALARA program, licensing and off-normal event reporting. She also serves as the BNW representative on four intercontractor commit-tees -- the Hanford Safety Analysis Forum, the Hanford Dosimetry Advisory Committee, the Hanford Emergency Preparedness Council Dose Assessment and Classification Committee, and the Hanford Dose Overview Committee. She is on loan to Westinghouse Hanford Company as a dose evaluator for the Emergency Control Center. She participates in the Region 8 Emergency Response Team for the DOE's Richland Operations Office. Ms. Lucas has developed BNW's ALARA program to better satisfy the DOE Richland Operations Office's expectations and has expanded the scope and distribution of the quarterly ALARA Report, developed procedures for the preparation and review of RCPs, and developed a system for tracking and evaluating staff with relatively high doses. In having lead responsibility for the field dosimetry services office, she has worked with staff members to develop procedures and train backup support for that office.. From 1977 to 1983, Ms. Lucas worked for the Westinghouse Hanford Company where she participated in multidisciplinary safety activities associated with nuclear research facilities and developed expertise in accident analysis and risk assessment. She has extensive experience in the prepara-tion of safety analysis reports, and the analysis of accidental releases of radioactive materials to the environment. Ms. Lucas is a member of the Health Physics Society, the American Nuclear Society, and the Society for Risk Analysis. J. R. Berry, manager of the radiation protection section Mr. Berry has 31 years of experience at Hanford in the field of applied health physics including 14 years as a radiation monitor, 2 years as a radiation monitoring specialist, 5 years as a radiation monitoring supervi-sor, 4 years as a senior technical specialist in waste management, O II.11-17

k 1-1/2 years as~ a senior technical specialist in radiological engineering, g and'as manager of the radiation protection section from May 1982 to the w. present. These positions provided experience in radiological surveillance, interpretation and implementation of the radiation protection program in the field, review and assessmant of new facility designs and facility modifications, and administration of BNW radiation protection policy. In addition, Mr. Berry co-authored several BNW documents, including PNL-MA-8, Waste Management, PNL-MA-81, Radioactive Materials Shipping Manual, environmental assessments, environmental evaluations, safety evaluations, and articles for the journal of the Health Physics Society. R. J. Kofoed, manager of the Emergency Planning Office Mr. Kofoed received his B.S. in Chemistry from the Illinois Institute of Technology in 1951. Mr. Kofoed has 35 years of operating experience in a wide range of assign-ments. His most recent experience in Safeguards and Security, and his 15 years as a commissioned Reserve Police Officer have given him in-depth practical experience in dealing with unusual, as well as, emergency events. In addition, he has training in MORT and Accident Investigation techniques. His triennial review of the BNW emergency preparedness activity was an important element in establishing the present Emergency Planning Office. He developed and implemented a state-of-readiness to effectively manage h the response, recovery, and mitigation of incidents and events not con-forming to normal or expected conditions that cause damage to, or pose a threat to, the safety of persons, facilities and/or the environment. Mr. Kofoed performed special assignments at the direction of the Laboratory Director. The three major assignments were: Member of Security Task Force -- developed security upgrade program Performed BNW triennial review of emergency preparedness (solo assignment) Represented BNW on Hanford Inspection and Evaluation Security Task Force. Made significant contributions to the accomplishment of identified Hanford needs (e.g., developed questions for briefing and training DOE, Rockwell Hanford Operation, Westinghouse Hanford Company and BNW senior management for the Inspection and Evaluation interviews, acted as assistant director of one force-on-force exercise; acted as player in two DOE Inspection and Evaluation exer-cises; provided training for selected BNW senior management for the Inspection and Evaluation interviews). O II.11-18

t [ lQ D. P. Carlisle, manager of the Safeguards.and Security Department Mr. Carlisle received his B.S. from Brigham Young University in 1977 and his Master of Accountancy from Brigham Young University in 1978. He l became a Certified Public Accountant in 1979 and was awarded the certifi-i cate in Management Accounting in 1980. He has worked on a tracking system i for classified work and planned renovation of. the BNW Security Control Room, prepared action plans for special security audits by DOE, and developed a priority list of Safeguard and Security needs as the BNW 4 representative on the Hanford task force. He leads and directs the Nuclear Safeguards, Security and Technical Security Services organizations. O. P. Amacker, Jr., manager of the safeguards section Mr. Amacker received his B.S. in Accounting from the University of Nevada 4 ] in 1975. He is directly responsible for the control of and accounting for all nuclear material at BNW and directs the overall operation of the section to meet the MCA requirements prescribcd by DOE, NRC and state of Washing-ton guides. He has worked as the alternate nuclear material representative with the primary objective of maintaining the accounting system and records for BNW's DOE nuclear material, and material held on the NRC and Washington !n State licenses. He contributed to the formulation of MCA plans for spe-U cific processes and material balance areas, reviewed and investigated i inventory differences. prepared special study data, participated in phys-j ical inventories, and revised manuals-and procedures to meet the require-ments of DOE Orders (5630 series) for MCA. D. B. Cearlock, Director of_ Research Dr. Cearlock received his B.S. degree in Civil Engineering from Washington State University in 1964, his M.S. in Sanitary Engineering from Washington State University in 1965, and his Ph.D. in Civil Engineering from the University of Washington in 1977. 1 Dr. Cearlock is responsible for the research activities conducted by eight departments, which are staffed by over 1000 scientists, engineers and professional specialists. These research responsibilities cover the i broad technical areas of materials, atmospheric, hydrologic, geochemical, radiological, chemical, environmental, biological, ecological, computer and social sciences, and manufacturing and process engineering. j Before becoming Director of Research, Dr. Cearlock had been manager of l 1 the Geosciences Research and Engineering Department and subsequently the-Director of Government and Industrial Programs. In the latter assignment, his responsibilities included business development activities for BNW's major clients, including the NRC, Department of Defense, Environmental Protection Agency, Electric Power Research Institute, and Gas Research Q Institute. These activities included strategic planning, senior management i II.11-19 1

4 liaison, business development, and the development of new technologies. In addition, Dr. Cearlock was responsible for management and commercial-ization of the Laboratory's intellectual property. He is a member of the American Society of Civil Engineers and Sigma Tau, Tau Beta Pi, and Phi Kappa Pht. G. R. Hoenes, manager of the Health Physics Department .Mr. Hoenes received his B.S. in Mathematics from Western Illinois Univer-sity in 1970 and his M.S. In Environmental Health from the University of Minnesota in 1973. Mr. Hoenes is responsible for the direction and management of about 76 scientists and technicians working on problems in radiation dosimetry and applied health physics. He manages scientists, technicians and other staff who perform work on a variety of projects related to occupational radiation exposures, the control and reduction of radiation exposures, radiation measurements and calibration, internal and external dosimetry, and radiation shielding and design. Mr. Hoenes was a health physicist and environmental scientist with Radia-tion Management Corporation in Philadelphia, Pennsylvania, from 1973 to 1974. While with the RMC, he managed radiological environmental monitoring programs being conducted in the vicinity of nuclear power reactor sites, prepared safety analysis reports, and helped develop a training program in basic health physics. g Since joining BNW in 1974, he has published more than 20 reports and papers in his areas of expertise. Mr. Hoenes is a member of the Health Physics Society and the American Nuclear Society. He is also a working member of Subcommittee 10.03 of the American Society of Testing and Materials, which is preparing standards for radiation protection during decontamination and decommissioning. J. R. Houston, manager of the personnel dosimetry section Mr. Houston received his B.S. in Physics from California State College in 1967. Mr. Houston has 18 years of experience in health physics. This experience has included radiation monitoring, radiation detection instrument calibra-tion and repair, film dosimeter processing and evaluation, TLD processing and evaluation, radiation shielding analysis, facilities safety analysis, internal and external radiation dose calculations, radiation dosimetry studies, design of environmental surveillance programs, computer program-ming, emergency preparedness and operational readiness reviews. As exposure evaluator for the Hanford Site, he was responsible for eval-uating the exposure of employees to both external and internal radiation. He developed mathematical models describing uptake and retention of radio-O II.11-20

i i Q nuclides in the human body. He developed an automated data acquisition i and reduction system for the Hanford in vivo counting system and a compu-terized record keeping system providing for. storage and rapid recall of in vivo data. For a number of years he was involved in the development of mathematical models and computer codes for the assessment of internal radiation doses from inhalation of airborne radionuclides and the evaluation of the con-sequences of hypothetical atmospheric releases of radionuclides in con-nection with the preparation of environmental reports. As a radiation engineer he was heavily involved in radiation shielding calculations, making a major contribution to the design effort on a spent { fuel reprocessing plant and making significant improvements to a radiation shielding computer code. He was also involved in external dosimetry studies using TLD's and in the preparation of safety analysis reports on new facilities. As coordinator for emergency preparedness, he was responsible for the j development and maintenance of emergency plans, training of emergency personnel and the development and conduct of emergency exercises. He j has also been responsible for the development and implementation of an operational readiness review system. This system was developed to assure that complex, high risk facilities and equipment receive appropriate l review prior to the start of operations. He is a member of the Health Physics Society. D. M. Fleming, manager of the instrumentation and external dosimetry i section Mr. Fleming received his B.A. in Engineering Physics from the Northwest i Nazarene College in 1960 and his M.S. in Nuclear Engineering from the University of Washington in 1967. i i Mr. Fleming has specialized in the areas of radiological physics and applied health physics since 1960. He has contributed in a wide variety of programs involving health physics instrumentation and dosimetry.- Programs in which he has been a major contributor include: i Instrument Calibration and Evaluation. Mr. Fleming is manager of i the instrumentation and external dosimetry section. This section has the responsibility of operating a health physics instrument pool for all of the hanford contractors. The pool consists of nearly 3,000 health physics instruments. The section develops procurement specifications, procedures, acceptance tests, calibrates, repairs, picks up and delivers and maintains inventory control of this instru-ment pool. Mr. Fleming has provided input in the design and development of i many of the health physics instruments currently being marketed by i major instrument manufacturers. He is frequently requested to, provide l II.11-21 1 I i

an evaluation of products before the design is committed to produc-gI tion. Recently, he has been heavily involved in the development of a new radiological calibration and evaluation facility for Hanford. Fea-tured in the new facility are a number of " state-of-the-art" instru-ment and dosimeter calibration systems, including computer-controlled, air density corrected, photon and neutron calibration wells. l Standards Committee Work. Mr. Fleming was a member of the Health Physics Working Group responsibie for the development of ANSI N13.27, " Performance Requirements for Pocket-Sized Alarm Dosimeters and Alarm Rate Meters," and is currently a member of the committee writing ANSI N42.17, " Performance Specifications for Radiation Protection Survey Instrumentation." Radiological Calorimetry. Mr. Fleming has designed and developed several calorimeters to measure absorbed dose, measure proton-induced damage in materials, measure proton beam dose rates, make measurements on radioisotopes and do microwave dosimetry on animals. His accomplishments also include measurements of half-lives, specific powers and total powers of a variety of isotopes, and calorimetric-absorbed dose measurements for both tonizing and nonionizing radiations. He is a member of the Health Physics Society. R. A. Libby, senior specialist, criticality analysis, nuclear design unit Mr. Libby received his B.S. degree in Engineering Physics from Oregon State University in 1971 and his M.S. degree in Nuclear Engineering from the University of Washington in 1972. From 1972 to 1973, he worked as a physicist at Lawrence Livermore Laboratory while taking additional courses in Applied Science at the University of California / Davis. From 1974 to the present he has been employed by BNW first as a shielding specialist, then as a criticality safety specialist. As a senior criticality analysis specialist, he writes or reviews the technical basis memos for all BNW criticality safety specifications and is involved with plant audits and inspections of BNW laboratories. He has presented papers at several American Nuclear Society national meetings. P. E. Branson, manager of the environmental evaluation section Mr. Bramson holds a B.S. degree in Engineering Physics from Northwest Nazarene College. He was employed for 6 years by General Electric Company in Hanford's Radiological Development and Calibration Operation where he performed neutron and gamma radiattor, detection equipment engineering, development and calibration. In 1965, Mr. Bramson transferred to BNW as a senior engineer in whole body counter research, development and applications. Since that time, he has served as manager of an internal G II.11-22

i ,( dosimeter section, staff scientist in radiation standards and engineering and senior engineer of the environmental evaluations section. 1 During his professional employment, he authored and co-authored numerous papers and has given subject lectures at Washington State University and' the University of Washington. He is a member of the Health Physics Society. j 11.6 Training ) The success of the radiation protection program depends heavily on 1 individual employee performance; therefore, considerable time and effort is j devoted to assuring that employees have an adequate understanding of radiation and radiation protection as it applies to their work. Supervisors have the primary responsibility for ensuring that their t employees receive adequate training in radiation protection. The amount and type of training depends on the kind of work they perform and the facility or facilities in which they work. Radiation safety training for BNW's radiation area workers begins with the introductory orientation slide program that all staff members attend in their first week. The section manager then gives the l staff member an orientation to the facilities that they will be working.in and reviews with them the radiation areas, procedures, dressing rooms, monitor-ing offices, and other appropriate information about their facility. The staff member may then begin to work with experienced staff members to become i familiar with the work and procedures used, but must be constantly escorted j while in a radiation area, i Within the first three months after becoming a radiation area worker, the + staff member is scheduled for general radiation safety training where they i are given instruction in BNW policy and basic radiation principles. This i training includes discussion of the nature of nonoccupational sources of radi-ation, occupational radiation controls,- ALARA philosophy and techniques, rad-iation work procedures, protective clothing, self-surveying instruments and i procedure, and emergency alarms and responses. The basic training is required to be retaken every two years. After the general training the staff members are directly supervised until they become familiar with the routine and proced-j ures of the facilities. This job-specific training is a continuing process that occurs whenever changes are made to the radiation work procedures or other changes occur where the managers feel that specific training is necessary. A ]; program of periodic retraining is also administered. j i Training programs are presented for professional, scientific, and engineering personnel, including those engaged in. radiation protection activities. Programs of this kind are offered as needed, based on personnel turnover, new developments in the field of atomic energy and changes in BNW j business. There is a policy and practice of complete and prompt communications with all BNW staff members regarding the radiation aspects of their work and i their own individual exposure status. All information on the BNW radiation-protection program is available in full to any staff member. A year-end report II.11-23 I _______..,_.___._.__._-___,__._-_._.,._..___,_.-,....i

is issued to every employee informing them of their individual radiation a exposure for the entire year. Information and training bulletins on radiation W protection matters are issued periodically to staff members. These are supple-mented by articles covering radiatier, protection items of general interest in the plant newspaper. t 9 II.11-24

