ML20195J714

Standard Review Plan for the Recertification of the Gaseous Diffusion Plants.Draft Report for Comment

ML20195J714
Person / Time
Issue date:	02/28/1999
From:	Cox C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUREG-1671, NUREG-1671-DRFT, NUREG-1671-DRFT-FC, NUDOCS 9906210105
Download: ML20195J714 (140)

Text

NUREG-1671 1 Standard Review Plan for the Recertification of the Gaseous Diffusion Plants i

.i.]

m Draft Report for Comment

-2 N

oe z E U.S. Nuclear Regulatory Commission j'~'%,

2 Office of Nuclear Material Safety and Safeguards  ; i

, Washington, DC 20555-0001 \,,,,,

62 g990228 1671 R PDR c

o NUREG-1671 l

l Standard Review Plan for the Recertification of the Gaseous Diffusion Plants i 1

l Draft Report for Comment Manuscript Completed: December 1998 Date Published:Febmary 1999 Prepared by C.R. Cox Division of Fuel Cycle Safety and Safeguards Omce of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 7 ~ s,,

o)-

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COMMENTS ON DRAFT REPORT Any interested party may submit comments on this report for consideration by the NRC staff.

Comments may be accompanied by additional relevant information or supporting data. Please specify the report number draft NUREG-1671 in your comments, and send them by May 28,1999, to:

Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T-6 D59 Washington, DC 20555-0001 You may also provide comments at the NRC Web site, http://www.nrc. gov. See the link under " Technical Reports in the NUREG Series" on the " Reference Library" page.

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Charles,Cox Mail Stop: TWFN 8 A33 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Phone: 301-415-6755 E-mail: CXC5 O

r ABSTRACT This NUREG provides guidance to the staff reviewers in the Office of Nuclear Material Safety and Safeguards who perform safety and environmentalimpact reviews of the recertification applications for the two gaseous diffusion plants in Paducah, Kentucky, and Portsmouth, Ohio.

The standard review plan (SRP) presented in this NUREG ensures the quality, uniformity, stability, and predictability of the staff reviews. It presents a defined basis from which to evaluate proposed changes in the scope and requirements of the staff reviews. The SRP makes information about certification acceptance criteria widely available to interested members of the public and the regulated industry. Each SRP section addresses the responsibilities of persons performing the review, the matters that are reviewed, the l Commission's regulations pertinent to specific technical matters, the acceptance criteria used by the staff, how the review is accomplished, and the conclusions that are appropriate to summarize the review.

iii NUREG-1671

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TABLE OF CONTENTS Eage ABSTRACT........................................................................................................................ iii 1.0 G E N E RAL I N FO R MATI O N . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. .. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .1-1 .

i 1.1 Site De scription . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.1.1 R esponsibility f or R eview .. . . . .. . . . . . . . . . . . . . .. . . . . ... . . . . . . . .. . . . . . . . . . . . . . . . . . . .. . . . . . . . 1-1 i i

1.1.2 Pu rpose of Review . . . . . . . . . .. . . . . . . . . . . . . . .. . . .. . .... . . . . .. . . .. . . . . . . .. . . . . . .. . . . . . . . . . . . . . 1-1 1.1.3 Are a s of R evi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.1.4 R evi ew P rocedu res . . . . . . . . . . . . . . . . . . . . .. . . . ... . . ... . .. . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . 1-2 1.1.5 Acceptance C rite ria . .. . . . . . . . . . . . . . . . . . . . ... .. . . .. . . . . . . .. . . . . .. . . . . . .. . . .. . . . . . . . . . . . . . . . . 1-2 l

l 1.1.6 Evaluation Findings . . .. . .. . . . . . . . . . . . . .. . .. ... . . . .. . . . . . .. . . . . . . . . . . . . . . . . . .. .. . . . . . . . . . . . . . 1-3 1.1.7 Reference........................................................................................ 1-4 i

i 1.2 I nstitutional i nform ation . . . .. . . . . . . . . . .. . . . . . . . . . . .. . ... . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. . ... . . . . . . . 1-5 i 1.2.1 Responsibility for Review . ................. .. ............. ................. ..... ..... ..... 1-5 l 1.2.2 Pu rpose of Review . . .. .. . . . . . . . . .. . . . . . . . . . . .. . . .. .. . . ... . . .. .. . . . . . . . . . . . . . . . .. .. . . . .. . . . . . 1-5 1.2.3 A re as of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 .

1.2.4 Review Procedu res . .. . . . . . . . . . . . . . .. . . ... .. . . . .. . . . .. . .. . . .. . . . . . . . . . . . . .. .. . . . . . .. . . . . . . . . 1-5

[ 1.2.5 Accepta nce C rit e ria . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . .. . . . . . . ... . . . .. . . . . . .. . . . . . . . . .. . . . . 1-5 l 1.2.6 Evaluation Findings . . . . . . . . . . . . . . . . . . . . . . . . . .. .. .... .. . . .... . . . . . . . . . . . . . . .. . . . .. . . .. . . . . . . 1-7 l 1.2.7 Reference........................................................................................ 1-7

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2.0 ORGANIZATION AND ADMINISTRATION ............................................................ 2-1 2.1 O rga nizational Structu re . .. . . . . . . . .. . . . .. . .. . . .. . . ... . . . .... . . .... . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . 2-1 2.1.1 Responsibility for Review ... . .... ..... ..... .................. . .... . . . ...... ........... .. .. 2-1 2.1.2 P u rpose of Review . . . . .. . . . .. . .. . ... . . . . . . .. . . . .. ... . ... . . . . . .. . .. . .. .. . . . . . . . . . . .. .. . . . . . . . 2-1 2.1.3 Areas of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1.4 Review Procedu res . . . . . . . . . . . . . . . .... . ... . . . . ... .. . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . .. . . .. . . . . 2-2 2.1.5 Accepta nce C riteria . . . ... . . .. .. . .. .... . . . . . . .. . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . 2-2 i 2.1.6 Evaluation Finding s .. . . . . .. . . .. .. . .. . . . . . . . .. . . . . . . . . . . .. . . . . .. . . . . . . . . . . . .. . . . . .. . . . . . . . .. 2-4 l 2.1.7 Refarence....................................................................................... 2-5 t

l 2.2 Safety Review System s .. . . .. . . . . . . .. . . . . . . . . . . .. . . . . . . . . ... .. . .. . . . . . . . . . . . . . . . . . .. . . . . . . . . . .. .. . . . 2-6 l 2.2.1 Responsibility for Review ... ....... ....... ........... .... ......... ..... ................... 2-6 2.2.2 Purpose of Review . . . . . .. . . . . . . . . . . . . . . ... . .. .. .. . . . . .. . . .. . . . . . . . . .. . . .. . . . . . . . . ... . . . . . .. . 2-6 2.2.3 A reas of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 ...

2.2.4 Review Procedures . . . ... .. .. . . .. . . . . . . . ... . . . . . . ... ... ... . . .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . 2-6 2.2.5 Acceptance Crite ria . . . . . . . . . . . . . . . . . . .. . . . .. . . . . ... . . .. .. . . . . . . . . . . . . . . . . . . . .. ... . . . . .. . . . .. 2-6 2.2.6 Evaluation Findin gs . . . . . . ... . . ... . . . . . . . . . . . .. . . ... . ... . . . . . . . . . . . ... . . . . . . . . . . .. . .. . . . . . . . . 2-8 2.2.7 Ref e re nces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9 2.3 Training and Qualification .... .. ... ........ .... .. .. .. .. .. ....... ....... .. .............. ..... ...... ... 2-10 2.3.1 R esponsibility f or Review . . . .. . . . .. .. . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 2- 10 O

v Draft NUREG-1671 f

Paae 2.3.2 Pu rpos e of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . 2- 10 2.3.3 Are a s of R e view . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . .. . . . . . . . . . . . .. . . . . . . . . . . . . . . . 2- 10 2.3.4 R eview P roce d u re s .. . . . . . . . . . . . . . . . . . . .. . . . . . . .. . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . 2-1 1 2.3.5 Acce p t an ce C rite ria . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . . .. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . 2- 12 2.3.6 Evalu ation Fin din g s .. . . . . .. .. . . .. . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. . . . . . . . . . . . 2- 1 5 2.3.7 R e f e r e n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-

. . .1. 6 2.4 Procedures............................................................................................. 2-17 2.4.1 Responsibility for Review ........................................... ..................... 2-17 2.4.2 Pu rpo se of R evie w . . . .. . . . . . . . . .. . . . . . . . . .. . . . . . . . . . . .. . .. . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .. 2- 17 2.4.3 Are as of R evie w . . . . .. . .. . . . . . .. . . ... . . . . .. . .. .. . . . . . . . . . . . . . . .. . . . .. . . . . . . . . . . .. . . . . . . . . . . . . 2- 17 2.4.4 R eview Proced u re s . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . . .. . . . . .. . . . .. . . . . . . . . . . . . . . . . .. . . .. . . . . 2- 17 2.4.5 Accepta nce C rite ria . .. . . . . .. .. . .. . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. . . . . . . . . . . 2- 17 2.4.6 Fvaluation Fin din g s . . . . . . . .. . . . . . . . . . . . . . . . .. . . . . . . . . . . . ... . . . . . . .. . . . . . . . . ... . . .. . . . .. . . . 2-2 0 2.4.7 R e f e re n ce s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20 2.5 i ncid e nt i nve stig ation ... . .. . . .. .. . . . . .. . .. . . . . . .. . . . . . . . . ... . . . . . . .. . . . . . . . ... . . . .. . . . . . . ... . . . .. . . . . . . 2-21 2.5.1 Responsibility f or Review ............................................................... 2 21 2.5.2 Pu rpos e of R eview . . . . . . .. . . .. . . .. . . . . . . . . . . . .. . . . . . .. . .. . . . . ... . . . . .... . . .. . .. . . . . . . . . . . . . 2-21 2.5.3 Are as of R eview ...... . . . .. . . . .. . .. . . . . . . . .. . .. .. . . . . . .. . . . . . . .. . . . . .. . . . . . . .. . . . . . . . . . . .... 2-21 2.5.4 R eview Proce d u res . . .. . . . . . .. .... . . . . . .. . . . . . .. . .. . . . . . . . . . . . . .. . . . . . . . .. . . . . . . . . .. . . .. . .. 2-21 2.5.5 Acceptan ce Crite ria . .. . . . . . . . ... . .. . .. .. . ... .. . .. . . . . . . . . .. . . . . . .. .. .. . . . . . . . . . . . . . . . . . . ... 2-22 2.5.6 Evaluation Findin g s . . . . . . . . . .. . .. . . . . . .. .. . . . . .. . . . . . ... . . . . . . . . . . . . . . . . . . . ... . . .... . . . . . . 2-24 2.5.7 R e f e re n e e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24 2.6 R e cords Mana g em e nt .. . . .. . .. . . .. . .. . . .. . . . . . . . . . . .. . . . . . . . . .. .. . . ... . . . . . .. . . .. . . . .. .. . . . . . . . .. . ... 2-25 2.6.1 Responsibility for Review ................................................................ 2-25 2.6.2 Pu rpos e of R eview . . . .. . . . . .. . . . . . .. . . . ... . . . . . . . . . .. .. .. . . . . . . .. .. . . ... .. . . . . . . . . . . . . . . .. . 2-25 2.6.3 Are as of R eview .. . ... . . . . . .. ... . . . . .. . .. . . .. . . ... . . . . ... ... . .. . . . . . .. . .. . .. . ... . ... . . . . . . ... 2-25 2.6.4 R eview P roced u re s .. . . . . .. . . . . .. . . . . . . . .. . ... ... .. . . ... .. ... . . .. . .. . . .. . . ... . . . . . .. . . . . . . . 2-25 2.6.5 Acceptance C rite ria . .. . .. .. . . . . .. . . .. . . . .. . . . . ... . . . . . . . . . . . . .. . . . .. . . . . ... . .. . . . .. . .. . . . .. 2-27 2.6.6 Evaluation Findin g s ... . . . .. . .. . . . . . . . ... . . . . . . .. . . . .. ..... . . . .... . . . . . . . . .. . . .. .. . .... . . . . . 2-28 2.6.7 R e f e r e n c e . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 8 2.7 M ai nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.7.1 Responsibility for Review ................................................................ 2-29 2.7.2 Pu rpose of R eview .. ... . . . .. . . .. . . . .. . . . . . . . . . . . . .. . ..... . . .. . . . . . . . .. .. . . . ... ... . .. . . . . ... 2-29 2.7.3 Are as of Review . . .. . . .. ..... . . . ... .. ... .. . . .. .. . . .. . . . . . .. .. . .... . .... . ... . ... .. . ... . . . .. . .. 2-29 2.7.4 R eview Proce dure s . ... . . . . . ... ... . . .. . . . . . .... . . . . . . . ..... ... . . . . .. . .. . ..... .... ... ... . . .. 2-29 2.7.5 Acceptance C rite ria . .. . .. . . . .. ... .. . . . . . . ..... ... . . . . ... . . ... .. . . . . . . . . . . . . . .. . .. .. . .. ... . . 2-30 2.7.6 Eva luation Findin g s .. .. . . . .... .. . . . . . . . . . .. .. . . .. . . .. . ... . . . . .. .. . . . . . .. .. .. . . ... . . . . . . ... . 2-33 2.7.7 R eM re n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-34 2.8 Contig u rathn Man a g e m ent . .. . . . . . .. .... ... . . . . ... . . . .. . . . . ... ... . .. . . . . .. . . . . . ... . . . . .. . . . . . . . . . . 2-35 2.8.1 Res aonsibility for Review ................................................................ 2-35 2.8.2 Pu rt. ose of R eview .. ... . . .. .. . . ... . . .. .. . . . . . . . .... ... . . . . . .. . . . .. .. . . . . . . . . . . . .. . . . . . . . . .. 2-35 2.8.3 Are as of R eview . ... .. . . . .. . . . . . ... .. . . . . . . . . ... . .. .. . . . . . .. . . .. .. . .. . . . . . . .. . ... . . .. . . . . . . .. 2 35 Draft NUREG-1671 vi

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[ enan 2.8.4 Review Procedu res . . .. . . . . . .. . . . . . . . . . .. . . . ... .... . .. .. . . . . . . . . .. . . . . . . . .. . . . . ... . . . . . . .. . 2-36 2.8.5 Accepta nce C rite ria . . . . . . ... .. . .. . . . . ..... . . ... . . . . . .. . . . . . ... .. . . . . . . . ... . . .. . ... .. . . . .. . . 2-38 2.8.6 Evaluation Findin g s . . .. . . . . . . . . .. .. . .. .. .. . . . . .. .. . .. . .. ... . . . . . . . .. ... .... . . .. . . .. . . . . . . . 2-39 2.8.7 R ef e re n ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 0 3.0 Q U ALITY A S S U R A N C E ... . . . .. . . . . .. ... . . . .. . . . . .. . .. . . . . . . ..... . . . . .. . . . . . . . . .. . . . . . . .... . . 3-1 . . . . . . .. . . .. . ..

3.1 Responsibility for Review . .. . ..... . .. . . . . .. . . . . .. . . . .. . . . .. . . . . .. . . . .. . .. .. . . .. . .. .. . . .. . .... . .. . . . . . . 3-1 3.2 Pu rpose of Review . ... . .. . . . . . . . . . .. .. . . .. . . .. . . .. ... .. . . . . .. . . . .. . . .. .. . . . .. .. . .. . . . . . . . . . .. . .. .. . .. . . 3-1 3.3 Areas of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..3-1 .................

3.4 Review Procedu res . .. . .. . .... . . .. .... .. . .. . . . . . . . .... .. .... .. ... . .. . . . .. .. . . . . . .. . . . ... .. .. .... .... . .. . 3-2 3.5 Accepta nce C rite ria . . ... ... .. . . . . . . .. . . .. .... . .. . . . . .. . . . . . . .. .. . . . . .. . . . .. .. . ... . . .. . . . . . .. .... . . . . . .. 3-3 3.6 Evaluation Finding s . . . .... ... . . . . . ... . . . . . .. . .. . . . .. .. .. . ..... ... . . . .. .. . . .. . .. . . . .... . . .. .. . . .. .. .. . . . 3-4 3.7 Referances................................................................................................. 3-5 4.0 FACILITY AND PROCESS DESCRIPTION ...................................................... 4-1 4.1 Responsibility for Review . .. ...... . ... .. ... . . . ... . . . .... .... . . .... . ... . . . ..... . . . . .. . ...... . . . .. . . . ... 4-1 4.2 Purpose of Review .. . . ..... . . .. .. . . .. .. . .. .... ... . . .. . . ..... . .. . . . . . . . . . . .. .. . . . . .. ..... .. . . .... ... ... . . 4-1 4.3 Area s of R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 4.4 Review Procedu res . . .. . . .... .. ... .... . .... .. . . ... . .. . . ... ... . ..... . ... ... .. ...... .... . . ..... . .... . . .. . . 4-1 4.5 Acceptance C riteria .. .. . . .. ... . .. ... . . .... .. .. . ...... . .. .. .. .. . . .. .. . ..... . ..... ... ... . . ...... . ... . . . .. . 4-2 4.6 Evaluation Findings ... . .. ..... ..... . . . ..... . .. . .. ...... ........ .. . .. .. .. ... . .. ...... .. .. . .... ...... ..... 4-4 4.7 References................................................................................................. 4-5 5.0 H AZA RD/ACCI DENT AN ALYSI S ...................................................................... S.

5.1 Responsibility for Review . .... .. . . .. .. . ... . .. . ... . . . . .. . .. .... ..... . . . ..... ... .. . . . .......... . .. .. . .. 5-1 5.2 Purpose of Review .... ................ ....... .. . ..... .. . .. .. .. . .. .. . ... . .. . .... . . .. .. ..... ...... ... .... 5-1 5.3 Area s of Review . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-1 . . . .. . . . . . . . . . . . .

5.4 Review Procedu res . .. .. . ... . .. . . .. .... .. .... ... ...... ... . ..... ... . . ... .... .. .. .. ..... . .... ....... . .... 5-3 5.5 Acceptance C rite ria .. .. ....... . . . .... . . . .. .. .. . .... . .... .... . ... .. . .. .. . . . .. . .. . .... .. . .. . ....... . . ... 5-4 5.6 Evaluation Findings ... . ... . ... .... . . . . .... .. . . ...... . ... . ... ... .. ... .. .. ............. . . ....... .... . . . .. 5-8 5.7 References................................................................................................. 5-8 5.8 Definitions.................................................................................................. 5-9 6.0 TECHNICAL SAFETY REQUIREMENTS ......................................................... 6-1 6.1 Responsibility for Review ......... .. .. ..... ... .. . .... . ........ . .. ................ . .. ... . ......... .. . .. 6-1 6.2 Purpose of Review ... ............. ... . . . . .... .. ......... ... ... . ...... . . . .. .. ... ...... . ................. 6-1 6.3 A reas of R eview . . . . . . . . . . . ... . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 C.4 Review Procedu res . .. . ........ .... ... .. .. .... .. ... . ... ... .... . . .. .. ....... ..... ........ .. . .. ..... . .... . 6-1 6.5 Acceptance Crite ria ..... . ..... .... ... ...... .. .... .. .... ....... .. .. . . .... .. ....... ...... ............ .... 6-2 6.6 Evaluation Findings ... ..... . .. ..... . . ...... . .... ... ... . ........ . . . . . .. . . . ..... . .. ..... . ... . ... .. .. . . ... . 6-4 6.7 Referenoe................................................................................................... 6-4 6.8 Definitions.................................................................................................. 6-5 vii Draft NUREG-1671

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Paag 7.0 RA D I ATl O N S A F ETY . . . . . . . . . . . .. . .. . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . . . . . . . .. . . . . . . . . . .7-1 . .. . . . . . .

7.1 R espo n sibility f or R eview .. . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . .. .. ... . . . . . . . . . . . . . . . . .. .. . .. . .. . .. . . .. . . 7-1 7.2 Pu rpos e of R eview . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. . . . . . .. . . . . . . . .. . . . . . . .. .. . . .. . . .. . . 7-1 7.3 A re a s of R evi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1 i 7.4 R e view Proced u re s . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .. . . . . . . . .. . . .. . . . . . . . .. . . .... . . . . . . . . . . . . . . 7-4 7.5 Acce p tance C rit e rla . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. . . . . . . . . . . .. . . . . .... . . . . . .. . .. . . .. 7-7 7.6 Eval uation Find i n g s . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . ... . . . . . . . . .. ... . .. .... . . . . ... . . . . .. . . . . .. . ... . . . . 7-2 6 7.7 R e f e r e n ce s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2 7 8.0 N UC LEAR C RITICALITY SAFETY ..................................................................... 8-1 8.1 R e sponsibility f o r R evie w . . . .. . . . . . .. . . . . . . . . . . .. . .. . .. . . . . . . . . .. .. . . .. . . . . .. . . . ... . . . . .. ..... . ... .. . . 8-1 8.2 Pu rpos e o; R eview .. . . . . . .. ... . . .. . .. . . . .. . .. . . . . .. . .. . . . . .. . .. . . . .. . . ... . . . . .. . . . . . .. .. . .... ... . . .... . 8-1 8.3 Are a s of R evi e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8-1 .....

8.4 R eview P roced u re s .. . .... . .. .. . .. ... .. . . . . .. . . .. . . .. . . . . . . . . . .. .. . . . . . . . .... . . . ... . . .. . . . .. . ... .. . .. . 8-3 8.5 Accep ta nce C rit e ria .. . . . . .. . . . . . .. . . . . . . . . .. . . . . . . . . . . . . . . .. ... . .. . . . . . . .. . . . . . ... . . . . . ... . . . . .. . . .. .. 8- 1 1 8.6 Evaluation Findin g s .. .. .. .. ... .... . ... . . . . .. . . . . . . . . .. . . .. . . .. . ... . .. .... .. . ... . . ..... . .. .. ... .. . . .... 8- 18 8.7 R ef e r e n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8- . . .1. .8. . . . . . .

9.0 ENVIRONMENTAL PROTECTION AND WASTE MANAGEMENT ............... 9-1 9.1 R e sponsibility f o r R eview .. . . . . . . . . . .. . . . . . .. . . . . . . ... .. . . . . . . . . . . . . .. . . . .. . . . .. ... .. . ... . .. . . . . . ... . . 9-1 9.2 P u rpo s e of R evi e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 9.3 A re a s of R evi e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 9.4 R eview P roced u re s .. . ... . .. . . . .. . . . . .. . .. . . . . . . . .... . . . . . . ... .. . .. . . . . . ... . . ... . . . . ....... . . . ... ..... . 9-1 9.5 Acceptan ce Crite ri a . ... . . .. ... . . .. . . .. . .. . . . . .. . . . . . . .. . . .. . .. .. . . . . . .. . . . . . . .. . . . . .. . ... .. ......... . . . 9-1 9.6 Evaluation Findin g s . . ........ . . . . . ... . . . . .. . . . . . . . .. .. ... . . ... . . . .... . . .. . . . . . ... . ....... .... . . . . . .... . . 9-5 9.7 References.................................................................................................. 9-5 10.0 C H E M I C AL S A FETY . .. . ... ... . .... .. . . ... ... . . . . . ..... . .. . . . .. . .. . . . . . . . . . .... ... . . .. .... . . ... . . . .. ... .. . .... 10- 1 i

10.1 Responsibility f or Review ............................................................................. 10-1 1 10.2 Pu rpose of R eview ... .... . .. .. .. ... .. . . .... .. . . . .... . .. . . . .. .... . . .... .... . . . .. .. . .. . . . . ... .. .. .... .. . . 10-1 l 10.3 Areas of R eview ... . .. .. . .. . ... . .. . . . . . . . ... . . . . .. . . . .. . .. . . . ... . . . .... . . . . . . .. ... . . .. . . . .. . . . . . .. . . .... . 10- 1 )

10.4 R eview P roced u re s . . . .. . . . . . . . .. ..... . . . . . . .. . . . . .. .. . . . . .. .. . ... . . . . ... . . . . .. . .. .. .......... .. . ... . . . 10-2 l 10.5 Acceptan ce C rite ria .. . .. . . . . .. .. . ... . .. ... . . .. . . . . . . . ....... . . . . . .... . . . ....... .. . . ....... .... ... .. . .. . 10-3 J 10.6 Evaluation Finding s .. . .. ... ... . . .. . . . . ... . . . .. . . . . . .. . .. . . ... .. . . ... . . ... . . . .. . . . ... . ... ...... ..... .. .. 10-4 10.7 R e f e re n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . 1 0 11.0 F1RESAFETY....................................................................................................... 11-1 11.1 Responsibility f or Review ............................. ............................................... 1 1 -1 11.2 Pu rpose of R eview ..... .. . ... . .. . .. . ...... .. . . . . . .. . .... .... ... . . .. . ... . ... . . .... .. ... ..... . ...... . . . .. 1 1 -1 (

11.3 Are as of R eview . .... ....... .... . . .... . . . . . . .. . . . . . . .... ... ... . .. . . ... . .. . ..... .... . . ..... .. . .... . . .. . .. . 1 1 - 1 l 11.4 R eview P roce d u re s .. ..... . .... . . . ... .. . . . . . . .. . ... .. ..... . . . . .. . .. .. . . . . . . . . .... .. ... . ........ ... . . . . . 1 1 -2 Draft NUREG-1671 viii Ol 4

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EaQA 11.5 Acceptance C rite ria . .... . ... . . . . ... ... . . . .. . . . ... . . . .... .. .... . . .. . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . .. . . 1 1 -6 11.6 Evaluation Finding s . . . .. . . .. . .. . . . . .. . .. . . . . . . . . . . . . . .... . . .. . . . . . . . . . . . . . . . .. . . . . . . . . .. . ... . .. . . .. . . . 1 1 -1 1 11.7 I m plem e ntation .. ... . . . ... . ... . . . . . . . . . . . . . . . . . . . . . . . ..... . .. .. . .. . . . .. .. . . . . . . .. . . . . . . . . . . . . . . .. . . . . . . . 1 1 - 1 1 11.8 R ef e re n ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 12.0 E ME RG ENCY MAN AG E MENT PROG RAM .................................................... 12-1 12.1 Responsibility for Review . .. . .. . . . .. .. . . . . .. . . . .... .. . ... . . . .. .... . . . .. . . . .. . .. . . . . . . . . . . . . . . . . . . .. . . 12-1 12.2 P u rpose of R eview .. .... . . . ... . .. . .. . .. .. . ... . ... . . . . . . . . . . . . . . . . ... . ... . . . . . .. . . . . . . . .... .... . . . . . .. . . 12-1 12.3 Are as of R eview . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12-1 12.4 Review Procedu res . . . .. ... . .. . . . . . .. . .. .. . . . . . .. . . . . . .. . . . . . . .... . . . ... . . . . ... . . . .. .. . . . . . . . . . . . .. . . . . 12-1 12.5 Acceptance C rite ria . . .. ...... . .... . ... . . .. . ... . . .... .. ..... . ... . .. . . . . . . . . .. . . . . . .. . .. . ... . . . . . .. . .. . . 12-2 12.6 Evaluation Findings . . . . . . . . . . .. . .. . . . . ... . . . .. . . .. . . .... ... ... . . . . . . . . . . . .. .... .. .. .. . .. ..... .. .. . . . . . 12- 13 12.7 R ef e r e n ces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2-13.0 SEC U RITY AN D SAFEG U ARD S ................. ........................ ....................... ....... 13-1 13.1 Material Control and Accounting ............................................................ 13-1 13.1.1 Responsibility for Review ................................................................ 13-1 13.1.2 Pu rpose of Review .. .... . .... . . ....... . .. . . ..... . . ... .... .. . . .. ... .. . ... . .. . ... . . .. . .. .. .. . 13-1 13.1.3 Areas of Review . .. .. .... .. .... .. . . .... ........ ... .. .. . . .. . .... . . .... . . . .. . . . . ... .. .. ...... . . 13- 1 13.1.4 Review Procedu res .. . . .... .. ... ... . .. . . . .. ... .. ... . .. . . ........ . . . . . .. ....... ....... . .. . .. 13-1 13.1.5 Acceptance Criteria ................................... ........ ...... ....................... 13-3 13.1.6 Evaluation Findings ..................................................... ................... 13-6 13.1.7 R efe rences .. . . . .. ..... . . . . . . . . . .. . .. . .. . .. ... .. . .. .. . . .. ... .. . . .. .. . . .. ..... .... ..... . . . ...... 13- 10 13.2 Physical Security and Transportation Protection of Special Nuclear Material of Low Strategic Significance at GDP Facilities ................... 13-11 13.2.1 Responsibility for Review ................................................................ 13-11 13.2.2 P u rpose of Review . . . . ..... ... .. .. .. . ... ...... . . . . . .... .. ........ . ..... . ... ..... . ..... . . ... 13- 1 1 13.2.3 Areas of Review . . . ..... ... . . .. . ... . ... ... .. .... .. .. ........ . . . . ..... . .. .. ... ... . .... . .. . ... . 13-1 1 13.2.4 Review Procedures ..................................... ............ ....................... 13-11 13.2.5 Acceptance Criteria .............-......................................................... 13-11 13.2.6 Evaluation Findings .................. ...................................................... 13-14 13.2.7 References .. .. . . .. .. . .. . ..... .. ... . . . ...... . . . . .... .. .. . . .... . ... ... ... . ... . . .. ............ ... 13-15 13.3 Protection of Classified Matter .............................................................. 13-16 13.3.1 Responsibility for Review ................................................................ 13-16 13.3.2 Pu rpose of Review .. ..... . . . ... . . .. .... .... ....... .. . .... .. . .. . . . .. . . .. . .. . ......... ...... . 13- 16 13.3.3 Areas of Review ...... ... .. .... ..... .. . .. .... .. . . . ..... . . . .... .. . ..... .. ....... ... ... . . .... .. 13-16 13.3.4 Review Procedures ........................................................................ 13-16 13.3.5 Acceptance Criteria .... .................................................................... 13-16 1 3.3. 6 Evaluation Findings . . . . . . . .. . . . . . .. . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . 1 3- 17 13.3.7 Ref e rances ... . .......... . . .. ...... . ..... .. ... ... . ... . ... .. .... .. .. . .. .. . .. . . ... .... ......... .. 13- 18 O

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14.0 DECOMMISSIONING FUNDING

PLAN AND FINANCIAL ASSURANCE MECHANISMS................................................................................................14-1 14.1 Responsibility f o r Review ................... ............ .... .... .... . .. .. ..... .. . .. ...... .. .. .. .. 14-1 14.2 P u rpo s e of R eview . . . . . . . . . . . . . . . . . . . .. . .. . . . . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . 14-1 14.3 Ar e a s of R evi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-1 ........

14.4 R eview Proced u res . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-1 14.5 Acceptance C rit e ria . . . . . . .. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-5 14.6 Evalu ation Findin g s . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . 14-8 14.7 R e f e re n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

15.0 C O M P L I A N C E P LA N . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . 15-1 15.1 R esp onsibility f o r R eview . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . .. . . . . 15-1 15.2 P u rpo s e of R evie w . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . .. .. . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . 15-1 15.3 Are a s of R evi e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15-1 15.4 R eview P roced u res . . . . . . . . . . . . . . . . . .. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . 15-1 15.5 Acce pta nce C ri t e ria . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . 15-3 15.6 Evaluation Fin din g s . ... . . . . . . . . . . . . . .. . . . . . . .. . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. . . . . . . . 15-4 15.7 Reference.................................................................................................. 15-4 16.0 DETERMINATION OF FOREIGN OWNERSHIP, CONTROL, OR DOMINATION, COMMON DEFENSE AND SECURITY, AND RELIABLE AND ECONOMICAL SOURCE OF DOMESTIC ENRICHMENT SERVICES ................................. 16-1 16.1 R e spon sibility f or R eview . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . .. . . . . .. . . . . . . . . . 16-1 16.2 P u rpo se of R eview . .. . . . . . .. . .. . . . . . . . . . . . . . . . . . . . . .. . .. . . . .. . .. . .. . .. . . . .. .. . . . . . . . . . . . .. . . . ... .. . . . 16-1 16.3 Are a s of R e vi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16-1 .........

16.4 R eview P roced u re s . . . . . . .. . . . . . . . .. . . . . . . . .. . . . . . . . . .. . . . . . . . . . . . . . . . .. . . . . .. . . . . . .. . . . . . . . . . . ... . . . 16-2 16.5 Acce ptance C rite ria . ... . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . .. . .. . . . . . . . . . . ..... . . . .. . ... . . .. . . . .. .. . 16-9 16.6 Evalu ation Findin g s . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . .. .. .. . . .. .. . . . . .... .... . . . 16-1 1 16.7 R e f e re n ce s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 6- 1 1 AP P E N D l X A - P RO C E D U R E S . ... . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .. . . . . .. . .. . . . . . . . . . . . . . . . .. .. . . .. . . . . . . . .. . . . .. . . .. . . A-1 AP P EN D I X B - R E C O R D S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1 i

i APPENDIX C - PROPOSED CONSEQUENCES OF CONCERNS / THRESHOLDS ............. C-1 APP EN DIX D - SAMPLE SI G HT D RAFT ............ .... .. .............................. ...... .............. ........ D-1 Draft NUREG-1671 x O

I 1.0 GENERAL INFORMATION 1.1 Site Description 1.1.1 Responsibility for Review 1.1.1.1 Primary: Certification Project Manager i

1.1.1.2 Secondary: All reviewers 1.1.1.3 Supporting: Resident inspector staff i 1.1.2 Purpose of Review  !

The purpose of this review is to establish that the information provided by the applicant I adequately summarizes the geographic, demographic, meteorologia, hydrological, geological, and seismological characteristics of the site and the surrounding area.