1 CHAPTER 12 RADIATION PROTECTION PROCEDURES AND' EQUIPMENT 12.1 Procedures i Although administrative responsibility for radiological control is assigned to facility and operations management, the radiation protection l surveillance program provides continuity and technical support needed to ensure effective radiological control. Methods and plans for conducting l radiation surveys are described in subsection 12.4, " Surveys," below. Battelle-Northwest has a strong management commitment to ALARA. This policy appears in BNW Management Guide 11.2, " Safety." In this policy state-ment, the manager of Laboratory Safety is given responsibility for providing i guidance on maintaining exposures ALARA. Line managers are assigned responsi-bility for reviewing work environments, proceduras and equipment to ensure i compliance with the principles of ALARA. Staff members are assigned the respon-i i sibility of maintaining exposures to themselves and coworkers ALARA. The i Radiation Protection manual, PNL-MA-6, restates this commitment to ALARA as the basic radiation protection policy of BNW and provides guidance for achieving i this. Management is involved in an ongoing program to maintain exposures ALARA. Radiation exposure status reports are issued regularly (i.e., monthly, quar-terly, or annually depending upon the level of radiation work performed by j the group and the corresponding dosimeter exchange frequency) to line man-g agement for review. Operating line management also reviews and approves pro-l cedures involving radioactive materials. The quarterly ALARA report, which is issued to line management, provides additional information on trends and locations for exposures and skin contaminations. All newly hired employees receive a radiation protection orientation which includes discussion on ALARA. In addition, radiation workers must com-plete radiation worker training and retraining which provides more detailed j explanations on radiation protection requirements and techniques for ensuring j that ALARA is met. Line management provides task-specific on-the-job training. j Radiation work permits are reviewed and approved by radiation protection staff as well as operations line management. In the event that an operation a is considered unsafe or out of compliance with safety requirements, the manager i of Laboratory Safety has written authority (BNW Management Guide 11.2) to shut l down or restrict the operation. Modifications to RWPs and to equipment and facilities involving work l with radioactive materials are reviewed by Laboratory Safety personnel to ensure adequate implementation of radiation protection features. l Areas of potential radiation exposure are identified on RWPs or radia-tion work specifications (RWSs) prepared and administered by the radiation li protection section. Expected exposure rates are shown on these documents; surveys by radiation protection personnel show measured exposure rates at the time of survey. In addition, radiation exposure trends and skin contaminations are discussed by location and organization in each ALARA report. II.12-1 j l .__ _~__._ _._ _,._ _ _._

The radiation protection staff continually seek ways to reduce radiation exposures. When there is suspicion that unusual exposures may have occurred, the radiation protection staff directs and participates in the investigation of circumstances and assists in identifying methods to reduce the likelihood of similar future occurrences. Descriptions of these events and the methods of investigation are reported as described in PNL-MA-7, Off-Normal Event Repor-ting System. The radiation protection staff reviews operating procedures that have been prepared by the research staff. Members of the radiation protection section regularly observe plant operations during scheduled walkthroughs, and report their observations and recommendations via reports to radiation protec-tion management. Adequate radiation protection equipment and supplies (including clothing, tape, respirators, wiping materials, etc.) are maintained by the research staff. Radiation protection staff routinely inspect and inventory decontami-nation supplies and the emergency supplies, apparel, and instruments kept avail-able in their assigned vehicles. Access to and occupancy of any area in which the potential exists for personnel exposure to radiation in excess of environmental levels is controlled by an established system of radiation areas, with specific designations appro-priate to the type and levels of radioactive materials expected. The respon-sibilities of the radiation protection section, which are identified in PNL-MA-6 include: determining the levels of radiation exposure, surface contamination, or e airborne radioactivity that may be expected establishing radiation areas in which access must be controlled specifying the requirements and restrictions that must be followed e to keep personnel radiation exposures ALARA. The responsibilities of operations and facilities management include: maintaining conspicuous radiological posting, as directed by radiation protection, of areas within their responsibility establishing procedures for work in radiation areas,and require that valid RWPs, RWSs and operating procedures are available and followed maintaining supplies of protective equipment ensuring that staff members entering a radiation area are aware of the significance of the area and are aware of their responsibility to comply with the requirements of the RWP or RWS maintaining personnel exposure ALARA. 9 II.12-2 l l l

v I /3 PNL-MA-6 further identifies staff member responsibilities, including atten-V dance at training as required for work in radiation areas, complying with the j requirements of the RWP or RWS, Informing management or the radiation protection section of any failure of control procedures or protective equipment, and maintaining personal exposure ALARA. Radiation exposure records for the Hanford DOE contractors, including BNW, are maintained by the BNW radiation records program. This program meets the requirements of ANSI Standard N13.6, and, as such, meets the requirements of NRC Regulatory Guide 8.7. Newer radiation exposure data, currently maintained on an integrated data base, are immediately available on-line. Some older data (bioassay or dosimeter results) are stored off-line. Annual reports from the data base are microfilmed and stored in individual exposure files and at the national archives storage in Seattle, Washington. Hard copy data not easily reducible to the data base are entered into the individual exposure record file and are microfilmed with the annual report. Hard copy documents may include: 2 radiation occurrence reports skin decontamination reports medical treatment or work restrictions radiation training documents respirator-fit testing records new hire & monitoring frequency changes 1 special evaluation reports. s O The integrated data base system is described in the BNW internal working document, " Occupational Radiation Exposure Design Document". The radiation .I records program operating procedures are in " Internal Working Procedures, i Radiation Records", personnel dosimetry section of the Health Physics Depart-ment. Additional guidance is in PNL-MA-68, Records Management. I 12.2 Posting and Labeling Posting of radiation areas within BNW meets the requirements of Section 20.203 of 10 CFR 20 by conspicuous use of the signs identified in I PNL-MA-6. The radiation symbol used on BNW signs and tags conforms with ANSI-l Standard N2.1-1969, or, for fissile material, ANSI Standard N12.1-1971. The radiation symbol is the conventional three-bladed design, magenta or purple f on yellow background. i l Radiological posting, under the direction of radiation protection person-nel, is done at boundary locations to achieve the best visibility for person-l nel. Normally, signs are posted at eye level on the wall next to the latch side of the entrance door. Movement or removal of radiological signs or tags by personnel other than those from radiation protection may be cause for dis-ciplinary action. Each radiation area, high radiation area, airborne radioactivity area, and area containing radioactive material is posted with a sign or signs bearing II.12-3 4 A

the radiation symbol and the word " CAUTION", with description or combination h of descriptions appropriate for the designated area. 12.3 Personnel Monitoring Personnel doses are measured using either a basic dosimeter or multipurpose dosimeter. The basic dosimeter consists of a single chip of TLD-700. The sensitivity of this dosimeter is approximately 10 mrem from penetrating beta or gamma radiation. The dosimeter will respond within approximately 25% for doses greater than about 100 mrem. The upper range of the dosimeter is at least 10,000 rem. This dosimeter is assigned to personnel who do not work with radiation routinely in their job. The multipurpose dosimeter consists of a card with three TLD-700 and two TLD-600 chips placed within a multifiltered holder. The dosimeter responds to penetrating beta and photon radiation as well as thermal and fast neutron radiation. The sensitivity of the dosimeter is approximately 50 mrem for all radiations except for penetrating photon and thermal neutron radiation where the sensitivity is about 10 mrem. The accuracy of the dose components is 3 in excess of about 100 mrem. The upper range of approximately 25% for dost the dosimeter is at least 10,000 rem. In areas where an accidental criticality is possible, the multipurpose dosimeter is supplemented by a area nuclear accident dosimeter. This dosimeter is capable of estimating the tissue dose from photon and neutron radiation as i well as estimating the neutron energy fluence for neutrons. gl An extensive quality control and audit program is an integral component of the routine processing of dosimeters. Dosimeter reader sensitivity and back-ground are routinely measured and re.;arded. Operating limits are established which require that processing is stopped if any limit is exceeded. Quality j control dosimeters involving both predosed and background dosimeters are pro-cessed every fifty dosimeters. Operating limits are established for the results i of the quality control dosimeters. If any dosimeter result is outside of these limits, the processing is stopped for corrective action. Audit dosime-ters are processed also. The radiation dose and the type of radiation (i.e., beta, photon or neutron) are unknown to the processor. The reported results of the audit dosimeters are compared to the given doses. These must be within predetermined limits or corrective action is necessary. Secondary dosimeters are worn by BNW personnel in work areas where exposure rates are expected to be relatively constant, but may be nonuniform across the work area. BNW secondary dosimeters include self-reading gamma pencils and personal alarming devices. Although self-reading pencils are available with a variety of ranges, the most commonly used at BNW is 0 to 500 mR. Pencil-reading drift shall not exceed plus 5 mR or minus O mR in 24 hours. Alarming dosimeters, such as the personal alarming dosimeter integrator or the personal alarming rate dosimeter, will " beep" as each 1 mR of exposure is recorded. The "superdad" alarming dosimeter, with both integrating dose and dose rate alarms, has an operating range from 0 to 9999 mR, a sensitivity (constant response) of plus or minus 30% for photons within the energy range 60 kev to 9 II.12-4

4 1.25 MeV. Exposures are accurate to within plus or minus 20% for radiation from mCs to rates up to 10 R/h. i Radiation that might be preser.t from accidental criticality events is measured by specific chip combinations within the multipurpose thermoluminescent (TLD) dosimeter. Multipurpose TLDs are processed at least quarterly. Proces-sing frequency is monthly when the staff member's projected annual exposure is 2.8 rem, or when temporary nonunifom exposure is planned, or in other cases specified by radiation protection personnel. In the event of unplanned exposure, dosimeters may be processed to obtain inmediate results, as directed by radiation protection personnel. A few individuals who do not routinely receive radiation exposure ((500 mrem annually) but who do have a need for unes-corted access to radiation areas or who have emergency response responsibilities wear multipurpose dosimeters that are processed annually. l Radiation exposure trends and skin contaminations are discussed by location and organization in the quarterly ALARA report. Dosimetry results are issued regularly to line management for review and use as appropriate in operational planning. The quarterly ALARA report, which also is issued to line management, provides information on doses and exposure trends which can be used in opera-tional planning. 12.3.1 Justification for Substitution of DOE 5480.1 Exposure Limits l Work performed by BW under license SNM 942 is carried out in the same q facilities at the same time and by the same people as work performed under contract with DOE. It is neither technically or administratively feasible to apply two different sets of exposure limits to the same employees. The exposure that employees may receive from licensed materials cannot be distinguished from that which they may receive from DOE materials. The annual and long-term exposure limits applied by BW for work under l the DOE contract are based on those contained in the DOE Orders. The purpose i of requesting approval of the quarterly limits in the DOE Orders as an alter-I nate to the 10 CFR 20.101 limits is to avoid possible confusion, misunderstand-ing, or concern on the part of-BW or other Hanford employees. i Presently, the 10 CFR 20.101 quarterly permissible dose limits are numer-i ically equivalent to one-fourth of the applicable annual limit. In contrast, the DOE quarterly limits permit a higher degree of nonuniformity of exposure s throughout the year, as established by the Federal Radiation Council and the International Con. wion on Radiological Protection. Since BW personnel rarely exceed the quarterly limits specified in 10 CFR 20.101, it is seldom necessary or desirable to permit exposures up to the DOE quarterly limits. The few cases where such exposure has been necessary have been related to l whole body exposure rather than exposure to the skin or extremities. In those cases, the 3 rem per quarter limit is applied (same as permitted by 10 CFR 20.101(b)) except that the combined annual whole body exposure from external and internal sources is limited to 5 rem in the year. Every new employee is required to complete an exposure history question-naire to aid in the evaluation of internal dose and to assure that the new II.12-5 _. _ _ _ _. _ _ - _. _ _... _ _ _ _ _. - _ _ _. ~. _...._.__ _ _... _., _ _ _

employee does not exceed a quarterly or annual limit as a result of his or h her combined exposure for the year. In the event that the new employee has been occupationally exposed prior to employment with BNW, administrative con-trols will be imposed to restrict exposure for the remainder of the year until such time that the prior exposure record is obtained. These controls include the assumption that he or she has received 1.25 rem per quarter for each quarter or fraction thereof in the current year prior to employment with BNW. Addi-tionally, if the accrued or assumed exposure exceeds any quarterly or annual limits, the employee will not be permitted to receive additional exposure while working for BNW until his or her exposure is within the appropriate limits. Any special controls deemed necessary because of either real or assumed exposure will be provided in writing to the employee's supervisor, to the radiation protection section, and to the employee's exposure records file. 12.3.2 Justification for use of Calendar Quarter Beginning on the Last Saturday of December The exposure year at the Hanford Site consists of four quarters ending on the last Friday of March, June, September and December. No quarter is less than 12 weeks nor more than 14 weeks in accordance with a portion of the definition presented in 10 CFR 20.3. However, the remaining days in December, if any, become a part of the new exposure year. A change of the calencar quarter to meet the requirements of 10 CFR 20.3 would impact heavily across the Hanford Site. The contract with the dosimeter processing company specifies that the calendar year will end on the last Friday lh of December. All dosimeter processing schedules and exposure records data processing schedules are based on this definition of the calendar year. The last Friday of December was chosen as the end of the calendar year since Friday is the only day of the week that all Hanford contractor employees other than firemen are at work, regardless of shift schedule. 12.4 Surveys Routine surveys are repeated on definite, established schedules to define radiation levels and identify contamination in laboratories, offices, shops, or other areas. Survey frequencies for each location are determined by a combination of professional judgment and experience, and are periodically reviewed by radiation protection supervision. A number of radiation surveys are performed at the discretion of the radiation protection technologist, or at the request of facility or operating personnel. Nonroutine surveys include, but are not limited to, determination of personnel exposure rates and control of contamination during work with dispersible radioactive material, release of material from a radiation area, identification of contaminated surfaces and records of decontamination progress in the event of suspected contamination on skin or personal effects, or any other off-normal event. Specific forms are used by radiation protection technologists to report results of routine and nonroutine radiation surveys. Requirements for radiation surveys and reporting are described in PNL-MA-6. h II.12-6

Q 12.5 Reports and Records Justification for Alternate Exposure Records The exposure records and reports for the current exposure year at BW include all of the information required on NRC Form 5 with the exception of item 13 (running total for calendar quarter) and item 18 (unused part of per-missible accumulated dose) as required by 10 CFR 20.401(a). The various data on the monthly exposure reports produced by BW have permitted management to effectively maintain BW employee's exposure below 3 rem per quarter. The addition of the running quarterly total to these records and reports would not change the exposure control program but would increase the cost of the Hanford Site exposure records program since any change would necessarily affect the entire plant. No accounting is made of the amount of exposure remaining under the 5 (n-18) rule since an employee's annual exposure is limited to 5 rem. Events that may lessen the effectiveness of the health and safety provi-sions of the license are reported by BW in the manner established in PNL-MA-7, Off-Normal Event Reportina System. A BW research or building manager initiates and prepares a report of an off-normal event or unusual occurrence, with assistance, as needed, from a Laboratory Safety representative. The research department manager and the director of facilities and operations, and the cognizant research director approve unusual occurrence reports. In addition, the laboratory director of O BW provides a formal report to the NRC within 5 days following any event related to 10 CFR 21. Records describing the radiological status of work environments, and records containing radiological information which document personnel activities and exposures throughout their BW employment are accumulated by the radiation protection section and are transferred annually to BW records storage. These records include: external and internal exposure received occupationally during employment at BW reports of unusual exposures or occurrences e radiation work orientation and training respirator training and fitting 1 skin decontamination records radiation protection policies and procedures e procedures and methods for control and evaluation of individual exposure capabilities of dosimeters and instruments e II.12-7

i instrument calibration and maintenance procedures and schedules records of audit and performance tests demonstrating the reliability of the measurement program routine and nonroutine radiation and contamilnation survey reports e RWPs airborne radioactivity monitoring results. + Employee training and retraining records are kept with sufficient detail to evaluate the adequacy of the training. Records include: specific radiation training criteria identification of the applicable RWPs or RWSs e description of the material presented e l employees' cames, signatures, payroll numbers, and date and location of training,' retraining evaluation of effectiveness of the training (examinations or obser-vation of performance 4, trainer's signature. Training records are forwarded, via the Laboratory Safety training coor-dinator and the personnel dosimetry section, for long-term (75 years) reten-tion. Copies of assigned employees' radiation safety training records are retained by line management for two years. Retention times for all ' radiation protection records are 75 years or longar. The records handling methods for BNW are described in PNL-MA-68, Records _. Management. 12.6 I_nstrumentation 12.6.1 Portable Survey Instruments The portable snrvey instrument ' pool is set up to cover two basic functions: personnel and equipment / facility contamination surveys and exposure rate and dose rate. surveys. The portable survey instrumentation for contamination surveys are designed to detect alpha, beta and gamma radiation. Alpha contamination is surveyed with the Eberline PAC-6 air proportional probe unit and the "pam" (portable alpha monitor) which is composed of an Eberline or Bicron count rate meter and an alpha particle scintillation probe. This equipment is calibrated in two parts. The count rate meter is set and aligned by using an electronic pulser on each range and then by an alpha II.12-8 s

emitting source (mTh) to verify that both detector and count rate meter are i operating properly. This work is performed by personnel in the instrument calibration and external dosimetry section of the BNW Health Physics Depart-ment. The electronic signal pulser is calibrated by the Westinghouse Hanford Company standards laboratory at Hanford, and their work is traceable to the National Bureau of Standards. The alpha emitting source was fabricated at Hanford by a radiochemist at Westinghouse from a stock solution that is trace-l able to the National Bureau of Standards. The alpha particle survey instruments are calibrated every 3 months and i this equipment is part of the Hanford portable instrument pool so spare equipment with the same quality is available. Beta and gamma contamination is surveyed with count rate meters connected to the Geiger Mueller detectors. The thin-wall Geiger Mueller detector tube is used in most cases, but the hard-wall Geiger Mueller detector is also availa-ble. The thin-wall Geiger Mueller detector is calibrated by the use of a i plexiglass calibration jig that contains "C, "Cl, "Th and #Sr Y stan-dards. The count rate meter is calibrated and aligned with the use of an 1 electronic signal pulser at each range. The instrument response to each hole is compared to posted, acceptable, count rate limits. Calibration is 1 performed by personnel in the instrument calibration and external dostmetry i section of the BNW Health Physics Department. Prepared calibration procedures are used for this work. The electronic signal pulser is calibrated by the u Westinghouse Hanford Company standards laboratory at Hanford. This work is traceable to the National Bureau of Standards. The calibration sources used for the thin-wall Geiger Mueller detector are traceable to the National Bureau of Standards. The beta and ganna contamination survey instruments have 4 different calibration frequencies. The thin-wall Geiger Mueller detector i probes are calibrated on a 6-month frequency; the hard-wall Geiger Mueller probe is calibrated on a 3-month frequency; and the count rate meter is cali-brated on 6-week frequency. This equipment is included in the Hanford Site portable instrument pool so that spare equipment of the same quality is avail-i able. The exposure rate and dose rate surveys use portable instruments to detect beta, gamma and neutron radiation. Beta and gamma exposure rate and dose rate surveys are performed with ion chamber instruments which include the Eberline R0-3 "cutiepie," the Victoreen Emergency CP (model 325) and the Hanford family of totem pole ton chamber survey instruments. The Eberline R0-3 has a full-scale range of 5 mR/h to 5 R/m in four decade scale selected by a top rotary switch. Instrument sensitivities of 0.5 mR/h can be realized because l of display scale zeroing capability by a manually operated dial. This instru-ment can also measure beta particle dose rate by the use of a manually operated 1 beta window on the front of the ion chamber (beta dose rate correction tables are available in the current instrument manuals). The Eberline R0-3 ion chamber is calibrated on 187Cs wells at the radio-logical calibration facility by personnel from the instrument calibration and O external d simetry secti n f the Health Physics Department. These is7Cs II.12-9 j

calibration wells are corrected for geometry and half life as well as atmo-spheric pressure and temperature that can affect ton chamber performance. Prepared calibration procedures and calibration and repair documentation cards are used. The calibration wells are tested and calibrated (correction factors determined and programmed into the computer control) by personnel in the dosim-etry technology section of the Health Physics Department. Transfer standards are used that are traceable to the National Bureau of Standards. The Hanford CP is calibrated on a 3-month frequency and is part of the Hanford portable instrument pool so that spare equipment with the same quality is available. Special high-range emergency ion chambers are available at radiation protection offices at BNW facilities. This equipment includes older equipment such as the TPC, the LPC, and the HPC, which were designed and fabricated at Hanford. This equipment has a range of 6,000 R/h for the HPC, 500 R/h for the TPC, and 50 R/h for the LPC. A newer, improved CP meter manufactured by Victoreen (model 325) is being introduced into use at BNW facilities. This new instrument has logarithmic and linear led scales that can cover up to 50,000 R/h. This instrument is microprocessor controlled and uses two in-line ion chambers to measure pene-trating and nonpenetrating radiation. Internal temperature and atmospheric pressure sensors correct for temperature and pressure variations. This instru-ment also has an integral exposur,e scale so that accumulated exposure can be displayed.~ ~ _e All hich-range emergency ion chambers are calibrated in the high-range exposure facility at the radiological calibration facility. The high-range exposure facility uses both 88Co and 137Cs sources to provide exposures in excess of the instrument's highest range to ensure that instrument saturation does not occur and lower the meter indications. The high-range exposure facil-ity is calibrated and verified by personnel from the dosimetry technology section of the Health Physics Department. Their calibration transfer standards are transferable to the National Bureau of Standards. Instrument calibration is performed by personnel from the instrument calibration and external dosimetry section. Log books are kept with instrument calibration documentation. The Victoreen Model 325 emergency CP meter has a calibration computer interface to simplify calibration. The older model high-range emergency ion chambers are calibrated on a 6-month maximum frequency (but usually calibrated on 3-month frequency), and the newer Victoreen model 325 is calibrated on a 3-month frequency. This equipment is part of the Hanford portable instrument pool so that spare equipment with the same quality is available. Neutron dose rate is measured with the " Snoopy" which is the AN/PDR-70 manufactured by the Nuclear Research Corporation. This portable survey instru-ment is designed to measure neutron dose equivalent rate over the neutron energy range from thermal to 15 MeV. The Snoopy detector consists of a BFa proportional counter surrounded by a boron-loaded attenuator and inner and outer polyethylene moderators. The detector is cylindrical and has a fixed handle, which makes it easy to use. g l T II.12-10 l l

h The Snoopy has an analog meter with linear ranges calibrated in units of dose equivalent rate: 0 to 2 mrem /h, O to 20 mres/h, O to 200 mrem /h, and O to 2000 mrem /h. Linearity is i 10% of full scale. The Snoopy is calibrated on a neutron well at the radiological calibration facility at Hanford. The neutron well uses a PuBe source which is traceable to the National Bureau of Standards. The neutron field emitted from this calibration well is measured with transfer standards that are traceable to the National Bureau of Standards. An algorithm has been developed and programmed into the neutron calibration well computer unit to set accurate dose rates for equipment calibration. The Snoopy is calibrated by personnel from the instrument calibration and external dostmetry section of the Health Physics Department. Established calibration procedures are used and documentation of calibration and repair is kept. Each instrument is calibrated at two points on each range, and the highest range is tested to ensure that the meter indication does not drop when a dose rate twice as high as the highest indication is present. l The Snoopy is calibrated on a 2-month frequency. This instrument:is part of the Hanford portable instrument pool so that spare equipment with the same quality is available for exchange. 12.6.2 Criticality Monitors Criticality monitoring systems are used in all BNW facilities where labora-O~ tory experi eats or operatioas iavoivias fissiaa bie teri is are bove certeia prescribed quantities. The criticality monitors are connected in arrangements of these instruments so that at least two units need to alarm to energize the facility criticality alarm evacuation. + The criticality monitor units were designed and fabricated at Hanford. Each unit consists of a BFs proportional counter surrounded by an outer polyethylene moderator. The detector is cylindrical and the electronics are I i mounted in a chassis below the detector. The criticality monitors at BNW facilities are set to alarm at 80 mrem /h equipment dose rate, in one second. The criticality monitor units are calibrated yearly or whenever repaired, as specified by ANSI-N323-1978 at the radiological calibration facility by per-sonnel in the instrument calibration and External dosimetry section of the Health Physics Department. A PuBe neutron standard is used in a special calibration fixture to align the equipment. The PuBe standard has traceability to the National Bureau of Standards. Nuclear instrumentation module instrumentation and scalers used for measuring count rate are calibrated by the Westinghouse Hanford Company i standards laboratory which maintains traceability to the National Bureau of Standards. II.12-11 1 I ,,m.,. ,m .w--y,,,.,-,~,...,.r-m..m.,,.--. ,.-m,,_m.-,,,,--,,-.--wu ,.-..c.,-.%,. vr..

Calibration and maintenance records are maintained and spare units are kept calibrated, constantly energized and routinely checked at the radiological g calibration facility so that immediate exchange of inoperative instruments or those due for calibration can be performed. 12.7 Protective Clothing Protective clothing available to operating personnel for all appropriate uses includes coveralls, caps and hoods, shoe covers, waterproof shoe protec-tion, cloth and plastic (" surgeons") gloves, and waterproof suits. Radiologi-cal protective clothing shall normally be white, and white clothing shall be used only for this clothing purpose. Yellow waterproof clothing (pants and hooded jackets) are acceptable. Flame retardant welder's coveralls, brown or red color, may be used as radiological protective clothing, as needed, by welders and their assistants. Waterproof shoe protection may be low rubber or plastic overshoes, or long overboots (" British leggings"). This shoe protection is normally black or amber in color, and may have areas of yellow, red, or other colors for easy identification. Leather or thick rubber gloves may be worn instead of, or in addition to, the thin cloth, plastic, or rubber gloves as directed by radiation protection and when the work may involve the potential for contact with sharp or abrasive surfaces that could penetrate thin gloves. Each person entering a radiation area shall wear the protective clothing specified in the RWP or RWS. Only items in good repair shall be worn. Clothing w that is damaged should be segregated for repair or disposal. 12.8 Administrative Control Levels Administrative action levels, alarm set points, frequency of measurements, and corrective actions are described in appropriate sections of PNL-MA-6 for each major BNW radiation protection monitoring program. 12.8.1 Occupational Exposure BNW operational controls to minimize external radiation exposure are listed in Table 12.1. BNW operational controls to minimize internal radiation exposure include the requirement for respiratory protection: whenever radiation protection becomes aware of conditions in which the airborne radioactivity concentrations may exceed the limits specified in PNL-MA-6 when uncontained dispersible radioactive matertal on small areas readily 2 accessible to personnel is in excess of 10,000 dpm/100 cm alpha activity and/or 100,000 dpm/100 cn2 beta-gamma activity (1. e.,10,000 cpm with a pancake probe). G f l II.12-12

Measurement frequency of external exposure rates are specified in each RWP or RWS. If the work involves a potential for personnel contamination, ~ personnel shall be surveyed before exiting the area. When working in areas where loose contamination is suspect, periodic checks of protective clothing shall be made as specified by radiation protection. j TABLE 12.1 BNW Operational Controls Dose Equivalent, rem Part Exposed Annual Quarter Whole body, head 4(*) 2.4 and trunk, etc. Skin, other organs 12 4 Bone, forearms 24 8 Hands, feet 60 20 (a) Approval of the Laboratory Safety manager is required ] to exceed 2.8 rem. If an event has occurred that may have resulted in personnel contami-O_ nation, radiation protection shall be notified promptly, and a complete survey ~ of the personnel and the work site will be performed. If personnel contami-1 nation is detected, the person should remain at the location and radiation protection and line management should be notified. If no one else is present, 4 help should be called. Precautions should be taken to minimize the possible spread of contamination. Detection of internally deposited radionuclides is based on measurements from BNW bioassay dosimetry programs. Personnel who routinely work with radio-active materials are scheduled for an internal dosimetry evaluation at least 4 once every 15 months. 12.8.2 Airborne Activity l The BNW air monitoring program is designed to ensure that personnel are not knowingly exposed to airborne radioactivity in excess of the values in } PNL-MA-6. Areas where concentrations may be in excess of these limits are provided with continuous air monitors that will alarm at less than or equal i to30 maximum-permissible-concentration (mpc)-hours. Continuous air monito-ring may be established at other locations as determined by radiation protec-tion. Air samples shall be taken in all locations of potential airborne radi-oactivity that are not continuously monitored. 1 O l II.12-13 i _ _, _ _. _ _ _ _ --,,,--- _-.. _.,. _ _, A.. _ _ _ _ _... _ _,. -. _, _,. _ _. ~.. _ _ - -.

Required responses to an air monitor alarm are: Personnel not wearing respiratory equipment shall immediately leave the area, remain in the vicinity, and obtain a personal survey for contam-ination. Radiation protection personnel shall be notified at once. Only personnel wearing respiratory equipment may enter the area to eval-uate the source of airborne radioactivity and/or stabilize it. Personnel wearing respiratory equipment may remain in the area to stop operations that might be the source of the airborne radioactivity. 12.8.3 Liquid Waste Activity Any liquid waste that might be generated at BNW under licensed activities is collected in appropriate containers as near as practicable to the source of generation. An example is the use of a drum or carboy under a sink drain in a laboratory fume hood. The wastes are neutralized, if necessary, and absorbed to form a solid matrix. Shipments are made in compliance with PNL-MA-8, Waste Management. 12.8.4 Surface Contamination Administrative control of areas in which surface contamination could occur is maintained by the use of posted radiation areas, protective clothing, and controlled release of personnel and of equipment from the radiation areas. g Protective clothing, as prescribed by radiation protection, shall be worn by personnel entering areas where smearable contamination may be expected to exceed unconditional release criteria limits specified in PNL-MA-6. Per-sonnel shall not be released to eat or go home (except with specific approval and precautions as directed by radiation protection) if contamination on body surfaces or personal effects exceeds the unconditional release criteria limits. Any material or equipment item in an area where contact with radioactive materials may have occurred shall be surveyed before removal from BNW radiation protection controls. Items that meet the unconditional release criteria limits may be released without restrictions from radiation protection controls. If the contaminants are unknown, the most restrictive limits will be used. Released items shall be promptly removed from the radiation area so inad-vertent recontamination does not occur. A radiation release label is used to show that release requirements have been met, this label is valid only for 24 hours. Corrective action in areas of potential surface contamination may include personnel surveys before exiting the area, periodic checks of protective clothing, and prompt notification of radiation protection if an event occurs that may have resulted in personnel contamination. Other description of cor-rective actions is incluced above in subsection 12.8.1, " Occupational Exposure". O II.12-14

t ({ } 12.9 Respiratory Protection i Only respiratory protection equipment approved by Laboratory Safety shall-be used for personnel protection against radioactive materials. The full-face respirator with tested HEPA filters is the most commonly used BNW respiratory protection. Powered air-purifying respirators and full-face supplied-air respirators are used, as directed by the radiation protection section, when i the potential exists for gaseous or for relatively large amounts of particulate airborne material to be present. In addition, self-contained breathing appa-ratus (" Scott Air Packs") are available for energency use. The respirator fitting program includes, for each qualified staff member, a medical clearance from the Hanford Environmental Health Facility, a respi-rator fit, and respiratory protection equipment training. All parts of this program are repeated biennially for each qualified staff member. f Line management designates which staff members are qualified to use res-piratory protection equipment and ensures that other staff members do not enter areas that require respiratory protection equipment. Only respirators that have been decontaminated, performance tested, sterilized, bagged, and are within the current use-date shall be worn. Before entering an area l requiring respiratory equipment, each person shall verify a proper facepiece j seal. This seal requires that the person be clean shaven in the area of fit and wear only approved types of eyeglasses. When a proper seal cannot be maintained, the person shall not enter, an area requiring respirators. () Respiratory protection equipment training shall be in accordance with i requirements in PNL-MA-6. 9 i i O l II.12-15 4

x.-

m ,,...,.,,,__..._,.~.-.,-.y... ,..~.-__mm ,--._.v...--,-, .m_.-,.