1.1.3 Areas of Review The types of information the staff should review would include the following:

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1. Site Geography j U a. Site location: State, county, municipality (including maps at each level)

b. Major highways

c. Nearby bodies of water

d. Any other significant geography that may impact accident analyses within 1.6 km (1 mile) of the site (e.g., ridges, valleys, etc.).

2. Demographics

a. Latest census results for area of concem

b. Description, distance, and direction to nearby population centers I

c. Description, distance, and direction to nearby public facilities (e.g., schools, hospitals, parks, etc.)

d. Description, distance, and direction to nearby industrial areas that may include potential hazards (including other nearby nuclear facilities).

e. Uses of land in area of concern (i.e., residential, industrial, commercial, agricultural)

f. Uses of nearby bodies of water (if any)  !

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3. Meteorology

a. Primary wind direction (s)

b. Annual amount (s) and form (s) of precipitation 1-1 Draft NUREG-1671

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GeneralInformation

c. Design basis meteorological event descriptions (tornado, wind, lightning, etc.)

used for accident analysis

4. Hydrology

a. Characteristics of nearby rivers, streams, and bodies of water as appropriate

b. Distance to the water table

c. Ground-water flow direction and speed for the site

d. Design basis flood event used for accident analysis

e. Locations of ground-water monitoring wells,if any

5. Geology and Seismology

a. Characteristics of soil types

b. Vibratory ground motion (including seismicity, geologic and tectonic characteristics, seismic wave transmission characteristics, design basis earthquake used for accident analyses)

c. Surface faulting

d. Stability of subsurface materials

e. Slope stability 1.1.4 Review Procedures 1.1.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial coplication" and 10 CFR 76.36, " Annual renewals" with respect to site description for gaseces diffusion plant (GDP) facilities, have been included--see Section 1.1.5.1, " Regulatory Reqeirements" --and that topics discussed in Subsection 1.1.3, " Areas of Review," have been addressed.

If significant oeficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

i 1.1.4.2 Safety Analysis The primary reviewer should ensure that the description of the site is adequately detailed, including maps and plan, to provide reviewers with enough background material to permit efficient reviews in other sections of this standard review plan (SRP).

1.1.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

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.I General Information 1.1.5.1 Regulatory Requirements Section 76.35 (a)(8) requires applicants to provide a description of the plant site and a description of the principal structures, systems, and components of the plant.

1.1.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

1.1.5.3 Regulatory Review Criteria The information that is the basis of the site description summary is an important element of the application. Site description information is also important to the environmental review that is conducted. Staff should use the following regulatory review criteria, or information demonstrating acceptable alternatives, in its review of the safety analysis report (SAR).

Acceptability should be based on:

1. A brief description of the site geography, including its location relative to prominent natural and man-made features such as mountains, rivers, airports, population centers, schools, commercial and manufacturing facilities, etc.

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2. Population information, based on the most current census data, to show population distribution as a function of distance from the facility

3. Appropriate meteorological data

4. Appropriate hydrological data

5. Appropriate geological and seismic data 1.1.6 Evaluation Findings 1.1.6.1 Introduction l l

The staff's review should verify that sufficient information has been provided in the application to satisfy the intent of 10 CFR 76.35, " Contents of initial application" and 10 CFR 76.36. " Annual renewals," requirements with respect to the site description and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff I can document its review as follows. l l

1.1.6.2 Sample Evaluation Findings i

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GeneralInformation The staff has reviewed the site description for [name of facility] according to the SRP Sections 1.1.3,1.1.4, and 1.1.5.

I The applicant has adequately described and summarized: (1) the site geography, including its location relative to prominent natural and man-made features such as mountains, rivers, airports, population centers, schools, and comrnercial and manufacturing facilities; (2) population information based on the most current census data to show population distribution as a function of distance from the facility; (3) meteorological data relating to the site;(4) hydrological data relating to the site and nearby surface and ground-water sources; and (5) geological and seismic data relating to the site and its surroundings.

1.1.7 Reference U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

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[G General Information l 1.2 Institutional Information 1.2.1 Responsibility for Review 1.2.1.1 Primary: Certification Project Manager 1.2.1.2 Secondary: All reviewers 1.2.1.3 Supporting: Resident inspector staff 1.2.2 Purpose of Review The purpose of this review is to establish that the application for certification includes adequate information identifying the applicant and the proposed activity.

1.2.3 Areas of Review Information provided for review should include the identity and address of the applicant; corporate information as appropriate; the site location; a one-line description of each proposed n activity in the form of requested authorized uses; and the type, quantity, and form (s) of material (s) proposed to be used pursuant to the certificate of compliance.

1.2.4 Review Procedures 1.2.4.1 Acceptance Review -

The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to institutional information for GDP f acilities, have been included--see Section 1.2.5.1, " Regulatory Requirements," and that topics discussed in Subsection 1.2.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review, 1.2.4.2 Safety Analysis The primary reviewer should ensure that there is sufficient information available to permit other reviewers to gain a sufficient familiarity with the institutional information to facilitate efficient reviews in other sections of this SRP.

1.2.5 Acceptance Criteria 0 1-5 Draft NUREG-1671

GeneralInformation The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

1.2.5.1 Regulatory Requirements Section 76.33(a)(2) requires that the application include the full name, address, age (if an individual), and citizenship of the applicant. If the applicant is a corporation or other entity, it shall indicate the State where it is incorporated or organized, names, addresses, and citizenship of its principal officers, and shall include information known to the applicant concerning the control or ownership, if any, exercised over the applicant by any alien, foreign corporation , or foreign government.

Section 76.35(a)(1) requires that the application include the activities and locations involving special nuclear material.

Section 76.35(1)(2) requires that the application include the name, amount, and specifications l (including the chemical and physical form and, where applicable, the isotopic content) of the special nuclear material, source, and byproduct material the Corporation proposes to use, possess, or produce, including any material held up in equipment from previous operations.

1.2.5.2 Regulatory Guidance No regulatory guidance has been dotteloped in this area.

1.2.5.3 Regulatory Review CritM4 ,

l Staff should use the following regulatory review criteria, or information demonstrating j acceptable alternatives, in its review of the SAR. Acceptability should be based on: 1

1. Identity and Address The applicant has furnished its full name and address. The address of the facility to be certified is provided if it is different from that of the applicant. The State where the applicant is incorporated or organized and the location of the principal office are indicated. If the applicant is a corporation or other entity, the names, citizenship, and  !

social security numbers of its principal officers are provided. The location of the plant l site (i.e., State, county, and municipality), is given.

2. Activities and Locations i

The applicant has provided the information necessary to support the requested j certificate of compliance.

3. Type, Quantity, and Form of Material The elemental name, maximum quantity, and specifications, including the chemical and Draft NUREG-1671 1-6 O

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General Information physical form (s) of the special nuclear material (s) (and any source and byproduct subject to U. S. Nuclear Regulatory Commission (NRC) requirements) the applicant proposes to acquire, deliver, receive, possess, produce, use, transfer or store are identified. For special nuclear material the specifications should include the isotopic content. ,

1.2.6 Evaluation Findings 1.2.6.1 Introduction  ;

The staff's review should verify that sufficient information has been provided in the license application to satisfy the intent of 10 CFR 76.35, " Contents of initial application," requirements, with respect to the institutional information and that the information provided is consistent with I the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows. I 1.2.6.2 Sample Evaluation Findings j The staff has reviewed the institutionalinformation for (name of facility] according to the SRP l Sections 1.2.3,1.2.4, and 1.2.5.

{ The applicant has adequately described and documented institutional arrangements with the site owner and the staff finds that the applicant is in compliance with those parts of 10 CFR l'

76.35 relating to institutional information. In addition, the applicant has adequately described the types, forms, quantities, and proposed uses of materials, under the regulatory authority of NRC, to be permitted at this facility, as follows:

Material Form Quantity Authorized Uses(s)

No applicant responsibilities were found to be in conflict with the regulations pursuant to the Atomic energy Act, as amended.

1.2.7 Reference U.S. Code of FederalRegulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

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O lQ 2.0 ORGANIZATION AND ADMINISTRATION 2.1 Organizational Structure 2.1.1 Responsibility for Review 2.1.1.1 Primary: Certification Project Manager l 2.1.1.2 Secondary: Specialists in safety-related organizationai ad administrative l requirements for GDPs, including nuclear criticality safety, radiation protection, fire safety, emergency management, chemical safety, etc.

l 2.1.1.3 Supporting: GDP inspector 2.1.2 Purpose of Review ,

I l The purpose of this review is to ensure that management systems and structures are in place that provide reasonable assurance that the certificate holder plans, implements, and controls i

site activities in a manner that ensures the safety of workers, the public, and the environment.

It is also to ensure that the corporate management is involved with, informed about, and ,

dedicated to the safe operation of the facility and that sufficient technical resources have been  !

l provided to adequately accomplish this objective.

l 2.1.3 Areas of Review The etaff should review the corporate level management and technical organizations of the applicant and its major contractors for the project, including the technical resources to support ,

operation.  !

The applicant's management, engineering, and technical support organization (s) should be described. Organizational charts reflecting the applicant's current headquarters and site l management structure should be included. Planned modifications and additions reflecting any l added functional responsibilities should be included. Operational responsibility should include clear assignment of responsibility for:

a. SSCs important to safoty;

b. an effective safety review system;

c. a training program for proper operation and proper conduct of the safety components;

d. clear and accurate procedures;

e. determining compliance with procedures, policies, and regulatory requirements;

f. an investigation process adequate to enable understanding of the root cause of p incidents and off normal conditions, and to promote rectification of significant U 2-1 Draft NUREG-1671

Organization and Administration institutional problems.

2.1.4 Review Procedures 2.1.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36," Annual renewals" with respect to organizational structure for GDP facilities, have been included--see Section 2.1.5.1, " Regulatory Requirements- " and that topics discussed in Subsection 2.1.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

2.1.4.2 Safety Analysis The primary reviewer should ensure that the corporate-level management and technical support structure, as demonstrated by organizational charts and descriptions of functions and responsibilities, are free of ambiguous assignments of primary responsibility. A corporate officer should clearly be responsible for radiological safety activities, without having ancillary responsibilities that might detract from his/her attention to radiological safety matters. The primary reviewer should consult with the secondary reviewers in their areas of expertise to verify that other positions and responsibilities are reasonably well defined in terms of both numbers of persons and experience required to carry out their responsibilities. The staff must recognize that there are many acceptable ways to define and delegate job responsibilities.

The appropriate reviewers (with support from the onsite resident) should visit the site and corporate headquarters, to review, discuss, and verify implementation of the management structure and technical resources. With respect to site visits, review teams may also include inspection and enforcement personnel.

The staff should then determine, on the basis of the foregoing, the overall acceptability of the applicant's management and technical support organization and staffing plans.

1 2.1.5 Acceptance Criteria )

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The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to  !

this SRP are listed in the following sections. {

I 2.1.5.1 Regulatory Requirements  !

Section 76.35 (a)(7) requires applicants to provide a description of the management controls and oversight program to ensure that activities directly relevant to nuclear safety, safeguards, Draft NUREG-1671 2-2 O 1

l Organization and Administration and security are conducted in an appropriately controlled manner that ensures protection of ,

employee and public health and safety, and security of the national interests. i l- 2.1.5.2- Regulatory Guidance No regulatory guidance has been dweloped in this area.

2.1.5.3 Regulatory Review Crwei.a Staff should use the following regulatory review criteria, or information demonstrating acceptable alternatives,in its review of the application. Acceptability should be based on the following:

1. The applicant has identified and functionally described the specific organizational groups  !

and has provided organization charts.

2. The applicant has described the method of implementing its responsibilities for dealing with the safety-related aspects of the operation of the plant, including control of major contractors.

3. Clear unambiguous management control and communications exist between the organizational units involved in the operation of the plant.

() 4. Substantive breadth and level of experience and availability of personnel exist to operate the plant safely.

5. The organizational structure provides for the integrated management of activities that support the operation and maintenance of the facility.

6. In the organizational hierarchy, the health, safety, and environmental protection (Health, safety, and environmental protection) organization (s) are independent of the operations organization (s), allowing them to provide objective Health, safety, and environmental protection audit, review, or control activities. " Independent" means that neither organization reports to the other in an administrative sense. Both may report to a common manager.

7. The qualifications, responsibilities, and authorities for each position assigned a function related to Health, safety, and environmental protection are clearly defined in po3l tion descriptions that are accessible to all affected personnel, and to NRC, on request.

8. The number of personnel and their availability within the Health, safety, and environmental protection organization (s) are adequate to carry out the Health, safety, and environmental protection function.

9. The individual delegated overall responsibility for the Health, safety, and environmental protection programs has the authority to shut down operations if they appear to be 2-3 Draft NUREG-1671

Organization and Administration unsafe. Typically this individual should be at as high a management level as the production manager and have direct line responsibility to the plant manager.

10. The functions essential for effective implementation of the Health, safety, and environmental protection program (s) are documented in formally approved, written procedures, prepared in compliance with a formal document control program. (This includes considerations regarding persons possibly impaired by drugs or alcohol, mental state, etc.)

11. The qualifications, responsibilities, and authorities for each supervisory and management function listed in Section 2.1.3 are clearly defined in position descriptions that are accessible to all affected personnel, and to NRC, on request.

2.1.3 Evaluation Findings 2.1.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application to satisfy the intent of 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36.

" Annual renewals," requirements with respect to the organizational structure and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.1.6.2 Sample Evaluation Findings The staff has reviewed the organizational structure for (name of facility] according to the SRP Sections 2.1.3,2.1.4, and 2.1.5. I l

I On the basis of that review and evaluation of the health, safety, and environmental protection organization (s) described in the application for certification for (facility name], the staff concludes the following:

1. The applicant has desur ad its organization and management of its means for providing technical support for the facility. The staff has reviewed these measures and concludes that the applicant has an acceptable organization and adequate resources to provide technical support for the operation of the facility under both normal and abnormal conditions.

2. The organizational hierarchy is such that the organizations charged with administration of the health, safety, and environmental protection programs are at a sufficiently high level, are independent from production management, and that there is a high probability of effective programs in these areas.

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3. Organization charts adequately reflect the organizational structure, and the l

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Organization and Administration and environmental protection position are clearly identified.

4. Commitments are included for the preparation and timely revision of procedures crucial to effective implementation of the health, safety, and environmental protection programs.

2.1.7 Reference U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

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Organization and Administration 2.2 Safety Review Systems 2.2.1 Responsibility for Review Primary: Certification Project Manager Secondary: None Supporting: GDP inspector 2.2.2 Purpose of Review The purpose of this SRP section on safety review systems is to present the regulatory requirements and regulatory guidance and to establish the acceptance criteria and review procedures to be used by reviewers. The NRC review should establish that the applicant has established an acceptable safety system as part of its management controls that includes the use of safety committees.

2.2.3 Areas of Review The staff will review the process the applicant has defined for the use of safety committees. The description should include the function, responsibilities, frequency of meetings, quorum requirements, membership, qualifications, and reporting and record-keeping requirements. The review will include applicable SAR sections as well as any technical safety requirement on the safety committee.

2.2.4 Review Procedures The reviewer should determine that the applicant has committed to establishing a safety committee to perform multi-discipline reviews of day-to-day and proposed activities to ensure that these activities are/will be conducted in a safe manner. The review should ascertain that the committee reviews and approves operating procedures and design changes. The reviewer i should determine that committee membership is composed of qualified staff from a variety of the plant operations.

On the basis of its review, the staff may request that the applicant provide additional information or modify the submittal to meet the acceptance criteria in Section 2.2.5 of this SRP.

2.2.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP section are listed in the following sections.  ;

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Organization and Administration 2.2.5.1 Regulatory Requirements The regulations in 10 CFR 76.68(a) require that plant changes must be approved by a safety review committee. A safety review committee is also considered to be an essential part of the management controls and oversight program required by 10 CFR 76.35(a)(7).

2.2.5.2 Regulatory Guidance Although no regulatory guidance document specific to the GDPs has been developed, portions of the following documents may be used as guidance.

1. . U.S. Nuclear Regulatory Commission Regulatory Guide 3.52, " Standard Format and Content for the Health and Safety Sections of License Applications for Fuel Cycle Facilities" l

2. " Guidance on Management Controls / Quality Assurance, Requirements for Operation,  !

Chemical Safety, and Fire Protection for Fuel Cycle Facilities," Federal Register 54 (No. 53),11590-11598, March 21,1989"

-2.2.5.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant commits to the following acceptance criteria:

1. There is a commitment to estabhsh a plant safety committee, typically this will be a Plant Operations Review Committee but may have different titles.

2. The General manager approves the procedure implementing the safety committee activities.

3. Membership should be multi-disciplinary and include expertise in the following functional areas: cascade and chemical operations, engineering, maintenance, nuclear safety, nuclear criticalitsj safety engineering, radiological safety, quality assurance, safeguards, and chemical, industrial and environmental safety.

4. Minimum qualifications for the membars should be established.

5. Specifics on the frequency of meetings for the safety committee. In general, the safety committee should meet monthly.

6. Specifics such as what constitutes a quorum. At a minimum, the quorum should include members with technical competence in operatior t engineering, nuclear criticality safety engineering, radiological safety, and quality asst, "e.

7. Specifics on the committee functions should be provided. This should include advising the General Manager on matters related to nuclear safety and recommending the 2-7 Draft NUREG-1671

Organization and Administration approval or disapproval of items before the committee.

8. The safety committee shall review, at a minimum, the following activities: all proposed 1 j

procedures and procedure changes; all proposed changes to the safety analysis report; j all proposed changes to the separate application documents; all proposed changes to the TSRs, the TSR basis statements, the Certificates of Compliance, or the Compliance -

Plan; all proposed changes to the plant or the plant's operations, including tests and experiments, that require a written safety analysis in accordance with 10 CFR 76.68; all i nuclear criticality safety evaluations and approvals; all proposed requests for enforcement discretion; and NRC-required event reports.

9. Provisions to maintain written records of safety committee reviews that include at a minimum: results of the activities conducted under the TSR; recommended approval or l disapproval of items considered under item 8; determination of whether each item considered requires NRC approval before implementation per 10 CFR 76.68 and 76.45; minutes of meetings; and appointments of members and alternatives.

10. Assigns auditing and oversight of the committee to the head of quality assurance program (Safety, Safeguards, and Quality Manager).

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11. The safety committee can establish subcommittees to assist in its responsibilities. In those cases it should clearly state that the committee maintains overall responsibility.

The Chairperson should approve the procedures, membership, and qualifications of any subcommittee. Subcommittees might include an ALARA committee, which would be discussed in the radiation protection section.

2.2.6 Evaluation Findings Following is an example of an evaluation finding that the reviewer prepares for the CER:

The applicant has committed to the creation of a safety committee that advises the General Manager on matters related to nuclear safety. The General Manager approves the committee procedure. The committee includes multi-disciplinary representation from organizations with routine access to the operating facility, and the members possess the qualifications, competence, and experience necessary for reviewing the key functional areas.

The committee's responsibilities and authorities are clearly identified conceming plant changes that impact nuclear safety. A commitment is also included to maintain a written record of the committee's actions.

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Organization and Administration

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2.2.7 References U.S. Code of FederalRegulations, Title 10, " Energy," U.S. Government Printing Office, Washington, DC.

U.S. Nuclear Regulatory Commission, NUREG-1324, " Proposed Method for Regulating Major Materials Licensees," Section 3.2.2, Safety Committees, February 1992.

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.52, " Standard Format and Content le the Health and Safety Sections of License Applications for Fuel Cycle Facilities.*

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l 2-9 Draft NUREG-1671

Organization and Administration 2.3 Training and Qualification 2.3.1 Responsibility for Review 2.3.1.1 Primary: Training Specialist 2.3.1.2 Secondary: Certification Project Manager 2.3.1.3 Supporting: Resident inspector staff 2.3.2 Purpose of Review The purpose of this review is to establish that the proposed training and qualification programs of the applicant and its principal contractors provide reasonable assurance that involved personnel will have the knowledge and skills necessary to operate, maintain, and modify the facility in a manner that will protect the health and safety of the public and workers and the environment.

2.3.3 Areas of Review The primary reviewer should review the personnel training and qualification program described in the application. Some of this information may be found in the applicants' response to the guidance in SRP Chapter 3.0," Quality Assurance," regarding the qualification of personnel.

The information should include the training and qualification of managers, supervisors, technical staff, operators, technicians, maintenance personnel, and others whose level of knowledge is relied on for safety. Subject matter content should also be reviewed. The review of the applicant's and the principal contractors' personnel training and qualification programs should address the following training elements:

1. Organization and management of the training system;

2. Trainee selection; l

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3. Conduct of needs/ job analysis and identification of tasks for training;

4. Development of learning objectives as the basis for training;

5. Organization of instruction using lesson plans and other training guides;

6. Evaluation of trainee mastery of leaming objectives;

7. Conduct of on-the-job training; and

8. Systematic evaluation of training effectiveness.

Draft NUREG-1671 2-10 O

Organization and Administration 2.3.4 Review Procedures 2.3.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to training and qualification for GDP facilities, have been included--see Section 2.3.5.1 " Regulatory Requirements," and that the topics discussed in Subsection 2.3.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

2.3.4.2 Safety Evaluation The primary staff reviewer should review the training and qualification program description to verify that the applicant and principal contractors have addressed each of the training elements listed in Subsection 2.3.3, " Areas of Review." For evaluating adequacy, the reviewer should consider the guidance in Subsection 2.3.5, " Acceptance Criteria," recognizing that the rigor and formality of the training and qualification may be adjusted to correspond to the hazard potential and to the complexity of the training needed. The review should determine if the applicant and principal contractors have adequately planned for the training and qualification to be 7 accomplished, and whether necessary policies, procedures, and instructions will be in place, ,

and appropriate training and qualification will be accomplished before personnel begin activities l relied on for safety. The review should result in a determination that there is reasonable i assurance that the applicant's (and the applicant's principal contractors') training and j qualification program will ensure that only properly trained and qualified personnel will perform i activities relied on for safety.  ;

When an applicant's training and qualification program references other sections of the application, the primary reviewer should review these other sections of the application to determine the applicant's commitment to the overall training and qualification program and the proposed method for implementation. The primary reviewer should focus on the training and qualification of personnel who will perform activities relied on for safety. l The secondary staff reviewer should become familiar with the applicant's and principal contractors' training and qualification programs and determine whether ongoing activities are in agreement with them.

Supporting staff reviewers should review the training and qualification programs, to ensure  !

there are no contradictions between them and their review areas of the application. They should also ensure that the scope of the training and qualification programs includes the personnel who perform activities, relied on for safety, in their primary review areas of the application.

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Organization and Administration The final step in the review is the primary staff reviewer's writing of a CER that summarizes the conduct of the review, identifies what material in the application forms the basis for a finding of reasonable assurance with respect to the regulatory requirements, and presents any recommendations for license conditions that are necessary to conclude that reasonable assurance is achieved.

2.3.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

2.3.5.1 Regulatory Requirements Section 76.35(a)(5) requires that the application include a training program that meets the requirements of 10 CFR 76.95.

Section 76.95 requires that a training program must be established, implemented, and maintained for individuals relied upon to operate, maintain, or modify the GDPs in a safe manner. The training program shall be based on a systems approach to training that includes the following:

(a) Systematic analysis of the jobs to be performed; (b) Leaming objectives, derived from the analysis, that describe desired performance after training; (c) Training design and implementation, based on the learning objectives; (d) Evaluation of trainee mastery of the objectives during training; and (e) Evaluation and revision of the training, based on the performance of trained personnelin the job setting.

2.3.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

2.3.5.3 Regulatory Review Criteria

1. Organization and Management of the Training System The organization and management of the training system is acceptable if the operation, maintenance, and modification of the facility are organized, staffed, and managed to facilitate planning, directing, evaluating, and controlling a systematic training process that fulfills job-related training needs. Formal training should be provided for each position or activity for which the required performance is relied upon for worker or public safety or protection of the environment. The application should state what training will be conducted and what personnel will be provided this training. For operations, the positions or activities for which formal training is provided should include at least the following:

Draft NUREG-1671 2-12 O

Organization and Administration Radiological, chemical, criticality, and industrial safety personnel

. Process operators

. Technicians

. Maintenance staff

. Emergency response staff

. Supervisors and managers Visitors allowed unescorted access

. Auditors and other QA/QC personnel, and Nuclear criticality safety analysts.

The training program should include recurrent training of previously trained and qualified personnel based on specified criteria.

The following commitments should be in the application regarding organization and management of training:

. Line management should be responsible for the content and effective conduct of the training and qualification programs.

The job function, responsibilities, authority, and accountability of personnel involved in managing, supervising, and implementing training should be clearly defined.

A performance-based training system should be implemented as the primary management tool for analyzing, designing, developing, conducting, and evaluating training.

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Procedures should be documented and implemented to ensure that all phases of training can be conducted reliably and consistently. Training documents should be linked to the configuration management system to ensure that design chan0es are accounted for in the training given to constructors, operators, and other personnel.

. Training should be completed before qualification. Trainee and incumbent exceptions from training may be granted when justified and approved by management.

. Auditable training records should be maintained. Training records, both programmatic and individual, should support management information needs and provide required data on each individual's training, job performance, and fitness for intended duty. (Refer to Chapter 2.8 of this SRP for detailed guidance on records management.)

2. Trainee Selection Trainee selection is acceptable if minimum requirements for selection as trainee candidates is specified for candidates who perform actions that prevent / mitigate accident sequences.

. Trainee candidates should meet entry-level criteria defined for the position including minimum educational, technical, experience, and physical fitness (if necessary) requirements.

. Candidates for job functions other than process operators should be required to meet minimum qualifications for selection for training, but these minimum requirements need not be described in the application.

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Organization and Administration

3. Conduct of Needs/ Job Analysis and Identification of Tasks for Training The conduct of needs/ job analysis and identification of tasks for training is acceptable if the tasks required for competent and safe job performance are identified, documented, and included in the training.

. Operations facility personnel, training staff, and other subject matter experts, as appropriate, should have conducted or should conduct a needs/ job analysis to develop a valid facility-specific task list for specific jobs. The jobs treated in this ,

manner should include, as a minimum, jobs including the activities specified in the Accident analysis as necessary to prevent or mitigate accident sequences.

- Each task selected for training (initial or continuing) from the facility-specific task list should be matrixed to supporting procedures and training materials.

. The facility-specific list of tasks selected for training and the comparison with training materials should be reviewed on an established schedule and updated as necessitated by changes in procedures, facility systems / equipment, or job scope.

4. Development of Learning Objectives as the Basis for Training The development of learning objectives as the basis for training is acceptable if leaming objectives that identify training content and define satisfactory trainee performance are derived from Job performance requirements.

. Learning objectives should state the knowledge, skills, and abilities the trainee should demonstrate, the conditions under which required actions will take place, and the standards of performance the trainee should achieve upon completion of the training activity.

. Learning objectives should be sequenced based on their relationship to one another.

5. Organization of Instruction Using Lesson Plans and Other Training Guides The organization of instruction using lesson plans and other training guides is acceptable if lesson plans and other training guides that provide guidance and structure to ensure the consistent conduct of training activities are based on the required learning objectives derived from specific job performance requirements.

. Lesson plans or equivalent training guides should be used for in-class training and on-the-job training and should include standards for evaluating proper trainee performance.

- Review and approval requirements should be established for all lesson plans, training guides, and other training materials before their issue and use.

6. Evaluation of Trainee Mastery of Leaming Objectives The evaluation of trainee mastery of learning objectives is acceptable if trainees are evaluated periodically during training to determine their progress toward mastery of job performance requirements.

7. Conduct of On-the-Job Training Draft NUREG-1671 2-14 O

, Organization and Administration The conduct of on-the-job training is acceptable if on-the-job training used for activities required for safe operation of the plant are fully described.

On-the-job training should be conducted using well-organized and current performance-based training materials.

On-the-job training should be conducted by designated personnel who are competent in the program standards and methods of conducting the training.

Completion of on-the-job training and task qualification should be by actual task performance. When the actual task cannot be performed and is therefore simulated, the conditions of task performance, references, tools, and equipment should reflect the actual task to the extent possible.

8. Systematic Evaluation of Training Effectiveness A systematic evaluation of training effectiveness and its relation to on-the-job performance is acceptable if it ensures that the training program conveys all required skills and knowledge and is used to revise the training, where necessary, based on the performance of trained personnelin the job setting.

. A comprehensive evaluation of individual training programs should be conducted periodically by qualified individuals to identify program strengths and weaknesses.

. Feedback from trainee performance during training should be used to evaluate and refine the training program.

. Feedback from former trainees and their supervisors should be used to evaluate and O .

refine the training program.

Change actions (e.g., procedure changes, equipment changes, facility modifications) should be monitored and evaluated for their impact on the development or modification of initial and continuing training programs and should be incorporated in a timely manner. This should be accomplished through the configuration management system.

. Improvements and changes to initial and continuing training should be systematically initiated, evaluated, tracked, and incorporated to correct training deficiencies and performance problems.

2.3.6 Evaluation Findings 2.3.6.1 Introduction The staff's review should verify that sufficient information has been provided, in the application for renewal of certification, to satisfy the intent of 10 CFR 76.35, " Contents of initial application" i and 10 CFR 76.36, " Annual renewals," requirements with respect to the training and qualification and that the information provided is consistent with the guidance in this SRP. On L the basis of this information, the staff should be able to conclude that this evaluation is j complete. The staff can document its review as follows.

2.3.6.2 Samplo Evaluation Findings The staff has reviewed the (subject area] for (name of facility] according to SRP Sections 2.3.3, 2-15 Draft NUREG-1671

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Organization and Administration 2.3.4 and 2.3.5.

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The applicant and its principal contractors have committed to personnel training and qualification programs that satisfy regulatory requirements, are consistent with the guidance in this SRP, and are acceptable. There is reasonable assurance that implementation of the described training programs will result in personnel who are qualified and competent to operate, maintain, and modify, the facility safely.

2.3.7 Reference U.S. Code of Federal Regulations, Title 10, Part 7e, " Certification of Gaseous Diffusion Plants."

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Organization and Administration 2.4 Procedures 2.4.1 Responsibility for Review 2.4.1.1 Primary: Certification Project Manager d

2.4.1.2 Secondary: None 2.4.1.3 Supporting: Inspector 2.4.2 Purpose of Review The purpose of this SRP section on procedures is to present the regulatory requirements and regulatory guidance and to establish the acceptance criteria and review procedures to be used by reviewers. The NRC review should establish that the applicant has an adequate management controls program that includes procedure development, review, approval, and control.

2.4.3 Areas of Review The staff will review the process the applicant has defined for the development, review, approval, and control of proceduras. This will include the basic elements of identification, development, verification, review arid comment resolution, approval, validation, issuance, change control, and periodic review. The staff will review the commitment to a procedures program. The review will include the SAR section on procedures as well as any technical safety requirements related to the procedure program.

2.4.4 Review Procedures i

The staff will review the application portions related to the procedures program by comparing j them to the acceptance criteria contained in Section 2.4.5. I On the basis of its review, the staff may request that the applicant provide additional information or modify the submittal to meet the acceptance criteria in Section 2.4.5 of this SRP. l l

2.4.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to l this SRP section are listed in the following sections.

2.4.5.1 Regulatory Requirements 2-17 Draft NUREG-1671

Organization and Administration Although a procedures program is not specifically required by the regulations, it is considered an essential part of the management controls and oversight program required by 10 CFR 76.35(a)(7).

2.4.5.2 Regulatory Guidance Although no regulatory guidance document specific to the GDPs has been developed, portions of the following document can be used as guidance.

ANS 3.2-1994," Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."

2.4.5.3 Regulatory Review Criteria The applicant should commit to the guidance contained in the subsections of ANS 3.2-1994 which deal with procedures programs. Note that the applicant will need to take exception to some of the subsections, particularly those that clearly apply to reactors. The extent of the commitment should be captured in the application section on procedures; a separate appendix is acceptable.

The applicant should describe the types of procedures used by the facility. These will typically include administrative, operations, alarm response, and emergency operating procedures. The applicant should state the types of procedures captured by each type.

The applicant should commit to a formal process to accomplish procedure development, review, approval, and control. The process is acceptable if each of the following elements is adequately described: identification, development, verification, review and comment resolution, approval, validation, issuance, char;ge control, and periodic review.

The identification discussion is acceptable if it clearly states areas for which a procedure is required. Procedures must be required for operator actions that are necessary to prevent or mitigate the consequences of accidents described in the accident analysis contained in the application. The applicant should provide a listing (in an appendix) of the types of activities that should be covered by written procedures. The listing is acceptable if it includes the topics of administrative procedures; system procedures that address startup, operation, and shutdown; abnormal operation / alarm response; maintenance activities that address system repair, calibration, inspection and testing; and emergency procedures. Appendix A provides an acceptable listing of the items to be included under each topic.

There should be a commitment to review procedures following unusual incidents, such as an accident, unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system. ,

l The discussion on procedure development is acceptable if it contains a commitment to have i procedure guidance. A commitment to ANS 3.2-1994, subsections 5.3.1 through 5.4.10 is acceptable. j Draft NUREG-1671 2-18 O'

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(d Organization and Administration The verification process is to ensure the technical accuracy of the procedure and to make sure it can be performed as written. The discussion should identify who is responsible for verification. The verification process should ensure that the technical information is included and correct, including formulas, set points, acceptance criteria. The verification process should include either a walk-down of the procedure in the field or a table-top walk through. The process should also include a check for format and style.

The review procese is acceptable if it includes technical, cross-discipline reviews by affected organizations. This process should include both new procedures and procedure changes.

There should be a commitment to resolve the comments and if the resolution of the comments changes the intent of the original that a revised draft is re-distributed for review. The reviews should ensure that the operating limits and controls identified in the SAR and TSRs are specified in the procedures and that quality assurance requirements are identified and included in operating procedures.

The approval discussion should state who can approve procedures. The section should indicate the types of procedures that require PORC approval. Note that this information may be included in the TSRs. At a minimum PORC should review new procedures that are required by the procedure section and changes to procedures that involve intent changes, changes requiring a written safety analysis in accordance with 10 CFR 76.68, and changes that result in ,

changes to the application documents.

p Validation should be required for new or revised procedures that require PORC review and should be performed by qualified personnel. There should be a commitment to document the

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procedure validation.

Documents should be distributed in accordance with current distribution lists. A process should be established to limit the use of outdated procedures. Copies should be available to appropriate members of plant staff. Commitments relative to issuance and distribution will be contained in discussion on Records Managment and Document Control.

The procedure program should include a section on temporary changes. Temporary changes can be made if : the temporary change does not require a written safety analysis in accordance with 10 CFR 76.68; the changes does not result in a change to the application documents; the change is not an intent change; the change is approved by two members of the plant management staff, at least one of whom is the Plant Shift Superintendent; and the change is  !

documented and reviewed in accordance with the normal process within 14 days of implementation.

Temporary procedures may be issued only when permanent procedures do not exist to: (1) direct operations during testing, maintenance, and modifications; (2) provide guidance in unusual situations not within the scope of permanent procedures; and (3) ensure orderly and uniform operations for short periods when the plant, a system, or component of a systerr is performing in such a manner not covered by existing permanent procedures, or has been modified or extended in such a manner that portions of existing procedures do not apply. The discussion should include establishment of a time frame for use of the temporary procedure.

There should be a commitment that the same level of review and approval will be utilized as 1

2-19 Draft NUREG-1671 u . . .. . .

Organization and Administration that for permanent procedures. ]

There should be a commitment to conduct periodic reviews of all procedures to ensure their continued accuracy and usefulness. The section should establish the time frame for reviews of the various types of procedures. At a minimum all procedures should be reviewed every 5 years and emergency procedures should be reviewed every year. 1 The applicant should describe the use and control of procedures. There should be c

- commitment to stop work and place the system in a safe condition if a step of a procedure cannot be performed as written. Guidance should be provided to identify the manner in which procedures are to be implemented. Routine procedural actions that are frequently repeated might not require the procedure to be present. Whereas procedures for extensive or complex jobs where reliance on memory cannot be trusted should be present and referenced directly when the job is conducted.

2.4.6 Evaluation Findings 2.4.6.1 Introduction The staff's review should verify that sufficient information has been provided, in the application for renewal of certification, to satisfy the intent of 10 CFR 76.36, " Annual renewals,"

requirements, with respect to the procedures, and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.4.6.2 Sample Evaluation Findings The staff has reviewed the procedure program for [name of facility) according to SRP Sections 2.4.3,2.4.4, and 2.4.5.

The applicant has adequately described and documented a program for the development, approval, and implementation of procedures, as committed to and described in the application.

Special attention has been paid to systems important to safety, as well as to systems important to the health of plant workers, the public, and the environment.

2.4.7 References U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

ANS 3.2-1994," Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."

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(O V) Organization and Administration 2.5 incident investigation 2.5.1 Responsibility for Review 2.5.1.1 Primary: Certification Project Manager 2.5.1.2 Secondary: GDP Inspectors 2.5.1.3 Supporting: None 2.5.2 Purpose of Review Abnormal events should be investigated and corrective action taken to prevent (or minimize) these from occurring again or leading to more serious consequences. The purpose of this review is to determine that a system is in place with the organizational structure and procedures for the systematic investigation of abnormal events, assignment of corrective actions, and follow-up to ensure completion of the actions.

2.5.3 Areas of Review 4 p) g V

The staff will review the applicant's plan and procedures for investigating abnormal events. The review will include the provisions for establishing investigating teams, the methods for determining root causes, and procedures for tracking and completing corrective actions and for documenting the process, for the purpose of applying the " lessons learned" to other operations.

2.5.4 Review Procedures 2.5.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to incident investigation for GDP facilities has been included--see Section 2.5.5.1 " Regulatory Requirements"-- and that the topics discussed in Subsection 2.5.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to '

submit additional material before the staff resumes the application review. j 2.5.4.2 Safety Evaluation l

The reviewer should be able to determine that the applicant has in place:

1. A documented plan for investigating an abnormal event. This plan is separate from any required Emergency Plan. The investigation of an abnormal event should begin as soon 2-21 Draft NUREG-1671

l Organization and Administration as possible, commensurate with the safety of the investigative team, after the event has been brought under control.

2. A description of the functions, qualifications, and responsibilities of the management l person who would lead the investigative team, and those of the other team members; the scope of the team's authority and responsibilities; and assurance of cooperation of ,

management. I

3. Assurance of the team's authority to obtain all the information considered necessary, ,

and of independence from responsibility for, or to, the functional area involved in the incident under investigation. {

4. Procedures requiring maintenance of all documentation relating to abnormal events for 2 years or for the life of the operation, whichever is longer.

5. Guidance for the team conducting the investigation on how to apply a reasonable systematic, structured approach to determine the root cause(s) of the problem. The level of investigation should be based on a graded approach relative to the severity of the incident.

6. Requirements to make available to NRC original reports of investigative teams, on request.

7. A system for monitoring to ensure completion of any corrective measures specified.

2.5.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in tho following sections.

2.5.5.1 Regulatory Requirements Section 76.60 requires that the applicant comply with all applicable portions of 10 CFR Part 20.

Section 20.2202 requires the applicant to notify the NRC after specified events, including overexposures, effluent releases in excess of specified values, certain specified equipment failures, etc.

Section 76.120 requires the applicant to notify NRC after other incidents, including criticality accidents, loss or theft of special nuclear material, declared emergencies, failure of specified equipment, etc. It further requires that the applicant report the direct, contributing, and root causes for the event; corrective actions taken or planned; exposures received as a result of the event; and lessons learned.

2.5.5.2 Regulatory Guidance Draft NUREG-1671 2-22

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Organization and Administration No regulatory guidance has been developed in this area.

2.5.5.3- Regulatory Review Criteria Staff should use the following regulatory review criteria, or information demonstrating acceptable altematives, in its review of the incident investigation program. >

1. The reviewer should expect to find commitments to the prompt investigation of abnormal events, including the following:

(a) The establishment of teams to investigate abnormal events that may occur during operation of the facility; determination of the direct, contributing, and root cause(s);

and recommendation of corrective actions. These teams should be independent from the line function (s) involved with the incident under investigation.

(b) The monitoring and documenting of corrective actions, through completion.

(c) the maintenance of documentation so that " lessons loamed" may be applied to future operations of the facility.

O 2. The assessment of the adequacy of the applicant's commitments to establish and use a plan for the investigation of abnormal events will be based on the following acceptance criteria:

(a) The licensee has described the overall plan and method for investigating abnormal events.

(b) The functions, responsibilities, and scope of authority of investigating teams are documented in the plan, j l

(c) Qualified intomal and/or extemal investigators are appointed to serve on investigating teams.

(d) Prompt investigation of any abnormal events is ensured. l (e) The investigation process anr' 'nvestigating team are independent of the line management and participants are assured of no retribution for participating in investigations.

(f) A reasonable, systematic, structured approach is used to determine the root cause(s) of unusual or abnormal events.

(g) Auditable records and documentation related to abnormal events, investigations, and root cause analysis are required.

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l Organization and Administration (h) Documented corrective actions are taken to resolve findings from abnormal event I investigations.

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2.5.6 Evaluation Findings 2.5.6.1 Introduction The staff's review should verify that sufficient information has been provided, in the application for renewal of certification, to satisfy the intent of 10 CFR 76.35, " Contents of initial application",

and 10 CFR 76.36, " Annual renewals," requirements with respect to the incident investigation and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.5.6.2 Sample Evaluation Findings The staff has reviewed the incident investigation program for (name of facility), according to SRP Sections 2.5.3,2.5.4, and 2.5.5. The applicant has committed to the investigation of abnormal events through the preparation of a plan and procedures outlining the function, responsibility, and scope of authority of the responsible management personnel and of the team members involved in the investigation of abnormal events. The applicant has demonstrated a commitment to each of the acceptance criteria of Section 2.5.4 of this SRP.

[The reviewer should address each criterion in the CER) 2.5.7 Reference U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants." j l

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O Organization and Administration V

2.6 Records Management 2.6.1 Responsibility for Review 2.6.1.1 Primary: Certification Project Manager 2.6.1.2 Secondary: Staff Reviewers for Chapter 3 2.6.1.3 Supporting: None 2.6.2 Purpose of Review The purpose of the review is to identify and determine that the applicant has established and l maintains a facility records management system. The review should provide reasonable assurance that the applicant has committed to a system that adequately ensures the  ;

maintenance of records relating to the health and safety of the public and facility workers, and the protection of the environment during the life span of the plant.

2.6.3 Areas of Review

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q This section of the SRP is written to direct the review to areas related to the handling and storing of records documenting the health and safety aspects of the GDP and the records generated or needed in the operation of the facility. The following should be reviewed:  ;

1. The process whereby records pertaining to the health and safety of the public and workers, site characterization and facility items' relied upon for safety are created, selected, verified, categorized, indexed, inventoried, protected, stored, maintained, distributed, deleted, or preserved. The process (es) may be linked with a part of the facility configuration management and QA systems. The primary reviewer should coordinate this review with the persons reviewing the CM and QA systems (SRP Chapters 2.8 and 3.0).

2. The handling and control provinions for the various kinds of records, the different sets of records, and the methods of recording media that comprise the materials accounted for in the records management system.

3. The physical characteristics of the records storage area (s) that assure the preservation and protection of the records for their designated lifetimes.

2.6.4 Review Procedures 2.6.4.1 Acceptance Review

' Items include SSCs; materials (including consumable materials); parts; measuring and C'N test equipment; computers; computer programs (software and firmware); etc., as appropriate.

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Organization and Administration The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to records management for GDP facilities, have been included--see Section 2.6.5.1, " Regulatory Requirements"-- and that the topics discussed in Subsection 2.6.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

2.6.4.2 Safety Review A review should be conducted of the applicant's records management system to examine the adequacy of the policies, procedures, and practices. Examples of records that should be included in the system are listed in Appendix B. In general, the records management procedures should address the creation and verification of records; categorizing of records; indexing, inventorying, maintaining, and distributing of records; storage, retrieval, and disposal of records; and guidance for handling selected records and record types. Records should be categorized by relative safety importance to identify record protection and storage needs and to designate the retention period for individual kinds of records. Typically, storage media includes paper, microforms, optical disks, magnetic media, and audiovisual media (including photographic film and prints). The procedures should assign responsibilities for records management; specify the authority needed for records retention or disposal; specify which records must have controlled access and provide the controls needed; provide for the .

protection of records from loss, tampering, or theft, or during an emergency; and specify procedures for ensuring that the records management system remains effective (that is, that deficiencies are discovered and corrected in a timely manner).

The staff should review the physical characteristics of the records storage area (s), as described in the application, to determine the area's ability to protect and preserve the records that are stored there during the mandated periods, including protecting the stored records from damage, deterioration, or theft, or during and after emergencies. Certain documents may be j retained or stored at a site other than the plant. (For example, master drawings for structures l might be kept in the engineering department of the headquarters of the parent company.) The

! reviewer should review the physical characteristics of these offsite record storage areas, as well.

The reviewer should examine the facility's method (s) for controlling the records management system. This includes generating or obtaining the necessary records and approving, verifying, categorizing, inventorying, maintaining, protecting against tampering or loss, storing, retrieving, distributing, and preserving them to asses retrievability and legibility during the designated retention period. For computer codes tW . omputerized data relied upon for safety,!he reviewer should examine the procedureW ior maintaining readability and usability of older codes and data, as computing technology changes. This could include transcribing older forms of information (e.g., punched cards or paper tapes) and codes for older computing equipment to contemporary computing media and equipment.

The reviewer should examine the procedures for ensuring that the records management system l Draft NUREG 1671 2-26

Organization and Administration remains effective (that deficiencies are discovered and corrected in a timely manner). l 2.6.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

2.6.5.1 Regulatory Requirements A records management program !s not specifically required by the regulations; however it is considered part of the management con &ols and oversight program required by 10 CFR 76.35(a)(7) and a necessary part of the OA program required in 10 CFR 76.35(d).

2.6.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

2.6.5.3 Regulatory Review Criteria The reviewer should expect to find in the license application a commitment to a records management system for records that are important to health, safety, and the protection of the environment, as follows:

1. Records are specified, prepared, verified, characterized, and maintained.

2. Records are legible, identifiable, and retrievable for their designated lifetimes.

3. Records are protected against tampering, theft, loss, unauthorized access, damage, or deterioration for the time tney are in storage.

4. Procedures are established and documented specifying the requirements and responsibilities for record selection, verification, protection, transmittal, distribution, retention, maintenance, and disposition.

It should be determined whether the applicant has a records management system that meets the requirements of regulations and guidelines for safe plant operation. A records management system is acceptable if it is determined that implementation of the GDP records management system and procedures:

1. Ensures that the records management system remains effective in obtaining, validating, protecting, and storing information about the health and safety aspects of the GDP and its operations and can retrieve these records in readable form for the designated lifetime of the information.

2. Provides a records storage area (s) with the capability to protect and preserve records durir;g the mandated periods, including protection of the stored records from loss, theft, or tampering, 2-27 Draft NUREG-1671

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l Organization and Administration or during and after emergencies.

3. Ensures that any deficiencies in the records management system or its implementation will be detected and corrected in a timely manner.

2.6.6 Evaluation Findings 2.6.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the Intent of 10 CFR 76.35, " Contents of initial application" and 10 CFR 76.36, " Annua! renewals," requirements with respect to the records management and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.6.6.2 Sample Evaluation Findings The reviewer verifies that sufficient information has been submitted and the appropriate commitments have been made to conclude that the actual or proposed records management system will be adequate to meet the requirements to keep and maintain records. The review should be sufficiently complete to support conclusions similar to the following, in the CER The staff has reviewed the applicant's records management system and concluded that there is reasonable assurance that the system will: (1) be effective in validating, protecting, and storing information about the health and safety aspects of the GDP and its operations and will be able to retrieve the information in readable form for the designated lifetimes of the records; (2) provide records storage area (s) with the capability to protect and preserve records that are stored there during the mandated periods, including protection of the stored records against loss, theft, or tampering or during and after emergencies; and (3) ensure that any deficiencies in the records management system or its implementation will be detected and corrected in a timely manner.

2.G.7 Reference U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants." ,

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l Draft NUREG-1671 2-28

Organization and Administration 2.7 Maintenance 2.7.1 Responsibility for Review 2.7.1.1 Primary: Certification Project Manager 2.7.1.2 Secondary: Site Representative 2.7.1.3 Supporting: OA and Maintenance Reviewers 2.7.2 Purpose of Review An effective maintenance program directed to all items2 relied upon for safety is essential to ensure the reliable, safe operation of the plant. The purpose of this review is to ensure that the applicant has committed to an adequate maintenance program that encompasses all items identified as being relied on for the safe operation of the plant.

2.7.3 Areas of Review The staff should establish that the applicant has addressed the task of identifying all items

( relied on for safety for inclusion in the maintenance program. These will include items of varying risk.

The staff should also verify that the applicant used an appropriate methodology for the assignment of risk significance to each item to be included in the maintenance program. The differing risk levels among safety features may warrant varying treatment of the features within the program.

The licensee's description of the maintenance program is reviewed to establish that there is reasonable assurance that items relied on for safety are available and will function when needed. The review should include the following components: 1) corrective maintenance,2) preventive maintenance, and 3) surveillance (monitoring). Procedures, records, and training, as they apply to the maintenance of items relied on for safety, will be addressed in their respective SRP sections.

2.7.4 Review Procedures 2.7.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR ltems include SSCs; materials (including consumable materials); parts; measuring and Q test equipment; computers; computer programs (software and firmware); etc., as appropriate.

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i Organization and Administration 76.36, " Annual renewals" with respect to maintenance for GDP facilities has been included--see Section 2.7.5.1 " Regulatory Requirements"- and that the topics discussed in Section 2.7.3,

" Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

2.7.4.2 Safety Evaluation The primary staff reviewer should review the maintenance program description with respect to each of the acceptance criteria in Section 2.7.5. The review should determine if the applicant has adequately planned the work to be accomplished and whether necessary policies, procedures, and instructions either are in place or will be in place before work starts. The review should result in a determination that there is reasonable assurance that the applicant's maintenance, configuration management, and QA programs are coordinated.

When an applicant's maintenance program references other sections of the application, the primary reviewer should review these other sections of the application to ensure consistency with the applicant's selection of acceptance criteria and the proposed method for implementation.

The secondary staff reviewer should become familiar with the applicant's maintenance program and determine whether ongoing activities are in agreement with it. Supporting staff reviewers should review the maintenance program to ensure there is no contradiction between it and their primary review areas of the application. They should also ensure that the scope of the applicant's maintenance program includes the items relied upon for safety that are in their primary review areas of the application.

The final step in the review is the primary staff reviewer's writing of a CER that summarizes the conduct of the review, identifies what material in the application forms the basis for a finding of reasonable assurance with respect to the acceptance criteria, and presents the bases for license conditions that may be necessary to conclude that reasonable assurance is achieved.

2.7.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

2.7.5.1 Regulatory Requirements Section 76.87 requires that the applicant establish technical safety requirements (TSR) including establishment of procedures and/or equipment to address maintenance. This requirement includes record keeping, surveillance, and administrative controls.

2.7.5.2 Regulatory Guidance Draft NUREG-1671 2-30

t Organization and Administration

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No regulatory guidance has been developed in this area.

2.7.5.3 Regulatory Review Criteria l The reviewer should determine that acceptable commitments and descriptions are contained in I

the maintenance program description. 1 1

1. The maintenance program is acceptable if it includes corrective maintenance, scheduled preventive maintenance, and surveillance for the items that are relied upon for safety.

2. . The set of items selected for inclusion in the maintenance program will be acceptable if it includes at least those relied upon for safety to prevent or mitigate accident sequences. The scope of the maintenance program should include items that contribute to one or more of the following functions:

a. Ensure the containment of licensed material within a process

b. Prevent or mitigate the consequences of accident sequences

c. Items specified in plant emergency operating procedures or emergency plans

d. Items that are required to assure the availability or reliability or a safety function. as defined in Criteria 2a-c, above ,

In general, items that do not meet Criterion a-d - items that are not relied on for safety -  !

- are outside the scope of the required maintenance program. l

3. The applicant's selection and description of the method (s) used to establish the risk significance of the items selected for inclusion in the program are acceptable if the method is systematic and documented and/or has been approved by the Agency.

4. The applicant's description of the method used to establish the performance objectives and criteria for each item relied on for safety and the levels used in the maintenance program are acceptable if the pedormance objectives and criteria are stated in terms of availability, reliability, or condition for the particular item, are established at the structure, system, or component level, and criteria are established commensurate with the safety feature risk significance.

5. The applicant's description of the maintenance program is acceptable if the following essential components are committed to;

a. " Corrective maintenance" The applicant should have a systematic, controlled organization for repair and replacement activities to correct identified failures of items relied upon for safety. The history of identified failures should be used as an input into determining the surveillance and preventive maintenance schedules.

b. " Preventive maintenance" There should be evidence of and commitment to the O. .

2-31 Draft NUREG-1671

Organization and Administration organization and conduct of preplanned and scheduled periodic refurbishing, partial or complete overhaul, or requalification or the purpose of ensuring that unplanned failure of selected items relied upon for safety do not occur. This activity should be designed, in part, using the results of the surveillance component of the maintenance program. Instrumentation calibration and testing should be addressed by the applicant as part of the maintenance program. The applicant should describe how the program will be designed to ensure that the objective of preventing failures through maintenance is appropriately balanced against the objective of minimizing unavailability of items relied upon for safety because of monitoring or preventive maintenance.

c. " Surveillance (monitoring)" There should be evidence of and commitment to the organization and conduct of periodic surveillance to measure the degree to which engineered and human performance of safety functions meet performance specifications. This activity should be used, in part, to design the preventive maintenance function for specific safety features and to provide an instantaneous verification of the availability of the tested safety function. This activity should also be used to determine performance trends for items.

6. The applicant's maintenance program is acceptable if there is a commitment to the following actions regarding the design and conduct of preventive maintenance, corrective maintenanco, and surveillance:

a. Pre-maintenance reviews of the work to be performed, including procedure reviews for accuracy and completeness

b. Pre-maintenance and surveillance reviews of training, including scope related to work to be performed

c. Notification of, and retum confirmation by all affected operators and supervisors of, the maintenance to be performed and its potential effects on ongoing operations. In addition, notification and confirmation are performed after completion of the planned maintenance and restoration of the affected equipment to service

d. Records showing history of failures, the preventive maintenance schedule and activities, and the current surveillance schedule, performance criteria, and test results for all items relied on for safety should be maintained by the applicant consistent with Section 2.6 of this SRP.

e. Control of work by comprehensive procedures to be followed by maintenance and surveillance technicians. The procedures should be controlled within the QA and configuration management programs and should address, as a minimum, the following:

(1) Qualifications of personnel authorized to perform the maintenance or surveillance.

Draft NUREG-1671 2-32

Organization and Administration (2) Controls on and specification of any replacement items to be used (this should be controlled by the configuration management program treatment of the procedure).

(3) Post-maintenance testing to be done to verify operability of the equipment affected by the procedure.

(4) Requirements for notification and documenting the results of the procedure.

2.7.6 Evaluation Findings 2.7.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application .

for renewal of certification to satisfy the intent of 10 CFR 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals," requirements with respect to the maintenance and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.7.6.2 Sample Evaluation Findings The staff has reviewed the maintenance program for (name of facility) according to SRP Sections 2.7.3,2.7.4 and 2.7.5.

On the basis of the following findings, the staff concludes that the maintenance program for items relied on for safety included in the program is acceptable.

The applicant has suitably described and committed to the maintenance program for items relied on for safety in the license application. The maintenance program contains the basic components: corrective maintenance, preventive maintenance, and surveillance, and ensures the items relied on for safety are capable of fulfilling their intended functions. The program is proactive, using maintenance records to analyze equipment performance and seeking the root causes of repetitive failures.

In addition, the applicant's maintenance program: (1) is based on approved procedures; (2) employs work control methods that poperly consider personnel safety, awareness of facility operating groups, QA, and the ruls .i of configuration management; (3) links components and systems requiring maintenance to risk significance; (4) justifies the preventive maintenance and surveillance intervals in the terms of equipment reliability goals; and (5) creates documentation that includes detailed records of all maintenance and surveillance activities.

2-33 Draft NUREG-1671

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Organization and Administration 2.7.7 Reference U.S. Code of FederaIRegulations, Title 10, Part 76," Certification of Gaseous Diffusion Plants."

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Draft NUREG-1671 2-34

(m)

-V Organization and Administration 2.8 Configuration Management i

2.8.1 Responsibility for Review 2.8.1.1 Primary: Certification Project Manager 2.8.1.2 Secondary: OA Reviewer 2.8.1.3 Supporting: Site Representative 2.8.2 Purpose of Review The review is conducted to ensure that the applicant has implemented an acceptable configuration management (CM) program. The CM program is meant to establish consistency among design requirements, physical configuration, and facility documentation, and to maintain l this consistency throughout the operational life of the facility, particularly as changes are being made. The facility documentation, which includes as-built drawings and operating procedures, should accurately reflect both the physical configuration and the design requirements.

Changes to design requirements should be reflected in both the physical configuration and the facility documentation. Changes to either the facility physical configuration or facility l documentation should also be supported by the design requirements.

2.8.3 Areas of Review The staff wik review the applicant's submittal to ensure that an acceptable CM program is in place, to ensure that changes from a prior approved plant baseline configuration are managed so as to preclude inadvertent degradation of safety or safeguards. The CM program should include descriptions of the organizational structure responsible for CM activities, and the l process, procedures, and documentation required by the applicant for modifying the site, structures, systems, equipment, and components (SSECs) that are relied on for safety or safeguards. Specific elements to be presented are the development and installation of modifications; the training of affected staff; revision and distribution of operating, test, calibration, surveillance, and maintenance procedures and drawings; selection and control of replacement parts; post-modification testing; and readiness review.

The staff will review the following topics that should be addressed by the applicant:

1. An overall CM program statement, which should include the objectives, expected safety benefits, program elements, and CM organizational structure

2. Design requirements, including:

a. Description of how the plant design requirements and design basis were established and documented.

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Organization and Administration

b. Scope of the SSECs captured in the design basis. The specific SSECs included in the CM program should be identified.

3. Document control system, including the identification, storage, control, distribution, tracking, and retrieval of documents. {

4. Change control system, including identification, technical and management reviews, l documentation, and implementation of changes.

5. Assessment activity, including programmatic and physical configuration assessments.

2.8.4 Review Procedures 2.8.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to configuration management for GDP facilities has been included--See Section 2.8.5.1 " Regulatory Requirements-and that the topics discussed in Subsection 2.8.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

2.8.4.2 Safety Evaluation The primary reviewer should review the CM information and descriptions for completeness against the acceptance criteria in Section 2.8.5.3. The review should determine that the applicant has committed to a formal CM system for establishing design bases and reviewing proposed changes to SSECs, procedures, and processes that may impact systems relied on for safety.

The reviewer should be able to find, for systems important to safety, that the CM program controls: the design requirements, the physical configuration, and the facility documentation.

The reviewer should determine, with reasonable assurance, that the CM program will ensure that the physical configuration will accurately mirror the design requirements, and the facility documentation will accurately reflect both. Maintaining these relationships is particularly important when making changes. The reviewer should be able to identify these basic parts in the applicant's submittal.

The reviewer should ensure that the applicant has described a comprehensive CM function developed on the five elements discussed in the acceptance criteria (Section 2.8.5.3) of this SRP. Review activities for each element are discussed in the following:

1. Program Management Draft NUREG-1671 2-36

Organization and Administration The primary reviewer should ensure that the CM program plan states management commitments, gives the policy directive, and defines key responsibilities, terminology, and equipment scope. The method for initiating immediate corrective actions should be examined. Appropriate interfaces both within the CM program and with external organizations and functions should be examined. In particular, the functionalinterfaces with QA, maintenance, and training (including qualification) need to be examined in detail. The reviewer should look for the applicant's identification of required databases and the procedures for their maintenance. The reviewer should examine implementing procedures for the CM program.

2. Control of items Relating to Technical Safety Requirements (TSRs) and the SAR The primary reviewer, with support from the secondary reviewer, should be satisfied that a specific group is assigned the responsibility for maintaining the TSR and the SAR.

The reviewer shn uld verify that the SSECs to be listed under CM are clearly defined in

, the requirementa documents, along with the assignment of any grades or quality levels.

The grades or quality levels, if any, should be based on the qualitative risk assigned to l

i each safety-related function.

1

3. Document Control Systems The primary reviewer should evaluate the applicant's material showing that the CM system will capture documents that are relevant to and relied on for safety. This should include as-built drawings; specifications; all safety-important operating procedures; l procedures involving training; QA; maintenance; audits and assessments; emergency i operating procedures; emergency response plans; system modification documents; I assessment reports; and others, as necessary. The reviewer should determine that a  ;

controlled document database is used to control documents and track document change I status. Rules of storage for originals or master copies of documents within the CM l program should follow the guidance of " Records Management" discussed in Section 2.6 l i

4. Change Control ,

The primary reviewer should assure that the description of change control within the CM l function is sufficient to ensure that methods are in place for: (a) the identification of changes in configurations relied on for safety; (b) technical and management review of changes; (c) tracking and implementing changes, including placement of documentation in a document control center and distribution to affected functions such as training, design, operations, maintenance, and QA, and (d) post-modification testing of hardware (or procedure drills or walk-throughs).

5. Assessments l

The primary reviewer, with assistance from the supporting reviewer, should ensure that both program assessments and physical assessments (system walkdowns) will be l conducted periodically to check the CM function. The reviewers should ensure that all assessments and follow-ups are documented. These reports can provide the basis of i 2-37 Draft NUREG-1671

Organization and Administration future changes. The reviewers should assure that assessments willinclude reviews of safety systems from design requirements through implementation.

2.8.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

2.8.5.1 Regulatory Requirements Section 76.35(a)(7) requires that the application include a description of the management controls and oversight program to ensure that activities directly relevant to nuclear safety and safeguards and security are conducted in an appropriately controlled manner that ensures protection of employee and public health and safety and protection of national security Interests.

Section 76.68 describes the requirements for making changes to the plant or to the plant's operations, as described in the SAR, without prior Commission approval.

2.8.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

2.8.5.3 Regulatory Review Criteria The reviewer should determine that the five elements of an acceptable CM program are functional within the plant site organization. The acceptance criteria for each of the elements are as follows:

1. Program Management The applicant's description of CM program management functions should include at least the following topics: (a) the scope of the SSECs to be included in the CM program; (b) objectives of each program activity; (c) description of each program activity; and (d) organizational structure and staffing interfaces. The functional interfaces with QA; maintenance, and training and qualification are of particular importance and should also be individually addressed.

2. Control of items Relating to the TSRs and the SAR The applicant should demonstrate that the TSRs and the SAR have been established and are maintained by an appropriate organizational unit. The applicant should demonstrate that the TSR and SAR are kept current and that suitable hazard / accident ,

analysis methods, including controlled computer codes, if used, are available and are properly used to evaluate safety margins of proposed changes. Technical management l

j review and approval procedures should be described. The specific SSECs included in i Draft NUREG-1671 2-38 l

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(j I'

l Organization and Administration i the CM program should be identified.

3. Document Control The applicant should' describe the method 'used to establish and control documents within the CM program, including cataloging of the document data base, document maintenance and distribution of documents.

4. Change Control The applicant should demonstrate that the CM program maintains strict consistency among the design requirements, the physical configuration, and the facility documentation. The applicant should maintain procedures for identifying proposed changes, performing appropriate technical and safety reviews of proposed changes, approving changes, implementing changes, and documenting changes.

5. Assessments The applicant should confirm that assessments, including initial and periodic examinations of the CM system, are conducted to determine the program's effectiveness and to correct deficiencies.

2.8.6 Evaluation Findings 2.8.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of 10 CFR 76.35, T,ontents of initial application",

and 10 CFR 76.36, " Annual renewal," requirements with respect to CM and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

2.8.6.2 Sample Evaluation Findings

. The staff has reviewed the CM systems for (name of facility) according to the SRP Section 2.8.

The applicant has suitably described its commitment to its proposed CM system, including the method for managing changes in procedures, facilities, and equipment for systems relied on for safety. Administrative controls, including an analysis and independent safety review of any proposed activity regarding systems relied on for safety, are described that will ensure that the relationship between design requirements, physical configuration, and facility documentation is maintained as part of the new activity or change in an existing activity invoMng licensed material. The administrative controlincludes the following elements of CM:

i 1. Program Management LO l 2-39 Draft NUREG-1671

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Organization and Administration The organizational structure, procedures, and responsibilities necessary to implement CM are in place or documented.

2. Control of items Relating to TSRs and the SAR The TSRs and the SAR are documented and supported by analyses and the documentation is maintained current.

3. Document Control Documents, including drawings, are appropriately stored and accessible. The set of drawings and related documents adequately describe systems important to safety.

4. Change Control Responsibilities and procedures adequately describe the strict consistency among the design requirements, the physical configuration, and the facility documentation.

Methods are in place for suitable analysis, review, approval, and implementation of identified changes to systems important to safety. This includes periodic equipment performance monitoring and post-modification testing of hardware or procedure drills.

5. Assessments Methods or plans are in place to perform initial and periodic examination of the effectiveness of the CM system itself. In the case of existing facilities, assessments and follow-up reports of corrective actions are documented.

2.8.7 Reference U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

l Draft NUREG-1671 2-40

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3.0 QUALITY ASSURANCE 3.1 Responsibility for Review l

3.1.1 Primary

QA Engineer, Senior QA Engineer, or QA Specialist  ;

3.1.2 Secondary

Certification Project Manager 3.1.3 - Supporting: Reviewers of SRP Chapters 2.0 and 6.0 3.2 Purpose of Review The purpose of the review is to establish that the QA program changes in the application for certification renewal do not potentially degrade the QA program and that the QA program as revised continues to meet the NRC QA requirements of 10 CFR 76.93. That is, the  ;

revised QA program should continue to provide reasonable assurance that items' and activities relied upon for safety will perform their safety function in a satisfactory manner.

The review should determine whether the QA program changes in the application do or do not lessen the quality achievement and QA measures and controls to these items and activities such that they will not adequately protect the health and safety of the public, the workers, and the environment.

3.3 Areas'of Review This chapter of the Standard Review Plan (SRP) is written to direct the review of an application for certification renewal with regard to gaseous diffusion plant (GDP) items and/or activities that are relied on for safety. A graded QA program commensurate with importance to safety should continue to be applied to provide reasonable assurance of the availability and reliability of items and activities that are relied on for safety.