j Chapter 13 OCCUPATIONAL RADIATION EXPOSURES l 13.1 Occupational Exposure Analysis Battelle-Northwest conducts a comprehensive radiation protection program, as described elsewhere in this application, designed to assure that radiation exposures are kept to levels that are as low as reasonably achievable (ALARA). This includes monitoring of personnel exposures via external dosimetry, air sampling and bioassay programs. All of these programs include administrative control levels which, if exceeded, alert management of the need for further investigation or limitation on worker exposure. Battelle-Northwest will continue to provide a high level of radiological protection for workers regard-4 less of the status of NRC-licensed work. Nevertheless, no work with licensed j materials, other than storage, has taken place in BNW-owned or -controlled i facilities since the last license renewal. Consequently, no workers have received internal radiation exposure as the result of licensed activities. Therefore, while bioassay and air sampling data are available for DOE-sponsored 4 work in the 306W and the PSL buildings, they are not presented here to avoid confusion with licensed work. The only occupational radiation exposure due to licensed materials has occurred during required inventories of special nuclear materials in storage and is limited to whole body external radiation exposure. 1 Exposure due to licensed material cannot be distinguished from exposure due to work for the Department of Energy. Consequently, the exposure data presented here for calendar years 1984 and 1985 include exposure due to both types of work. The data are derived from exposure records maintained for O sro#as sis #ed to as' #4 aoew-1 l Whole Body Whole Body Whole Body j Year Number of Employees Total mrem Average mrem Maximum mrem j 1984 261 21,890 84 2,140 i 1985 264 10,930 41 1,520 l j i 13.2 Measures Taken to Implement ALARA Several specific tasks are included in the ALARA program. A quarterly 1 j ALARA report containing trend analysis and goals is prepared for line manage-i ment. Radiation work procedures receive a multidisciplinary safety review that specifically includes a review for implementation of tne ALARA philosophy. All staff with relatively high projected year-end doses receive quarterly exposure evaluations by their supervisors and Laboratory Safety. Exposure trends are reviewed monthly. Special ALARA evaluations are performed on oper-ations where judged appropriate. Publications on ALARA topics and techniques are issued periodically to all staff members. i ' O II.13-1 1

h 13.3 Bioassay Program Personnel who routinely work with radioactive materials are assigned to a periodic internal dosimetry evaluation schedule based on the following: staff members who are defined as radiation workers and who work with radioactive material shall be scheduled for an internal dosimetry evalua-tion at least once every 15 months. Other staff members are not normally scheduled for routine internal dosimetry evaluations. staff members who work with plutonium or uranium in unencapsulated forms shall be routinely scheduled for internal dosimetry evaluation (bioassay, whole body or lung count) at least as often as indicated in Table 13.1 staff members who work with other radionuclides shall be scheduled for and internal dosimetry evaluation. In unusual cases, a staff member may be placed on a routine internal dosimetry evaluation program as determined by Laboratory Safety even though the staff member does not meet any of the above criteria. Laboratory Safety must review and concur with the frequency of the internal dosimetry evaluation schedule for BNW staff members. Table 13.1 Routine Bioassay Evaluation Schedule g Frequency Plutonium (readily dispersible) Soluble Insoluble Urinalysis semiannually annually invivo(a) annually annually Plutonium (nondispersible) urinalysis annually annually Uranium (readily dispersible) Soluble Insoluble urinalysis quarterly annually in vivo annually annually Uranium (nondispersible) urinalysis annually annually in vivo annually annually (a)in vivo evaluations include whole body or chest counts as determined by Laboratory Safety. O II.13-2

i O. Follow-up in vivo or urinalysis examinations are scheduled for any staff member who exhibits routine results that may result in an internal dose in excess of 1% of the applicable DOE standard. 13.4 Air Sampling Program 13.4.1 Air Sampling Equipment Air sampling is used to monitor radionuclide concentrations in air where rooms and exhaust stacks of facilities where radioactive materials are used. Exhaust stack air sampling is performed at facilities where the radio-nuclide inventory, the fom the radioactive material is in, or the type of operation is considered to be necessary or prudent. The exhaust stacks have I sampling probes installed that are designed to be as isokinetic as practicable i i so that sampled aerosols are representative of emitted aerosols. l The isokinetic probe is connected to stainless steel in line sample holders i (Gelman model #2220) by stainless steel tubing with no sharp angles to reduce aerosol impaction. The airflow rate through the sample heads is set to prescribed values by Dwyer airflow gauges with an airflow control. The airflow gauges are checked routinely by radiatior, protection technologists to ensure that dirt and dust buildup do not alte-1e airflow rate. O The owier airfiew sauo, are set with a SAic/RADEco medei Ce12 airfiew i calibrator every 6 months. The results of these tests / alignments are entered into monthly reports. z 1 The SAic/RADEco model C812 airflow calibrator is calibrated yearly by l Westinghouse Hanford Company standards laboratory at Hanford which maintains traceability with the National Bureau of Standards. Room air sampling is performed with special plastic open face and in-line 4 i air sample heads that were fabricated under the supervision of the Materials Science and Technology Department at BNW. The airflow rate through the sample heads is set to prescribed values by Dwyer airflow rate gauges with an adjustable airflow control. The airflow gauges are routinely checked to ensure that dirt and dust buildup do not alter the airflow rate. The Dwyer airflow gauges are set to proper airflow rate with a SAic/RADEco model C812 airflow calibrator every 6 months. The results of these tests / alignments are entered into mor.thly reports. The SAic/RADEco model C812 airflow calibrators are calibrated yearly by 3 Westinghouse Hanford Company standards laboratory at Hanford which maintains traceability with the National Bureau of Standards. i!O II.13-3 r l f a .,w,-, --,g..yn ----, v., n e c ,v, ,,m,-, - -c,r,ge,--.n,m,-,-me, -.,-.---w--v,,.a--w-a ~wv-,e-- .-.g,,,nve,.- -e,,, ,~nmw,,*,,-.c

The investigation levels for positive air samples are listed below: Stacks Alpha = 1.0x10-14 pC1/cc Beta = 5.0x10-12 pC1/cc Daily or Weekly Air Samples for All Facilities Excluding 306W Building Alpha = 1.0x10-12 pC1/cc 5.0x10-1s pct /cc Beta = Daily or Weekly Air Samples for 306W Building Alpha = 3.0x10-12 pC1/cc Beta = 5.0x10-18 pC1/cc The stack values represent a level that is 1/6 of DOE Order 5480.1, Chapter XI, Attachment XI-1, Table II values for 239pu (alpha) and "Sr (beta). The daily or weekly building sample values for all facilities excluding 306W Build-ing represent a level which is 1/2 of DOE Order 5480.1, Chapter XI, Attach-ment XI-1, Table 1 values for 23sPu (alpha) and MSr (beta). The daily or weekly building sample values for 306W Building represent a level which is 1/2 of DOE Order 5480.1, Chapter XI, Attachment XI-1, Table 1 values for :sTh A' 2 (alpha) and '8Sr (beta). W 13.4.2 Air Sample Counting Equipment There are three basic counting systems in the BNW air sample counting program. This equipment includes: automatic air sample counting system manual air sample counting system manual low-energy-gamma air sample counting system. The automatic air sample courting system consists of a nuclear instrumen-tation module crate connected to an automatic sample changer and a 2000 mm2 surface barrier detector. This system detects and counts alpha and beta par-ticle emissions from collected filter media. The data from these counts is fed into a HP-1000 computer where radioactive air concentration values for each air sampling location is calculated. This data is stored in a hard disk unit and is printed in reports as well as used for computer prepared graphics when needed. The delayed air sample counts are counted on the automatic air sample counter. Delayed air sample counts means that a 7-day delay is used for radon daughter background activity decay. All room air samples and stack air samples (using a special computer program) are counted with this equipment. O II.13-4

The automatic air sample counter is tested monthly or whenever repaired or retuned with a CHI 2 confidence test. A minimum confidence of 95% using 20 counts is the acceptable operating point. i The automatic air sample counter is confidence tested with 2"Pu and "Sr standards that were prepared by a radiochemist at the Westinghouse Hanford Company. These standards were prepared from stock solutions that are traceable to the National Bureau of Standards. The automatic air sample counter is tuned and maintained by personnel in the radiological engineering section of the BNW Laboratory Safety Department. Spare nuclear instrumentation modules and detectors are kept on hand to reduce downtime during repairs. I The manual air sample counting system is comprised of nuclear instrumen-l tation modules connected to two photomultiplier tubes that have alpha scintil-lation plastic on one photomultiplier tube and beta scintillation material on the other photomultiplier tube. I The manual air sample counting system is used for first-day counts of selected air samples to ensure that safe operating conditions exist. The manual air sample counting system uses pseudo-coincidence counting to correct for radon daughter background contribution from the air sample media. The manual air sample counting system is tested monthly or whenever repaired or realigned with a CHI 2 confidence test. A minimum confidence of 95% of 20 sample counts is the acceptable operating point. The manual air sample counter is confidence tested with a specially fabri-cated source comprised of 2nPu and "Sr that was prepared by a radiochemist i at Westinghouse Hanford Company laboratories at Hanford from stock radioisotope solutions that are traceable to the National Bureau of Standards. The manual air sample counter is aligned and maintained by personnel in the radiological engineering section of the BNW Laboratory Safety Department. Spare nuclear instrumentation modules and detectors are kept on hand to reduce instrument downtime during repairs. The manual low-energy-gamma air sample counting system consists of nuclear instrumentation modules connected to a Bicron2 low-energy-gamma scintillation i probe. This system is used to count charcoal filter media from air sample heads in laboratories where itsI is used. l I The manual low-energy-gamma air sample counter is calibrated semiannually or whenever repaired or realigned. An mI standard from New England Nuclear is used for calibration and performing voltage plateau tests. The mI stan-dard has documentation showing traceability to the National Bureau of Standards. The manual low-energy-gamma air sample counting system is maintained and calibrated by personnel in the radiological engineering section of the Labo-ratory Safety Department. The calibration procedures have been prepared and reviewed. All calibration data and dead-time calculations for this counting i II.13-5 i i I i --,,+>-2.e- -w y -e - - w, - mm m y n e. w =, ,,--,m,w.,2-,,-em,im,,e,.,mwn, -,%,,y,-.-.,,,,,..v.,-,e,-,c.----3r-c.-me=,--y+ w,.,yr,-,,r-,we,, ,-y+r-e

system are maintained in an instrument logbook. Spare nuclear instrumentation modules and a detector are kept on hand to reduce downtime during repairs. hI 13.4.3 Radiation Detection in Air Radiation detection of particulates in air is performed by two different types of continuous air monitors in facilities at Hanford. Beta-emitting particulates are monitored with the beta-particulate continuous air monitor which is called a " Beta Cam". The Eberline AMS-2 and Eberline AMS-3 are the instruments used. Both pieces of equipment use thin-window Geiger Mueller detector tubes in a lead shielded enclosure to monitor a filter paper medium which has sampled air flowing through it. Both pieces of equipment have chart recorders. The Eberline AMS-2 has a linear meter with a selection switch so that 0-500 c/m, 0-5000 c/m and a 0-50,000 c/m can be selected. An alarm bell and an alarm light on the unit will activate if a set alarm point is exceeded. The Eberline AMS-3 has a logarithmic meter in a four-decade arrangement to cover 10 c/m to 100,000 c/m. An additional thin-window Geiger Mueller detector tube is placed behind the primary Geiger Mueller detector in the shielded enclosure to correct for gamma contribution to the Geiger Mueller detectors. Eberline circuitry in the instrument performs corrections on the analog signals to compensate for gamma radiation contribution. This equipment also has an alarm light and bell. The alarm set points for the beta cams are determined individually for each radionuclide and location. The beta cams are calibrated yearly or whenever repaired. This is because this equipment is not survey equipment, but sem1 portable instrumentation and the frequency of calibration is acceptable under guidelines issued in ANSI-N323-1978. The calibration is performed at the radiological calibration facility at Hanford by personnel of the instrument calibration and external dosimetry section of the Health Physics Department. Prepared calibration procedures are used. The beta cams are calibrated with electronic signal pulsers to set up the count rate meters. The Eberline Ams-2 units are checked and aligned on at least two points on each range. The Eberline Ams-3 units are checked and set at a midpoint and a decade end point on each decade on the meter scale. The electronic signal pulsers are calibrated at the Westinghouse Hanford Company standards laboratory at Hanford which maintains traceability with the National Bureau of Standards. The beta-emitting standards used to calibrate the beta cams consist of HC, 38C1, 21s81 and 231Pa and "Sr. These standards were procured from Eber-line Instruments Corporation and are traceable to the National Bureau of Stan-dards. A radium block-test source is also used to test for detector saturation that can cause the meter indication to drop before full-scale indication is achieved. II.13-6

i i i l i ,O Instrument calibration records are maintained for this equipment. Spare units are maintained and calibrated so that exchange can be made when repair or recalibration of an instrument is required. Alpha emitting particulates are monitored with the alpha particulate continuous air monitor which is called an " Alpha Cam." The Eberline Alpha-3 and Eberline Alpha-5 are the instruments used. Both units use charged particle j diode detectors that are mounted next to a filter paper medium which has sampled air flowing through it. Both units have radon correction electron circuitry and a chart recorder, as well as an analog meter. l The Eberline Alpha-3 has a linear count rate meter with a selection switch so that 0 to 50 c/m, O to 500 c/s, and 0 to 5,000 c/m can be selected. An alarm light and a sonalert are mounted to alarm if the alarm set point is exceeded. An instrument fail light is also installed that will energize if a low count 4 j rate is measured. I The Eberline alpha-5 has a logarithmic count rate meter in a four-decade arrangement to cover 1 c/m to 10,000 c/m. An alarm light and a sonalert alarm { transducer are mounted on this equipment to alarm if the alam set point is j exceeded. An instrument fail light is also installed that will energize if i no count rate is measured. The alpha cams are calibrated yearly or whenever repaired. This equipment is classified as semiportable, and thus.this frequency of calibration is accept-able under guidelines issued in ANSI-N323-1978. The calibration is performed , O-at the radiological calibration facility of the Health Physics Department. Prepared calibration procedures are used. t The alpha cams are initially calibrated with electronic signal pulsers to set up and align the count rate meters.- The Eberlina alpha-3 units are checked and aligned on at least two points on each range. The alpha-5 units are checked and aligned at a mid point and an end point for each decade on the meter scale. The electronic signal pulsers are calibrated at the Westinghouse i Hanford Company standards laboratory at Hanford, which maintains traceability with the National Bureau of Standards. The