The application for certification renewal should continue to describe the QA program, and the primary reviewer should examine the QA program changes in terms of the acceptance criteria given in SRP Section 3.5 The review objective is to obtain reasonable assurance of the implementatkm of accepted QA principles in the operation, maintenance, modification, and demmmissioning phases of a GDP facility's life. Fundamental to this effort is the applica*'s application of QA to the items and activities identified as being relied on for safety.

The application should continue to define the levels of QA to be applied to items and activities relied upon for safety. Further, the ap, lication should continue to describe the

' Items include structures, systems, components, materials (including consumable materials), parts , measuring and test equipment , computers , computer programs (software  ;

and firmware), etc., as appropriate, j

' k,  !

3-1 Draft NUREG-1671 ,

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Ouality Assurance relationship among the programs for QA, maintenance, and configuration management. I The application should continue to assign each item and activity that is relied on for safety to a OA level. The application should continue to address the applicant's approach to determining the relative risk, or relative safety importance, of the various items and activities to be treated by the OA program. This safety importance ranking should continue to determine the level of OA to be applied to individual items and activities relied upon for safety.

Many of the regulatory acceptance criteria that an applicant's OA program should control may be detailed in other parts of the application (for examples, see Chapter 2.1,

" Organization Structure," and Chapter 2.6, " Records Management"), and Chapter 3 of the application may reference these other parts of the application that present information relevant to the OA program. The application of quality levels commensurate with the risk involved should continue to parallel the risk levels established for the maintenance program addressed in Chapter 2.7 of the SRP.

The OA program description should continue to specify the applicable regulatory acceptance criteria, the basis on which the criteria were selected, where they are described in the application if not in the OA chapter, and the proposed method for implementation.

3.4 Review Procedures 3.4.1 Acceptance Review The staff review should start with the primary reviewer's determination whether the contents of the application for certification renewal, as required 10 CFR 76.36, " Annual renewals,"

includes changes to the applicant's OA program. If so, the primary reviewer should determine whether the changes meet the format requirements of the regulation. If the changes do not meet the format requirements, the applicant should be requested to resubmit with correct format. If no changes to the applicant's OA program are submitted, the primary reviewer should so report to the project manager, the secondary reviewer, and the supporting reviewers. This would complete the OA review of the application. If changes to the applicant's OA program are submitted, the primary reviewer should proceed with the safety evaluation.

3.4.2 Safety Evaluation The primary staff reviewer should ensure that the material presented by the applicant continues to support the previous NRC conclusion that the acceptance criteria of SRP Section 3.5 are met.

The primary staff reviewer should review the changes to the OA program description with respect to each of the acceptance criteria in SRP Section 3.5. The staff review should be based on an assessment of the changes presented. The review should result in a determination that there continues to be reasonable assurance that the applicant's OA, Draft NUREG-1671 3-2

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Quality Assurance configuration management, and maintenance programs are coordinated and that the QA program is an integral part of everyday work activities. The review should confirm that there continues to be reasonable assurance that the applicant will be able to monitor the effectiveness of the implementation of the OA program and will make needed adjustments on a timely basis. )

When an applicant's OA program references other parts of the application, the primary reviewer shouid review the changes to these other pads of the application to determine the applicant's commitment to the overall QA program, the selection of acceptance criteria and i

quality level, and the proposed method for implementation. The primary reviewer should l focus on changes to the QA and management controls applied to criticality, personnel safety, environmental safety, and product quality. The application of quality levels commensurate with the risk involved should continue to parallel the risk levels established for the maintenance program.

The secondary staff reviewer should report to the primary reviewer any changes to the applicant's OA program that have not been submitted in the application for certificate

. renewal, and the primary reviewer should follow-up through the project manager to have the application modified as necessary. The secondary staff reviewer should maintain familiarity with the applicant's (and the principal contractor's) QA program and determine whether ongoing activities are o agreement with it.

l Supporting staff reviewers should review changes to the applicant's OA program to ensure there is no contradiction between the changed QA program and their primary review areas.

They should also ensure that the scope of the applicant's OA program continues to include the items and activities relied upon for safety that are in their primary review areas of the application.

The final step in the review is the primary staff reviewer's writing of a Safety Evaluation Report that summarizes the conduct of the review, identifies changes to the applicant's OA program that could affect the previous finding of reasonable assurance with respect to the license conditions, and presents any recommendations for changes to existing license conditions such that reasonable assurance is maintained, l

3.5 Acceptance Criteria l

The regulatory requirements, regulatory guidance, and regulatory review criteria applicable ,

to this SRP chapter are list 'd in the following subsections. i 3.5.1 Regulatory Requirements The Code of Federal Regulations, Title 10, Part 76 (10 CFR 76), " Certification of Gaseous .

Diffusion Plants," 176.35(d), " Contents of initial applications," requires that the initial i p

y application for certification included a OA program that meets the requirements of 10 CFR 3-3 Draft NUREG-1671

Ouality Assurance 76,176.93, " Quality assurance."

10 CFR 76, 76.93 requires that the Corporation (applicant for certification renewal) establish, maintain, and execute a OA program satisfying each of the applicable requirements of American Society of Mechanical Engineering (ASME) NOA-1-1989,

" Quality Assurance Program Requirements for Nuclear Facilities," or satisfying acceptable alternatives to the applicable requirements, it also requires that the Corporation execute the criteria in a graded approach to an extent that is commensurate with the importance to safety.

10 CFR 76, 76.36, " Annual renewals," basically requires that each annual application for certification renewal describes any unreported changes made to the Corporation's OA program description.

3.5.2 Regulatory Guidance No regulatory guidance has been developed by the NRC in this area.

3.5.3 Regulatory Review Criteria The regulatory review criteria to be used by the staff to assess the acceptability of changes to the applicant's revised QA program are the basic and supplemental requirements in ASME NOA-1-1989 as specified in 10 CFR 76, 76.93.

3.6 Evaluation Findings

3.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy 10 CFR 76.36, " Annual renewals,"

requirements with respect to the OA program and that the information provided is consistent with the guidance in this SRP. Further, the staff review should verify that the revised QA program is adequate to ensure the quality of management controls for items and activities relied on for the health and safety of the workers and the public, relied on for the protection of the environment, and relied on for safeguarding nuclear material. On the basis of this information, the staff should be able to conclude that the evaluation is complete. The review record should demonstrate that the staff has reviewed the changes to the applicant's OA program deteription for the GDP facility according to this SRP Chapter. The staff can document its review as follows.

3.6.2 Sample Evaluation Findings The staff has reviewed the changes to the QA program for (name of facility] according to I Draft NUREG-1671 3-4

A Quality Assurance SRP Sections 3.3,3.4 and 3.5 and finds that:

1. The applicant continues to have a OA organization responsible for developing, implementing, and assessing the OA program for ensuring a safe facility and safe facility operations in accordance with the acceptance criteria of Section 3.5 of the SRP.

2. The applicant continues its commitment for a plant OA program for items and activities relied upon for safety with acceptable administrative controls for staffing, functbning, assessing findings, and implementing corrective actions.

3. The applicant has developed a process for preparation, review, approval, documentation, and control of written administrative plant procedures, including procedures for evaluating changes to procedures, equipment, tests, and processes relied on for safety.

4. The applicant has established and documented a surveillance, test, and inspection program to ensure satisfactory performance of items and activities relied on for safety.

I

5. The applicant has committed to conduct periodic independent audits to determine the I effectiveness of the management controls program. Management controls will continue to i provide for documentation of audit findings and implementation of corrective actions.  ;

p 6. The applicant has committed to establish and document training programt to provide Q employees with the skills to perform their jobs safely. Management controls will continue to provide for evaluation of the effectiveness of the training programs against predetermined i objectives and criteria.

7. The organizations and persons performing OA functions will continue to have the required independence and authority to effectively carry out the OA program without undue influence from those directly responsible for process operations. ,

8. The QA program continues to cover all items and activities identified as relied on for safety, with controls established to prevent hazards from becoming pathways to accidents.

Accordingly, the staff concludes that the applicant's revised description of the OA program complies with applicable NRC regulations and industry standards and can be implemented l for the (name of facility). l 3.7 References U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

Quality Assurance Program Requirements for Nuclear Facilities, NOA-1-1989, American Society of Mechanical Engineering, United Engineering Center,345 East 47th Street, New York, N.Y. 10017.

3-5 Draft NUREG-1671

~

4.0 FACILITY AND PROCESS DESCRIPTION ,

l 4.1 Responsibility for Review

4.1.1 Primary

Certification Project Manager

4.1.2 Secondary

Reviewers of Chapter 5 and Chapter 6 l

4.1.3 Supporting

Resident inspector Staff l I

4.2 Purpose of Review The purpose of this review is to establish that the facility and process description provided by the applicant is adequate to understand the facility processes and parameters to help determine the adequacy of the hazard / accident analysis (see Chapter 5.0 " Hazard / Accident Analysis") ,

and application of the graded approach to quality to the selection and treatment of systems, structures, and components important to safety.

4.3 Areas of Review

1. The staff reviews the facility description with respect to features that could affect potential accidents and their consequences. Examples of these features are facility i location, facility design information, and the location and arrangement of buildings on ON the facility site.

l l

2. The staff reviews the description of each process analyzed. Specific areas that are  ;

reviewed are basic process function and theory, major components-their function and operation, process design and equipment, and process operating ranges and limits.

3. The staff reviews the description of the structures, systems, and components (SSCs) identified as important to safety ( e.g., Chapter 4.0 " engineered safety features and physical barriers used to maintain safe operation of the facility") to ensure that the i number and quality for controls are commensurate with staff acceptance criteria. Such criteria are based on the consequence level (graded approach to QA) the controls are intended to prevent or mitigate.

4 4.4 Review Procedures I

The staff review should start with a determination by the primary reviewer that the content of the application as required by $76.35, " Contents of initial application" and 76.36, " Annual renewal" with respect to the description of the principal structures, systems, and components of the GDP facilities, including a description of equipment and facilities which will be used to protect health and minimize danger to life or property, has been included-See Section 4.5.1 " Regulatory Requirements, and that the topics discussed in Subsection 4.3, " Areas of Review," have been addressed.

J 4-1 Draft NUREG-1671

l l

Facility and Process Description if significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

1. The staff reviews the applicant's description of the facility to determine if the features that could affect potential accidents and their consequences are adequately discussed.

The reviewer should verify that information describing the location and arrangement of buildings at the site and their distance from the site boundary is provided. The reviewer should determine that design criteria for the facility are justified on the basis that (1) they are sufficient to withstand the effects of credible external events that could occur at the site or (2) the consequences of such credible external events are acceptable, given their expected frequency of occurrence.

2. The staff reviews the applicant's description of each process analyzed in the hazard / accident analysis to determine that it provides an adequate understanding of process function and theory, as well as major component function and operation . The staff also reviews information provided on process design, equipment, and instrumentation to determine that it is sufficient to understand the results of the hazard / accident analysis.

3. The staff reviews the applicant's identification of SGCs important to safety and description of their intended safety function to determine that the identified SSCs and the description of their intended safety function support the conclusions of the accident analysis and the selection of safety limits, limiting control setting, limiting condition for operations, design features for safety, surveillance requirements, and administrative controls identified for the facility's Technical Safety Requirements. The intended safety function description should also provide the bases for the graded approach of applying the criteria of ASME NOA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities".

4.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

4.5.1 Regulatory Requirements 676.35(a)(6) requires that the application include a description of equipment and facilities which will be used by the Corporation to protect health and minimize danger to life or property. In addition, $76.35(a)(8), requires that the application includes a description of the plant site and a description of the principle structures, systems, and components of the plant.

4.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

4.5.3 Regulatory Review Criteria Draft NUREG-1671 4-2 O

Facility and Process Description NRC staff should use the following regulatory review criteria, or information demonstrating L acceptable alternatives, in its review of the SAR. Acceptability should be based on:

.1. The information describing the locetion and arrangement of buildings at the site and their distance from the site boundary is in enough detail to support the consequence analysis from the hazard / accident anaiysis. The design criteria for the facility provides enough detail to determine that (1) they are sufficient to withstand the effects of credible external events that could occur at the site or (2) the consequences of such credible extemal events are acceptable, given their expected frequency of occurrence as evaluated in the hazard / accident analysis. ,

2. The description of the processes analyzed as part of the hazard / accident analysis are considered acceptable if the following features are identified and described. If the information is available elsewhere in the license application, reference to the appropriate sections is considered acceptable.

NOTE: Some descriptions of processes may contain confidential-restricted data and will not be available in the SAR. If such confidential-restricted information is needed to determine the adequacy of the SAR, it should be requested from the applicant and controlled accordingly.

l The information provided should adequately support an overall understanding of the '!

facility process operations as they pertain to the hazard / accident analysis: I

a. Basic process function and theory. This information should include a general j discussion of the basic theory of the process. I

b. Major components-their function and operation. This information should include

. the general arrangement, function, and operation of major components in the process. It should include process schematics showing the major components and instrumentation and, if appropriate, chemical flowsheets showing compositions of the various process streams.

c. Process design and equipment. This information should include a discussion of l process design, equipment, and instrumentation that is detailed enough to I understand the results of the hazard / accident analysis, in particular, the operational analysis from which the SSCs important to safety were derived. It should include equipment schematics with enough detail for tne reviewer to understand the process and its interactions with other systems.

d. Process operating ranges and limits. This information should include the operating ranges and limits for all measured variables (e.g., temperatures, )

pressures, flows, and compositions) used in engineered or administrativa controls to ensure safe operation of the process. The process operating limits and ranges are considered acceptable if they are consistent with those assumed in the hazard / accident analysis.

O 4-3 Draft NUREG-1671

Facility and Process Description

3. The description of the SSCs important to safety are considered acceptable if the following features are identified and described. If the information is available elsewhere in the license application, reference to the appropriate sections is considered acceptable,

n. The identification of the SSCs important to safety and description of their safety functions agree with the results of hazard / accident analyses, in particular the essential controls identified in the operational analyses, found acceptable from Chapter 5, " Hazard / Accident Analysis" and provides adequate detail to support the derivation of TSRs (see Chapter 6, " Technical Safety Requirements").

b. Support systems necessary for the SSCs important to safety to perform their safety function agree with the results of hazard / accident analyses, in particular the essential controls identified in the operational analyses, found acceptable from Chapter 5," Hazard / Accident Analysis".

c. Functional requirements which provide assurance the SSC can perform its intended safety function. The functional requirements should support the identification of the support systems identified above.

d. Performance criteria for the SSCs are supported by the results of hazard / accident analyses, in particular the essential controls identified in the operational analyses, found acceptable from Chapter 5, " Hazard / Accident Analysis" and provides adequate detail to support the derivation of TSRs (see Chapter 6, " Technical Safety Requirements").

e. A basis is provided on how the graded approach to quality will be applied to the SSCs and support systems identified above. The degree of application of the graded approach to quality (safety system classification) to the SSC and support  !

systems within the SSC's system boundary will be acceptable if it is commensurate with the SSC's importance to safety (i.e. if the safety system classification agrees with consequences of concern (Appendix B, Chapter 5,

" Proposed Consequences of Concern") that the intended safety function of the SSC is supposed to prevent or mitigate).

f. The SSC's system boundary includes the support systems necessary for the 3 SSC to perform its intended safety function.

4.6 Evaluation Findings l 4.6.1 Introduction i l

The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of $76.36, " Annual renewal," requirements with respect to the facility and process description and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to Draft NUREG-1671 4-4 O

i 7%

Facility and Process Description conclude that this evaluation is complete. The staff can document its review as follows.  !

4.6.2 Sample Evaluation Findings i

The staff has reviewed the facility and process description for [name of facility] according to the i SRP sections 4.3,4.4 and 4.5.

l The applicant has adequately described and documented the facility and process description and the staff finds that the applicant is in compliance with those parts of 676.36 relating to the facility and process description. In addition, the applicant has [The reviewer will describe the bases for this conclusion, addressing areas that were reviewed and a discussion of how the ,

acceptance criteria have been met. The reviewer should include a description of the general location, number, and type of controls, referencing appropriate sections of the application. The  ;

reviewer should also describe the applicant's approach to ensuring the quality and reliability of the controls.)

4.7 References .

U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

ASME NOA-1," Quality Assurance Program Requirements for Nuclear Facilities."

%J C%

4-5 Draft NUREG-1671

5.0 HAZARD / ACCIDENT ANALYSIS 5.1 - Responsibility for Review

5.1.1 Primary

Certification Project Manager

' 5.1.2 Secondary: Reviewers of Chapter 4 and Chapter 6

5.1.3 Supporting

Resident inspector staff 5.2 Purpose of Review The purpose of this review of the hazard / accident analysis is to establish reasonable assurance that the applicant has performed a systematic evaluation of the gaseous diffusion facility and its processes to determine that:

1. All hazards and credible accidents associated with deviations from normal processing, intamally initiated events (e.g., explosions, fires), and extemally initiated events (e.g.,

floods, high winds, earthquakes) that could result in unacceptable consequences to the public, facility worker, and the environment have been identified and evaluated.

2. Physical and administrative controls are identified that will provide reasonable j

(' assurance, through preventive and /or mitigative measures, that identified hazards do l not result in unacceptable consequences.  ;

5.3 Areas of Review.

A summary of the hazard / accidents analysis is reviewed to provide assurance that a systematic evaluation of the hazards and credible accidents has been performed. The review boundaries includes those accidents that result in a release of radioactive material or an inadvertent i criticality event. Accidents that result in the release of hazardous chemicals are reviewed only '

when they result from the certified processing of radioactive materials or have the potential to adversely affect radiological safety. An event sequence having radiological consequences less i than 10 CFR 20 limits and toxic consequences, if any, less that OSHA threshold health effecas limits, would not require further consideration within the hazard analysis. The staff reviews the hazard / accidents analysis summary to ensure conformance with the requirements of 10 CFR Part 76.85. The areas of review are as follows:

1. The staff reviews the site description (see Chapter 1,1, " Site Descriptien') with respect to those factors that could affect safety, such as geography, meteorology (e.g., high winds, flood potential), seismology, and demography.

2. The staff reviews the facility description (see Chapter 1.1, " Site Description" and Chapter 4.0," Facility and Process Description") with respect to features that could affect potential accidents and their consequences. Examples of these features are facility location, facility design information, and the location and arrangement of buildings on 5-1 Draft NUREG-1671 ,

Hazard / Accident Analysis the facility site.

3. The staff reviews the description of each process analyzed (see Chapter 4.0, " Facility and Process Description"). Specific areas that are reviewed are basic process function and theory, major components-their function and operation, prc ess design and equipment, and process operating ranges and limits.

4. The staff reviews the hazard / accident analysis method used and the justification for its selection. For purposes of this review, the hazard / accident analysis begins with an identification of hazards (chemical, radiological, criticality, etc.) that may present a potential threat to the public, facility workers, and the environment. Based on an analysis of these hazards, the hazard / accident analysis identifies a set of individual accidents (defined as a sequence of unplanned events with undesirable consequences) that could result from the hazards. The accidents thus transform the threat from the hazards into potential occurrences. The review of the hazard / accident analysis methodology includes evaluating the following specific areas:

a. The method used by the applicant for hazard identification.

b. The method used by the ripplicant for hazard analysis and accident identification.

c. The method used by the applicamt for consequence determination.

d. The method used by the applicant for accident sequence construction and evaluation.

5. The staff reviews the narrative de.scription and the tabular summary of the results of the hazard / accident analysis with respect to the following specific areas:

a. Description of the hazards and the resulting potential accidents caused by deviations from normal operations, internally initiated events (e.g., explosions, fires), and extemally initiated events (e.g., floods, high winds, earthquakes).

b. Description of the unmitigated consequences of each potential accident to facility workers and the public.

c. Comparison of the unmitigated consequences of each accident with the defined

" consequences of concem" (industry accepted thresholds for radiological or toxic chemical exposure, see Appendix C for proposed thresholds and consequences of concem).

d. Description of the accident sequence for each major potential accident (i.e., an accident sequence with consequences that exceed defined thresholds starting with the initiating event through the accident end state.

6. The staff reviews the description of the administrative controls, engineered safety features, and physical barriers used to maintain safe operation of the facility to ensure Draft NUREG-1671 5-2  !

l l

Hazard / Accident Analysis l that, for each accident sequence, the number and quality of controls are commensurate with staff acceptance criteria. Such criteria are based on the consequences the controls are intended to prevent or mitigate.

7. The staff reviews the administrative controls for conducting and maintaining the hazard / accident analysis to ensure its overall integrity as a continuously current and accurate design basis for the facility safety program and should be included in the review from Chapter 2.8 " Configuration Management".

5.4 Review Procedures

1. The staff reviews the applicant's description of the site for the gaseous diffusion facility to determine if adequate information is presented to provide an understanding of those factors that could pose a hazard to the facility (see Chapter 1.1 " Site Description").

Specific extemal hazards (such as location of nearby airports, rail lines, port facilities, other nuclear or chemical facilities, dams, rivers, etc.) should be identled in the application by the reviewer. The reviewer should also look for identification of severe weather conditions and other external factors such as hurricanes, earthquakes, floods, tornadoes, etc., that are specific threats to the site.

2. The staff reviews the applicant's description of the facility to determine if the features that could affect potential accidents and their consequences are adequately discussed O (see Chapter 1.1, " Site Description" and Chapter 4.0," Facility and Process Description").

The reviewer should verify that information describing the location and arrangement of buildings at the site and their distance from the site boundary is provided. The reviewer should determine that the construction of the facility is justified on the basis that (1) the facility construction is sufficient to withstand the effects of credible extemal events that could occur at the site or (2) the consequences of such credible extemal events are acceptable, given their expected frequency of occurrence.

3. The staff reviews (Chapter 4.0," Facility and Process Description") the applicant's description of each process analyzed in the hazard / accident analysis to determine that it provides an adequate understanding of process function and theory, as well as major component function and operation . The staff also reviews information provided on process design, equipment, and instrumentation to determine that it is sufficient to understand the results of the hazard / accident analysis.

4. The staff reviews the applicant's description of the hazard / accident analysis methodology selected to verify that the applicant has provided a cogent description of the methodology (i.e., the methods used for hazard identification, hazard analysis and accident identification, accident consequence determination, and accident analysis) and the bases for its choice. The reviewer verifies that the acceptance criteria in Section 5.5.3.4 are satisfied.

5. The staff reviews the narrative and tabular summary of the results of the hazard / accident analysis to determine if the information provided is complete and .

)

5-3 Draft NUREG-1671 l

Hazard / Accident Analysis satisfies the acceptance criteria in Section 5.5.3.5. The information reviewed includes:

a. A listing of hazardous materials and conditions; also a table showing interactions between materials and between materials and conditions that could result in a hazardous situation.

b. A listing of the potential accidents that could result from the hazards identified in Section 5.5.3.5.a including the consequences of each accident.

c. For each accident identified in Section 5.5.3.5.b that has been demonstrated or is assumed to have consequences in excess of defined thresholds, a Logic Diagram (or other appropriate technique) that identifies the independent failure events required to cause the accident.

6. The staff reviews the administrative and physical safety controls identified in the hazard / accident analysis to determine if they satisfy the acceptance criteria provided in Section 5.5.3.6. These criteria specify the number, quality, and reliability of the controls needed to prevent or mitigate the consequences of identified accidents.

7. The staff reviews the administrative controls that are proposed to ensure the integrity of the hazard / accident analysis. The reviewer verifies that the controls include procedures for hazard / accident analysis performance and update, review responsibility, documentation, and record maintenance.

5.5 Acceptance Criteria 5.5.1 Regulatory Requirements Hazard / accident analysis requirements are specified in 10 CFR Part 76.85.

5.5.2 Regulatory Guidance Guidance applicable to performing an hazard / accident analysis and documenting the results is Regulatory Guide (REGUIDE) 1.70,1983," Standard Format and Content of Safety Analysis Reports for Light Water Reactors.

5.5.3 Regulatory Acceptance Criteria The acceptance criteria for the hazard / accident analysis are based on meeting the relevant requirements in 10 CFR Part 76.85, " Assessment of Accidents." The hazard / accident analysis will form the basis for the safety program, which requires adequate controls and systems to be in place to ensure safe operation of the facility. The staff will accept the hazard / accident analysis, the designation of physical and administrative controls, and the management of the hazard / accident analysis process if the reviewer finds the following criteria are met:

1. The description of the site (see Chapter 1.1, " Site Description") is considered acceptable Draft NUREG-1671 5-4 O 1 1

Hazard / Accident Analysis w/

if the following safety-related information is included or referenced in the application:

a. A description of the site geography, including its location relative to prominent natural and man-made features such as mountains, rivers, airports, population centers, possibly hazardous commercial and manufacturing facilities, etc.

b. Population information based on recent census data to show population distribution as a function of distance from the facility.

c. A discussion of natural phenomena (e.g., tornadoes, hurricanes, earthquakes) and other external events that could have an adverse impact on safety. The discussion should indicate which events are considered to be incredible and the basis for that determination.

2. For purposes of the hazard / accident analysis, the description of the facility is considered acceptable if the features that are considered important to safety are identified and described. if such information is available elsewhere in the certification application, 3 reference to the appropriate sections is considered acceptable. The information 1 provided should adequately support an overall understanding of the facility structure and its general arrangement as it pertains to the hazard / accident analysis. As a minimum, the features that should be identified and briefly described are as follows:

O G

a. The facility location and the distance from the site boundary.

b. Engineering analyses regarding the ability of the facility to withstand the effects of credible external events identified in Section 5.3.1.

c. The location and arrangement of buildings on the facility site.

3. The description of the processes analyzed as part of the hazard / accident analysis are considered acceptable if the information reviewed from Chapter 4.0, ' Facility and Process Description" was considered acceptable. The information provided should adequately support an overall understanding of the facility process operations as they pertain to the hazard / accident analysis.

4. The descriptive summary of the hazard / accident analysis methodology is considered acceptable if the reviewer determines that the applicant has provided a cogent description of the methodology (i.e., the methods used for hazard identification, hazard analysis and accident identification, accident consequence determination, and accident sequence evaluation) and the bases for its selection. Specific acceptance criteria for the hazard / accident analysis methodology are:

a. The hazard identification method selected is considered ar .aptable if it:

1. provides a list of materials (radioactive, fissile, flammable, and toxic) and/or conditions that could result in hazardous situations (e.g., loss of containment of h

V licensed nuclear material). The list should include maximum intertded inventory 5-5 Draft NUREG-1671

Hazard / Accident Analysis amounts and the location of the hazardous materials at the facility.' The hazard l identification should focus on non-standard industrial hazards and those J standard hazards that impact the safe operation of the facility. Most standard hazards should be addressed in the chemical safety program (see Chapter 10.0

" Chemical Safety")

ii. determines potential interactions between materials or between materials and l conditions that could result in hazardous situations.  !

i

b. The hazard analysis method selected is considered acceptable if- I

l. its selection is consistent with the guidance provided in REGUIDE 1.701983

" Standard Format and Content of Safety Analysis Reports for Light Water Reactors". Justification and references for methods not addressed in REGUIDE 1.70 should be provided.

i

11. it analyzes the hazards identified in Section 5.5.4.a. Any hazards eliminated from further consideration should be identified and justified.

iii. it provides reasonable assurance that all significant accident sequences (including the controls used to prevent or mitigate the accidents) that could result in radiological and certain chemical consequences8 are identified.

iv. It takes into account the interactions of identified hazards and proposed controls to ensure that the overall level of risk at the facility is minimized.

v. it addresses all modes of operation including startup, operation, shutdown, and maintenance, vi. It addresses hazards resulting from process deviations (e.g., high temperature, I high pressure), internal (to the facility) initiators (e.g., fires, explosions), and l possible credible external events (e.g., floods, high winds, earthquakes, airplane I crashes). Justification should be provided for a licensee's determination that certain events are incredible and, therefore, not subject to analysis in the hazard / accident analysis,

c. For each accident identified in Section 5.5.3.5.b that has been demonstrated or l l

'At least the following hazardous chemicals should be included in the inventory list if i present on-site: ammonia, fines (UO2 dust), flammable liquids and gases, fluorine, I hydrofluoric acid, hydrogen, nitric acid, organic solvents, propane, uranium hexafluoride, Zircatoy. l 2The release of hazardous chemicals is of regulatory concem to NRC only to the extent that such hazardous releases result from the processing of licensed nuclear material or have the potential for adversely affecting radiological safety. )

Draft NUREG-1671 5-6

Hazard / Accident Analysis assumed to result in a criticality event or to exceeded consequences of concern, an accident analysis method should be used to identify and demonstrate the adequacy of controls implemented to provide protection. The accident analysis method is considered acceptable if:

1. its selection is consistent with the guidance provided in REGUIDE 1.70 (1983).

Justification and references for methods not addressed in REGUIDE 1.70 should be provided.

ii. It is able to demonstrate adherence to the double contingency principle or identifies the administrative controls and/or systems, structures, and components (SSCs) relied upon to not exceed the consequences of concem and the absence of common mode failures.

5. The narrative description and tabular summary of the results of the hazard / accident analysis are acceptable if the following criteria are met:

a. The hazard identification method should provide:

1. a list of materials (radioactive, fissile, flammable, and toxic) or conditions that could result in hazardous situations. The list should include maximum intended inventory amounts and the location of the hazardous materials at the site.

Some of this information may exist in other documents and may be referenced.

ii. a table showing potential interactions between materials or between materials and conditions that could result in hazardous situations.

b. The hazard analysis method should provide a tabular summary description of the potential accidents that could result from deviations from normal operations, intemally initiated events (e.g., explosions, fires), and extemally initiated events (e.g.,

floods, high winds, earthquakes). The description should list deviations from normal operations, the causes of such deviations, the unmitigated consequences of the resulting accidents, the controls or barriers expected to prevent or mitigate the accidents, and the level of quality and reliability established for each control. The listing should clearly indicate the linkage between each individual cause, the resulting consequence, and the control (s) used to prevent or mitigate the consequence. The magnitude of each consequence may either be evaluated (see Section 5.5.3.5.c) or may be assumed to exceed the consequences of concem.

c. The application of the consequence evaluation method (s) to the accidents identified in Section 5.5.3.5.b should be demonstrated by the applicant in the appropriate safety chapters of the certification application (i.e., "Nucl6ar Criticality Safety,"

" Chemical Safety"), i

d. For each accident identified in Section 5.5.3.5.b that has been demonstrated or I

assumed to have consequences in excess of the consequences of concem for O 5-7 Draft NUREG-1671 1

Hazard / Accident Analysis unlikely and highly unlikely events, the accident analysis methodology should clearly identify through an operational analysis, using logic diagrams or other appropriate techniques, the independent failure events required to cause the accident. This information is needed to demonstrate adherence to the double contingency or to identify and demonstrate the adequacy of the administrative controls and/or SSCs relied upon to not exceed the industry accepted thresholds for radiological or toxic chemical exposure and the absence of common mode failures.

6. The review from Chapter 6.0, ' Technical Safety Requirements", should determine the adequacy of the barriers or controls used to ensure safe operation of the facility.

7. The review from Chapter 2.8,' Configuration Management", should determine the adequacy of the administrative controls used to ensure the integrity of the hazard / accident analysis.

The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

5.6 Evaluation Findings

5.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of $76.36, " Annual renewal," requirements with respect to the (subject area] and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

5.6.2 Sample Evaluation Findings The staff has reviewed the hazard / accident analysis for (name of facility) according to the SRP sections 5.3,5.4 and 5.5.

The applicant has adequately described and documented the hazard / accident analysis and the staff finds that the applicant is in compliance with those parts of $76.36 relating to hazard / accident analysis. In addition, the applicant has [The reviewer will describe the bases for this conclusion, addressing areas that were reviewed and a discussion of how the acceptance criteria have been met. The reviewer should include a description and bases of the methodology used in the hazard / accident, the consequences of concern used in screening the scenarios, a summary of the major scenarios, a summary of the operational analysis and how the systems important to safety were identified through the operational analysis.]

5.7 References Draft NUREG-1671 5-8

I i

O Hazard / Accident Analysis U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

U.S. Code of Federal Regulations, Title 10, Part 20, " Radiation Protection."

ANSI /ANS-51.1-1983, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water l Reactor Plants," American Nuclear Society, La Grange Park, IL,1983.

5.8 Definitions l

The following definitions are provided to help the reader better understand the conceptual basis 4 for the Hazard / Accident Analysis (HAA) guidance given in this chapter.

1. Credible initiating (or secondary) event - An initiating (or secondary) event that is not incredible. Any event sequence that consists of credible initiating and secondary events must be addressed in the HAA. A graded (number and quality) level of controls / barriers should be implemented commensurate with the consequences that could result from such an event sequence. Credible events will include postulated failures of instrumentation and sensors designed to control equipment or initiate process alarms.

2. Event sequence - A sequence of occurrences, consisting of an initiating event and secondary events, that would result in a release of radioactive material and, in some cases, non-radioactive but toxic substance (s), that could result in adverse consequences to human health or the environment.

3. External event - An initiating (or secondary) event for which the likelihood of occurrence cannot be altered by the plant manager. This would include all natural phenomena events in addition to events such as airplane crashes, explosions, toxic releases, fires, etc. occurring near the plant site.

4. Incredible initiating (or secondary) event - As part of an event sequence, an initiating (or secondary) event that is so unlikely that additional controls / barriers are not needed to prevent the occurrence of the event sequence or mitigate its consequences.