Pu standards are used to calibrate the alpha cams. The *Pu standards that were procured from Eberline Instruments Corporation are traceable j

to the National Bureau of Standards. i Instrument calibration records are maintained for this equipment. Spare units are maintained with current calibration so that instrument exchange can be made when repair or recalibration is required. I 13.5 Surface Contamination Radiation areas are established in facilities wherever there is a potential for removable contamination in excess of the limits given in subsection 3.2.4. ] Radiation areas, where radiation protection has determined that a high potential for spread of contamination exists, must have a step-off pad at the entrance. Instructions are provided in the applicable RWP on how to enter or exit the f II.13-7 l l 1 4 --n,-<--r--em-ee-~e-------,-nm- ,em , e ~ m-e, r-w m-,,nv -n-w.-w wer m.v-pr,.-,wm.wn,,--m_ .w m ee-ron-ww+p-we--,----,-,-emev,e , r e, va

radiation area. Personnel survey requirements and protective clothing require-ments are also specified in the RWP. Where personnel surveys are required before exiting a radiation area, either portable survey instruments or hand and shoe counters are provided. Routine and snecial radiological surveys are conducted by radiation pro-tection personnel depending on the potential for contamination. In arear with extremely high potential for contamination, surveillance may be continuous. Other areas with lower potential may be surveyed routinely on a weekly, monthly, or annual basis. Residual contamination on surfaces not designed or intended to be contam-inated, which may be accessible to personnel, are maintained at unconditional release levels whenever practical. If operations or conditions exist where contamination levels are above detectable levels in these areas, approvals based on levels of contamination are required. When active decontamination is no longer being pursued, the contamination will be considered residual and written approvals from management must be obtained. 13.6 Shipping and Receiving Shipping and receiving radioactive material is carefully controlled to ensure adequate control of radioactive contamination and compliance with appli-cable packaging, documentation and safeguards requirements. All shipment or transfer of radioactive material or contaminated material, except for movements of material between radiation areas within a building or building complex, must comply with the requirements of PNL-MA-81, Hazardous Material Shipping Manual, and PNL-MA-5, Nuclear Materials Management and Safeguards Procedures. Use of private vehicles for transporting radioactive materials is not permitted. All incoming packages containing radioactive material are opened in an established radiation area with appropriate contamination controls. Continuous coverage by a radiation protection technologist is required when packages are opened. If the shipment is found to be contaminated, leaking, or otherwise not in accordance with shipping regulations, immediate notification of the hazardous material transportation officer of the Laboratory Safety Department is required. U.S. Department of Transportation labels are removed or destroyed upon emptying incoming packages. Packaging materials and reuseable containers are disposed of or salvaged in accordance with standard waste disposal procedures. Reuseable shipping containers are surveyed for radioactive contamination on the inside and on the outside. If the container is contaminated, and complete decontamination is practical, the container is decontaminated er tagged " EMPTY--HOLD FOR DECONTAMINATION." If decontamination of inner surfaces is not practical, external surfaces are decontaminated to unconditional release stan-dards. The container is then securely closed, tagged " EMPTY WITH INTERNAL CONTAMINATION" and removed to storage. All shipments containing radioactive material are made through an autho-rized and properly trained BNW shipping representative. Shipments of radio-active material made offsite must also be approved by the hazardous material g II.13-8

O-transportation officer to verify that proper procedures are followed, and required approvals, notifications and transfers are made. A properly completed onsite radioactive shipment record or offsite radioactive shipment record must accompany every shipment. A survey for radioactive contamination is required prior to any shipment of radioactive material. For onsite radioactive material shipments, the shipper is responsible for ensuring that the receiver is qualified to receive radioactive material. I i

O i

i l i O II.13-9

Chapter 14 ENVIRONMENTAL SAFETY - RADIOLOGICAL AND NONRADIOLOGICAL With the exception of the disposal of some contaminated scrap that had been in storage for a number of years, BNW's entire inventory of licensed material has been in storage since the date of the last license renewal. The material in storage consists of historical samples of sintered uranium pellets. There have been no licensed activities, other than storage, with these pellets since 1980. Consequently, there have been no airborne or liquid effluents, and, therefore, no radiation exposure of the public as a result of licensed activities since the last renewal date. Battelle-Northwest will continue to conduct a comprehensive environmental monitoring program, as described in subsection 5.2, to determine the impact of overall Hanford operations on the environment and the public, regardless of the amount of licensed material on hand or the amount of work performed with the licensed material. Because the Itcen,ed amounts represent a very small fraction of the total quantities of radioactive materials routinely handled by BNW under contract with DOE, and because the overall radiological impact of recent Hanford operations on the environment has been shown to be well below all applicable regulatory limits, it is expected that the radiological impact of licensed activities by BNW will continue to be insignificant. n O II.14-1

J Chapter 15. NUCLEAR CRITICALITY SAFETY j 15.1 Administrative and Technical Procedures { 15.1.1 Responsibilities and Authority This section provides a sunmary of the responsibilities and authority of i staff members involved in criticality safety. Director of Facilities and Operations -- Provide for the administration and control of the criticality safety program. Interface with and assist other departments to help assure compliance with PNL-MA-25. Request and obtain i corrective action or stop activities not in compliance with the criticality j safety program requirements. Designate the technical leader, nuclear safety. Technical leader, nuclear safety -- Provide support to research and operations i departments in all matters related to criticality safety. Approve criti-j cality safety specifications and isolated facility specifications. Define the need for criticality alarm systems and assist the Health Physics Depart-ment in determining need and location of nuclear accident dosimeters in facilities. Specify the location of the neutron criticality detectors. In conjunction with line management, determine those facilities, equipment, parts and components that are significant to criticality safety. Review i and approve engineering drawings and specifications for facilities, equipment, { parts and components significant to criticality safety. Approve outages of j criticality alarm systems in facilities. Delegate authority and assign 1 l responsibilities to the senior engineer, nuclear safety. i i Senior engineer, nuclear safety -- Exercise the authority delegated and j j fulfill the responsibilities assigned by the technical leader, nuclear safety. 3' Review and provide for preparation of criticality safety specifications, temporary variances, and isolated facility specifications. Verify completion of final inspection of new or modified facilities, equipment, parts, and i components significant to criticality safety if an operational readiness j review is not performed. Coordinate' audits of fissionable material facilities l and isolated facilities. Determine the fire fighting category to be assigned to each fissionable material facility. Provide signs denoting the fire-j fighting categories. Provide for training and qualification of staff members, i Line managers of fissionable material facilities -- Direct activities in a butiding or facility classed as a fissionable material facility to ensure } compliance to PNL-MA-25 and criticality safety specifications. Approve i criticality safety specifications. Provide for a training program, and-training and/or qualification of staff members assigned to the facility. 1 In conjunction with the technical leader, nuclear safety, determine those l facilities, equipment, parts and components that are significant to criti-l cality safety. Notify the senior engineer, nuclear safety, to provide crit-icality safety specifications. Provide for preparation and revision of safety analysis reports, including operations safety requirements for fis-sionable material facilities. Monitor operations to verify compliance with PNL-MA-25. Provide qualified fissionable material handlers to su ervise work activities of others (e.g., craft services), when requested gy the j II.15-1 l i I

building manager. Provide for maintenance of inventories, labeling, and g posting. Ensure that personnel, either permanent or temporary, working in the facility are instructed in the proper response to the criticality alarm. Criticality safety representative -- Exercise authority delegated and fulfill the responsibilities assigned by a department manager and/or operations manager. Review criticality safety specifications. Inspect fissionable material facilities. Assist the operations manager in training and/or qualification of staff members. Line manager of isolated facility -- Direct activities in an isolated facility to ensure compliance with PNL-MA-25 and the isolated facility specifications. Notify the senior engineer, nuclear safety, when a facility requires a clas-sification as an isolated facility and request initiation, revision or cancellation of isolated facility specifications. Approve isolated facility specifications. Provide for maintenance of inventories, labeling and posting. Isolated facility representative -- Exercise authority delegated and fulfill the responsibilities assigned by the department manager and/or operations manager. Approve movement of fissionable materials into the facility. Review isolated facility specifications. Manager of the Energy Systems Department -- Provide support, as needed, to Laboratory Safety and research and operations departments. Provide for development of technical basis memos to document the technical base for criticality safety specifications to include the signature of the staff g member developing the technical base and the signature of the staff member performing an independent review and verification of calculations and conclu-sions. Assign staff members as senior specialist and specialist for criti-cality safety analysis. Senior specialist, criticality safety analysis -- Provide support to the Laboratory Safety Department in criticality safety and fulfill the responsi-bilities assigried by the manager of the Energy Systems Department. Review criticality safety specifications. Prepare the technical basis memo. Review the technical basis memos every two years. Specialist, criticality safety analysis -- Fulfill the responsibilities assigned by the manager of the Energy Systems Department. Review criticality safety specifications. Perform peer review of technical basis memos. Building manager for fissionable material facility -- Provide support to the operations manager by maintaining the facility in a manner to help ensure criticality safety. Review criticality safety specifications and temporary variances. Notify the technical leader, nuclear safety, of a planned building modification that could affect the criticality alarm system. In facilities shared with other contractors, coordinate activities conducted by PNL. Coordinate maintenance / repair activities in a fissionable material work or storage location with the operations manager to ensure that maintenance personnel are supervised by a qualified fissionable material handler. O II.15-2

i. Q Staff members -- All staff members working with fissionable materials in a fissionable material facility or isolated facility conduct work activities as prescribed in PNL-MA-25, and other approved operating procedures, instruc-tions, and specifications. 15.1.2 Training i This section contains the criticality safety training and retraining j ~ requirements for all staff members assigned to a fissionable material facility. j All Staff Members j All staff members receive annual training in proper response to emergencies as specified in Emergency Preparedness, PNL-MA-11, ard applicable building i emergency procedures. All staff members who work in fissionable material i facilities are instructed in the potential danger of criMcality and that only qualified fissionable material handlers may handle fissionable material. l Fissionable Material Handlers ) Staff members selected as fissionable material handlers have the education, j training and experience that is cow.cnsuratre with their assigned tasks.- Line managers provide for a training program to qualify staff members assigned to j fissionable material facilities. The training program includes-initial training and qualification O annual requalification on emergency response e i biennial requalification on all other topics any additional training as determined by the line manager. Fissionable material handlers receive training to ensure understanding of activities related to the work being performed and requirements for opera-s j tions performed in the facility including, as appropriate: normal operating procedures including criticality safety specifications, and labeling and posting requirements i response to limit violations and other unusual occurrences e I principles of operations and responses to the criticality alarm system l 1 location and function of pertinent safety systems, including operations i i safety requirements radiation safety procedures procedures for making changes or alterations in the operations principles of nuclear fission and methods employed to prevent accidental criticality, e.g., mass, concentration, geometry, spacing, physical bar-j riers and administrative controls. !O i' II.15-3 1 i

All topics from the facility-specific training program are presented within a 24-month period, h Fissionable material handlers are subject to examination to demonstrate qualification for the assigned work. Examinations may be oral, written, or consist of practical exercises, operation of equipment, or any combination thereof. The acceptance criterion for examinations (oral, written or practical) is a satisfactory understanding of all the topics or concepts presented in the examir.ation. The examination can be accomplished through discussions between the fissionable material handler and the examiner on each substantive wrong answer. A final written evaluation of the fissionable material handler's proficiency is made by the examiner. Verification of training is conducted during the annual facility appraisal, except as noted below. Verification of training for a new fissionable material handler is made after the final evaluation of proficiency by a cognizant manager who is not the employee's immediate supervisor. Written records are maintained by the cognizant line manager to document attendance at training meetings and completion of qualification examination. A copy of the lecture notes or lesson outline is used to ensure that all the necessary items are recorded for training sessions. Equivalent records may be substituted. The qualification records include copies of written examinations, written g records or oral or practical examinations, or other records to document qual-ification. Qualification as a fissionable material handler is maintained by: being re-examined every two years on subjects pertaining to criticality safety applicable to the work being performed meeting minimum health standards meeting additional training requirements if established by the line man-e ager. 15.1.3 Audits and Inspections Criticality safety audits and inspections are performed to verify compli-ance with PNL-MA-25 and criticality safety specifications. Auditors and inspec-tors have access to all parts of the facility that are safe to enter and to all pertinent records. If in an auditor's or inspector's opinion an unsafe condition exists in facility operation, the auditor or inspector takes appro-priate action for resolving the problem immediately. Fissionable Material Facilities Line managers establish a program for periodic inspections of the facility to verify compliance with PNL-MA-25. Inspections are conducted at least monthly O II.15-4

i i l but are done more often during times of frequent movement of fissionable materials. Inspections are performed using a checklist. The criticality + safety inspections checklist may be used as a checklist and as the record of the inspection. The inspection may be included in the monthly. safety inspec-j tion. j The Laboratory Safety Department conducts biannual audits'of fissionable material facilities to verify compliance with PNL-MA-25. Audits are conducted i using appropriate checklists that identify activities or items to be audited. l Audit. reports include the audit date, identity of the author, a description j of findings and observations, and a request for a written response, by a spe-cified date, to include corrective action and schedule for completion. Audit reports are distributed to the cognizant department manager, the cognizant i line manager, the criticality safety representative, and the technical leader, nuclear safety. 1 j A pre-start-up audit of a facility is conducted by Laboratory Safety to i verify hardware dimensions and other parameters significant to safety when: i significant new work is scheduled to begin I special criticality safety analyses have been made to identify vital i j safety parameters equipment and systems significant to criticality safety have been fabri-e cated, modified, or repaired. { A pre-start-up audit may be included as part of an operational readiness review. j Isolated Facilities The Laboratory Safety Department conducts audits of isolated facilities, i as a minimum, once each calendar year to verify compliance with PNL-MA-25. Checklists are used and audit reports prepared and distributed to the cognizant department manager, the cognizant line manager, the isolated facility repre-y sentative, and the technical leader, nuclear safety. j Appraisals l Appraisals of fissionable material facilities and isolated facilities are conducted by Laboratory Safety as prescribed in PNL-MA-569, Safety Appraisal and Audit Guide. An audit performed during an appraisal is considered to meet the requirement for the audit, but a separate audit report is filed. 15.1.4 Fissionable Material Limits and Administrative Controls j This section identifies fissionable materials that require controls for criticality safety and gives the administrative requirements for safe handling j of these materials, i!O i II.15-5 ) 4 ) i 1 4

h Fissionable Material Identification All radionuclides capable of sustaining a neutron chain reaction are classified as fissionable material (see list below). For packaging and transportation purposes, certain radionuclides are classified as " fissile" material. 233U 239Pu 241Am 244Cm 23sU 24s,a 242'Am 24sCm 237sp 241Pu 243Am 247Cm 23aPu 242Pu 243Cm 249Cf ,S 2stCf Administrative Controls Whenever any of the fissionable materials are encountered in an operation, it is the responsibility of the line manager to determine the type of critical-ity safety control required for the operation. The senior engineer, nuclear safety, is available for guidance and provides for preparation of isolated facility specifications or criticality safety specifications (CSS) and technical bases, as applicable. The type of administrative controls is determined pri-marily by the amount of fissionable material that is in or could be in the facility. If more than one of the fissionable materials is involved, the type of control required can be determined by calculating the sum of the frac-tions of the allowed masses. Exempt Facility A facility containing not more than the quantities of fissionable materials listed in Table 15.1, i.e., 3% of the minimum critical mass, is exempt from criticality control. If more than one of the controlled fissionable materials are in the exempt facility, the sum of the fractions of the allowed masses does not exceed one. TABLE 15.1 Fissionable Material Mass Limits for an Exempt Facility Fissionable Fissionable Materials Grams Materials Grams 2330 16 243Am 750 23su 25 243Cm 2.7 237Np 600 244Cm 90 (50% 23aPu 16 24sCm 0.9 >50% 23sPu 90 247Cm 27 241Am 480 2s9Cf 0.3 242'Am 0.4 2stCf 0.15 Naturaluraniumanddepleteduraniumcontain{0.7wt% 23su and are exempt from criticality controls. 9 II.15-6

/ Isolated Facility ] A facility that may contain more than an exempt quantity of fissionable material and is procedurally limited to not more than 45% of minimum critical mass is designated an isolated facility. In some cases, the limit may be set at 50% of a guaranteed subcritical value. Quantities of most fissionable material that qualify for isolation control are given in Table 15.2. The quantity of assU qualifying for isolation control is dependent on 23s0 enrich-ment. Table 15.3 may also be used to determine amounts of plutonium / uranium mixtures that qualify for isolation control. Encapsulated fissionable material containing more than 45% of a minimum critical mass may be authorized for isolation control with written agreement between PNL and the DOE Richland Operations Office based upon an analysis of the reactivity of the encapsulated material. An isolated facility is physically separated by at least 6 ft from any other work involving fissionable materials. If more than one type of fission-i able material is involved in an isolated facility, the sum of the fractions of the allowed masses does not exceed one (see Table 15.1). An inveatory record is maintained listing the fissionable materials in the isolated facility. An isolated facility specification is required and is reviewed by the senior management, nuclear safety, the isolated facility repre-i sentative, and the building manager. The specification is approved by the line manager and the technical leader, nuclear safety. O TABLE 15.2 45% of Minimum Critical Mass of Fissionable Materials f I Fissionable Fissionable j Material Grams Material Grams 23:V 256 24 sam 12,500 237Np 10,000 24sCm 45 (50% 23sPu 230 2"Cm 1,500 >50% 23sPu 1,500 24sCm 15 2"Am 8,000 247Cm 450 242.Am 6.5 24eCf 5 2stCf 2.5 1 For mixtures of plutonium and enriched uranium (e.g., irradiated fuel rods), the effective plutonium enrichment is used to determine the appropriate mass limit for the mixture. The effective plutonium wt% enrichment is the sum of the calculated plutonium wt% plus any wt% 23su that is greater than 0.71 wt% (natural enrichment). The value of effective wt% plutonium is used with column 3 of Table 15.3 to determine the mass limit for the plutonium contained in the mixture. The sum of the fractions for more than one fissionable material does not exceed unity (one). i O II.15-7

g TABLE 15.3 Enriched Uranium and Plutonium-Uranium Mixtures (1) (2) (3) Enrichment, wt%(a) Contained 23su, a Contained Pu, g 0.71 no limit 632 1.0 9000 540 1.5 2532 427 1.7 2065 400 2.0 1622 378 2.5 1228 351 3.0 1053 333 3.5 977 319 4.0 880 310 4.5 823 301 5.0 783 297 8.0 632 274 10.0 585 265 20.0 496 252 25.0 472 247 30.0 450 243 40.0 428 227 50.0 413 227 75.0 376 227 g 100.0 369 227 (a)For enrichments between the values specified, the next higher enrichment is used. For enriched uranium, column 1 lists the wt% 23s0 contained and column 2 lists the total quantity of the enriched uranium that is 45% of a minimum critical mass. For plutonium-uranium oxide mixtures, column 1 lists the effective wt% Pu contained in the plutonium-uranium mixture and column 3 lists the total quantity of the plutonium in the mixture that is 45% of a minimum critical mass. Fissionable Material Facility A facility that contains, or may contain, 45% or more of a minimum crit-ical mass (see Table 15.2) is designated as a fissionable material facility. Smearable and fixed contamination at work or in storage areas is insignificant to criticality safety and is not considered in determining quantities of fis-sionable materials. All work with fissionable materials is accomplished in accordance with a CSS that contains the mandatory limits and controls. Whenever practicable, limits should preclude the possibility of a criticality. However, when not practicable, limits are predicated upon the two-contingency policy which states that two, unlikely, independent and concurrent errors or accidents must occur before criticality is possible. 9 II.15-8

l A Generally, the CSS limits the mass, volume or dimensions, and also limits !U or controls the spacing between arrays, batches, controlled areas, open shipping J containers or other fissionable materials. The CSS may include limits or controls on special materials that are better neutron reflectors and/or ) moderators than water. Carbon, beryllium, deuterium, certain hydrocarbons j (e.g., oil and plexiglass), concrete, and heavy metals (e.g., uranium, tungsten, i 1 and lead) are some of the common materials that are excellent reflectors or i moderators. These materials are accounted for in the technical bases whenever j any of these materials are or could be a factor. The CSSs are reviewed by the specialist, criticality safety analysis; 4 the senior specialist, criticality safety analysis; the senior engineer, nuclear i safety; the building manager; and the criticality safety representative. The i j CSSs are approved by the technical leader, nuclear safety, and the line manager. Technical bases for limits and controls are prepared and documented in a j technical basis memo prepared by the Energy Systems Department. All staff members who wcrk in a fissionable material facility receive training and are qualified, commensurate with their work responsibilities. Maintenance and/or repair of equipment and systems in work or storage locations, j 1.e., glove boxes, open-face hoods, storage racks,, etc. containing fissionable materials, are accomplished by or under the supervision of a fissionable material handler. 4 A safety analysis report and operational safety requirements are required for a fissionable material facility. l An operational readiness review is completed prior to start up of a new-fissionable material facility or for work that requires a new or supplement r to a safety analysis report. } i Fire Categories l For fire-fighting purposes, buildings or areas within a building are { classified into one of following four categories, depending upon the quantity j and nature of fissionable materials present. Category A areas have no probability of criticality if water is used to fight a fire. FissionaEle materials are present in a relatively small quantity. Fire-fighting methods are not restricted in any way by criti-cality safety. Category 8 areas have only a minimal probability of criticality if water is used to fight fires as the fissionable material present is either in 1 a very dilute solution or confined in a fixed geometry such that a criti-cality cannot occur. Water in any form may be used in any-amount. Category C areas have a finite low probability of criticality if unre-i i stricted use is made of water to Tight fires. Fissionable material is i present in an amount and configuration that might possibly be made critical upon rearrangement and the addition of water. The only forms of water i II.15-9 i } i i

that may be used are high-expansion foam, automatic sprinkler systems, g or hose fog nozzles. Water in other forms is used only upon specific w authorization by the senior fire officer present at the emergency. Category D areas have a finite high probability of criticality if water is used to fight fires. Fissionable material is present in a configuration that may become critical upon the addition of water. Water, as high expansion foam, may be used to fight fires. Water in other forms is used only upon specific authorization by the senior fire officer present at the emergency. There are no restrictions on the use of dry chemicals, CO, Halon 1301, and 2 inert gases. Justification for Alternate Methods for Criticality Detection Criticality detection systems, as required by 10 CFR 70.24(a), are installed in tnose buildings where BNW works with substantial quantities of fissile materials, and in those where substantial quantities of fissile mate-rials are stored. Those buildings where lesser quantities of fissile materials are used are established as isolated facilities as described in PNL-MA-25, Criticality Safety. An isolated facility is any facility where the inventory of fissile material is administratively limited to less than 45% of a minimum critical mass. Criticality detection systems are not provided in isolated facilities. Typical uses of fissile materials in these buildings include various chemical and physical analyses, measurements on samples or specimens, and studies of the deposition, uptake or biological effects of these materials on animals and plants. 15.1.5 Limit Violation and Criticality Emergency Criticality safety specifications and isolated facility specifications prescribe limits for fissionable materials and, if applicable, limits for ref.ecting and moderating materials and size and shape of vessels and tanks. Any action that reduces the safety margin created by these limits is considered a limit violation. Limit Violation Action is taken immediately if a violation of a criticality safety limit is observed or suspected. The staff member discovering an actual or potential violation takes the following action: stops work in the work or storage area immediately e ensures that any fissionable materials or other equipment and materials associated with the fissionable materials are not moved or disturbed 9 II.15-10

.~ 5 e O immediately notifies the line manager and the criticality safety representative or the isolated facility representative, as applicable if.the line manager and representative are unavailable, notifies the building manager or calls the single point contact (375-2400) and states the problem. The criticality safety representative provides assistance to the line manager or takes action prescribed for the line manager if the line manager is not available. If a limit has been violated or is suspected, the line manager ensures that all work activities are stopped and the single point contact is called. The line manager notifies the members of the: evaluation team as follows: technica! lecder, nuclear. safety senior engineer, nuclear safety e senior specialist, criticality safety analysis cognizant line manager e criticality safety representative or isolated facility representative, e as appitcable building manager. a The evaluation team evaluates'the suspected violation and determines the actions to be taken. O If it is determined that a iinit has not been vioiated. the evaivation team authorizes work to1 resume and documents the decision with copies of the report provided to the director of facilities and operations and the cognizant department manager. If is detemined that a. limit has been violated, but a second contingency still provides for prevention of criticality or other danger, notifications are made as specified in PNL-MA-7, Off-Normal Event Reporting System. The evalua-tion team prepares a' written plan for recovery from the violation. The recovery plan is based on a thorough review of the s.ituation and the potential hazards associated with the violation. If it is determined that a limit has been violated, and a second contin-gency does not provide for prevention of a criticality, the appropriate actions prescribed in PNL-MA-11 are taken. . Recovery from a criticality safety limit violation or suspected violation is accomplished as directed by a recovery plan. A recovery plan is prepared by the evaluation team and contains the specific steps to be taken to recover from the violation. To prevent future violations, the plan includes, as appli-cable,.the following: revision to operating procedures training of staff members e redesign of equipment e revision of the CSS or the isolated facility specification e II.15-11 I y

revision of the appropriate manuals. h The recovery plan is dated and signed to indicate approval by the evalua-tion team and the cognizant department manager. Staff members involved in actions specified in the recovery plan and others who perform work associated with the recovery are thoroughly briefed on the violation or malfunction, the real or potential consequences, and the details of the recovery plan. Criticality Emergency In the event that an unplanned criticality should occur or if it is known or suspected that protective contingencies of an operation' involving fissionable material have been lost, action is taken to protect personnel and the environ-ment. In the event of a criticality occurrence, the following actions will be ,taken: Evacuate people to a safe distance from the event in accordance with the butiding emergency procedures. Give aid to victims of the incident in accordance with the building emer-gency procedures. O Do not attempt to terminate criticality in a system that has undergone a e cri ticality. Conduct preplanned emergency activities that aid in preventing or con-taining radioactive material releases if such action does not further endanger personnel. Report the occurrence in accordance with PNL-MA-7, Off-Normal Event Reporting System. The following individuals are also notified of the occurrence:

1) the manager responsible for the operation; 2) the critical-ity safety representative; 3) the technical leader, nuclear safety; and

4) the senior specialist, criticality safety.

Take the action prescribed in PNL-MA-11, Emergency Preparedness. If a loss of all protective contingencies is evident, the following actions will be taken: Halt work at the work station. Do not take any action that may modify or disturb the operation. Evacuate people to a safe distance from the hazard in accordance with the building emergency procedures. 4 II.15-12

1 l l Notify the immediate supervisor of the operation or the criticality safety e l representative. i Report the occurrence in accordance with PNL-MA-7. The following individ-uals are also notified of the occurrence:

1) the manager responsible nical leader, nuclear safety; and 4)y safety representative; 3) the tech-for the operation: 2) the criticalit j

the senior specialist, criticality i safety. Take the action prescribed in PNL-MA-11, Emergency Preparedness. Upon completion of emergency activities to ensure safety of personnel and render aid to victims of the incident, a special task force will be assigned the responsibility of disarming the hazardous system or operation. ~ The purpose i of this task force is to direct restoration of at least one contingency for criticality safety. The makeup and duties of the task force are described in PNL-MA-11, Emergency Preparedness. 15.2 Preferred Approach to Desian Geometry control of fissionable material is the preferred means of cri-ticality safety controls and is used wherever feasible. Criticality safety r dimensions are attributed to spherical geometry, unless equipment design ensures a geometry less favorable to criticality than spherical (e.g., cylinder or j slab). O The maximum fractions that independently satisfy the two-contingency j criteria are: e 0.45 of critical mass J 0.75 of critical volume 0.75 of critical mass per unit area 0.85 of critical slab thickness 0.85 of critical cylinder diameter. ] Sumps are required to be safe by geometry or by using fixed poisons, i assuming credible leakage and accidental spillage from vessels and piping linked to the sump. Pipe connections are not permitted between a fissionable solution system controlled by safe geometry and a system controlled by-safe-mass. Safe cylinder and slab dimensions for process vessels are based on the most reactive form of the fissionable material that can reach the vessels. 15.3 Basic Assumptions The mandatory criticality safety limits are identified through a technical 1 analysis of the specified work involving fissionable material. Criticality safety limits used in establishing CSS are based on data from experimental measurements or, if direct experimental data are not available, on limits obtained from a calculational method that can be shown to be accurate or con-servative when compared to experimental measurements. Whenever practicable, limits preclude the possibility of a criticality. However, when not practi-cable, limits are predicated upon the two-contingency policy which states that 4 II.15-13 ) ..._._.-.-_.-___-,,___._____-.....___.-m,-_,

two, unlikely, independent and concurrent errors or accidents must occur before criticality is possible. Generally, the CSS limits the mass, volume or dimensions, and limits or controls the spacing between arrays, batches, controlled areas, open shipping containers or other fissionable materials. The CSS may include limits or controls on special materials that are better neutron reflectors and/or moder-ators than water. Carbon, beryllium, deuterium, certain hydrocarbons (e.g., oil and plexiglass), concrete, and heavy metals (e.g., uranium, tungsten, and lead) are some of the common materials that are excellent reflectors or moder-ators. These materials are accounted for in the technical bases whenever any of these materials are or could be a factor. Typical spacing limits are 12 inches between batches of fissionable material, where a batch is any amount of fissionable material (up to 45% of a minimum critical mass) separated by more than 12 inches from other fissionable material. Safe limits are based on full water reflection except when less reflection can be assured by the two-contingency policy. Instances in which less than full water reflection may be assumed are: fixed, unreflected process vessels in a sealed hood or cell into which access is controlled unreflected containers of vessels wrapped with sufficient cadmium or g other nuclear poison sheeting to ensure nominal reflection individual storage units in a storage array (less than full water reflec-e tion may be assumed for some arrays in the interaction calculations). Safe limits are based on optimum water moderation, unless other than optimum moderation can be assured by the two-contingency policy. Instances in which nonoptimum water moderation may be assumed are: fissionable material in watertight containers fissionable material in watertight glove boxes in which the amount of moderating material introduced into the glove box is limited and controlled. (Automatic, overhead, room, fire sprinklers are permitted if the glove boxes are critically safe by geometry under flood conditions. Under the situation where a glove box is not safe by geometry under flood conditions, the mass limit is reduced such that criticality would not be possible.) fissionable material stored in a vault or room which specifically excludes water flooding or significant moderation by other materials fuel rods securely bundled (closely packed) e 9 II.15-14

b systems in which the moderator is solid, thus fixing a H/X ratio to a certain value or range of values as in the case of fissionable materials in polystyrene or other compact substance fuel rods or groups of fuel rods. separated by sufficient water or equiv-alent material to prevent neutron interaction i systems in which the concentration can be limited within a safe range by the two-contingency policy. For instances where fissionable material processing or handling involves special reflectors or moderators such as D 0, carbon, or beryllium, a special 2 1 nuclear criticality safety evaluation is required if the quantities involved exceed the following: . 3.0 liters of D 0 2 9.0 kg of carbon 1.6 kg of beryllium metal 2.6 kg of Be0 3.0 kg of heavy metal. i 4 Emphasis is placed on moderation control in glove boxes in which unmod-i erated special nuclear material is processed. Typical controls employed are as follows: l Whenever the supply of water or oli is unlimited, potential flooding due h to rupture of a water or oil line is controlled by means of continuous operator surveillance, quick-acting shutoff valves, or liquid detectors located on the floor of the glove box. A limited quantity of hydrogenous liquid is pennitted in a glove box for cleaning purposes, provided that the liquid is not mixed with special nuclear material. As an added margin of safety, the amount of liquid permitted is limited to an amount that would be safe, even if mixed with the fissionable material. For vessels or units in arrays in which neutron interaction contributes to reactivity, allowance factors to obtain safety margins depend on the method used to calculate the critical number of units in the array and on how well the method predicts criticality for arrays that have been measured experimen-tally. When the density analog method is used, the calculated critical number of units is reduced by a factor of a least two for those cases that are known to be conservative as compared to measurements, and by a factor of between 3 and 5 when comparisons to measurements are less certain. Further, for complex shapes and geometry where the density analog parameters are difficult to cal-culate, assumptions made are always conservative. For questionable arrays, actual experimental measurements may be required. When the safety of an array is based on the calculation of k,gr for the array, the allowance factor required to obtain an adequate margin of safety also depends on the comparisons to experimental measurements. For those arrays that can be accurately computed, the maximum allowable k gr is 0.95 at a 95% confidence level; and for arrays ! O. II.15-15