An event sequence may be characterized by a claimed incredible initiating (or secondary) event. Justification should be provided for the characterization, if justified, the event sequence will be considered incredible and will not need to be further addressed in the HAA. Failure of an engineered or administrative control should not be considered incredible.

5. Internal event - An initiating (or secondary) event for which the likelihood of occurrence can be affected by actions of the plant manager. This would include all events resulting from deviations from normal process operating conditions, in addition to accidents (e.g., fires and explosions) resulting from conditions at the facility site.

6. Natural phenomena event - Earthquakes, floods, tomados, tsunamis, hurricanes, etc.

Natural phenomena events, depending on their probability of occurrence, may be credible or incredible.

( /

5-9 Draft NUREG-1671

Hazard / Accident Analysis

7. Unmitigated consequences - Those consequences that result assuming that engineered or administrative controls or barriers are not available to prevent or mitigate an accident.

O Draft NUREG 1671 5-10

1 I

O O 6.0 TECHNICAL SAFETY REQUIREMENTS 6.1 Responsibility for Review

6.1.1 Primary

Certification Project Manager

6.1.2 Secondary

Reviewers of Chapter 4 and Chapter 5

6.1.3 Supporting

Resident inspector staff 6.2 Purpose of Review The purpose of this review of the Technical Safety Requirements (TSRs), their selection criteria, and their bases is to establish reasonable assurance that the appropriate barriers or controls have been identified and controlled thereby continuing to ensure safe operation of the facility. Compliance with the TSRs should assure that overall facility operation is maintained within the limits determined by the hazard / accident analysis which was shown to be adequate to protect the public from undue risk (see Chapter 5.0," Hazard / Accident Analysis").

6.3 Areas of Review This chapter of the Standard Review Plan (SRP) is written to direct the review of an application O

V for certification renewal with regard to the TSRs, their selection criteria, and their bases for the safe operation of the gaseous diffusion plant. The TSRs need to demonstrate that they provide adequate protection to the public from undue risk by assuring that overall facility operation is maintained within the limits defined by a new hazard / accident analysis determined to be adequate (see Chapter 5.0, " Hazard / Accident Analysis") or by adequate technical justification based on previous analyses.

1. The staff reviews the operational analysis derived from the new accident analyses or previous accident analyses and the identified safety actions.

2. The staff reviews the identification and safety function of the systems, structures, or components (SSCs) required to perform the safety actions identified from above.

3. The staff reviews the identified design safety features, safety limits, limiting control  !

settings (LCS), limiting conditions for operations (LCO), surveillance requirements, and administrative controls (see Section 6.8, " Definitions") and their associated bases.

4. The staff reviews the graded approach to quality applied to each TSR SSC and support systems required by each SSC to perform its intended safety function. j 6.4 Review Procedures The staff review should start with a determination by the primary reviewer that the content of the

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6-1 Draft NUREG-1671

Technical Safety Requirements application as required by 976.35, " Contents of initial application" and 976.36, " Annual renewal" with respect to 676.87, " Technical Safety Requirements" for GDP facilities has been included--

See Section 6.5.1 ' Regulatory Requirements, and that the topics discussed in Subsection 6.3,

" Areas of Review," have been addressed.

1. The staff reviews the operational analysis derived from the new accident analyses or previous accident analyses to determine if there is adequate information to support identification of safety actions which will envelope the safe operation of the analyzed facility or process.

2. The staff reviews the identification and safety function of the SSCs required to perform the safety actions identified from above to decide if there is adequate information to determine that the essential SSCs have been identified to ensure that the safety actions would be performed when needed.

3. The staff reviews the identified design safety features, safety limits, limiting control settings (LCS), limiting conditions for operations (LCO), surveillance requirements, and administrative controls (see Section 6.8,

• Definitions") and their associated bases to decide if there is adequate information to determine that the analyzed facility or process would perform within the parameters of the accident and operational analysis.

4. The staff reviews the graded approach to quality applied to each TSR SSC and support systems required by each feature to perform its intended safety function to ensure that each TSR SSC is available and reliable, if significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

6.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to l this SRP are listed in the following sections. I 6.5.1 Regulatory Requirements 976.35(e) requires that the application include technical safety requirements in accordance with 976.87, " Technical Safety Requirements".

6.5.2 Regulatory Guidance No regulatory guidance has been developed in this area.

6.5.3 Regulatory Review Criteria NRC staff should use the following regulatory review criteria, or information demonstrating acceptable alternatives,in its review of the SAR. Acceptability should be based on:

Draft NUREG-1671 6-2

l Technical Safety Requirements

1. Chapter 5," Hazard / Accident Analysis", of this SRP should determine the adequacy of the operational analysis that supports identification of safety actions which will envelope the safe operation of the analyzed facility or process.

2. Chapter 4," Facility and Process Description", of this SRP should determine the adequacy of the identification of the SSCs required to perform the safety actions identified from above and the adequacy of the description of their safety function.

3. The design safety features are considered adequate if they included all identified SSCs l which passively prevent or mitigate the consequences of evaluated accidents from I exceeding the offsite/ member of the public consequences of concern for highly unlikely events (see Appendix C," Proposed Consequences of Concems/ Thresholds").

4. The safety limits are considered adequate if they provide bounds for the process variables that have been identified from the hazard / accident analysis which must not be exceeded in order to prevent uncontrolled releases of radioactive material which could exceed the offsite/ member of the public consequences of concern for highly unlikely events (see Appendix C, " Proposed Consequences of Concems/ Thresholds").

5. The LCS are considered adequate if they correspond to the safety limits identified above and they provide settings for automatic alarms or protective devices such that there is adequate assurance that the safety limits are not challenged.

6. The LCOs are considered adequate if each identified LCO has an applicability i statement which properly identifies all the operating modes and hazard state combinations for which the safety action is required and an LCO has been identified for all essential actions from the accident analysis that meet one of the following criteria:

a. The item is an active SSC that prevents exceeding the offsite/ member of the public consequences of concem for unlikely and highly unlikely events (see Appendix C," Proposed Consequences of Concerns / Thresholds").

b. The item is a process variable or operating restriction that preserves an initial condition in an accident analysis for an unlikely of highly unlikely event which would otherwise exceed the offsite/ member of the public consequences of concem.

c. The item is an active SSC that prevents or mitigates an event that could result in onsite workers being exposed to radiation or hazard chemical levels that could result in death or serious injury, I

d. The item is a single contingent control to prevent an accidental nuclear criticality where the double contingency principle cannot be met.

e. The item is required by 10 CFR 76.89 to detect and alarm an accidental criticality.  ;

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I 6-3 Draft NUREG 1671 ,

l

Technical Safety Requirements

7. The SRs are considered adequate if they verify that the required control can perform its intended safety function. That is accomplished by appropriato calibration, testing, and inspections based on accepted industry standards and equipment history.

8. The administrative controls are considered adequate if they provide strong commitments to organization and management, procedures, record keeping, review and audit, safety programs, and reporting necessary to assure safe operation of the facility. As a minimum the following areas should be covered:

a. administrative controls need to define the onsite an offsite organization, the organization responsibilities for safe operation, qualifications and training for organization and minimum staffing levels. ,

1

b. a TSR commitment to conduct the required reviews, assessments, and audits that provide the adequate management controls.

c. a TSR commitment to adhere to the procedure control program for safety related procedures.

d. a TSR commitment to an plant operations review committee defining the role of the committee, membership, qualifications, meeting frequency, responsibilities, and record keeping requirements,

e. a TSR commitment to follow the operations, criticality safety, fire protection, radiation protection, chemical safety, radioactive waste, maintenance, environmental protection, packaging and transportation programs as they are described in the certification safety analysis.

9. Chapter 4," Facility and Process Description", of this SRP should determine the adequacy of the graded approach to quality applied to each TSR SSC and their required support systems.

6.6 Evaluation Findings

The applicant has adequately described and documented the Technical Safety Requirements and the staff finds that the applicant is in compliance with those parts of 976.36 relating to the Technical Safety Requirements. In addition, the applicant has [The reviewer will describe the bases for this conclusion, addressing areas that were reviewed and a discussion of how the acceptance criteria have been met. The reviewer should include a description of criteria used to identify the TSRs, and type of TSRs, referencing appropriate sections of the application. The reviewer should also describe the applicant's approach to ensuring the availability and reliability of the controls identified by the TSRs.]

6.7 Reference Draft NUREG-1671 6-4 O

, Technical Safety Requirements U.S. Code of Federal Regulations, Title 10, Part 76," Certification of Gaseous Diffusion Plants."

8.8 Definitions

1. Safety limit (SL) - Those bounds within which the process variables must be maintained for adequate control of the operation and that must not be exceeded in order to protect the integrity of the physical system that is designed to guard against the uncontrolled release of radioactivity.

2. Limiting control setting (LCS) - A setting for an automatic alarm or protective device related to a variable having a significant safety functions such that a safety limit should not be exceeded.

3. Limiting conditions for operation (LCO) - The lowest funct!onal capability or performance levels of systems, structures, and components, and their support systems required for normal safe operation of the plant.

4. Design features (DF) - Those features (generally passive) of the facility such as material of -

construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety.

O 5. Surveillance requirements (SR) - Requirements relating to test, calibration, or inspection to assure that the necessary quality of systems, structures, and components is maintained.

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6-5 Draft NUREG-1671

q 7.0 RADIATION SAFETY i

7.1 Responsibility for Review

7.1.1 Primary

Health Physicist

7.1.2 Secondary

Certification Project Manager

7.1.3 Supporting

Region lliinspector 7.2' ' Purpose of Review- l

, I The purpose of this review is to determine that the applicant commits to implementing a i radiation protection program that is adequate to protect against intakes of soluble uranium and i

- the radiological health and safety of the occupational workers and to comply with the regulatory .j

. requirements imposed by the Commission in 10 CFR Parts 19,20 and 76. j 7.3 Areas of Review The radiation protection program is reviewed to provide assurance that the applicant has and will maintain an adequate radiation protection program that will meet the requirements of 10  ;

~ CFR Parts 19,20 and 76. The areas of review are as follows ,

7.3.1 ALARA Policy )

This section discusses the policy and procedures that are used to ensure that occupational radiological exposures are maintained ALARA. The applicant should  ;

describe the program policy and procedures that are used to ensure that occupational  !

radiological exposures are maintained ALARA and include: (a) the organization structure l and how units interact to maintain ALARA; (b) how intomal audits and assessments are structured and performed; and (c) how trend analysis is conducted to examine the j historical pattoms of exposures, activity concentrations, contamination levels,  ;

instrumentation performance, respiratory protection equipment performance, effluent filter performance, and worker performance.

7.3.2 Organizational Relationships and Personnel Qualifications This section discusses the organization of the radiological and uranium exposure protection program.and qualification requirements for the radiological protection personnel. The application should state that the General Manager, or equivalent, has

. overall responsibility and authority for safety; the Radiation Safety Manager, or equivalent, has direct access to the General Manager; the radiation safety specialist (s) is responsible for specific uranium exposure prevention and radiation safety activities; and the radiation safety technicians implement these functions.

7.3.3 Radiation Safety Procedures and Radiation Work Permits (RWPs) 7-1 Draft NUREG-1671

Radiation Safety This section discusses the use of approved written radiation safety procedures and RWPs for activities related to uranium exposure prevention and radiological safety. The applicant should describe written, approved radiation safety procedures and RWPs to carry out uranium exposure prevention and radiation safety activities. The application should describe how the need for such procedures is identified and how the procedures are created, approved, controlled, revised, and made avaliable to the worker.

7.3.4 Training This section discusses the applicant's uranium exposure prevention and radiological safety training for ali personnel who have authorized access to a restricted area. The applicant should describe a training program in which personnel and visitors entering restricted areas receive training in uranium exposure prevention and radiation safety or are escorted by a trained individual. Refresher training content and schedule should be described. The effectiveness of the training should be evaluated by written test or other methods. Further aspects of training are covered in Chapter 2.3 of this SRP.

7.3.5 Ventilation Systems -

This section discusses the design and operation of the ventilation systems. The applicant should commit to operating the ventilation systems in a manner that protects operating personnel and the public from airborne soluble uranium and other radioactive material. The applicant should describe minimum flow velocity at hood openings, the types of filters and the maximum differential pressure across filters, and the frequency and types of tests required to measure ventilation system performance.

7.3.6 Air Sampling This section discusses the requirements for radiological air sampling. The applicant should describe the air sampling objectives and procedures, including: (a) the frequency and methods of analysis of soluble uranium and other radionuclide airbome concentrations and total radioactivity levels for each area, (b) the sampling methods and frequency,(c) the counting techniques, (d) the lower limits of detection for specific radionuclides including soluble uranium, (e) the specific calculations for concentrations and levels, (f) the action levels and investigation levels, and (g) the location of continuous air monitors (CAMS), if used, and annunciators and alarms associated with CAMS.

7.3.7 Contamination Control This section discusses the requirements for control of radiological contamination within the facility. The applicant should describe a contamination survey program that includes the types and frequencies of surveys, limits for contamination levels, and methods and instruments used in the surveys. In addition, the applicant should describe the design features of the facility that control access and should specify: (a) the types and availability of contamination monitoring equipment; (b) the specife limits established for Draft NUREG-1671 7-2 O

I Radiation Safety j personnel contamination; (c) the minimum provisions for personnel decontamination; (d) the minimum types of protective clothing necessary for individuals to enter restricted areas; (e) the technical criteria and levels for defining contamination areas, and (f) the frequency of periodic reviews of all aspects of access control should be specified.

7.3.8 External Exposure i

This section discusses the applicant's program for monitoring personnel extemal  ;

radiation exposure. The applicant should describe a personnel monitoring program for external radiation that provides a means to measure, assess, and record personnel exposure to radiation. The type, range, sensitivity, accuracy, and frequency for reading  ;

personnel dosimeters and recording the radiation dose of the dosimeter reading should be stated and the applicant should test its dosimeters by participating in, the National Voluntary Laboratory Accreditation Program.

7.3.9 internal Exposure This section discusses the applicant's program for monitoring personnel intemal radiation and soluble uranium's toxic chemical exposures. The applicant should describe a program for monitoring worker internal exposures in which the following are specified: (a) the frequency of analysis, (b) the sensitivity and minimum detection levels, (c) the criteria for participation, and (d) the action levels and actions to be take on the results in addition, the applicant should specify: (a) the criteria for determining s when it is necessary to monitor an individual's internal exposure during work hours and (b) the methods for determining the worker intake from (l) the concentrations of radioactive materials in the work area air, (ii) the quantities of radionuclides in the body, (iii) the quantitles of radionuclides excreted from the body, or (iv) any combination of the above methods as may be necessary for determining the intake.

7.3.10 Summing internal and External Exposure This section discusses the applicant's program for summing internal and external radiological exposures in order to demonstrate compliance with the dose limits. The applicant should describe a policy for combining intemal and external radiological exposures in accordance with NRC Regulatory Guides 8.7, Rev 1. */nstructions for Recording and Reporting Occupational Radiation Exposure Data"; 8.34, ' Monitoring Criteria and Methods to Calculate Occupational Radiation Doses) and 8.36, " Radiation Dose to the Embryc/ Fetus."

7.3.11 Respiratory Protection This section discusses the applicant's respiratory protection program used for protecting workers from potential inhalation exposures to soluble uranium and other radionuclides.

The Lpplicant should describe a respiratory protection program that meets the requirements of 10 CFR Part 20 and states the equipment to be used, the conditions under which respiratory protection will be required for routine and nonroutine operations, 7-3 Draft NUREG-1671

Radiation Safety the protection factors that will be applied when respirators are being used, and the locations of respiratory equipment within the plant.

7.3.12 Instrumentation This section discusses the requirements for radiological measurement instrumentation.

The applicant should describe a policy for the maintenance and use of operating instrumentation in sufficient number and types to meet the requirements specified in 10 CFR Part 20. The applicant should provide a listing of the types of instruments that are available, including ranges, counting mode, sensitivity, alarm setpoints, planned use, and frequency of calibration. The applicant should commit to calibrate instruments at least annually, preferable semiannually, and recalibrate instruments after adjustments or repairs.

7.4 Review Procedures 7.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and i 10 CFR 76.36, " Annual renewals" with respect to the radiation protection programs for GDP facilities, have been included arid that the topics discussed in Section 7.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

7.4.1.1 ALARA The reviewer will determine that the application describes the program policy and procedures that are used to maintain occupational radiological exposures ALARA and includes: (a) the organization structure and how units interact to maintain ALARA, (b) how internal audits and assessments are structured and performed, and (c) how trend analysis is used.

7.4.1.2 Organizational Relationships and Personnel Qualifications The reviewer will determine that the application describes: (a) the administrative organization of the radiation protection program, including the authority and responsibility of each position identified; (b) the organizational relationships that are to exist between the individual position responsible for the radiation protection program and other line managers; (c) the authority of the Radiation Safety Manager, Radiation Safety Officer, or equivalent, to ensure that he/she is able to carry out his/her assigned responsibilities, as defined in the radiation protection program, and l (d) the education and experience criteria for the key radiation protection personnel. I Draft NUREG-1671 7-4 O.l l

Radiation Safety 7.4.1.3 Radiation Safety Procedures and RWP The reviewer will determine that the application commits to using written, approved radiation safety procedures or RWPs to carry out activities related to the radiation safety program and that the procedures and RWPs are reviewed, revised, and updated periodically.

7.4.1.4 Training -

The reviewer will determine that the application contains a training program, for all l personnel who have access to a restricted area, that is commensurate with the potential soluble uranium and radiological health protection problems in the restricted area. The effectiveness of the training program should be evaluated by written tests or other methods and the frequency of refresher training should not exceed a period

' of 2 years.

7.4.1.5 Ventilation Systems l

The reviewer will determine that the application commits to operating the ventilation systems in a manner that protects operating personnel and the public from airt>ome soluble uranium and other radioactive material. . Criteria for the ventilation systems should include minimum flow velocity at the hood openings, the types of filters and the maximum differential pressure across filters, and the frequency and types of tests required to measure ventilation system performance.

7.4.1.6 Air Sampling The reviewer will determine that the application describes the air sampling objectives and procedures and includes: (a) the frequency and methods of analysis of airbome  :

concentrations of soluble uranium and total radioactMty levels for each area; (b) the '

counting techniques; (c) the lower limits of detection for uranium and other specific radionuclides; (d) the specific calculations for concentrations and levels; (e) the action levels and investigation levels; and (f) the location of CAMS, if used, and annunciators and alarms associated with CAMS.

7.4.1.7 Contamination Control The reviewer will determine that the application commits to establishing a contamination survey promam that includes the types and frequencies of surveys, limits for contamination levels, and methods and instruments used in the surveys. In addition, the applicant should describe the design features of the facility that control contamination and should specify: (a) the types and availability of contamination monitoring equipment; (b) the specific limits established for personnel contamination; (c)the minimum provisions for personnel decontamination; (d) the minimum types of protective clothing necessary for individuals to enter restricted areas; and (e) the technical criteria and levels for defining contamination areas. A periodic review of all 75 Draft NUREG-1671 i

Radiation Safety aspects of contamination control should be specified.

7.4.1.8 External Exposure The reviewer will determine that the application commits to a personnel monitoring program, for external radiation, that provides a means to measure, assess, and record personnel exposure to radiation. The type, range, sensitivity, accuracy, and 4 frequency for reading personnel dosimeters and recording the radiation dose of the dosimeter reading should be stated. The applicant should test its dosimeters by participating in, or have plans to participate in, the National Voluntary Laboratory Accreditation Program.

7.4.1.9 Internal Exposure The reviewer will determine that the application commits to a program for monitoring worker internal exposures in which the following are specified to adequately demonstrate compliance with the 10 milligram per week soluble uranium intake limit and the radiological dose limits: (a) the frequency of analysis; (b) the sensitivity and minimum detection levels;(c) the criteria for participation; and (d) the action levels and actions to be taken on the results. In addition, the applicant should specify: (a) the criteria for determining when it is necessary to monitor an individual's internal exposure during work hours; and (b) the methods for determining the worker intake from (1) the concentrations of radioactive materials in the work area air, (ii) the quantities of radionuclides in the body, (iii) the quantities of radionuclides excreted from the body, or (iv) any combination of the above methods, as may be necessary for determining the intake.

7.4.1.10 Summing Internal and External Radiological Exposure The reviewer will determine that the application commits to a program for summing intemal and external radiological exposures, to demonstrate compliance with the radiological dose limits. The applicant should commit to a policy for combining intemal and extemal radiological exposures in accordance with Regulatory Guides 8.7, Rev.1, ' Instructions for Recording and Reporting Occupational Radiation Exposure Data) 8.34, ' Monitoring Criteria and Methods to Calculate Occupational Radiation Doses) and 8.36, ' Radiation Dose to the Embryo / Fetus'.

7.4.1.11 Respiratory Protection The reviewer will determine that the application commits to establishing a respiratory protection program which meets the requirements of 10 CFR 20 and states the equipment to be used, the conditions under which respiratory protection will be required for routine and nonroutine operations, the protection factors that will be applied when respirators are being used, and the locations of respiratory equipment within the plant.

Draft NUREG-1671 7-6

Radiation Safety 7.4.1.12 instrumentation The reviewer will determine that the application commits to a policy for the maintenance and use of operating instrumentation in sufficient number and types to meet the requirements specified in 10 CFR 20. The applicant should provide a list-ing of the types of instruments that are available, including ranges, counting mode, sensitivity, alarm setpoints, planned use, and frequency of calibration. The applicant should commit to calibrate instruments at least annually, preferably semiannually, and recalibrate instruments after adjustments or repairs.

7.5 Acceptance Criteria 7.5.1 ALARA(As Low As is Reasonably Achievable) Policy 7.5.1.1 Regulatory Requirements Regulations applicable to the ALARA program are the following from Title 10, CFR:

1. Section 19.12 " Instructions to workers"

2. Section 20.1101 " Radiation protection programs" g

3. Section 20.2102 " Records of radiation protection programs"

4. Section 20.2110 " Form of records"

5. Part 76 " Certification of Gaseous Diffusion Plants" 7.5.1.2 Regulatory Guidance NRC regulatory guides and American national Standards institute (ANSI) standards applicable to the ALARA program that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 19.12,20.1101, and 20.2102 are:

1. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation Monitoring

2. Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Rev.1-R Radiation Exposures As Low As is Reasonably Achievable'

3. Regulatory Guide 8.13, Rev. 2 Instructions Concoming Prenatal Radiation Exposure

4. Regulatory Guide 8.24, Rev.1 Health Physics Surveys During Enriched Uranium-235 Processing and FuelFabrication 7-7 Draft NUREG-1671

Radiation Safety

5. Regulatory Guide 8.29 Instructions Conceming Risks from Occupational Radiation Fxposure

6. ANSI N13.2-1969 Guide for Administrative Practices in Radiation Monitoring 7.5.1.3 Regulatory Acceptance Criteria The reviewer shall determine that the applicant commits to an ALARA program. The ALARA program should be evidenced and documented by an organizational structure in which radiation protection personnel interact, in a timely manner, with production personnel to ensure that methods and techniques for reducing occupational radiation exposure are incorporated in facility operation. {

An ALARA committee, or other similar safety committee, should be composed of managers from radiation protection, environmental, safety, and production. The committee's membership should be documented aryd its scope should be to review the radiation safety program at least annually.

The review should include the results of audits and self-assessments made by the radiation protection organization and reports of radiation levels, contamination levels, employee exposures, waste management, and effluent releases. The review should determine:

1. If there are any upward trends toward increased personnel exposure developing in identified categories of workers, types of operations, or effluent releases.

2. If exposures and releases are being lowered or maintained in accordance with the ALARA concept.

3. If equipment for effluent and exposure controls is being properly used, maintained, and inspected.

Trend analysis should be performed in such areas as the following:

1. Radiation exposures of plant workers and members of the public.

2. Concentrations of airborne radioactivity in plant areas and effluents.

3. Radioactive contamination in plant areas and on equipment.

4. Operation of radiation measurement instrumentation.

5. Operation of respiratory protection equipment.

l

6. Operation of effluent filtration systems'.

7.5.2 Organizational Relationships and Personnel Qualifications Draft NUREG-1671 7-8 1

1 Radiation Safety

. 7.5.2.1 Regulatory Requirements Regulations applicable to the radiation protection program organization are the following from Title 10, CFR:

1. Section 20.1101 " Radiation protection programs"

2. Part 76 " Certification of Gaseous Diffusion Plants" Section 20.1101(b) requires that the applicant use, to the extent practicable, procedure and engineering controls based upon sound radiation protection principles, to achieve occupational doses and doses to members of the public that are Al_ ARA.

7.5.2.2 Regulatory Guidance NRC regulatory guides and ANSI standards applicable to organizational relationships and personnel qualifications that in general describe a basis acceptable to the staff for implementing the radiation protection program requirements of 10 CFR Part 76 are:

1. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation Monitoring

2. Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Rev.1-R Radiation Exposures As Low As is Reasonably Achievable

3. ANSI N13.3-1969 Monitoring Guide for Administrative Practices in Radiation 7.5.2.3 Regulatory Acceptance Criteria The reviewer shall determine that the applicant commits to an organization in which the administrative organization of the radiation safety program is identified and includes the authority and responsibility of each position identified. In addition, the applicant should describe the organizational relationships that are to exist between the individual positions responsible for the radiation safety program and other line managers. The General Manager, or equivalent, shall have overall responsibility and authority for safety. The Radiation Safety Manager, or equivalent, may be delegated direct responsibility for establishing and implementing the radiation protection program and shall have direct access to the General Manager. ' Radiation safety specialist (s) shall be responsible for specific activities assigned to the radiation and soluble uranium safety function with radiation safety technicians implementing these functions.

Certain radiation safety technical support and/or audit activities may be supplied by qualified off-site corporate or consultant organizations.

7.5.3 Radiation Safety Procedures and Radiation Work Permits (RWPs)

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7-9 Draft NUREG-1671

Radiation Safety 7.5.3.1 Regulatory Requirements The regulations applicable to approved operating procedures and RWPs are the following from Title 10, CFR:

1. Section 20.2110 " Form of records"

2. Section 76.36 " Annual renewals"

3. Section 76.60 " Regulatory requirements which apply" 7.5.3.2 Regulatory Guidance NRC regulatory guide applicable to radiation safety procedures that in general describe a basis acceptable to the staff for implementing the radiation protection program requirements of 10 CFR Part 2.2110 is:

1. Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Rev.1-R Radiation Exposures As Low As Is Reasonably Achievable 7.5.3.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant commits to using written, approved radiation safety procedures and RWPs to carry out activities related to the radiation safety program and that the procedures and RWPs are reviewed, revised, and updated periodically. A mechanism for providing a current copy of the procedures to personnel should be established. Procedures should be reviewed and approved by the Radiation Safety Manager, and no longer than every 2 years the Radiation Safety Manager, or an individual who has the qualifications of the Radiation Safety Manager, should revise and update the procedures as necessary.

The applicant should make a commitment to use special reviews and approvals before ,

conducting an activity involving radioactive materials that is not covered by a written radiation safety procedure. The applicant should specify how the determination is made to use an RWP, the positions within the organization authorized to approve and issue an RWP, the types of information that should be included in an RWP, the provisions for updating and terminating an RWP, and the records to be kept for the RWPs. The applicant should specify the levels of approval necessary for an RWP before it can become effective and that the RWP should be approved and signed by a supervisor or specialist in radiation protection. Approvals should also be required from other involved groups to ensure that the provisions of the RWP cover all potential hazards and that the operations will be conducted according to proper standards.

The applicant should commit to using RWPs for specific purposes only. RWPs will be reissued when significant changes in the task or changes that affect the safety of the worker are made.

The applicant should state that the RWP will include a list of the safety requirements for work conducted under the authorization and will include the following, as applicable: (1) the type and Draft NUREG-1671 7-10 O

p-Radiation Safety frequency of monitoring to be conducted; (2) the total time alicMed for the authorization; (3) special shielding or ventilation to be used; (4) personal protective equipment; (5) work limitations; (6) radiological and soluble uranium conditions; and (7) special instructions.

The applicant should commit to a system that ensures that RWPs are not used past their termination dates. The system should include what types of records are to be kept, the retention times for these records, and the final disposition of the RWP. The record system should be sufficient to allow independent auditors to reconstruct the circumstances necessitating the RWP, the factors included, and the results.

7.5.4 Training -

7.5.4~1 Regulatory Requirements ,

Regulations applicable to the radiological training program are the following from Title 10, CFR:

1. Section 19.12 ' Instructions to workers"

2. Section 20.2110 ' Form of records"

3. Section 76.95 " Training" 7.5.4.2- Regulatory Guidance The following NRC regulatory guides and ANSI and American Society for Testing and Materials (ASTM) standards provide information, recommendations and guidance, and, in general, describe a basis acceptable to the staff for implementing the requirements of 10 CFR 19.12, 20.2110, and 76.95.

1. Regulatory Guide 8.10, ' Operating Philosophy for Maintaining Occupational 1

Rev.1-R Radiation Exposures As Low As Is Reasonably Achievable' L 2. Regulatory Guide 8.13, Rev. 2 " Instructions Concoming Prenatal Radiation Exposure' 1 3. Regulatory Guide 8.29 ' Instructions Concoming Risks from Occupational 1 Radiation Exposure *

4. ANSI NOA-1-1986 ' Quality Assurance Program Requirements for Nuclear Facilities"

5. ASTM C986-89 " Developing Training Programs in the Nuclear Fuel Cycle"

6. ' ASTM E1168-87 ' Radiological Protection Training for Nuclear Facility 7-11 Draft NUREG-1671 ,

i

Radiation Safety Workers" 7.5.4.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant cornmits to a training program such that all personnel and visitors entering restricted areas should either receive training in soluble uranium and radiation protection or will be escorted by an individual who has received such training.

The technical content of the training program should be commensurate with the potential soluble uranium and radiological health protection problems in the restricted area and should meet the requirements of 10 CFR Parts 19 and 20. The training should cover the following areas, as appropriate, in sufficient depth for the specific types of functions: (1) access and egress controls and escort procedures; (2) soluble uranium and radiation safety principles, policies, and procedures; (3) interr ' and extemal exposures of uranium and other radionuclides; (4) personnel dosims. ars; (5) monitoring instruments and protective devices; (6) contamination control, including protective clothing and equipment; (7) radiation area and airbome radioactive area; (8) use, storage, and transfer of radioactive rnaterials; (9) posting and labeling requirements; (10) ALARA and exposure limits; (11) soluble uranium and radiation hazards and health risks; and (12) emergency response requirements for individuals.

Refresher training should be completed not later than 2 years following the most recent training and should consist of a condensed version of the initial training, with emphasis on changes in policies, procedures, requirements, and facilities. The effectiveness of the training program should be evaluated by written tests or other methodologies and should include evaluation of the curriculum and the instructor's qualifications.

7.5.5 Ventilation Systems 7.5.5.1 Regulatory Requirements Regulations applicable to the regulatory requirements for the ventilation system are the following from Title 10, CFR:

1. Section 20.1701 *Use of process or other engineering controls"

2. Section 20.2110 " Form of records"

3. Part 76 ~ Certification of Gaseous Ditfusion Plants" 7.5.5.2 Regulatory Guidance NRC regulatory guides, ANSI standards, and National Council on Radiation Protection and Measurements (NCRP) report applicable to the regulatory requirements related to the ventilation system that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1701 and 20.2110 are:

1. Regulatory Guide 8.24, Rev.1 ' Health Physics Surveys during Enriched Draft NUREG-1671 7-12 O

l

Radiation Safety Uranium-235 Processing and Fuel Fabrication"

2. Regulatory Guide 3.12 " General Design guide for ventilation Systems of y Plutonium Processing and Fuel Fabrication Plants" i

3. ANSI N510-1900 " Testing of Nuclear Air Cleaning Systems"

r. ANSI NOA-1-1986 " Quality Assurance Program Requirements for Nuclear Facilities"

)

5. NCRP Report No. 59 " Operational Radiation Safety Program" 7.5.5.3 Regulatory Acceptance Criteria The reviewer should determir,e that the applicant commits to a policy for designing and I operating the ventilation systems in the facility in a manner that protects operating personnel and the public from airborne soluble uranium and other radioactive materials and on assures that the limits of 10 CFR Part 20 are not exceeded during normal operations. The applicant should specify criteria for the ventilation systems, including minimum flow velocity at openings of hoods, maximum differential pressure across filters, and types of filters to be used, where applicable. In addition, the applicant should specify the frequency and types of tests required to measure ventilation system performance, the acceptance criteria, and the actions to be taken O when the acceptance criteria are not satisfied. The applicant should also describe the maintenance, QA, fire safety, and chemical safety activitias associated with these ventilation systems' structures, systems, and components that are identified as important to safety.

Airflow patterns should generally be from areas of lesser contarAation potential to areas of greater contamination potential. Engineering controls should be utM to limit the intake of soluble uranium and other radioactive materials, including portable filtration systems used to control airborne contaminants and containment structures to protect personnel working in adjacent areas, when feasible.

7.5.6 Air Sampling 7.5.6.1 Regulatory Requirements NRC regulations applicable to the air sampling / monitoring program are the following from Title 10, CFR:

1. Section 20.1204 " Determination of intemal exposure"

2. Section 20.1703 "Use of Individual respiratory protection equipment"

3. Section 20.2103 " Records of surveys"

4. Section 20.2110 " Form of records" 7-13 Draft NUREG-1671 1

1.