that compare less favorably with experimental measurements, k,rr for the array is limited to a lower value depending on comparisons to measurements. 15.4 Analytical Methods and Validation References 15.4.1 Calculational Methods Safety limits used in establishing criticality safety specifications are based from experimental measurements; or if direct experimental data are not available, on limits obtained from a calculation method that can be shown to be accurate or conservative when compared to experimental measurements. The codes currently in use for criticality parameter calculations include GAMTEC-II, EGGNIT, THERMOS, HFN, DTF-IV, KENO-IV, and the AMPX modular code systems. The GAMTEC-II, EGGNIT, and THERMOS codes generate multigroup constants for use in the HFN multigroup diffusion or the DTF transport theory code. The GAMTEC-II and EGGNIT codes have proven to be quite successful (although conservative) for heterogeneous uranium-water systems. Correlations with experimental measurements have been good. GAMTEC-II, EGGNIT, THERMOS, HFN, and DTF are considered adequately reliable for a wide range of uranium and plutonium systems. Safety margins used are nonetheless commensurate to avail-ability of confirmation of experimental measurements. The KENO-IV Monte Carlo code can be used to examine many simple or complex problems which, with some reservations, may consist of any combination of boxes, containers, cylinders, spheres, or rectangular parallelepipeds. AMPX is a modular systems for producing coupled multigroup neutron-gamma cross-section sets. Basic neutron and gamma cross-section data are obtained from ENDF/B libraries. Most commonly used operations required to generate and collapse multigroup cross-section sets are provided in AMPX. Various analytical checks and comparisons with critical experiments are used to ensure that the results of system analyses with the various computer codes are conservative. 15.4.2 Neutron Interaction Calculations For neutron interaction calculations, four methods are used: Monte Carlo solutions, empirical models, solid angle, and density analog methods. The Monte Carlo code permits a nearly exact description of the geometries and fuels involved, so that a very close k,rr can be obtained for the overall system. Empirical models are being developed with adequate conservatism for solution of some types of problems, such a piping intersections. The solid angle method is used primarily for arrays of cylinders containing solution, for which the method has been shown to be reliable. The solid angle method is used on systems for which it has been shown to be conservative. The density analog method is used to calculate the critical number of moderated or unmod-erated units in a planar or cubical array. The method is based on the estab-lished fact that if density or an unreflected critical system is changed uni-formly, all dimensions of the system must be scaled inversely as the density changes in order for the system to remain critical. II.15-16 l [

15.5 Data Sources Typical data sources include information published in scientific litera-ture, e.g., ANS Transactions. Handbooks or other compilations of information such as ARH-600, Criticality Handbook; PNL-2700, Handbook of Critical Experiment Benchmarks; or TID-7016, Rev. 2, Nuclear Safety Guide are among the data sources available and used. 15.6 Fixed Poisons All operations that use raschig rings for criticality safety are conducted in accordance with the ANSI /ANS Standard. In processes conducted behind massive shielding, soluble and fixed neutron poisons such as boron in solution, Pyrex raschig.~ings, and steel plates con-r taining neutron poisons such as boron or gadolinium may be used as primary means of criticality safety control. When a soluble neutron poison is used as a primary means of criticality control in a solution system, at least two independent administrative controls must be used against omission of the poison (e.g., combinations of attenuation instrument, chemical analysis, double check ofaddition,etc.). In processes not conducted behind massive shielding, fixed poisons may be used as a primary means of criticality control if the positive design measures and maintenance controls ensure that the poison is always present, and that leaching of the poison away from the matrix does not occur. Soluble poisons may not be used as a primary criticality control in unshielded facilities. O 15.7 Structural Integrity Policy and Review Requirements The structure integrity and safety margins for arrays is addressed in the applicable safety analysis report and is reviewed by operations and safety. Before a building can be designated as a fissionable matertal facility in which greater than 45% of a minimum critical mass of fissionable material may be handled, a safety analysis report is required. Also, any significant modification or additional work not previously covered in a safety analysis report requires a safety analysis in a supplemental safety analysis report. These reports are the result of a thorough study that is performed to ensure that potential major nuclear hazards have been analyzed and appropriate action taken to reduce the probability of major accidents and to minimize the conse-quences in the unlikely event of their occurrence. The safety analysis considers foreseeable nuclear accidents that would substantially threaten the safety of personnel or the public, the use of or damage to property, and the continuity of operation of facilities. Each safety analysis report and each revision requires the approval of the responsible department manager, Laboratory Safety (which includes the nuclear safety group), and the Safety Review Council, and is reviewed by the Richland Operations Office of DOE. O II.15-17

w

.p. -m._ . _ v

15.8 Special Controls h 15.8.1 Fire Fighting Symbol Fire symbols are positioned in the center of and immediately above the entrances to a building or specific areas within a building dependent upon the fire fighting categorization. Where the height of the door exceeds 6 ft, 8 in., the sign is posted 6 in, on center to the right of the opening at a height of 6 ft. Each symbol, as specified in the Hanford Plant Standard No. AC-3-29, is made of metal at least 1/8-in. thick and lettered in black in the shapes and colors indicated. Category A -- no posting. Category B -- diamond shape with fluorescent green background. Category C -- an equilateral triangle with a fluorescent red background is used to denote rooms or areas. A square sign with the notation "C Hoods" on a fluorescent orange background is used to denote glove boxes, refrigerators, or other enclo-sures within a room. Category D -- a round sign with a fluorescent blue background is used to denote rooms or areas. A rectangular sign with the notation "D Hoods" on a fluorescent yellow background is used to denote glove boxes, refrigerators, or other enclo-sures within a room. 15.8.2 Additional Posting If fissicaable material is stored near a wall or other visual obstruction under conditions where access to the locations is unrestricted, the reverse side of the wall or obstructions is posted with the words "No Fissionable Material Allowed Within (distance required) Feet." 15.8.3 Posting of Exterior Walls and Entry Points in Isolated Facilities Each entry point through which fissionable materials may be brought into an isolated facility and each exterior wall without an entry point has a sign (metal material with painted letters, plainly visible at six feet), displayed with at least the following information: ISOLATED FACILITY -- (Building or Facility) FISSIONABLE MATERIAL BROUGHT INTO OR WITHIN 6 FEET OF THIS FACILITY MUST HAVE PRIOR APPROVAL OF (name of the isolated facility representative) 15.8.4 Posting of Walls in Adjacent Rooms of Isolated Facilities If a portion of a building has been designated as an isolated facility and a room adjacent to the isolated facility has a common wall, the wall in II.15-18

l Cs7 the adjacent room is posted with the following: "No fissionable material allowed within six feet." O O II.15-19

Chapter 16 PROCESS DESCRIPTION AND SAFETY ANALYSES 16.1 Physical Sciences Laboratory The principal operation performed with licensed material in PSL involves polishing, mounting and examination of small samples ((45% of the minimum critical mass) of normal, depleted, or enriched uranium samples in solid form from 306W. Because of the limited quantities of radioactive material permitted in PSL, the maximum credible accident would have minimal radiological impact. Consequently, an extensive safety analysis review of the PSL has not been performed. 16.2 306W Facility The 306W facility consists of four separate process or storage areas: the diversified metal-working facility, the ceramics laboratory, the specialty machine shop, and the special nuclear material storage area. Process descrip-tions and safety analyses are provided for each of these areas. It should be recognized that the processes described here pertain primarily to work performed for the DOE and are only included as examples of the types of processes which might be used in licensed work. 16.2.1 Diversified Metal-Working Facility Process Description The diversified metal-working facility in 306W performs a variety of nonrepetitive fabrications development jobs. Melting is performed in vacuum or inert gas chambers with the vacuum pumps exhausted to the building exhaust system. Iron, nickel, uranium and zirconium base alloys are melted in sized from a few grams up to 40 kgs uranium equivalent using ceramic, graphite or water-cooled crucibles and molds. Metal deformation and heat treating processes such as forging, extrusion, rolling, swaging compaction and drawing involve the handling of metal pieces from small wire up to billets weighing 40 kgs or more and temperatures up to 0 1200 C. Handling of these materials is usually performed using hand-held tongs, hydraulic carts and overhead cranes. Encapsulation methods are used on hot operations such as extrusion, heat treating and compaction involving powders and/or radioactive materials. Some chemical operations are performed to remove lubricants and oxides from metal surfaces or to remove metal mandrels and encapsulating materials such as copper or iron. These involve the use of solvents, aqueous solutions, and hot HF gas. Fumes from nonradioactive operations are directed to a scrubber system. Fumes from radioactive chemical operations are directed to the building exhaust system. The various experiments completed, underway, and contemplated require the use of strong acids (nitric acid), preparation of uranyl nitrate solutions of various concentrations, the containment and treatment of evolved nitrogen II.16-1

dioxide containing gas streams, etc. The majority of support equipment necessary to complete these operations is now available in the room. Specific experimental equipment for individual experiments is readily assembled and appropriately installed in the facility. Examples of specific experimental work which can be completed includes evaporation of uranyl nitrate solutions to produce products suitable for calcination to uranium dioxide, liquid extraction experiments, nitrogen oxide recovery to produce acid for recycle, and other similar studies related to nuclear fuels reprocessing. Because spccific experiments change from time to time, the basic laboratory equipment is designed to be as flexible as possible. The room can thus be modified to accept a variety of unit processes at a relatively modest cost in labor and hardware. Safety Analysis Any work involving fissionable material in the diversified metal-working laboratory is conducted within the limits of a CSS (as described in Chapter 4 of this application). For most types of work performed in the laboratory, the primary means of establishing two contingencies of protection are mass control and geometry control. Where practicable, operations with fissionable material are conducted such that criticality is precluded by geometry. However, due to the size and design of the equipment within the laboratory, the most prevalent means for establishing the required criticality control is by setting a limit on the g mass of fissionable material processed at a location or work station. Where mass limits are established they are normally based upon 45% of the minimum critical mass. If moderator control is used to provide a contingency of pro-tection in conjunction with a mass limit, the mass limit may be established at 90% of the minimum critical mass assuming optimum moderation and full reflec-tion (minimum critical mass). The mass limit established at 90% minimum critical mass shall also be restricted to (45% of the critical mass with permitted quantities of moderator present. Thus, for criticality to be pos-sible, two independent errors would be necessary -- 1) a mass limit exceeded, and 2) the inadvertent intrusion of moderator into the material. Where moder-ator control provides a contingency of protection, measures shall be taken to prevent the intrusion of moderator, i.e., sealed vessels and containers or the source of the moderator physically prohibited. A violation of a mass limit can more likely occur if the limit is stated in terms of a fissile (23sU) weight. Thus, in practice, mass limits are trans-lated into the weight of material being handled directly verifiable by scale weight without calculation. Spacings requirements, along with the basic limits that provide the two contingencies of protection, are posted in a location that is readily visible to operating personnel. Labels are provided on containers that identify the material and the contained mass throughout the processing operation. Each work station or temporary holding station has the current inventory of fission-able material posted at that location, recording each addition and removal to and from the station. II.16-2

O' Procedures are in force that include mandatory daily cleanup of the equipment and work area plus individual equipment cleanup after each use. Other procedures are in force that require periodic inspection of waste drain lines and sumps within the 306W facility for possible accumulations of material. For compliance with nuclear material management requirements, additional inspections for possible accumulations are made whenever " materials unaccounted for" values exceed amounts dependent upon measurement uncertainties. These amounts are small fractions of a minimum critical mass. Although the possibility of a criticality accident in the diversified metal-working laboratory cannot be precluded, an acceptable means of estab-lishing a minimum of two contingencies of protection on-fissionable material operations has been applied. The limit and controls in force on these opera-i tions have historically demonstrated a sufficiency for reducing the. probability of a criticality accident to an acceptable level. 2 In a typical uranium melting operation, the amount of molten metal ranges from 100 grams to 40 kgs. In all cases, water cooling is in close proximity to the molter uranium. A water leak during uranium melting could result in a reaction between the water and uranium. This reaction could result in the water flashing into steam and the evolution of hydrogen. A breach of the melting chamber would allow the hydrogen to enter the work area resulting in a possible explosive mixture. The following operating procedures and engineered safety features are used to minimized the possibility of an explosion. Uranium melting is performed with operator present at all times from power being turned on to solidification of the ingot. The chamber is evacuated before the melting power is turned on. Should there be a water leak at this time, it will be detected during pump down.- 1 A water leak occurring after the melting power is turned on will be detected by a rise in furnace pressure or by the operator's direct observation of the molten metal, at which time the heat is aborted by turning off the melting power and cooling water supply. The furnace j poder and cooling water can be turned off in less than 5 seconds. For enriched uranium, an audible alarm is electronically linked to the i e chamber pressure sensors so that a rise in chamber pressure sounds the alarm. The operator can then turn off the melting power and cooling i i water. For these heats operator attendance is required until the ingot j and furnace have cooled to below incandescence. 16.2.2 Ceramics Laboratory Process Description The principal material processed in the ceramics laboratory is uranium i dioxide (UO ). Natural, depleted, and enriched (to as high as 93% 2ssU) UO 2 2 may all be present in the laboratory at one time. Typically, UO is received i II.16-3 l v

w

.%,,--r<-- w w -,--e,w-ww-%---w.-r -, w w w-e---w-r-----w--,,,y--,yw-,vw, -.-r- ,-wwww-w-mye.--,-r---o-,gg.,wey-sw.+w-ee-*=w-v--r---er-g+r - ye-*---re-, rw-,,-,,

4 in powder form and is converted to nuclear fuel pellets by a series of h< processing steps which may include part or all of the following: weighing, blending, screening, hammer milling, ball milling, wet or dry binder addition, 1 drying, slugging (prepressing), granulating, pellet pressing, hole drilling, sintering, centerless grinding, and ultrasonic cleaning. All handling of UO2 and Th0 in powder form is limited to hoods. 2 The uranium may also be received in the form of dried ammonium diuranate (ADU) which is simultaneously calcined and reduced in a hydrogen or hydrogen-argon atmosphere furnace, yielding UO2 powder suitable for the processing operations already described. l Occasionally sintered U02 pellets may be recycled to the powder form by oxidizing to U 0s in an air atmosphere furnace, followed by hydrogen reduction 3 to reconvert the resulting powder to UO - 2 In some cases, the UO2 powder may be blended with other nonfissile oxide powders such as Th0, Ga0. Zr0, etc. and formed into sintered mixed oxide 2 2 2 pellets. Loading of fuel pellets into cladding tubes and welding of end caps in the tubes is perfomed in a vacuum welding chamber. The fuel rods are loaded into special capsules for irradiation in a nuclear reactor. Alternatively they are packaged separately or formed into fuel rod assemblies for use at other laboratories or reactors. Fuel pellets may also be packaged for shipment to other locations for assembly into fuel rods or assemblies. Another type of processing that may occur in the ceramics laboratory is the receipt of unirradiated reactor fuel assemblies from another site, followed by disassembly into fuel rods and removal of fuel pellets from the rods. The pellets may then be reloaded into rods having characteristics different from those 11 the fuel assemblies received from offsite. Safety Analysis Any work involving fissionable materials in the Ceramics Laboratory is carried out under the limits and controls of a CSS. As in the diversified metal-working facility, mass limits will be translated into net weight, whenever possible, to obtain an inventory directly verifiable without calculation. Violations of mass limits are possible whenever more than one allowed batch is introduced into the laboratory which is only likely during large-scale projects involving semi-routine operations. Under such conditions the personnel who are thoroughly familiarized with the limits are working with continuous inventory postings at each process station. These are maintained for accountability as well as criticality control at the work stations. The work stations are physically separated as a further means of control. II.16-4

{} The controls for material misidentification include: Containers for enriched UO2 are color and size coded for ease in identifying enrichments. Inventory sheets for work stations and storage arrays will have the enrichment limit clearly marked at the top, and enrichment shall be part of the required information for each entry. Misidentification could only occur if an operator were ignorant of the coding system and the enrichment limits presently in force for the laboratory. Personnel are reminded of the basic coding system at regular training sessions and special meetings are held whenever limits are changed for the laboratory. Qualified fissionable material handlers from other operating groups are permitted to handle fissionable material in the laboratory but only under the guidance of someone normally assigned to the laboratory. For compliance with nuclear material management requirements, effort is made to find inadvertent accumulations of materials whenever " materials unaccounted for" values exceed amounts dependent upon measurement uncertainty. These amounts are small fractions of a minimum critical mass. If inspection of the likely points of accumulation does not result in sufficient material recovery, an effort such as removal of most fissionable material from the laboratory (to reduce radiation background) followed by thorough survey of the laboratory by radiation detection instruments will be made, eb Large fires are not considered likely in the ceramics laboratory. Walls, hoods and cabinets are made predominately of metalc Accumulations of flammable materials are administratively held to a minimum, and waste containers are located in closed metal boxes. Several fire extinguishers are available in the facility, and the 306 Building is located two to three minutes travel time from tne 300 Area fire station. Small fires due to electrical shorts or equipment overheating are credible; however, no direct criticality contingency is envisioned as a result of such a fire. Such fires would not activate the fire sprinkler system. Even if the sprinklers were used to extinguish a fire in a hood, no criticality potential exists because limits for the laboratory are set with full water flooding of the material assumed. Criticality potential from flooding must involve some rearrangement of material, since limits for individual units are set with full water flooding assumed. The most readily imagined rearrangement of material is the washing of fissionable material from the hoods from some mechanism that floods them. General flooding from a pipe break can easily be demonstrated incapable of providing sufficient water depth to flood hoods located three feet from the floor. Water from accidentally activated fire sprinklers would accumulate in the hoods; however the rate of accumulation is conservatively calculated at 0.04 inch per minute, which allows 25 minutes for the line to be valved off before the minimum hood-lip depth of one inch is achieved. Hydrogen is used in the 306W ceramic laboratory as a continuously flowing reducing atmosphere in the processing of nuclear ceramic materials and sintering of nuclear fuel pellets. A relatively large volume of hydrogen is required II.16-5

in these operations to effect the necessary chemical reductions and to sweep h volatile impurities out of the furnace chamber. Because of the potential explosion and fire hazards associated with this high-volume usage of hydrogen, the hydrogen gas system, furnaces and associated control equipment are designed for foolproof and fail-safe operation. The entire gas and furnace system is in the routine preventive maintenance system. It is operated only by trained qualified operators, in accordance with a detailed procedure. The design of the system ma'Kes the possibility of an accident most unlikely. Specific safety-oriented design features of the system are described in the following paragraphs. The hydrogen source, a double manifold of cylinders, is located outside the north wall of the 306W facility between columns 7 and 8. These cylinders are connected to the manifold by qualified personnel, using spark-proof tools. Each primary connection to a bottle (pigtail) has a check valve to prevent leakage of hydrogen from the manifold. The manifold is equipped with a double pressure reducing station and a pressure relief pop valve, set at 75 psig. This precludes the possibility of high pressure hydrogen entering the building. Provisions are also available at the manifold to purge the entire piping system with inert gas before hydrogen is introduced. The reduced pressure, normally 30 to 40 psig, is piped outside the building wall to column 4, where it enters the building. The pipeline crosses bay 1 of the 306W facility at the partition of the ceramics laboratory and is extended to the furnace location along the south partition. Two separate sources of argon are used in the furnace system The manual argon purge system is used to purge the furnaces before hydrogen is introduced and to purge the hydrogen from the system at the completion of a process cycle. The safety argon system is another manifold system of cylinders which is on standby, open to the furnace at all times during the use of hydrogen. It is designed to flow automatically in any event of furnace power or hydrogen failure. A part of the furnace start-up procedure includes confirming that a minimum of twice the argon necessary to cool the furnace is available from this safety argon system. Argon from this system is not used for any other purpose. Hydrogen cannot be introduced into the furnaces without the availability of the propane pilot flame system to assure burnoff of the hydrogen flowing from the furnace. Propane pressure is required to open a normally closed electric solenoid in the hydrogen line and turn on the large red operation light on the furnace exhaust canopy. A second normally closed solenoid in the hydrogen line is opened only after the propane flame has heated a temperature sensor located at the point of gas exit from the furnace. This valve automatically closes and blocks hydrogen flow and initiates argon flow if the propane flame is extinguished. The furnace control system, some of which has already been discussed, also includes a pressure switch in the process gas line which will trip, disconnecting power to the furnace if pressure drops to (15 psig. In this event the solenoid valve blocks the hydrogen from entering the furnace and i the safety argon continues to flow at a reduced pressure of 10 psig. This allows the hydrogen to be purged from the system and protects the furnace I with the inert gas until it is cooled. The safety argon system, propane pilot g light interlocks and low hydrogen pressure interlocks are checked for W II.16-6 l l l

4 l.- operability prior to furnace start-up. This hydrogen gas furnace system has been in routine operation for approximately 20 years, and there has never been any explosion or fire. This experience provides assurance that when the operating procedures are followed occurrence of any mishap is improbable, Any addition to the system, such as the update addition of a new furnace, t will include the same or equivalent foolproof and fail-safe design and operating procedures. j } Propane is supplied to the 306W facility from a 1000-gallon liquid propane storage tank located about 50 feet east of the 306E facility. The tank is i protected with two pressure relief valves and relief pipes directed away from the 306E facility. A pressure-reducing valve maintains the propane gas pressure at 15 psig, with relief valves at the tank set at 20 psig. The line runs underground to the 306W facility, up the east wall inside the building, then west along column line C into room 121 of 306W. There are no propane outlets in the 306W. There are no propane outlets in the 306E facility. The propane is used in the heat-treating furnaces in room 121. A propane line runs north from room 121 to column line D, then west to room 126 of the ceramics laboratory i. where it is used to burn excess hydrogen from the sintering furnaces (described i in detail in preceding section). The pipe runs in the 306E and 306W facilities i are located out of reach of the building cranes. All horizontal propane pipe i runs in the 306E and 306W are next to walls and are at least 11 feet above floor level. The very low gas pressure in these lines and their location in the building makes the risk of pipe rupture extremely low. The propane system 1 was installed in accordance with Hanford Plant Standards for type of pipe, l fittings and pressure test. Completion record verification of testing is on file at the Rockwell Hanford Company's engineering files. Accordingly, the 1 probability of a propane explosion or fire in 306E or 306W is minimal. 3 2 16.2.3 Specialty Machine Shop f Process Description i The bulk of fissionable materials handled in the specialty machine shop is depleted uranium with only an occasional machining service performed on thorium or enriched uranium. Ingots, bars, pellets, and other similar forms are milled, drilled, turned or otherwise machined to produce finished precision hardware or research and development. I Safety Analysis j The shop is limited to uranium-bearing materials only, generally in the fonn of ingots, bars, pellets, etc. l d When enriched uranium is handled or machined, the amounts, batch spacing i i and accountability are governed in strict accordance with approved criticality j safety specifications suitable to the enrichment. A significant loss of material during a machining or handling process would be immediately noticed in the accountability and inventory records and would be investigated and j resolved. iO II.16-7 ,,n.-.,, -.--,.,.,.w-. ... n _---nn-,--,,.--,.~n,,--.-,-,.,c-,,.-..,a.-- -n--

Standard maintenance procedures of craft services require complete cleanout of all surfaces and internal areas of machines including the machine coolant sumps before and after machining operations on enriched uranium. Internal criticality safety audits of the shop operation are performed monthly if enriched uranium is present. Independent audits are made by safety and nuclear materials management. In normal operations considerations are given to the possibility of improper labeling, spacing error and amount of material. Proper labeling of enriched uranium is a condition of acceptance of the material to the shop, and the labeling is maintained throughout the machining assignment. Spacing of batches is understood and maintained by assigned personnel in strict accordance with CSSs. The amount of material per batch is governed by the limits and controls prescribed in the CSS. Mandatory training of personnel prior to assignment to the 306W machine shop is required in craft services standard maintenance procedures. Instruction by the foreman is mandatory prior to each assignment for enriched uranium handling or machining. The foreman maintains qualification to instruct others in accordance with BNW Criticality Procedure No. 7. Enriched uranium machining is performad infrequently to a point that it is considered an unusual operation. Capability and criticality safety provi-h sions are, however, maintained for the present and future. The shop foreman must have prior notice before enriched uranium may be authorized for entry into the shop. The unauthorized entry of material is considered to be an abnormal situation, and subsequent handling of the material could lead to loss of safety control as well as accountability. Precautionary measures include a sign stating material restrictions at the shop entrance. Shop personnel are informed of the material restriction in the observance of Criticality Safety Procedure No. 7, and Standard Maintenance Procedure No. 10, " General Shop Operations," which limits uranium entry to the shop to depleted uranium except by the custodian's (foreman's) authoriza-tion. Fire and explosion are considered since uranium metal is pyrophoric and since any small fire has the possibility of leading to a major uncontrolled fi re. Fire prevention is based on strict housekeeping procedures and controls. These controls include mandatory cleanup of the shop and equipment each working day, plus individual machine cleanups after each use. Other controls include frequent shop inspections by craft services manage-ment and monthly safety meetings with shop personnel. Gl II.16-8 I {

16.2.4 Special Nuclear Materials Storage Area Process Description There are three different types of storage arrays in the special nuclear materials storage area:

1) normal and depleted uranium storage. cages (2 cages),

2) low-enriched uranium storage racks (2 racks), and 3) high-enriched-uranium storage cabinets (2 cabinets).

Each of these storage arrays are under separate lock and key, permitting maximum flexibility in sharing the arrays between the two material balance areas represented in the facility. The low-enriched-uranium storage racks each consist of fifteen 24-foot long, 5-inch-ID troughs (heavy gauge steel half-rounds). The troughs may be replaced by shelving under certain conditions. The racks are approved for U or UO2 up to 5.1% enrichment. The high-enriched-uranium storage cabinets are two types, differing in color, size of cubicle and enrichment permitted. The cubicle sizes are designed j to limit the number of approved containers per cubicle to three, maximum. Each container is limited to a specific mass that assures the safe storage of material in the cabinet if all the material was at the maximum permitted enrichment. The containers going to each cabinet must have lids the same color as the cabinet for which they are intended, Safety Analysis Criticality is considered the major credible hazard in the storage area. Fire is precluded by the almost total lack of combustible material in the area and the presence of sprinklers. The storage arrays are built substantially of steel. They rest on a concrete floor and are surrounded by steel walls. The most common form of fissionable material in the storage area is uranium metal and uranium oxide as powder or sintered pellets. Other chemical and physical forms may at times be present, however, subject to review by nuclear criticality and safeguards and security. All fissionable material will be in sealed metal containers (cans or rods) with the possible exception of large uranium metal pieces stored in the low-enriched-uranium racks or in the normal and depleted uranium storage cages. Since large quantities of fissionable material are present in the storage area, the possibility of a criticality cannot be considered incredible. The following section discusses the controls that reduce the possibility of criticality. The two engineered safety features in the current storage arrays are the i limited width of the troughs in the low-enriched-uranium storage rack and the limited size of the cubicles in the high-enriched-uranium storage cabinets. The troughs are 5-inch-ID half-rounds, spaced 8-inches apart and held coplanar by their supports. They thus form an array which is approximately 5 inches in depth, but with an effective depth of less than 2.5 inches. The minimum critical slab depth for 5.1% (maximum) enriched uranium is 4.2 inches fully water reflected and optimally water moderated; but is 6.3 inches without water II.16-9

reflection. The trough array is considered critically safe for the following g reasons: The effective slab depth is less than 60% of the absolute minimum critical slab depth of optimally water moderated and reflected (5.1 enriched uranium. The actual slab depth is less than 80% of the critical unreflected slab depth (still assuming optimal water moderation). Flooding of the storage racks such as to achieve array reflection is not considered credible. Holes are drilled every 6 inches in the bottom of the troughs to prevent water accumulation, to minimize even partial water moderation of the array. Metal cans have a ridge on their circumference that prevents blockage of the holes. The high-enriched-uranium storage cabinets have been analyzed for criti-cality safety on a different basis than the low-enriched-uranium storage racks. Only unmoderated uranium compounds in watertight metal cans are permitted in these cabinets. The size of the cubicles for each type of cabinet physically limits the total number of (approved) containers in each cabinet to 180 maximum. A density analog analysis of the cabinets estimated that this number is less than 0.25 of the minimum critical number of such containers assuming optimum interspersed moderation and full water reflection. The cabinets are fixed greater than three feet apart to preclude significant neutron interaction. W They have sloping tops to prevent storage on top and to deflect water away. In addition, the bottom 18 inches of available storage space has been blanked off to prevent moderation of the material from flooding. The administrative controls for criticality safety have been mentioned previously and are listed here for reference. Access is limited to a few designated and specially trained persons. Criticality specifications detail the storage and entry / removal limits for each type of array. Fissionable material containers are coded with color and size to show enrichment range (when any possibility of confusion exists).

All containers of fissile materials are labeled to identify the amount, enrichment and form of the material. Moderated fissile materials are labeled with a distinctive magenta border and the words " moderated material" across the top.

Spacing control on the storage array is emphasized by signs and safe distance indicators (e.g., lines on the floor). Fire -- Storage arrays are constructed entirely of metal with the exception of the styrofoam spacers in high-enriched-uranium storage cabinets. Whereas, g II.16-10

these spacers are important controls for the entry of material, their melting or deformation within the locked cabinets does not constitute a criticality hazards. Flooding -- Flooding of either storage array such as to produce effective lateral reflection is not credible, as has been shown before. Incidental wetting from fire sprinklers or a water pipe break will not lead to criticality in either array, as mentioned previously. Earthquake -- The storage arrays per se can withstand credible earthquakes. Measures are taken (e.g., taping down Toose rods in the storage troughs) to assure against dislodgment of material from the low-enriched-uranium racks. The doors on the high-enriched-uranium cabinets keep material from being dis-placed from them. O O II.16-11 ) . ~ _. -. _

1 (q Chapter 17 ACCIDENT ANALYSIS %)' Based on analysis of all credible accident scenarios, including criticality, hydrogen explosion, furnace explosion, and design basis fire, it has been concluded that the maximum credible accident in the 306W facility that would cause a release of radionuclides to the environment would be a criticality. The radiation doses shown in Table 17.1 were calculated using conservative assumptions. TABLE 17.1 Calculated Radiation Doses From An Accidental Criticality in 306W External Exposure Organ of Maximum Population Dose, person-rem (a) Interest Individual Dose, rem for 1985 l Total Body 0.17 3.2 i Inhalation Pathway Organ of Maximum Individual Dose, rem PopulationDose, person-rem (*) Interest 1 year 50 year for 1985 Total Body 0.012 0.013 0.49 m Bone 0.087 0.091 3.5 Lung 0.12 0.12 5.3 Thyroid 1.4 1.4 53.0 GI(LLI) 0.034 0.034 1.4 ("I The population dose is calculated for a 50-mile radius. The data in Table 17.1 are taken from PNL-2549, Safety Analysis Report, 306-W Building, 1979. Copies are available on request. 1 1 1 i O II.17-1 _ _ _ _}}

ML20155K131

Text

Navigation menu

Search