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Radiation Safety

5. Section 20.2203(a)(3)(I) " Reports of exposures, radiation levels, and and (ii), (b), and (d) concentrations of radioactive material exceeding the limits" 7.5.6.2 Regulatory Guidance NRC regulatory guides, and NUREG, and ANSI standards applicable to the air sampling / monitoring program that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1204,20.1703,20.2103,20.2110, and 20.2203 are:

1. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation Monitoring

2. Regulatory Guide 8.24, Rev.1 Health Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication

3. Regulatory Guide 8.25, Rev.1 Air Sampling in the Workplace

4. NUREG-1400 Air Sampling in the Workplace

5. ANSI N13.1-1969 Guide to Sampling Airbome Radioactive Materials in Nuclear Facilities

6. ANSI N13.2-1969 Guide for Administrative Practices in Radiation Monitoring 7.5.6.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant commits to providing representative air sampling for areas in which a potential exists for airborne radioactive materials. Air sampling data should be provided that demonstrates that soluble uranium and other radionuclide exposures do not exceed established limits and that radiation exposures are maintained ALARA.

The applicant should provide for each work area a determination that the frequency for analyzing the airborne level of soluble uranium and other radionuclides, the counting techniques, and the method for determining the airborne concentration are adequate. The {

calibration methods and frequencies that ensure proper operation of the instrumentation and l the calculations of airborne concentrations, in various areas, to obtain the airborne levels, j should also be described. The application should contain a description of action levels, alarm setpoints, frequency of measurements, and action to be taken when airbome levels are exceeded. In those facilities where CAMS are used, the location of the CAMS and the readouts, annunciators, and alarms should be described.

The applicant should demonstrate that the action levels, investigation levels, and derived air i

Draft NUREG-1671 7-14 l

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Radiation Safety concentrations (DACs), including soluble uranium's toxicological DAC, used are based on appropriate technical criteria to evaluate air sampling and monitoring results and determine necessary control procedures. The minimum detectable activities (MDAs) for tne specific radionuclides of interest should be provided. The detection levels should provide optimum

- worker protection and should be appropriate for established actions levels, investigation levels, and DACs.

7.'5.7 Contamination Control 7.5.7.1 Regulatory Requirements NRC regulations applicable to the contamination control program are the following from Title 10, CFR:

1. Section 20.1501(a)(2)(ii) " Surveys and Monitoring-General"

2. Section 20.1703(a)(3)(ii) "Use of individual respiratory protection equipment"

3. Section 20.1901 " Caution signs"

4. Section 20.1902(e) " Posting requirements" l

lh

! d

5. Section 20.1904 " Labeling containers" l- 6. Section 20.1906 " Procedures for receiving and opening packages"

7. Section 20.2103 " Records of surveys"

8. Section 20.2110 " Form of records"

9. Section 20.2203(a)(3)(1) " Reports of exposures, radiation levels, and and (ii), (b), and (d) concentrations of radioactive material exceeding the limits" l

10. Part 76 Certification of Gaseous Diffusion Plants" 7.5.7.2 Regulatory Guidance NRC regulatory guides, NRC Branch Technical Positions, and ANSI standards applicable to the contamination control program that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1501,20.1703,20.1901,20.1904,20.1906, 20.2103, and 20.2110 are:

1. Regulatory Guide 8.1 Radiation Symbol  !

l

2. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation 7-15 Draft NUREG-1671 3

Radiation Safety Monitoring

3. Regulatory Guide 8.24, Rev.1 Health Physics Surveys During Enriched Uranium-235 Processing and FuelFabrication

4. ANSI N2.1-1989 Radiation Symbol

5. ANSI N13.2-1969 Guide for Administrative Practices in Radiation Monitoring

6. ANSI N512-1974 Protective Coatings (Paints) for the Nuclear Industry

7. ANSt N542-1977 Sealed Radioactive Sources Classification

8. NRC Branch Technical Position License Condition for Leak Testing Sealed Byproduct MaterialSources, April 1993

9. NRC Branch Technical Position License Condition for Leak Testing Sealed Plutonium Sources, April 1993

10. NRC Branch Technical Position License Condition for Plutonium Alpha Sources, April 1993

11. NRC Branch Technical Position License Condition for Leak Testing Sealed Source Which Contains Alpha and/or Beta-Gamma Emitters, April 1993

12. NRC Branch Technical Position License Condition for Leak Testing Sealed Uranium Sources, April 1993

13. NRC Branch Technical Position Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material, April 1993 7.5.7.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant commits to establishing a contamination survey program, based on the specifications in Regulatory Guide 8.24, that includes the types and frequencies of surveys, limits for contamination levels, and methods and instruments used in the surveys. Contamination surveys should be conducted routinely for the areas of the plant site where contamination is likely, and the methods and types of instruments used in the surveys should be adequate to allow accurate assessment of working conditions. Information should be stated about survey frequency for each area, the types of radiation, the criteria for contamination levels for both removable and fixed contamination and the action levels and actions (including the time frame for action initiation and completion) to be taken when the levels are exceeded. Instruments with sufficient sensitivity to measure contamination at or Draft NUREG-1671 7-16  !

I

Radiation Safety k

below the action level should be provided.

The . pplicant should describe the features of the facility that help control contamination including step-off pads, personal monitoring equipment at exits, and change rooms. The applicant should specify: (1) the types and availability of contamination monitoring equipment, (2) the specific limits established for personnel contamination, (3) the minimum provisions for personnel decontamination, (4) the minimum types of protective clothing necessary for individuals to enter restricted areas, and (5) the technical criteria and levels for defining contamination areas.

1 Sealed sources should be leak-tested on a regular basis in accordance with NRC's Branch Technical Positions: (1) " License Condition for Leak Testing Sealed Byproduct Material Sources," April 1993; (2) " License Condition for Leak Testing Sealed Plutonium Sources," April 1993; (3) " License Condition for Plutonium Alpha Sources," April 1993; (4) " License Condition j for Leak Testing Sealed Source Which Contains Alpha and/or Beta-Gamma Emitters," April 1993; and (5) " License Condition for Leak Testing Sealed Uranium Sources," April 1993. The applicant should establish acceptable contamination levels, test frequencies, and actions to be followed,if limits are exceeded.

The applicant should commit to a periodic review of all aspects of access control to determine j that: (1) signs, labels, and other access controls are properly posted and operative; (2) restricted areas established to prevent the spread of contamination are identified with appropriate signs; and (3) step-off pads, change facilities, protective clothing facilities, and personnel monitoring instruments are adequate. The reviews should be documented, along with any deficiencies, and the corrective actions taken. ,

Allowable limits (fixed and removable) and action levels for immediate cleanup or delayed 3 clesir)up should be specified for clean areas, intermediate areas (change rooms), and coelminated areas.

The radiological contamination levels of items (e.g., tools, equipment, material, premises, or '

scrap) given clearance for release for unrestricted use should be in accordance with NRC's Branch Technical Position, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993.

A system should be established to ensure that equipment and materials removed from contaminated areas are not contaminated above specified release levels. Maxinam permissible personnel contamination levels (skin and clothing) should be established. Detected i

contamination in excess of these levels should be investigated and documented as to source, probable cause, and other pertinent information. Records of these investigations should be maintained and reviewed by radiation protection management for trends and corrective action taken, as necessary.

, The policy on the use of personnel monitoring equipment should be stated. Personnel should l

perform a whole body survey each time they leave known contaminated areas, or a minimum of a hand and shoe survey each time they leave restricted areas that are potentially contaminated.

7-17 Draft NUREG-1671 l

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Radiation Safety 7.5.8 External Exposure 7.5.8.1 Regulatory Requirements NRC regulations applicable to the measurind, documenting, and maintaining the external exposure of personnel below the applicable external exposure limits are the following from Title 10, CFR:

1. Section 19.13 " Notifications and reports to individuals"

2. Section 20.1201{a)(2) and(c) " Occupational dose limits for adults"

3. Section 20.1501(a)(2)(l) " Surveys and Monitoring-General" and(c)

4. Section 20.1502(a) " Conditions requiring individual monitoring of extemal andintemaloccupationaldose"

5. Section 20.1601 " Control of access to high radiation areas"

6. Section 20.1901 " Caution signs"

7. Section 20.1902(a) " Posting requirements"

8. Section 20.1906 " Procedures for receiving and opening packages"

9. Section 20.2101 " Records-GeneralProvisions"

10. Section 20.2103 " Records of surveys"

11. Section 20.2106 " Records ofindividual monitoring results"

12. Section 20.2110 " Form of records"

13. Section 20.2202(a), " Notification ofincidents" (b), (c), and (d)

14. Section 20.2203(a)(2), " Reports of exposures, radiation levels, and (a)(3)(l) and (ii), concentrations of radioactive material exceeding the (b), and (d) limits"

15. Section 20.2206 " Reports ofindividualmonitoring"

16. Part 76 " Domestic Licensing of Special Nuclear Material"

17. 10 CFR 20 " Radiation Dose Limits forIndividualMembers of the Draft NUREG-1671 7-18

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Radiation Safety Public" 7.5.8.2 Regulatory Guidance NRC regulatory guides and ANSI standards applicable to measuring, documenting, and maintaining the extemal exposure of personnel below the applicable extemal exposure limits that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1201,20.1501,20.1502,20.1901,20.1906,20.2103,20.2106,20.2110, and 20.2206 are:

1. Regulatory Guide 8.1 Radiation Symbol

2. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation

. Monitoring

3. Regulatory Guide 8.3 Film Badge Performance Criteria

4. Regulatory Guide 8.4 Direct-Reading and Indirec: Reading Pocket Dosimeters

5. Regulatory Guide 8.7, Rev.1 Instructions for Recording and Reporting l Occupational Radiation Exposure Data j l

6. Regulatory Guide 8.24, Rev.1 Health Physics Surveys During Enriched Uranium-235  ;

Processing and FuelFabrication 1

7. Regulatory Guide 8.34 Monitoring Criteria and Methods to Calculate OccupationalRadiation Doses

8. ANSI N2.1-1989 Radiation Symbol

9. ANSI N13.2-1969 Guide for Administrative Practices in Radiation Monitoring

10. ANSI N13.5-1972 Performance Specification for Direct Reading and Indirect Reading Pocket Dosimeters for X- and Gamma-Radiation

11. ANSI N13.6-1966 (R1972) Practice for Occupational Radiation Exposure Records Systems 12.' ANSI N13.7-1983 Radiation Protection-Photographic Film Dosimeters-Criteria for Performance

13. ANSI N13.11-1983 Dosimetry-Personnel Dosimetry Performance-Criteria for Testing 7-19 Draft NUREG-1671

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l Radiation Safety

14. ANSI N13.15-1985 Radiation Detectors-Personnel Thermoluminescence )

Dosimetry Systems-Performance l

15. ANSI N13.27-1981 Performance Requirements for Pocket-Sized Alarm Dosimeters and Alarm Ratemeters

16. ANSI N322-1977 Inspection and Test Specifications for Direct and Indirect Reading Quartz Fiber Pocket Dosimeters 7.5.8.3 Regulatory Acceptance Criteria The reviewer should determine that the applicant commits to a personnel monitoring program for external radiation, that provides a means to measure, assess, and record personnel exposure to radiation and commits to an ALARA philosophy. The types of monitoring equipment that will be used and the types of radiation that will be measured should be described. Regulatory Guide 8.34, " Monitoring Criteria and Methods to Calculate Occupational Radiation Doses", provides guidance for determining who is required to wear personnel monitoring dosimeters. The type, range, sensitivity, accuracy, and frequency for reading personnel dosimeters and recording the radiation dose of the dosimeter reading should be stated. In addition, the use of dosimetry results as a guide to operational planning and the specific exposure levels below the regulatory requirements at which action will be taken to reduce exposures should be specified. The applicant should participate in or have plans to participate in the National Voluntary Laboratory Accreditation Program (NAVLAP) to test its dosimeters.

7.5.9 Internal Exposure 7.5.9.1 Regulatory Requirements NRC regulations applicable to the measuring, documenting, and maintaining the internal exposure of personnel below the applicable intemal exposure limits are the following from Title 10,CFR:

1. Section 20.1201(d) and (e) " Occupational dose limits for adults"

2. Section 20.1204 " Determination ofintemal exposure"

3. Section 20.1502(b) " Conditions requiring individualmonitoring of extemal andintemaloccupationaldose"

4. Section 20.1703(a)(3)(ii) "Use ofindividualrespiratoryprotection equipment" and (b)

5. Section 20.1901 " Caution signs"

6. Section 20.1902(d) " Posting requirements" Draft NUREG-1671 7-20

Radiation Safety

7. Section 20.2101 " Records-GeneralProvisions"

8. Section 20.2103 " Records of surveys"

9. Section 20.2106 " Records ofindividual monitoring results"

10. Section 20.2110 " Form of records"

11. Section 20.2202(a), (b), " Notification ofincidents"

. (c), and (d)

12. Section 20.2203(a){2), " Reports of exposures, radiation levels, and .

(b), and (d) concentrations of radioactive material exceeding the limits"

13. Section 20.2206 " Reports ofIndividualmonitoring"

14. Part 76 " Certification of Gaseous Ditfusion Plants" l

15. Section 20, Subpart D " Radiation Dose Limits forIndividual Members of the Public" 7.5.9.2 Regulatory Guidance NRC regulatory guides, ANSI standards and NUREG document applicable to the measuring, documenting, and maintaining the extemal exposure of personnel below the npplicable intemal exposure limits that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1201,20.1204,20.1502,20.1703,20.1901,20.1902,20.2103, 20.2106,20.2110, and 20.2206 are:

1. Regulatory Guide 8.1 Radiation Symbol

2. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation Monitoring

3. Regulatory Guide 8.7, Rev.1 Instructions for Recording and Reporting OccupationalRadiation Exposure Data

4. Regulatory Guide 8.9, Rev.1 Acceptable Concepts, Models, Equations, and Assumptions fora Bioassay Program

5. Regulatory Guide 8.24, Rev.1 Health Physics Surveys During Enriched Uranium-235 Processing and FuelFabrication

6. Regulatory Guide 8.25 Air Samplingin the Workplace 7-21 Draft NUREG-1671

Radiation Safety

7. Regulatory Guide 8.34 Monitoring Criteria and Methods to Calculate OccupationalRadiation Doses

8. ANSI N2.1-1989 Radiation Symbol

9. ANSI N13.2-1969 Guide for Administrative Practices in Radiation Monitoring

10. ANSI N13.6-1966 (R1972) Practice for Occupational Radiation Exposure Records Systems

11. NUREG/CR-4884 Interpretation of Bioassay Measurements 7.5.9.3 Regulatory Acceptance Criteria The applicant's program for intemal exposure must meet the requirements of 10 CFR 20.1201, 20.1204, and 20.1502(b). Regulatory Guides 8.25, ' Air Sampling in the Workplace' 8.34,

' Monitoring Criteria and Methods to Calculate Occupational Radiation Doses *, and 8.9, Rev.1,

' Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program"and NUREGICR-4884, " Interpretation of Bioassay Measurement' provide information, recommendations, and guidance and a basis acceptable to the staff for implementing the internal exposure program.

The reviewer should determine that the applicant has established a program for monitoring worker intemal exposures. The program should specify the methods to be used, the frequency of analysis, the sensitivity and minimum detection levels, the frequency of measurements, the criteria for participation, and the action levels and actions to be taken on the results. In addition, the program should specify: (1) the methods for determining if monitoring of worker internal exposure is needed; (2) the criteria for determining when it is necessary to monitor an individual's internal exposure during work hours; and (3) the methods for determining the worker intake from (a) the concentrations of soluble uranium and other radioactive materials in the work area air, (b) the quantities of soluble uranium and other radionuclides in the body,(c) the quantities of radionuclides excreted from the body, or (d) any combination of the above methods as may be necessary for determining the intake. The action levels for internal exposure levels should be established based on the clearance time of the radioactive material from the lung.

When air sampling measurement results are used for determining worker intake, the applicant should specify the frequency of sampling and data analysis, the minimum detection levels, and the action levels and actions to be taken on the results.

When bloassay results are used for determining worker intake, the applicant should specify the types of bloassay to be used, the frequency of data collection for each type of measurement, the minimum detection levels, and the action levels and actions to be taken on the results.

7.5.10 Summing internal and External Radiological Exposure Draft NUREG-1671 7-22 O

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). Radiation Safety 7.5.10.1 Regulatory Requirements NRC regulations applicable to summing internal and extemal exposures are the following from title 10, CFR:

1. Section 20.1201(a)(1) " Occupational dose limits for adults" and (f)

2. Section 20.1202 " Compliance with requirements for summation of extemalandintemaldoses"

3. Section 20.1207 " Occupational dose limits for minors"

4. Section 20.1208 " Dose to an embryoietus"

5. Section 20.2101

" Records-GeneralProvisions" .

6. Section 20.2103 " Records of surveys"

7. Section 20.2104 " Determination of prior occupational dose"

8. Section 20.2106 " Records ofindividualmonitoring results" N

9. Section 20.2110 " Form of records"

10. Section 20.2202(a), (b), " Notification ofincidents" (c), and (d)

11. Section 20.2203(a)(2), " Reports of exposures, radiation levels, and (b), and (d) concentrations of radioactive material exceeding the limits"

12. Section 20.2206

• Reports ofindividualmonitoring"

13. Part 76 " Certification of Gaseous Ditfusion Plants"

14. Section 20, Subpart D " Radiation Dose Limits forIndividual Members of the Public" 7.5.10.2 Regulatory Guidance NRC regulatory guides and ANSI standard applicable to the summing of internal and extemal exposures that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1201,20.1202,20.1207,20.1208,20.2101,20.2106,20.2110, 20.2203, and 20.2206 are:

1 7-23 Draft NUREG-1671 1

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Radiation Safety

1. Regulatory Guide 8.2 Guide for Administrative Practice in Radiation Monitoring

2. Regulatory Guide 8.7, Rev.1 Instructions for Recording and Reporting Occupational Radiation Exposure Data

3. Regulatory Guide 8.34 Monitoring Criteria and Methods to Calculate OccupationalRadiation Doses

4. Regulatory Guide 8.36 Radiation Dose to the Embryc/ Fetus

5. ANSI N13.6-1966 (R1972) Practice for Occupational Radiation Exposure Records Systems 7.5.10.3 Regulatory Acceptance Criteria The radiological reviewer should determine that the applicant commits to a policy for combining Internal and external radiological exposures in accordance with Regulatory Guide 8.7, Rev.1,

" Instructions for Recording and Reporting Occupational Radiation Exposure Data) 8.34,

' Monitoring Criteria and Methods to Calculate Occupational Radiation Doses'; and 8.36,

' Radiation Dose to the EmbryalFetus".

7.5.11 Respiratory Protection 7.5.11.1 Regulatory Requirements NRC regulations applicable to respiratory protection are the following from Title 10, CFR:

1. Section 20.1701 "Use of process or other engineering controls"

2. Section 20.1702 "Use of other controls"

3. Section 20.1703(a), (c), "Use of individual respiratory protection equipment" and (d)

4. Section 20.2110 " Form of records"

5. Part 76 " Certification of Gaseous Diffusion Plants" 7.5.11.2 Regulatory Guidance The NRC regulatory guide and ANSI standards applicable to the respiratory protection program that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1702 and 20.1703 are:

1. Regulatory Guide 8.15 Acceptable Programs for Respiratory Protection Draft NUREG-1671 7-24 9

Radiation Safety

2. ANSI 238.2-1992 Practices for Respiratory Protection 7.5.11.3 Regulatory Acceptance Criteria The reviewer shall determine that the applicant commits to establishing a respiratory protection program that meets the requirements of 10 CFR Part 20. The program should identify the equipment to be used, the conditions under which respiratory protection will be required for routine and nonroutine operations, the protection factors that will be applied when respirators are being used, and the locations of respiratory equipment within the plant. ANSI 288.2, which defines responsibilities and requirements in the areas of (1) training, (2) control and use of respiratory equipment, (3) mask-fit testing, and (4) breathing-air purity, should be used as appropriate.

The applicant should describe: (1) the types of engineering and administrative controls that have been implemented to reduce the risk of internal exposure without the need for respiratory protection and (k) the methods for determining exposure while an individual is using respiratory protection to ensure that a proper estimate of exposure and intemal dose is made. Factors that are critical in this calculation include the time of exposure to airbome soluble uranium and other radioactive materials, the protection factor for the respirator, the proper fitting of the equipment before use, and the measurement of the concentrations of soluble uranium and other radioactive material during the exposure.

/ 7.5.12 Instrumentation 7.5.12.1 Regulatory Requirements NRC regulations applicable to the instrumentation program are the following from Title 10, CFR:

1. Section 20.1501(b) " Surveys and Monitoring-General"

2. Section 20.2103 " Records of survey" l l

3. Part 76 " Certification of Gaseous Diffusion Plants' 7.5.12.2 Regulatory Guidance NRC regulatory guides and ANSI standards applicable to the instrumentation program that in general describe a basis acceptable to the staff for implementing the requirements of 10 CFR 20.1501 and 20.2103 are:

1. Regulatory Guide 8.24, Health Physics Surveys during Enriched Uranium-235 Rev.1 Processing and FuelFabrication

2. ANSI N13.4-1971 Specification of Portable X- or Gamma-Radiation SurveyInstruments 7-25 Draft NUREG-1671

l Radiation Safety j

3. ANSI N42.12-1980 Calibration and Usage of Sodium lodide Detector Systems

4. ANSI N42.15-1980 Performance Verification of Liquid-Scintillation Counting Systems

5. ANSI N42.17A-1989 Performance Specifications for Health Physics Instrumentation-Portable Instrumentation for Use in NormalEnvironmental Conditions

6. ANSl N42.17B-1989 Performance Specifications for Health Physics Instrumentation-Occupational Airborne Radioactivity Monitoring Instrumentation

7. ANSI N323-1978 Radiation Protection Instrumentation Test and Calibration

8. ANSI N542-1977 Sealed Radioactive Sources, Classification l

7.5.12.3 Regulatory Acceptance Criteria The reviewer shall determine that the applicant commits to a policy for the maintenance and use of operating instruments in sufficient number and types to meet the requirements specified in 10 CFR Part 20. The applicant should provide a listing of the types of instruments that are available, including ranges, counting mode, sensitivity, alarm setpoints, planned use, and frequency of calibration. The applicant should commit to calibrate instruments at least annually, preferably semiannually, and should recalibrate instruments if the equipment is adjusted or repaired.

The applicant should justify the criteria for selecting radiation measurement instruments for:

(1) performing direct radiation and surface and volumetric contamination surveys, (2) sampling airborne soluble uranium and other radioactivity, (3) monitoring area radiation, (4) monitoring personnel, and (5) performing radioactive analyses.

The applicant should describe the instruments and related equipment and the quantities of such equipment provided for plant operations. The applicant should also describe the (1) instrument storage, calibration, and maintenance facilities; (2) the health physics (radiation safety) facilities; and (3) the laboratory facilities for radiological analyses. Instrumentation and instrumentation calibration should be consistent with ANSI N42.17A and ANSI N323, as appropriate. Instrument calibrations should be traceable to a recognized standard such as ,

National Institute of Standards and Technology (NIST). l

7.6 Evaluation Findings

The reviewer should write a CER addressing each topic reviewed and explaining why the NRC staff has reasonable assurance that the application is acceptable. Conditions may be Draft NUREG-1671 7-26 O

l Radiation Safety proposed to impose requirements where the application is deficient. The following kinds of i statements and conclusions should be included in the staff's CER:

The applicant has committed to a radiation safety program that includes: (1) an ALARA program to ensure that occupational radiological exposures are ALARA; (2) an organization with qualification requirements for the radiation safety personnel; (3) approved written radiation safety procedures or RWPs for soluble uranium and radiation safety activities; (4) soluble uranium and radiation safety training for all '

personnel who have access to restricted areas; (5) requirements for the ventilation systems; (6) requirements for soluble uranium and other radiological air sampling; (7) requirements for control of soluble uranium and other radiological contamination within the facility; (8) programs for monitoring personnel external and intemal exposure; (9) a respiratory protection program; and (10) requirements for soluble uranium and other radiological measurement instrumentation.

The NRC staff concludes that the applicant's radiation safety program is adequate and i that the applicant has the necessary technical staff to administer an effective radiation  ;

safety program. Conformance to the application and certificate conditions should l ensure safe operation and should provide early detection of unfavorable trends to allow prompt corrective action.

7.7 References -

U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffus'on Plants."

U.S. Nuclear Regulatory Commission, Branch Technical Position, " License Condition for Leak Testing Sealed Plutonium Sources," April 1993.

U.S. Nuclear Regulatory Commission, Branch Technical Position, " License Condition for Plutonium Alpha Sources," April 1993.

U.S. Nuclear Regulatory Commission, Branch Technical Position, " License Condition for Leak ,

Testing Sealed Source Which Contains Alpha and/or Beta-Gamma Emitters," April 1993. l U.S. Nuclear Regulatory Commission, Branch Technical Position, " License Condition for Leak Testing Sealed Uranium Sources," April 1993.

U.S. Nuclear Regulatory Commission, Branch Technical Position, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, So';rce, or Special Nuclear Material," April 1993.

U.S. Nuclear Regulatory Commission, Information Notice No. 92-34, 'New Exposure Limits for Airbome Uranium sad Thorium."

U.S. Nuclear Regulatory Commission, Information Notice No. 93-03, "Recent Revisions to 10 CFR Part 20 and Change of implementation Date to January 1,1994."

7-27 Draft NUREG-1671

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Radiation Safety U.S. Nuclear Regulatory Commission, Regulatory Guide 8.1, " Radiation Symbol."

U.S. Nuclear Regulatory Commission, Regulatory Guide 8.36, " Radiation Dose to the Embryo / Fetus."

U.S. Nuclear Regulatory Commission, Regulatory Guide 8.37, "ALARA Levels for Effluents from Materials Facilities."

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Draft NUREG-1671 7-28

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g 8.0 NUCLEAR CRITICALITY SAFETY 8.1 Responsibility for Review

8.1.1 Primary

Nuclear Process Engineer (Criticality)

8.1.2 Secondary

Certification Project Manager

8.1.3 Supporting

Health Physicist 8.2' Purpose of Review The purpose of this evaluation is to establish that there is reasonable assurance that the applicant has: (1) identified and assessed scenarios that could result in conditions leading to criticality; (2) established and implemented adequate nuclear criticality safety (NCS) limits and margins to prevent a criticality for those conditions; (3) performed suitable calculations which  ;

clearly support the NCS limits and margins; (4) established and implemented adequate controls to maintain operations within the established limits and margins; (5) established an acceptable organization with which to implement the NCS program; and (6) established appropriate management controls necessary to maintain NCS for structures, systems, and components (SSCs) relied on for nuclear criticality safety.

8.3 Areas of Review The following areas of the applicant's SAR are reviewed as they relate to the applicant's  !

proposed NCS limits, programs, and procedures.

8.3.1 Criticality Scenarios The following areas of the applicant's SAR related to the applicant's stated criticality scenario l are reviewed:

1. The specific criticality scenarios which were considered including initiating events.

2. The description of methods used to identify possible criticality scenarios such as process hazard analyses.

3. The criteria which was used to establish whether particular scenarios were or were not credible.

4. The description of the methods used to analyze the criticality scenarios.

5. If applicable, the justification that a criticality event is incredible for a portion of the facility during normal conditions, anticipated operational occurrences, and credible accidents.

8.3.2 NCS Limits and Margins The following areas of the applicant's SAR related to the applicant's proposed NCS limits and margins are reviewed:

O 8-1 Draft NUREG-1671

Nuoear Criticality Safety

1. The specific NCS limits and their associated safety margin including a determination of the basis for subcritical limits establishment, effects of system sensitivity, and systems .

interactions.

2. The description of the basis for selection of NCS limits and margins.

3. The description of the methods by which the NCS limits were determined, including pertinent codes, assumptions, and techniques used or to be used in the calculations. l

4. Information describing implementation of special protective features, as applicable, and information describing any additional margins of safety adopted for specific functions or activities.

8.3.3 Criticality Calculations The following areas of the applicant's SAR related to the applicant's analyses of proposed NCS limits and margins are reviewed:

1. The description of all calculations performed including physical and theoretical assumptions, computer inputs and results, and data such as cross-section data.

2. The description of calculational methods used including hand calculations, computer codes, and other approximations.

3. The description of the validation for all calculational methods used including code bias, bias uncertainty determination, and areas of applicability as a function of composition and other variables.

4. The description of the method of software control and periodic re-confirmation of the code's mathematical operations.

8.3.4 NCS Controls The following areas of the applicant's SAR related to the applicant's proposed NCS controls are reviewed:

1. The description of all NCS controls relied on to maintain operations within established limits.

2. Where applicable, the description of the method used to develop controls such as double contingency analyses.

3. Review of systems relied upon to implement controls including active hardware (e.g.,

electrical, mechanical, hydraulic, etc.), a determination of the fail-safe properties for these systems (i.e., failure of the control or system results in a safe shutdown condition),

and quality assurance requirements (calibration, testing, maintenance, etc.) associated with these systems.

4. The description of NCS control availability and reliability determinations and methods to ensure continued functionality.

8.3.5 NCS Organizational Responsibilities The following areas of the applicant's SAR related to the applicant's NCS organization are reviewed:

Draft NUREG-1671 8-2 O

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1. The administrative organization of the NCS program, including the authority and responsibility of each position identified, and the applicable activities carried on by the individuals in management having responsibility for NCS.

2. The experience, qualifications, training, and re-training of the personnel responsible for i NCS. The information can be included in this SAR chapter through reference to SAR Chapter 2.0.

3. Review of qualifications, experience, and organization is to be coordinated with the primary reviewer of Chapter 2.1, " Organizational Structure," who is a secondary reviewer for this chapter.

8.3.6 Management Controls for NCS The following areas of the applicant's SAR related to the operationallimits of the applicant's NCS program are reviewed:

1. Management policy with respect to operating the plant, and the planned organizational structure, as related to NCS.

2. Management control systems (e.g., CM, maintenance, QA, Procurement, TSRs, training, human factors, self-audits) to ensure that those controls relied upon for NCS, are adequately incorporated into the applicant's procedures, proposed compliance conditions, and operating limits.

3. The description of the management program established to monitor the overall l

) 4.

effectiveness and adequacy of the NCS program.

The integration and administrative aspects of the NCS program with respect to intemal support organizations such as training, design, and operations, and extemal interface with emergency response organizations.  ;

5. The applicant's compliance with criticality alarm system requirements, which should be l coordinated with the reviewer of Chapter 7," Radiation Safety." The reviewer of Chapter 7, " Radiation Safety," is a supporting reviewer for this chapter in that he or she evaluates information relative to the instrumentation itself such as sound pressure measurements and alarm visibility, and its spacing and maximum tolerable shielding. '

The priniary reviewer for NCS evaluates the adequacy of alarm trip point settings, potential accident locations, alarm coverage, and system operability /inoperability status.  ;

6. Review of the management control systems related to NCS should be coordinated with the primary reviewer (s) of Chapter 2, " Organization and Administration," who is a supporting reviewer for this chapter. The NCS reviewer evaluates limited information relevant to NCS (e.g., criticality control zoning), above those management controls which would otherwise be applied if NCS were not an issue. The primary reviewers of Chapters 2.1 through 2.8 verify that these NCS management controls are integrated into, and are consistent with, their review areas.

8.4 Review Procedures 8.4.1 Acceptance Review c

The staff review should start with the primary reviewer's determination that the contents of the 8-3 Draft NUREG-1671

Nuclear Criticality Safety application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to criticality safety for GDP facilities, have been included-

-see Section 8.5.1, " Regulatory Requirements," and that the topics discussed in Subsection 8.3,

" Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

8.4.2 Safety Evaluation The staff should perform a safety evaluation of the information presented in the application against the acceptance criteria presented in Section 8.5, below. Based on this safety evaluation, a request for additional information or modification of the submittal may be issued, for clarification or elaboration of the information submitted to address the acceptance criteria in Section 8.5 or to provide alternatives that demonstrate an equivalent level of safety to those acceptance criteria.

8.4.2.1 Incredible Scenarlos The primary reviewer should review all scenarios rejected as incredible to insure adequacy of the information related to each specific scenario. The primary reviewer should determine that conservative assumptions have been employed to characterize the scenario and that the conclusion is reasonable. The primary and supporting reviewer should then consider if there are any additional scenarios not identified or otherwise not adequately treated by the applicant, that could result in criticality.

8.4.2.2 Credible Scenarios Where Criticality Could Result For credible scenarios identified that result in the potential for criticality, the following review procedures should be employed.

1. Evaluation of Results The primary reviewer should determine if the models, variables, and processes identified in this section related to criticality are appropriate. This should be performed through a review of the scenarios presented in the application. Any additional margins of safety, or special controls, taken for specific functions or activities that are described, should be reviewed.

The primary reviewer should determine if any credible conditions exist that could result in effects that increase neutron multiplication such as heterogenous regions or moderation level (i.e., under-moderated, over-moderated, or optimum moderation), particularly in systems that concentrate or dilute waste, or involve chemical reactions. If a parameter affecting NCS is not explicitly controlled, then it should be conservatively evaluated at the most credible abnormal I conditions expected. Credit may be taken for the physical characteristics of the process, l material, or environment. The reviewer should also ensure that the analyses adequately l evaluate the effects of changes in controlled and uncontrolled parameters and in the conditions Draft NUREG-1671 8-4 O

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Nuclear Criticality Safety to which they apply.

The primary reviewer should ensure that the evaluation and results adequately considered systems interactions such that single-consequence accidents appropriately consider the effects of other associated hazards which may amplify the significance or consequence of the identified i scenario. '

2. NCS Bases and Controls 1

The primary reviewer should evaluate the consistency of the information in the application with respect to NCS practices, limits, and the validity of calculational models, using the guidance I given in industry-acceptable literature (e.g., Regulatory Guides, ANSI /ANS Standards, and I accepted handbooks). The primary reviewer should verify that the applicant has identified specific NCS controls and limits and the bases for NCS, for each process and SSC for which i the applicant has identified credible scenarios leading to criticality. The primary reviewer should i verify that all information in the acceptance criteria in Section 8.5 has been included. A tabular  !

format is acceptable. '

The primary reviewer should evaluate the NCS controls to ensure that there is a basis for their availability, reliability, and control independence (i.e., no common mode failures exist). The reviewer should also evaluate the availability and reliability of systems used to implement such controls including plant hardware and should make a determination of the fail-safe properties I for these systems and controls.

s The primary reviewer should determine that the applicant has committed to providing double contingency wherever practicable, such that the likelihood of a criticality event is extremely remote. A less favorable approach exists where the applicant may only provide for single contingency, but ensures sufficient redundancy, diversity, or mitigating features, such that the likelihood of criticality is equally remote, or the consequences of criticality are adequately mitigated. However, the basis for controlling a single parameter as opposed to the preferred method should be documented. If such single contingency controls are used then Technical Safety Requirements (TSRs) shall be established for these controls that define the operating limits, limiting conditions of operation, acceptance criteria for restoration of controls, surveillance requirements, the basis thereof, safety boundaries, and management controls necessary to prevent an inadvertent criticality.

3. Subcritical Limits In the absence of directly applicable experimental measurements, the reviewer should determine that suberitical limits have been derived from a method that has been benchmarked against experimental data. A suberitical limit is a margin in the correlating parameter which may be a function of composition and other variables and is sufficient to ensure subcriticality.

This margin of subcriticality must include allowances for the uncertainty in the bias and for uncertainties due to any extensions of the area (s) of applicability. The reviewer shall determine that the method used to establish suberitical limits is included in the application and 1 incorporates such allowances fro uncertainty including an additional margin for any extension of I the area of applicability.

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1 Nuclear Criticality Safety

4. Cases Analyzed and Codes The primary reviewer should verify that the SAR includes descriptions of criticality analyses for the most reactive, parameter sensitive, and risk-significant cases of the identified processes.

These should be demonstrated to include and envelop all proposed processes and SSCs j having the smallest margins of criticality safety (in assurance probability and/or k,) and determine the adequacy of methods used to determine the suberiticality of the systems.

For verification of Monte Carlo calculations, the primary reviewer should review input data such as the number of neutron histories and convergence criteria including frequency distribution, and the computer model and assumptions adequately represent the intended equipment or process. As the number of neutron histories increases, the mean value for k, should approach some fixed value and the standard deviation associated with each mean value should decrease. Depending on the code used, a number of diagnostic calculations are generally available to demonstrate adequate convergence and adequate statistical variation. Computer generated plots of the modeled geometry can be evaluated to ensure adequate model representation. For deterministic codes, a convergence limit may be prescribed in the input.

The primary reviewer should verify the selection of a proper convergence limit and achievement of this limit.

5. Cross-Section Treatment if a multigroup treatment is used, the primary reviewer should verify that the neutron spectrum is appropriately considered. In addition to selecting a cross-section set collapsed with an appropriate flux spectrum, a more detailed processing of the energy-group cross-sections is also required to properly account for resonance absorption and self-shielding. The use of KENO es part of the SCALE sequence provides for such processing directly.

Some cross-section sets include data for fissile and fertile nuclides (based on a potential scattering cross-section) that can be input bfthe user. If a stand-alone version of KENO is used, potential scattering must be properly considered. [ Note: The " working-format" library, commonly distributed with SCALE / KENO to enable calculations of the manual's sample problems, is not acceptable for criticality calculations of actual systems (NRC Information Notice 91-26). NRC has accepted "27-Group NDF4' cross-section library in SCALE-4.1 PC KENO Va for criticality calculations.)

6. Range of Applicability and Benchmarking The primary reviewer should verify that computer codes used for criticality calculations are benchmarked against critical experiments. Benchmark comparisons can validate the computer I code, its use on a specific geometric configuration, the neutron cross-sections used in the )

analysis, and consistency in modeling. The calculated k,,'s and confidence levels of the base I criticality computations must be adjusted to include the appropriate blas and uncertainties I determined from the benchmark comparisons. This correlation is commonly expressed in j terms of calculated k,, values, but other parameters may be used.  !

l The benchmark experiments should be relevant to the actual situation analyzed. The range of Draft NUREG-1671 8-6 l

l I

i (nv) Nuclear Criticality Safety applicability should be defined by identifying the range of imprtant parameters and I

I characteristics for which the code was validated. The primary reviewer should verify that the procedure used to establish the range is included in the application along with the method used to estimate the bias and uncertainty in the extended range. If the extension is large, the method shall be supplemented by other methods or codes to provide a better estimate of the safety  ;

margin.

No critical benchmark experiment will precisely match the fissile material, moderation, neutron poisoning, and configuration in the actual situation. However, the applicant can perform a proper benchmark analysis by sclecting experiments that adequately represent the actual i situation and fissionable material features and parameters important to reactivity. The applicant must justify the suitability of the critical experiments chosen tc benchmark the criticality code and calculations. UCID-21830 provides guidance for benchmarking and contains a substantial bibliography of benchmark experiments and validation testing.

7. Bias and Uncertainty Treatment and Trending Multiple applicable benchmark experiments should be analyzed. Critical experiments using a different fissionable isotope than that intended should not be included in this benchmark comparison. A sufficient number should be analyzed to determine if statistically significant trends may exist with parameters important to the validation process. The results of these benchmark calculations should be converted to a bias for application to the criticality O

(/

computations. The bias for a set of criticals should be taken as the difference between the best fit of calculated k,n and 1.0. Simp!/ using an average of the biases from a number of benchmark calculations is typically not considered to be sufficient, particularly if one benchmark yields results that are significantly different from the others.

The primary reviewer should verify that only biases determined by benchmark comparisons which increase k,n or lower the confidence level nave been applied. If the benchmark calculation for a critical experiment results in a neutron multiplication that is greater than unity, it should not be used in a manner that would reduce the k oncalculated.'

The primary reviewer should consider three kinds of uncertainty; (1) experimental data or techniques; (2) calculational method; and (3) the particular analyst and model inputs. Examples of uncertainties in experimental data include variability in important input parameters (e.g.,

materials) or inadequate descriptions of experimentallayout. Examples of uncertainties in calculational method are uncertainties in the approximation used by the code to solve the analytical equation, uncertainties from convergence, and uncertainties from cross-section data and processing. Interpretation of calculated results, individual modeling techniques, or selection of code input options are possible sources of analyst /model input uncertainty.

Known uncertainties in the experimental data should be identified, along with a discussion of how they were included in the overall bias and uncertainty for the calculational method. The statistical treatment used to establish the bias and uncertainty should be thoroughly discussed in the application with suitable references.

O 8. Neutron Interaction 8-7 Draft NUREG-1671

Nuclear Criticality Safety The primary reviewer should evaluate the degree of neutronic isolation of each systern or unit {

containing fissile nuclides, to verify that adjacent systems do not impact their respective criticality analyses' results. Items reviewed should include the minimum spacing, geometry, structural integrity, and material properties of units with respect to adjacent units and, it relied upon for NCS, the controls to prevent communication under normal conditions, anticipated operational occurrences, and credible accidents. This can be accomplished by engineered devices (spacers) to maintain physical separation between units (which should meet the safety-related requirement; of the appropriate construction standard), or administrative controls such as procedures (provided that the spacings are identified in workstation procedures with visual indicators and posting). The primary reviewer should also evaluate the sensitivity studies conducted by the applicant, to ensure that the controls in place are capable of preventing unacceptable dimensional changes that would lead to criticality.

9. Confirmatory Calculations The primary reviewer should perform an independent kg calculation and confirmatory analyses using industry acceptable computer codes and methods that are preferably different than those used by the applicant and that have been sufficiently validated against experimental data.

These analyses should verify the applicant's criticality analysis associated with the minimum margins of criticality safety. A separate computation should be performed by the primary reviewer to verify the calculations associated with a design basis accident-level event resulting in criticality.

In determining the level of effort appropriate for the confirmatory calculations, the primary reviewer should consider:

(1) Experience of the applicant in using the methods and codes, and in validating the methods and codes with benchmark critical experiments; (2) The criticality margin proposed by the applicant, the sensitivity or reactivity of the scenario, and the degree of process control over controlled variables; (3) Use of methods or codes not previously reviewed by the staff; (4) Any significant departures from prior designs or procedures (e.g., unusual geometry, new types of materials, different nuclides); and (5) The existence (or lack thereof) of applicable critical experiments to benchmark codes.

The minimum review should include an examination of the applicant's input to the computer program used for the criticality analysis, use of that input in the program, reasonableness of results, and use of the results in developing the NCS margin.

8.4.2.3 The Applicant's NCS Organization The primary reviewer of Chapter 2.1," Organizational Structure,"is a secondary reviewer for this chapter in that he or she should review and determine if the applicant's proposed NCS organization, meets the acceptance criteria in Sectinn 8.5 and that of Chapter 2.1. The secondary and primary reviewer should coordinate evaluation of the organizational positions, functional responsibilities, experience, and qualifications of persons responsible for the NCS Draft NUREG-1671 8-8

s-Nuclear Criticality Safety program.

8.4.2.4 Management Controls The primary reviewers of Chapter 2.0, " Organization and Administration" and Chapter 3.0

" Quality Assurance," are secondary reviewers for this chapter in that they should review and determine if the applicant's program for CM, maintenance, QA, training, audits, investigations, records, safety committees, and procedures meet the needs of NCS and the acceptance criteria in Section 8.5. The primary reviewer of this chapter should also evaluate those provisions related to management controls that are specific to NCS. Often, these controls should be above the normal controls. For example, a plant modification to an SSC, not necessarily " relied on for safety," that is physically adjacent to an SSC that is " relied on for NCS," would need to consider the impact on both SSCs from neutron reflection or communication. If the applicant uses criticality control zones, the plant modification procedures should include specific provisions limiting work and changes in these zones.

The secondary reviewers and the primary reviewer should coordinate their review of the application to ensure that the applicant has adequately addressed NCS in the following programmatic areas:

1. CM and Change Control to provide documentation and record keeping of the process description, process and equipment design, as-built drawings, operating procedures, maintenance and testing of NCS control instruments, and NCS evaluations and limits.

The reviewers should agree that documentation and recordkeeping are adequate to limit and control changes in the facility and procedures that may affect NCS, during design, construction, operations, and decommissioning.

2. , A maintenance program to maintain the reliability of NCS controls through calibration, surveillance, and testing. The primary reviewer and the reviewer of Chapter 2.7,

" Maintenance," should coordinate to ensure that controls identified as relied on for NCS are covered by the maintenance program and that the NCS significance of affected SSCs is clear. The maintenance program should provide for the periodic functional testing and calibration of active engineered controls and surveillance testing of passive engineered controls, and apply appropriate compensatory measures that ensure safety during maintenance, calibration, surveillance, and testing prior to retuming the system to

. operable status.

3. A work control program in conjunction with the maintenance program should be evident such that work is planned, authorized, and accomplished under controlled conditions using technical requirements, instructions, procedures, or other appropriate means of detail commensurate with the complexity and risk significance of the task. Management controls should be evident and responsibilities assigned to ensure appropriate lines of communication and organizational interface for work assigned to extemal organizations that may have a safety significant impact on plant operations and processes.

4. The primary reviewer of Chapter 3.0," Quality Assurance," should review the application to ensure that QA for components relied on for NCS is of the highest quality. QA program mechanisms should be evident to ensure that processes and equipment which do not result in the anticipated quality a're promptly identified, documented, analyzed, g resolved, and followed up. The primary reviewer should also determine that appropriate 8-9 Draft NUREG-1671

1 1

Nuclear Criticality Safety OA is applied to codes used for criticality analyses.

5. A program should be provided for tracking safety deficiencies which directly or indirectly impact NCS controls or systems relied upon for safety and taking permanent corrective actions to reduce the probability of recurrence of such safety deficiencies.

6. A program should be provided for the procurement of safety-related components such that modification and replacement items are appropriately received, inspected, controlled, and stored, and that appropriate integration and lines of communication of safety organizations (e.g., NCS, OA, maintenance, etc.) is evident to ensure that applicable requirements and specifications are appropriately incorporated and followed.

7. A program should be provided for monitoring and surveil!ance as necessary to detect and prevent unauthorized accumulations of fissile materials in process equipment, storage areas, piping and ventilation systems.  ;

8. The procedure control program, as applicable to NCS operations, should incorporate l NCS requirements which are expected to be administratively implemented along with j appropriate controls to reflect changes in operation and ensure adequate dissemination  !

and control of the latest revisions. A program should be provided for the periodic review of active procedures and for new or revised procedures.

9. The primary reviewer and the reviewer of Chapter 2.3, " Training and Qualifications,"

should coordinate to ensure that NCS training will be provided such that human actions are performed in a reliable and predictable manner. The design and development of NCS training should be traceable to a systematic analysis of the job to be performed and NCS staff participation in the development, implementation and evaluation of its effectiveness shall be evident.

10. An emergency preparedness and incident response program and plan should be established for the evacuation of plant personnel, personnel accountability, and lines of communication and integration of on and off site organizations that are expected to provide assistance during accidents related to nuclear criticality. Coordination with the training program is expected to ensure that individuals responding to NCS incidents are appropriately trained and informed of conditions that might be encountered. This program should also include the periodic performance of drills and exercises to maintain familiarity with emergency procedures; such procedures should address re-entry requirements, lines of communication, and membership of response teams.

11. A posting and operator aid program to provide necessary information regarding emergency evacuation routes, fire fighting restrictions, response to alarm signals, and NCS requirements on all parameter limits subject to procedural control (i.e., human action).

12. The primary reviewer and the reviewer of Chapter 2.5, " Incident investigations," should coordinate to ensure that a program of inspections, audits, self assessments, and investigatinns is estabF shed to identify and correct deficiencies that may arise and to ensure that improvements are made to the NCS program.

8.4.2.5 Criticality Monitoring Instrumentation The primary reviewer and the supplemental reviewer (i.e., the reviewer of Chapter 7.0,

" Radiation Safety,") should determine that the licensee has complied with the criticality accident alarm system requirements of 10 CFR 76.89 and Regulatory Guide 8.12. The primary reviewer should evaluate the adequacy of the information related to the dose rates and total doses Draft NUREG-1671 8-10 1

, Nuclear Criticality Safety resulting from criticality excursions and the adequacy of potential accident locations at the points where criticality monitoring instrumentation are placed. The effects of shielding and geometry should be included. The effects of shielding and geometry should be treated in a conservative manner with respect to the alarm set points; inis conservative treatment is not always intuitive. The results of this review should be provided to the primary reviewer of Chapter 7.0, who evaluates (in that chapter's review procedures) the adequacy of the instrumentation's location as related to adverse atmospheric environments or process-conditions, audibility and visibility, calibration, response time, and false alarm rate.

The guidance in Regulatory Guide 3.33 provides information for determining the source terms from a criticality event for use in the design of criticality accident alarm systems.

8.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this chapter are listed in the following sections.

8.5.1 Regulatory Requirements The regulatory requirements applicable to this chapter include:

10 CFR 76.35(a)(7) requires the applicant to provide management controls and oversight O adequate to protect public health and safety. Criticality control is one part of those management controls and oversight.

10 CFR 76.60(d) requires the applicant to comply with the applicable provisions of 10 CFR 20 which includes requirements for the use of procedures and engineering controls to protect the public and workers from unnecessary exposures (i.e., criticality accidents).

10 CFR 76.60(e) requires the applicant to comply with the applicable provisions of 10 CFR 21 which includes requirements for: 1) a procurement program to identify, evaluate, and control deviations, defects, and failures associated with safety hazards of dedicated items; and 2) a program for the identification and evaluation of defects and failures associated with safety hazards.

10 CFR 76.60(g) requires the applicant to comply with the applicable provisions of 10 CFR 71 which requires appropriate controls to preclude criticality accidents in the packaging and transportation of radioactive materials.

10 CFR 76.85 requires the applicant to perform an assessment of accidents to establish the basis for limiting conditions for operation of the plant and assurance that plant operations will be conducted in a manner to ensure adequate public and worker safety.

10 CFR 76.87(c)(3) requires the applicant to establish technical safety requirements which address procedures, equipment, and processes involving criticality prevention.

8-11 Draft NUREG-1671 l

Nuclear Criticality Safety 10 CFR 76.89 requires the applicant to maintain and operate a criticality monitoring and audible alarm system.

10 CFR 76.91 requires the applicant to establish a written emergency plan identifying the types of accidents and associated protective actions. A nuclear criticality accident is a credible class of accident for which protection must be maintained.

10 CFR 76.93 requires the applicant to establish a quality assurance program commensurate with the importance to safety.

10 CFR 76.95 requires the applicant to establish, implement, and maintain a training program for individuals relied upon to safely operate, maintain, or modify plant systems.

10 CFR 76.120 requires the applicant to establish a reporting, corrective actions, and lessons learned program for equipment failure, disablement, or unplanned abnormal conditions which directly impact nuclear criticality prevention or degradation of safety margin.

8.5.2 Regulatory Guidance NRC regulatory guides (RG) applicable to this chapter include:

RG 3.1, 'Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Materials," January 1973, and its finding related to the general acceptability of ANSI /ANS-8.5-1986,"Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Material," 1986.

RG 3.4, " Nuclear Criticality Safety in Operations with Fissionable Materials at Fuels and Materials Facilities," February 1978, as it relates to acceptable NCS administrative and technical practices for sing le parameter and multiple parameter criticality control, and its finding related to the general acceptability of ANSI /ANS-8.1-1983, " Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors," 1983.

RG 3.33, " Assumptions used for Evaluating the Potential Radiological Consequences of Accidental Nuclear Criticality in a Fuel Reprocessing Plant," April 1977, as it relates to determining the source terms from a criticality event for use in the design of criticality accident alarm systems.

RG 3.43, ' Nuclear Criticality Safety in the Storage of Fissile Materials," April 1979, and its finding related to the general acceptability of ANSI /ANS-N16.5-1975 (now ANSI /ANS-8.7-1987),

" Guide for Nuclear Criticality Safety in the Storage of Fissile Materials," 1987.

RG 3.45," Nuclear Criticality Safety for Steel-P"pe Intersections Containing Aqueous Solutions of Fissile Materials," April 1989, and its finding related to the general acceptability of ANSI /ANS-8.9-1987, " Nuclear Criticality Safety Criteria for Steel-Pipe intersections Containing Aqueous Solutions of Fissile Material," 1987.

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RG 3.57, " Administrative Practices for Nuclear Criticality Safety at Fuels and Materials Facilities," October 1986, and its finding related to the general acceptability of ANSI /ANS-8.19- 3 1984, " Administrative Practices for Nuclear Criticality Safety," 1984. I RG 3.68, ' Nuclear Criticality Safety Training," April 1994, as it relates to training of individuals who perform NCS functions, and its finding related to the general acceptability of ANSI /ANS-8.20-1991, " Nuclear Criticality Safety Training," 1991.

RG 8.12, ' Criticality Accident Alarm Systems," October 1988, as it relates to a system l acceptable to the staff for meeting the Commission's requirements for a criticality accident l alarm system.

8.5.3 Regulatory Review Criteria l l

8.5.3.1 NCS Limits and Margins The following regulatory review criteria should be used by the staff for credible scenarios that could result in criticality during anticipated operational occurrences or credible accidents.

1. NCS Bases Acceptance should be based on a description by the applicant that describes the bases for f

\

NCS in each process or SSC, for credible scenarios leading to the potential for criticality.

These NCS bases should identify:

(1) The functions of the SSC relied on for NCS for the given scenario, during normal operations, anticipated operational occurrences, and credible accident conditions; (2) The specific controlled parameters, and any design and operating controls on these parameters; (3) The credible scenario or event sequence, including initiating events, leading to the potential criticality and the basis for suberitical operation including effects of system sensitivities and system interactions; (4) Additional control (s) and the additional margin of suberiticality provided by the controlled parameters; and (5) The applicant's application of the double-contingency principle as described in ANSI /ANS-8.1-1983, to the specific process or SCC.

Adherence to the double-contingency principle requires that process and equipment designs and operating procedures should incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible. In so far as it may not be practicable to implement the double-contingency principle as stated in the ANSI standard for all processes, the staff should accept the following exception with adequate justification in the SAR:

In those processes where it has been determined that double contingency is not practicable to implement, the facility will implement sufficient redundancy / diversity on a 8-13 Draft NUREG-1671

1 Nuclear Criticality Safety single control or the system being controlled such that at least two independent and concurrent uniikely errors, accidents, or equipment malfunctions must occur before a criticality accident is possible. Adequate control shall be exercised to ensure the availability and rehability of such single barrier control.

2. NCS Limits and Safety Margins NCS limits are acceptable if they ensure that an adequate safety margin exists under normal conditions, anticipated operations, and credible accidents. Acceptance should also be based on the sensitivity and probability of exceeding such a limit and the consistency with which such limits are applied (i.e., with NCS practices, limits, and validity of calculational models) with the guidance in Regulatory Guide 3.4 and ANSI /ANS-8.1-1983.

The establishment of a controlled parameter safety limit should rely on the ability to control that parameter around that safety limit. As such, any percentage used for establishing NCS limits based on the value of a controlled parameter where calculated k,, equals the safety limit, will j require the demonstrated ability to control that parameter to within one-third of the margin to  !

criticality (e.g., if the limit is 85 percent, then the parameter must be controlled to plus or minus l 5 percent of the critical value). Control on such limits should be determined from reliability studies (i.e., historical plant and industry experience) to ensure such controls will be available and reliable. The acceptance of a control's reliability should not be limited to the application itself, but should also consider impacts from supporting systems and a determination of fail-safe properties.

Where double batching is possible, NRC accepts adoption of mass limits that are less than 0.45 of the minimum critical mass based on spherical geometry; where double batcHng is not possible, the mass should be limited to 0.75 of the critical mass based on spherical geometry.

Acceptable geometry margins of saf ny for large single units are 90 percent of the minimum critical cylinder diameter; 85 percent of the minimum critical slab thickness; and 75 percent of the minimum critical spherical volume. Maximum slab dimensions should be specified for j small units.

An acceptable alternative to the above limits is to establish a maximum allowable multiplication factor (safety limit) that includes allowances for uncertainties and biases. Calculations with .

assumed parameter controls for processes and SSCs would then demonstrate that controls are i established on parameters such that this safety limit is not exceeded for all normal conditions, anticipated operational occurrences, and credible accidents. The methods in ANSI /ANS- ,

8.17-1983, for establishing the limit on k on, are generally acceptable to NRC. I

3. Analyses The information in ANSI /ANS-8.1-1983 and ANSI /ANS-8.17-1984 is generally acceptable to NRC with respect to providing the descriptions of the analytical methods by which the NCS limits were determined. Consistent with this information, acceptability of the analytical methods should be based on the following:

(1) Methods are described with sufficient detail, clarity, and lack of ambiguity to Draft NUREG-1671 8-14

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Nuclear Criticality Safety allow independent duplication of results; (2) Nuclear data (e.g., cross-sections) are demonstrated to be consistent with experimental measurements; (3) Data taken from relevant benchmark experiments are used for the validation effort (e.g., composition, enrichment, geometric configuration, and nuclear properties including reflectors, absorbers, and moderators);

(4) Verification that the mathematical operations are done as intended (i.e.,

calculation of k,, values via the calculational method from the data in item 2 and comparison to experimental k,, values (typically 1));

(5) Determination of area (s) of applicability, typically spanning the range of parameters in the experiments (e.g., enrichment, moderation, reflection, neutron j absorbers), and any extrapolation beyond the range of experiments and the i basis of validity;  !

(6) Calculation of bias, the prescribed margin of subcriticality over the area (s) of applicability, and the basis for the margin; (7) Any additional margins added based on extension of the area of applicability; i (8) Estimation of uncertainties in the analytical method (e.g., from statistics, j computational convergence, nuclear cross-section data) and uncertainties in the  ;

benchmark experiments; (9) Specification of software QA and configuration control on the nuclear data and calculational method; and (10) Provisions exist for documentation of the above and maintenance of the documentation in the facility CM function.

Acceptability should also be based on performance and descriptions in the SAR of criticality l analyses for the most reactive cases (including effects of changes to fissile content,  ;

moderation, reflection, and heterogeneity), and on a demonstration that the analyses include and envelop the proposed processes and SSCs having the smellest margins of criticality safety (in probability of occurrence or k,n). The model(s) used for criticality analyses are acceptable to NRC if:

(1) The dimensions and materials used in the model are consistent with the descriptions, drawings, and design of the facility, as presented in the SAR and include provision for material tolerance due to design flaws or corrosion.

(2) Conservative assumptions are incorporated for all variables, including simplifications of geometry and materials, location and concentrations of fissile materials, etc.

(3) The effects of different moderator densities or types (e.g., organic content) are assessed for the processes and SSCs being analyzed.  ;

(4) Representative sample input and output files for codes used are provided for  !

review. ,

4. Specific Criticality Controls The following regulatory guides and industry standards may be used regarding specific NCS controls:

8-15 Draft NUREG-1671

Nuclear Criticality Safety '

Favorable ceometry Regulatory Guide 3.43 and ANSl/ANS-8.7-1987, and Regulatory Guide 3.45 and ANSI /ANS-8.9-1987, provide guidance, acceptable to NRC, related to favorable geometry control.

Fixed Absorbina materials ANSI /ANS-8.21-1995,"Use of Fixed Neutron Absorbers in Nuclear Fuel Facilities Outside Reactors," provides guidance acceptable to NRC with respect to applications of fixed absorbers as criticality control techniques. Regulatory Guide 3.1 and ANSI /ANS-8.5-1986 provide guidance, acceptable to NRC, related to the use of Borosilicate-glass Raschig rings.

Administrative Controls Administrative controls on NCS parameters should be acceptable in cases where use of engineered safety features such as favorable geometry or fixed neutron absorber material for these yJrposes is not practicable. However, the use of administrative controls in lieu of passive or active engineered controls shall be documented. Acceptability of administrative NCS controls should be based on:

(1) The margin of safety for a controlled parameter should be established and controlled during normal conditions, anticipated operational occurrences, and accident conditions, in accordance with the above review criteria section, "NCS Limits and Safety Margins."

(2) Performance of testing and surveillance is proposed that will verify the continued efficacy of such controls.

(3) Training programs and procedures explicitly cover the limiting safety settings.

(4) instrumentation to monitor controlled variablps is of the highest QA, has a specified calibration frequency, adequate sensitivity, and can adequately signal a control system to terminate a given process.

8.5.3.2 NCS Organizational Responsibilities Acceptance should be based on a description of the organizational positions, functional responsibilities, experience, and qualifications of persons responsible for NCS. An individual with the appropriate NCS experience and qualifications should be in a management position at the plant during operations. The plant organization, the functional responsibilities, and the qualifications of personnel are the responsibility of the primary reviewer for Chapter 2.1.

Therefore, information related to the NCS organization may be included in this chapter or a reference may be provided to relevant information in SAR Chapter 2.1.

8.5.3.3 Management Controls for NCS Acceptance should be based on inclusion in the SAR of an appropriate statement concerning management policy with respect to designing and constructing the plant, operating the plant, and the planned organizational structure related to NCS. The administrative procedures in Draft NUREG-1671 8-16 O

i t

Nuclear Criticality Safety l . Section 4 of ANSI /ANS-8.1-1983,' Regulatory Guide 3.57, and ANSI /ANS-8.19-1984, provide information and guidance related to NCS management controls that are generally acceptable to NRC.

, The applicant's OA program should be considered acceptable with respect to NCS based on l the following criteria:

l (1) The QA level for all nuclear criticality controls used to fulfill double-contingency should be of the highest quality (as defined by the applicant in accordance with Section 11.3, " Quality Assurance").

(2) NCS codes and software are subject to QA controls.

(3) QA is applied to measuring and test equipment and processes for obtaining l l representative samples and measurements for establishing NCS limits.

i (4) Compliance of new or modified equipment with NCS specifications is verified by supervision and the appropriate safety discipline before its use (e.g., based on inspection reports).

l The NCS training program should be considered acceptable based on the following criteria:

(1) All elements contained in ANSI /ANS-8.20 are provided in the applicant's training program.

(2) The applicant uses individuals responsible for NCS in the development and implementation of NCS training and in the evaluation of its effectiveness.

The operational inspections, audits, assessments, and investigations function should be considered acceptable based on inclusion of the following elements:

(1) Consistent with ANSI /ANS-8.1-1983, NCS operations are reviewed at least annually by persons knowledgeable in NCS and who (to the extent practicable) <

are not responsible for the operation, in consultation with operating personnel, to ascertain that procedures are being followed and that process conditions have not been altered so as to adversely affect NCS; (2)- Quarterly safety audits are conducted in a manner such that all NCS aspects of conduct of operations are audited at least every 2 years; and (3) Weekly NCS inspections of all operating special nuclear material process areas are conducted.

8.5.3.4 CriticalityInstrumentation Instrumentation to monitor for criticality should be acceptable if it meets the criteria and guidance in 10 CFR Part 76.89, Regulatory Guide 8.12, ANSI Standard 8.3, and the following:

(1) Personnel have the capability to assess the radiation hazard in areas which may need to be accessed during the course of an accident.

(2) Portable instruments to be used in the event of an accident should be placed so as to be readily available to personnel responding to an emergency.

(3) Emergency power should be provided for installed accident monitoring systems.

(4) The accident monitoring systems should have usable ranges that include the maximum calculated accident levels; and should be designed to operate properly in the environment caused by the accident.

8-17 Draft NUREG-1671

l l

Nuclear Criticality Safety Acceptance should be based on an identification of the source terms used in the design and placement for the instrumentation for monitoring accidental criticality.

Information relevant to the instrumentation (response time, false alarm rate, placement, visibility and audibility, etc.) should be provided in this chapter. This chapter should also include the identification of the source terms from the accidental criticality and their durations, magnitude, etc., at the receptor (i.e., instrument) location.

8.6 Evaluation Findings

The review should verify that sufficient information has been provided in the SAR and amendments to meet the requirements of 10 CFR 76.36 to support conclusions of the following type, which will be included in the staff's CER.

1. The staff concludes that the information provided by the applicant with respect to nuclear criticality safety is acceptable and meets the requirements of Part 76. This conclusion is based on the following information.

2. The applicant has described a facility that can meet the requirements of Part 76, as they relate to evaluation of NCS. The applicant has committed to have in place a staff of managers, supervisors, engineers, process operators, and other support personnel who by required skills, knowledge, and training, are qualified to conduct the proposed operations according to approved NCS practices.

3. The applicant has documented and implemented a safety program using a systems approach; that includes a description of an adequate program for prevention, immediate detection and annunciation, assessment, and mitigation of an unintended nuclear criticality when there is potential for nuclear criticality. [Briefly describe the organization and qualifications of NCS personnel).

4. The primary sources of criticality risk exist in the [ identify the systems and events constituting the primary sources]. The applicant has committed to control the risk of nuclear criticality in the processes, SSCs that are relied upon for nuclear criticality safety by (describe the NCS bases that the applicant has used for the relevant processes and SSCs].

5. The applicant has submitted, and staff has reviewed, conservative technical analyses that demonstrate that acceptable margins of safety will be maintained in the nuclear criticality parameters, commensurate with the uncertainties in the data and bias in the calculational methods.

8.7 References U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

The following references contain information that is not specifically applicable to GDP facilities, but which is nevertheless relevant to this review area. Applicants may choose to reference portions of these documents in the SAR, with adequate justification.

American National Standards Institute, ANSI /ANS 8.1 1983, ' Nuclear Criticality Safety in Draft NUREG-1671 8-18

Nuclear Criticality Safety v

Operations with Fissionable Materials Outside Reactors," 1983.

U.S. Nuclear Regulatory Commission, NUREG/CR-0200, " SCALE Code User's Manual," Vol.

1-4, Rev 4, April 1995.

Los Alamos National Laboratory, "MCNP 4A, Monte Carlo N-Particle Transport Code System,"

December 1993.

U.S. Nuclear Regulatory Commission, Information Notice 91-26, " Potential Non-Conservative Errors in the Working Format Hansen-Roach Cross-Section Set Provided with the KENO and SCALE Codes," April 2,1991.

UCID-21830," Determination and Application of Bias Values in the Criticality Evaluation of Storage Cask Design," January 1990.

American National Standards Institute, ANSI /ANS 8.5,-1986, "Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Material," 1986.

American National Standards institute, ANSl/ANS 8.7-1987, " Guide for Nuclear Criticality Safety in the Storage of Fissile Materials" formerly ANSI /ANS-N16.5-1975,1987. i American National Standards institute, ANSI /ANS 8.9-1987, " Nuclear Criticality Safety Criteria

/' for Steel-Pipe Intersections Containing Aqueous Solutions of Fissile Material," 1987.

\ i American National Standards Institute, ANSI /ANS 8.12-1987, " Nuclear Criticality Control and Safety of Plutonium Uranium Fuel Mixtures Outside Reactors," 1987.

American National Standards Institute, ANSI /ANS 8.191984, " Administrative Practices for Nuclear Criticality Safety," 1987.

American National Standards Institute, ANSI /ANS-8.20-1991, " Nuclear Criticality Safety Training," 1991.

American National Standards Institute, ANSl/ANS 8.17, " Criticality Safety Criteria for the Handling, Storage, and Transportation of LWR Fuel Outside Reactors," 1989.

American National Standards institute, ANSI /ANS 8.21-1995,"Use of Fixed Neutron Absorbers in Nuclear Fuel Facilities Outside Reactors," 1998.

American National Standards Institute, ANSI /ANS 8.3," Criticality Alarm Systems," 1986.

Los Alamos National Laboratory, Alcouffe, R.E.," User's Guide for TWODANT: A Code Package lor Two-Dimensional, Diffusion-Accelerated, Neutral Particle Transport," LA-10049-M Rev.,

LANL, April 1992.

O' Dell, R.D., " Revised User's Manual for ONEDANT: A Code for One-Dimensional, Diffusion Accelerated, Neutral Particle Transport," LA-9184-M, Rev., LANL, December 1989.

8-19 Draft NUREG-1671

Nuclear Criticality Safety Radiation Shielding Information Center, "ANISN/PC-Multigroup One-Dimensional Discrete Ordinates Transport Code System with Anisotropic Scattering," CCC-J14 Micro, Oak Ridge, ,

I TN,1990.

American National Standards Institute, ANSl/ANS-N16.8-1975 (now ANSI /ANS-8.10-1983),

" Criteria for Nuclear Criticality Safety Controls in Operations with Shielding and Confinement,"

1975, as it relates to criticality control practices for facilities where confinement and shielding limit the consequences of a criticality accident.

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.58, ' Criticality Safety for Handling,  !

Storing, and Transporting LWR Fuel at Fuels and Materials Facilities," May 1990.

Los Alamos National Laboratory, LA-10860-MS," Critical Dimensions of Systems Containing rasU, " SPu, and U, H. C. Paxton and N. L. Pruvost, Los Alamos National Laboratory, Los Alamos,1987.

H. K. Clark, DP-1014," Maximum Safe Limits for Slightly Enriched Uranium and Uranium Oxide," Du Pont de Nemours and Co., Aiken, SC,1966.

U.S. Department of Energy, Draft RG, DOE /NCT-04, "A Review of Criticality Accidents," W. R.

Stratton, Revised by D. R. Smith, March 1989.

R. A. Knief," Nuclear Criticality Safety-Theory and Practice," 1988.

ARH-600, Criticality Handbook, Volume I,11, Ill, W.A. Blyckert, et. al, September 1971.

TID-7016 (NUREG/CR-0095), Nuclear Safety Guide, Rev. 2, J.T. Thomas, ORNL, June 1978.

TID-7028, Critical Dimensions of Systems Containing masU,239pg, gng 23 U, H.C. Paxton, et. al, LASL and ORNL, June 1964.

ORNL/TM-12292, Estimated Critical Conditions for UO2 F,-H2 O Systems in Fully Water-Reflected Spherical Geometry, W.C. Jordan, J.C. Tumer, December 1992.

ORNL/CSD/TM-284, Minimum Mass of Moderator Required for Criticality of Homogeneous Low-Enriched Uranium Systems, W.C. Jordan, J.C. Turner, December 1992.

Draft NUREG-1671 8-20 o

( 9.0 ENVIRONMENTAL PROTECTION AND WASTE MANAGEMENT 9.1 Responsibility for Review

9.1.1 Primary

Environmental Engineer or Environmental Scientist

9.1.2 Secondary

Certification Project Manager

9.1.3 Supporting

Inspector 9.2 Purpose of Review The purpose of this SRP section on environmental protection and waste management is to present the regulatory requirements and regulatory guidance and to establish the acceptance criteria and review procedures to be used by reviewers. This section covers the environmental safety program, waste management program, environmental compliance report, and environmental reviews related to the Compliance Plan for an application to renew the Certificates of Compliance for the Gaseous Diffusion Plants. NRC uses the review as the basis for determining the programs adequacy and documenting the review in the Compliance Evaluation Report. The review also determines if the requirements in 10 CFR Part 76 that relate to the environmental program are met.

~

9.3 Areas of Review The staff will review the program for effluent control and the applicants evaluation and demonstration of compliance with 40 CFR Part 61 and 10 CFR Part 20. The staff will review the description of the environmental safety program to assess the impact of certified activities.

The staff will ensure that the applicant addresses the following: media to be monitored, frequency of sampling and analysis, action levels and actions to be taken when the levels are exceeded, and trend analysis. The staff will review the waste management program to ensure that processing, management , and disposal of wastes is included in the discussion, and a commitment to waste minimization.. The staff will review the compliance status report, including the environmental and effluent data. The staff will also review information submitted to support preparation of are environmental assessment related to the compliance plan. The staff will review the TSRs for appropriate commitment to the program. The staff will also review any compliance plan item that relates to environmental protection and waste management.

9.4 Review Procedures The staff will review the application portions related to environmental protection and waste management by comparing them to the acceptance criteria contained in Section 9.5.

On the basis of its review, the staff may request that the applicant provide additional information or modify the submittal to meet the acceptance criteria in Section 9.5 of this SRP.

9.5 Acceptance Criteria 9-1 Drsft NUREG-1671

Environmental Protection and Waste Management 9.5.1 Regulatory Requirements Section 76.35(a)(6) requires the applicant to include a description of equipment and facilities such as devices for the treatment and disposal of radioactive effluent and wastes.

l Section 76.35(m) requires the applicant to submit a description of the program for processing, management, and disposal of mixed and radioactive wastes and depleted uranium generated by operations. The description must include a description of the waste streams generated, annual volumes of depleted uranium and waste expected, identification of radioisotopes contained in the waste, physical and chemical forms of the depleted uranium and waste, plans for managing the depleted uranium and waste, and plans for ultimate disposition of the waste and depleted uranium.

Section 76.60 requires the applicant to comply with applicable provisions of 10 CFR Part 20.

Section 76.35(g) requires the applicant to submit a compliance status report that includes status of various permits and provides environmental and effluent monitoring data.

Section 76.350 requires the applicant to provide any relevant information concerning deviation from the published Environmental Impact Statement, Environmental Assessment (EA), or environmental permits under which the plant is currently operated, from which the Commission can prepare an EA related to the compliance plan.

9.5.2 Regulatory Guldance The following documents can be used as guidance. I U. S. Nuclear Regulatory Commission, RG 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations)-Effluent Streams and the Environment".

U. S. Nuclear Regulatory Commission, RG 4.16 " Monitoring and Reporting Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants and Uranium Hexaflouride Production Plants," .

i U. S. Nuclear Regulatory Commission, RG 4.20, " Constraint on Releases of Airborne Radioactive Materials to the Environment for Licensees Other than Power Reactors".

U. S. Nuclear Regulatory Commission, RG 8.37, "ALARA Levels for Effluents frorn Materials Facilities".

ANSI N13.1-1982,"Gu!de to Sampling Airbome Radioactive Materials in Nuclear Facilities." ,

1 ANSI N42.18-1980, " Specification and Performance on On-Site instrumentation for l Continuously Monitoring Radioactive Effluents."  !

Draft NUREG-1671 9-2

n I

Environmental Protection and Waste Management 9.5.3 Regulatory Review Criteria i The applicant's effluent control and monitoring program is acceptable if it meets the following criteria:

i

a. There is a commitment to the ALARA principle as it pertains to effluents and a commitment  !

to review the environmental data as part of the plant ALARA committee annual review.

l j b. The program description includes a discussion of each emission or effluent control point and the emission / effluent controls, as appropriate. The applicant should include the most recent

" National Emissions Standards for Hazardous Air Pollutants (NESHAPS) Annual Report",

c. There should be a commitment that all major sources are continuously monitored. For minor i

sources, periodic sampling, use of indirect monitoring, or use of emission estimating methods i l_ established in NESHAP regulations may be used to estimate source emissions. If other l methods than actual measurement are used, it should be in compliance with a NESHAP Compliance Plan for the site or the applicant should provide adequate justification. For liquid effluents, continuous, flow proportional sampling should be used for continuous flow outfalls, and grab samples should be collected for intermittent outfalls.

d. The program should include establishment of action levels and actions for each continuously

. monitored location. Action levels should ensure that operational control system deficiencies are

] documented and acted upon in a time frame to remain within regulatory limits. Action levels should be incremental, such that each increasing action level results in a more aggressive l action. Levels should be established for both uranium and Tc99 l

3. The applicant should specify the sampling and analysis frequency, sample types, location and parameters. It is acceptable if the sampling and analysis frequency is in accordance with permits. At a minimum analysis should include alpha (or total uranium) and beta, and Tc99.

Analysis frequency can vary from daily to quarterly composites.

l l The applicant should briefly describe its analytical support program. This may be in a separate l section of the application. The program is acceptable if it includes the analytical techniques and

! minimum detectable levels and describes the control of the analytical process including i traceability of standards, calibration of instruments, chain of custody, and use of quality control.

l The applicant's environmental monitoring program is acceptable if it establishes the following:

l

! a. Media to be monitored. Possible media for environmental monitoring include air, surface water, groundwater, soil, sediments, and vegetation, as appropriate.

b. Sampling frequencies, locations, analyses, and reporting. The description of sampling frequencies, locations, and analyses is acceptable if it identifies sampling locations for each environmental medium, the frequency of sampling, the frequency of analysis and the type of analysis to be performed on each medium. At a minimum, annual samples for soil, sediment, and vegetation should be collected and analyzed for uranium. Liquid and air sampling should be more frequent. Air samples should be collected en a continuous basis with a minimum of 9-3 Draft NUREG-1671

1 Environmental Protection and Waste Management )

monthly collection and analysis. Water samples should include both continuous and grab i samples. Ambient air stations that collect on a continuous basis should be established. l Sample collection and analysis should at a minimum be monthly and includes gross alpha and i beta analysis. Representative water samples should be collected, as well as grab samples. It is acceptable if the frequency is in accordance with issued permits. Analysis should include gross alpha and beta. Thermoluminescent dosimeters should be included in the program and be collected and read on a quarterly basis.

c. Action levels and corrective actions. The reviewer should verify that the applicant commits to establishing action levels and to conducting an investigation into the cause of any exceedence of the action level. The corrective actions may include actions to reduce emissions to additional monitoring.

d. Trend Analysis. The reviewer should verify that the applicant commits to conducting a trend analysis of the environmental sampling data.

The applicant should provide the results of its dose calculations for the maximally exposed individual. It is acceptable if the applicant briefly explains the inputs for the computer codes.

The computer code is acceptable if it is an authorized code by EPA under 40 CFR Part 61. The dose is acceptable if it is less than 10 mrem per year.

The waste management program should include both waste and the depleted uranium tails.

The depleted uranium may be addressed in a separate document. The waste management program description is acceptable if it includes the following:

a. A brief description of the waste minimization program.

y b. A brief description of the various waste streams, including estimated volume.

c. The principle radiological contaminants in the waste, i.e. U235, Pu2aa, etc.

d. The waste characterization.

e. A description of the waste management activities, including waste separation and collection, processing, and storage.

1

f. The plans for disposition (disposal). j l

For the tails, the plan is acceptable if it includes the following:

a. An estimate of depleted uranium production for future years and the current inventory, and )

b. A discussion of the management and disposition plan. DOE is responsible for actual disposition of the depleted uranium tails, upon the request of the applicant. The applicant is responsible for the cost. The applicant may suggest an alternative method which would then need to be assessed.

Draft NUREG-1671 9-4

Environmental Protection and Waste Management -

The TSRs related to environmental protection and waste management programs are acceptable if they contain an appropriate commitment to the program as described in the application.

The compliance status report is acceptable if it provides: (1) a discussion of the status of compliance with the State, local, and Federal permits, licenses, approvals, and other entitlements that are held by the facility; and (2) the environmental and effluent monitoring data for both radiological and nonradiological components.

If a Compliance Plan is part of the application, the applicant must submit information concerning deviations from previous environmental documents from which the staff can prepare an environmental assessment for the noncompliances. The information is acceptable of it addresses those items of noncompliance that are in the Compliance Plan and discusses any deviations caused by the noncompliances. Note that the NRC staff must prepare an environmental assessment to support approval of any Compliance Plan. There is no requirement for the applicant to submit an environmental report or include discussions on alternatives, no action, etc.

9.6 Evaluation Findings

1 9.6.1 introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of 76.36, " Annual Renewal," requirements with respect to environmental protection and waste management and that the information is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that the evaluation is complete. The staff can document its review as follows.

l 9.8.2 Sample Evaluation Report  !

After completing the review of the applicant's submittal, the staff should report the findings in the Compliance Evaluation Report. The Compliance Evaluation Report should document the adequacy of the application, describe the bases for the findings, and recommend additional i conditions in areas where the application is not adequate. The documentation should include the bases for the conclusions, including a discussion of the areas of review and how the information demonstrates that the acceptance criteria have been met and conclusion that the

. application meets the requirements of 10 CFR Part 76. The documentation should also contain a conclusion relative to the adequacy of the TSR commitments to the program. Note that if there are areas of noncompliance in the Compliance Plan, the issues must be addressed in the appropriate section and referenced in the conclusion.

9.7 References U.S. Code of FederalRegulations, Title 10, Part 20, " Standards for Protection Against Radiation."

O 9-5 Draft NUREG-1671 l

b

Environmental Protection and Waste Management U.S. Code of FederalRegulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

American National Standards Institute, N13.1-1982," Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities." l l

American National Standards Institute, N42.18-1980, " Specification and Performance of On-site instrumentation for Continuously Monitoring Radioactive Effluents."

National Council on Radiation Protection, NCRP Commentary No. 3, Rev.1, " Screening 1 Techniques for Determining Compliance with Environmental Standards," January 1989.

U. S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, Division of Fuel Cycle Safety and Safeguards, Rev. 4.0,"FCLB Materials Licensing Procedures Manual," June 1996.

U.S. Nuclear Regulatory Commission, Regulatory Guide 4.15, Rev. 2," Quality Assurance for Radiological Monitoring Programs (Normal Operations)-Effluent Streams and the Environment," 1995.

U.S. Nuclear Regulatory Commission, Regulatory Guide 4.16, Rev. 2, " Monitoring and deporting Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants," December 1985.

U.S. Nuclear Regulatory Commission, Regulatory Guide 8.37, "ALARA Levels for Effluents from Materials Facilities," July 1993.

Draft NUREG 1671 9-6

r 10.0 CHEMICAL SAFETY 10.1' Responsibility for Review 10.1.1 Primary: Chemical Process Specialist 10.1.2 Secondary: Certification Project Manager 10.1.3 Supporting: Primary Reviewer of Chapter 5.0 10.2 Purpose of Review The purpose of this review is to establish that there is reasonable assurance that the applicant has adequately provided for chemical safety at its facility. Chemical safety addresses the l consequences of potential accidents involving hazardous chemicals', and the controls used to prevent their occurrence or mitigate their consequences. The reviewer will determine that:

l 1. The applicant has identified and evaluated all credible chemical safety hazards, initiating i events, and accident sequences that could result in unacceptable consequences to the l public or workers.

l O 2. The applicant has identified and maintains controls that are adequate to prevent or l V i

mitigate the accident sequences that may result in unacceptable consequences, 10.3 Areas of Review As stated in the 1988 Memorandum of Understanding (MOU) between NRC and the Occupational Safety and Health Administration (OSHA), NRC generally manages chemical safety issues related to (l) radiation risk produced by radioactive materials; (ii) chemical risk l produced by radioactive material; and (iii) plant conditions that affect the safety of radioactive l materials and thus present an increased radiation risk to workers. NRC does NOT manage l plant conditions that result in an occupational risk, but do not affect the safety nor use of radioactive materials under the jurisdiction of NRC A review of accidents that result in the release of hazardous chemicals from the processing of radioactive materials are covered in chapter 5.0, Hazard / Accident Analysis. The Chemical Safety review encompasses the release of hazardous chemicals that have the potential to adversely affect radiological safety. The areas of review are as follows:

'As defined in Draft NUREG-1601, hazardous chemicals are toxic, explosive, l l flammable, corrosive, or reactive to the extent that they can cause significant damage to property or endanger life if not adequately controlled, Also included are substances not normally considered hazardous under ambient conditions, but may, under extreme conditions or i i in combination with other chemicals, produce hazardous situations.

j 10-1 Draft NUREG-1671 ,

l l

Chemical Safety

1. A list of hazardous chemicals that are stored or used on the site, including the locations and amounts stored;

2. A description of potential interactions between chemicals stored and used on site;

3. The methodology selected for identifying and evaluating chemical safety hazards, and the applicant's justification for selecting that methodology;

4. A description of the hazards identified, the accident sequences evaluated, and the potential consequences of a release of hazardous chemicals;

5. The controls or engineered features that prevent or mitigate the evaluated accident sequences;

6. The application of the Configuration Management, Quality Assurance, Maintenance, Training, and Procedures programs and policies to the Chemical Safety Program.

10.4 Review Procedures 10.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to chemical safety for GDP facilities, have been included-

-see Section 10.5.1, " Regulatory Requirements"-- and that the topics discussed in Subsection 10.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the staff resumes the application review.

10.4.2 Safety Evaluation if the applicant's submittal is acceptable, staff should continue the review for chemical safety.

The safety evaluation forms the basis for staff findings, and supports the reviewers' conclusions based on the acceptance criteria of Subsection 10.5.

The primary reviewer should establish that the applicant's chemical safety program provides reasonable assurance that it will function as intended. The primary reviewer should identify the mechanisms that will allow the applicant to identify and correct potential problems.

The secondary reviewer should confirm that the chemical safety program is consistent with other sections of the submittal. Moreover, supporting reviewers should confirm that provisions made in the applicant's submittal are in accordance with specified sections of the SRP. The supporting reviewer should establish that the program described by the applicant provides reasonable assurance the chemical safety program will not impede radiological safety at the facility.

Draft NUREG-1671 10-2 O

Chemical Safety When the safety evaluation is complete, the primary staff reviewer should write a Certification Evaluation Report (CER) for chemical safety, as described in Subsection 10.6.

10.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

10.5.1 Regulatory Requirements Section 76.87 requires the applicant to establish technical safety requirements (TSR).

Chemical safety is one of the listed safety topics and includes the chemical hazards derived from radioactive materials, and plan conditions related to the hazards of chemicals on. or near the site.

10.5.2 Regulatory Guidance U. S. Nuclear Regulatory Commission, Draft NUREG-1601," Chemical Process Safety at Fuel Cycle Facilities," August,1997.

10.5.3 Regulatory Acceptance Criteria The staff will accept the chemical safety program if the following criteria are met:

1. The list of hazardous chemicals results from a review of the entire process, and censiders both consumables used in the process and waste products resulting from the process. The list of hazardous chemicals should include the chemical form, maximum daily inventory, and storage location as appropriate. A material safety data sheet should l be available for all hazardous material listed.

2. The list of potential chemical interactions should consider the interaction between all i chemicals used and stored on the site. The list should identify the potential hazard created by the mixing of the chemicals.

3. The description of the hazard identification and evaluation methodology is acceptable of the reviewer determines that the applicant has provided a cogent description of the methodology and the basis for it's selection. The methodology will be considered acceptable if it meets the requirements of the OSHA Process Safety Management rule, 29 CFR 1910.119.

4. The description of the identified hazards and evaluated accident sequences is considered acceptable if a description is provided of potential accidents that could result from the identified hazards and the possible initiating events (internal and extemal) are given. The accident sequence evaluation should address all modes of operation (startup, shutdown, maintenance, etc.) Justification should be provided if initiating events are deemed incredible and the resulting accident sequences not evaluated. The U 10-3 Draft NUREG-1671

Chemical Safety description should include the possible consequences of the release resulting from the worst case accident sequence, and a description of the method used to calculate the consequences.

5. The controls or engineered features that are expected to prevent or mitigate all accident sequences that could result in an impact on radiological safety should be identified. The level of quality applied to each control should be identified.

6. The application of the Configuration Management, Quality Assurance, Maintenance, Training, and Procedures programs and policies to the Chemical Safety Program is identified by the assignment of a quality rating. the application of these programs, as described in the respective SRP chapters, for the level of quality assigned, is appropriate for the accident consequence of concern.

! 10.6 Evaluation Findings 10.6.1 Introduction After reviewing the applicant's submittal, the staff should report the findings in the certification evaluation report. The certification evaluation report should document the adequacy of the application, describe the bases for the findings, and recommend additional certificate conditions in areas where the application is not adeq' ate. To support the bases for the findings, the certification evaluation report should include a discussion of the areas of review and how the information demonstrates that the acceptance criteria have been met.

10.6.2 Sample Findings An example of how the chemical safety program could be documented in the certification evaluation report follows:

The staff has reviewed the applicant's Chemical Safety Program according to the SRP chapters 10.3,10.4, and 10.5. The staff concludes that the applicant's plan for managing chemical safety and the chemical safety controls established to maintain safe facility operation meet the requirements of 10 Part 76.

[The reviewer will describe the bases for this conclusion, addressing areas that were reviewed, and discuss how the acceptance criteria have been met. The reviewer should include a description of the general type, location, and controls used for the most significant hazards. The reviewer should also describe the applicant's approach to ensuring the quality and reliability of the controls. If acceptance criteria have not been met, the reviewer will recommend certificate conditions here.]

10.7 References U.S. Code of Federal Regulations, Title 10, Part 76," Certification of Gaseous Diffusion Plants."

Draft NUREG-1671 10-4

-( Chemical Safety

U.S. Nuclear Regulatory Commission /U.S. Occupational Safety and Health Administration, Memorandum of Understanding " Worker Protection at NRC Licensed Facilities"[ Federal

! Register No. 53, page 43950, October 21,1988)].

l U.S. Nuclear Regulatory Commission, NUREG-1601," Chemical Process Safety at Fuel Cycle

_ Facilities," August 1997.

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'g 11.0 FIRE SAFETY <

11.1 Responsibility for Review .

l 11.1.1 Primary: Fire Protection Specialist 11.1.2 Secondary: Certification Project Manager 11.1.3 Supporting: Resident inspector staff I i

11.2 Purpose of Review Tho purpose of this review is to ensure that the certificate holder for a gaseous diffusion plant (GDP) has demonstrated that the proposed equipment, facilities, and procedures provide assurance of adequate fire safety sufficient to protect health and minimize danger to life or property in accordance with stated regulatory requirements for those SSCs determined to be important to plant fire safety. This includes those areas that may not of themselves be important to plant fire safety, but which present a fire exposure to those areas identified as important, the result of which could compromise plant fire safety.

11.3 Areas of Review .

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(^ The reviewer should examine the level of plant fire safety proposed or established by the applicant to evaluate the adequacy of plant fire safety to protect health and minimize danger to the life of both plant personnel and the public, to minimize damage to property relied on for safety, and to minimize any significant effect on the quality of the environment as a result of fire. The areas of reviewinclude:

1. Oraanization and Conduct of Ooerations The staff fire protection specialist should verify that the applicant adequately addresses appropriate issues related to the plant fire protection organization and conduct of operations. Such issues include organization, fire prevention, engineering review of design changes, QA, and documentation and record-keeping.

2. Fire Protection Features and Systems l The staff fire protection specialist should verify that the applicant adequately I addresses suitable means of fire prevention, detection, containment, and suppression related to physical plant features and systems. Plant fire protection features and systems include construction features; passive fire-rated barriers; l process and operational features; fire detection and alarm systems; fire suppression i systems and equipment; design-basis documents; and inspection, maintenance, and testing of fire protection measures.

3. Manual Fire-Fiahtina Capability 11-1 Draft NUREG-1671 I

The staff fire protection specialist should verify that the applicant adequately addresses applicable aspects of manual fire-fighting espability for the plant. This includes organization and coordination of onsite and offsite fire-fighting resources, personal protective and fire-fighting equipment, training, and pre-fire emergency planning.

4. Fire Hazard Analysis / Fire Hazard Survey (FHA /FHS) j If the applicant has performed an FHA to support the Hazard Analysis (see Chapter ,

5, Hazard / Accident Analysis) the staff fire protection specialist should verify that the l FHA adequately documents specific fire hazards, fire protection features proposed to control those hazards, and the overall adequacy of plant fire safety. The FHA consists of a systematic analysis of the fire hazards, an identification of specific areas and systems important to plant fire safety, the development of design-basis fire scenarios, an evaluation of anticipated consequences, and a determination of the adequacy of plant fire safety.

Where an FHA has not been performed, an FHS should exist. The FHS will have much of the basic information contained in an FHA but will not include consequence analysis. The FHS should be reviewed and upgraded, if necessary, on an annual basis but should not be expecad to contain the level of analysis provided in an FHA.

11.4 Review Procedures 11.4.1 General Although much of the review will be focused on the Certification Renewal SAR, the reviewer should also rely on the staff's previous certification SER, inspection reports, and other reports obtained from the certificate holder for additionalinformation. Items specifically reviewed in staff documents should be referenced.

11.4.2 Organization and Conduct of Operations The application will be reviewed by the staff fire protection specialist to verify that the licensee has established and implemented a comprehensive fire protection program throughout the facility to ensure safe operation. This review will address specific management controls related to fire protection activities, OA measures, and documentation and record-keeping related to fire protection. Specific provisions related to the establishment and implementation of a comprehensive QA program should be reviewed in accordance with the provisions of Chapter 3.0 of this SRP.

The reviewer should examine the specific management functions identified as having responsibility for fire protection issues. Organization, qualifications, and training with respect to plant fire protection will be examinei The reviewer should evaluate the documentation describing the plant's administrative controls for fire prevention including (1) the control of combustibles and Ignition sources and (2) a formal permit-to-work system.

Draft NUREG-1671 11-2

Fire Safety The reviewer should ensure that the CM system established to control the engineering r design changes and modifications considers the potentialimpact on fire protection.

The reviewer should ensure that the applicant is committed to maintain documentation to evidence a functioning fire protection program. Such documentation should include technical qualifications and experience required of personnel; twining; permit-to-work system; de installation, inspection, maintenance, and testing of fire protection features (both passive an active); manual fire-fighting capability; the fire hazard analysis or survey; fire incident reco and fire protection inspections and audits. Specific provisions related to the establishment an implementation of the comprehensive records management system for the facility should reviewed in accordance with the provisions of Chapter 2.6 of this SRP.

11.4.3 Fire Protection Features and Systems The application should be reviewed by the staff fire protection specialist to verify that the certificate holder's program will minimize danger to life or property through the provision of fire protection features and systems. This review should include plant layout and construction features; fire safety of facility processes, equipment, and storage; and installed fire prote features, including fire detection and alarm systems and fixed fire-suppression systems.

The staff should review the description of the fire protection aspects of the layout, desig T construction of the entire facility. The information described in Chapter 4.0 in this SRP ma

, serve as the basis for the description of the site and facility. However, additional details necessary to evaluate the adequacy of fire protection. If necessary, the reviewer should evaluate plant documentation of architectural floor-plan drawings of all buildings includin process, storage, office, and associated structures such as emergency power, cooling towers, and other related facilities to the extent that fire involving any of these features could affect the safety of radioactive materials; details of combustible construction materials used through the site; fire doors, fire dampers, and barrier-penetration seals; details of the ventilation and drainage system related to fire protection; normal and emergency lighting systems; and mean of access to and egress from each building compartment.

Many details of plant security are outside the scope of fire protection. However, the reviewer should evaluate plant documentation that demonstrates that security measures do not compromise important fire protection features, such as means of egress for site personnel and access to plant areas for fire-fighting personnel.

The staff should review for completeness the description of the process and operational features important to fire protection. The information described in Chapter 4.0 of t suffice as the basis for the facility process description. The reviewer should examine equipment-arrangement drawings showing location of SSCs important to safety (includi power and instrumentation cable routing, where significant). The reviewer should examine the plant's listing of a!! flammable and combustible liquids and gases used in the facility, quantities and location of materials. The reviewer should also examine the plant's listing of affect health or the quality of the environment through a release O 11-3 Draft NUREG 1671

Fire Safety The staff should review the description of the fire protection features designed to detect and suppress fires throughout the f acility and to provide employee notification of fire conditions.

The reviewer should examine the description of the water supply proposed for fire protection use including related aspects of storage, pumping, and distribution-piping systems. The reviewer should examine the description of the fire detection and alarm system, including classification of alarm circuits, the specific equipment type and location in each fire area, local fire alarm means, remote alarm annunciation, and employee notification and evacuation means in the event of fire. The reviewer should also examine the detailed description of fire-suppression systems including specific equipment type and area of coverage within 2 each fire area. System suppression design densities for water based systems (or concentrations for CO or Halon systems) should be compared with the applicable NFPA code requirements.

The staff should review the listing of design-basis dmuments for all construction features and fire protection features (both passive and active). Rei ences to the codes of record for design of all fire protection systems, equipment, and components should be examined, Additional design-basis documents should be examined to evaluate compliance with standard building codes, where applicable.

The reviewer should evaluate the documentation describing the plant's procedures for the inspection, maintenance, and testing (where applicable) of fire protection features (both passive and active). Specific provisions related to the establishment and implementation of the inspection, maintenance, and testing program for fire protection features important to plant fire safety should be reviewed in accordance with the provisions of Chapter 6.0 of this SRP.

11.4.4 Manual Fire-Fighting Capability The application should be reviewed by the staff fire protection specialist to verify the licensee's manual fire-fighting capability. The plant's provisions for the fire-fighting organization, manpower, training, equipment, and pre-fire emergency planning for both onsite and offsite resources should be examined, as applicable.

The reviewer should evaluate the description of the manual fire-fighting capability proposed for the facility. The description includes (1) the establishment and organization of the immediate action response team, (2) the onsite fire trigade team, (3) reliance on qualified offsite resources, or (4) a combination of the approaches, as appropriate for the facility. The reviewer should find the management position (s) identified as having authority and responsibility for overall management, organization, and coordination of fire-fighting activities at the facility, including liaison with offsite resources, where appropriate. Where the fire-fighting response is provided from a designated offsite resource, the reviewer should examine the formal agreement (s) and any documents submitted to demonstrate that the manpower, equipment, and training provided are adequate to protect health and minimize danger to life or property in the event of a fire at the facility.

Where ari onsite fire brigade is provided, the reviewer should evaluate the facility's documentation describing the minimum personnel available for fire-fighting, the fire-fighting equipment provided, the training regimen, and the qualifications required of personnel assigned to the fire brigade. The description of the initial training program and refresher 11-4 I

Draft NUREG-1671 l

Fire Safety training, classroom training sessions, subjects covered in the training program, live-fire (hands-on) training, medical qualifications, fire-drill practice sessions, and coordination of training between onsite and offsite resources (where applicable) should be examined.

The reviewer should evaluate the documentation describing the detailed pre-fire emergency plans developed for all areas of the facility that could compromise plant fire safety (including those plant areas that could expose areas important to fire safety). These pre-fire plans supplement the general Emergency Preparedness Plan discussed in detail in Section 9.0 of the Safety Program Description. The pre-fire emergency plans provide documentation of all appropriate information needed by fire fighters to use safe and effective fire-fighting techniq.les in each fire compartment. The pre-fire emergency plans also assign responsibility for specific actions such as shutting down processes and implementing personnel evacuation.

The reviewer should evaluate the documentation describing the complete set of procedures for the inspection, maintenance, and testing of all manual fire-fighting equipment provided at the facility, as applicable.

11.4.5 FHA /FHS The application should be reviewed by the staff fire protection specialist to determine if specific certificate conditions are proposed that commit the certificate holder to conduct a comprehensive FHA as a means of documenting that the proposed facilities and equipment are

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adequate to protect health and minimize danger to life or property including any significant l

effect on the quality of the environment.

The FHA may exist as a discrete, separate document specifically addressing fire protection and fire safety issues, but its essential information shall be integrated within the HAA, a comprehensive document that addresses all hazards, including fires.

The reviewer should examine a listing of those SSCs identified as important to plant fire safety.

The reviewer should examine samples of the plant's detailed analysis for each of the areas containing these components as well as the analysis of each area that could present a fire exposure to one of these areas identified as being important to plant fire safety.

The staff should determine if, for purposes of the facility's detailed FHA, the facility has been divided into designated fire areas along logical lines, such as functional areas divided by fire-  !

rated barriers or defined spatial separation. The reviewer should examine the physical  ;

description, the postulated fire hazards, and a description of the fire protection features  !

provided. The FHA provides a discussion of the design-basis fire scenario for each fire area and technical documentation indicating that fire protection features provided (including administrative or engineered controls) are adequate to protect health and minimize danger to life or property, including any significant effect on the quality of the environment. Adequacy is determined by the number and quality level of controls and is related to the accident i consequences that the controls are intended to prevent or mitigate.

The reviewer should examine the specific compensatory measures that are identified which should be implemented on a temporary basis in the event that any identified fire protection feature, system, or component is inoperable. Both the compensatory measure to be implemented and the time schedule for its implementation should be examined. The staff

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Fire Safety should assure that an FHA /FHS exists that reflects the current status of the facility and that concludes W a finding that there is no significant deficiency regarding fire protection at the facility.

11.4.6 Requests for Additional Information On the basis of its review, the staff may request that the applicant or licensee provide additional information or modify the submittal to meet the acceptance criteria in Section 11.5 of this SRP.

11.5 Acceptance Criteria 11.5.1 Regulatory Requirements The NRC regulations applicable to the areas of review in this SRP are found in Title 10, CFR Part 76.

11.5.2 Regulatory Guidance Regulatory guidance applicable to the areas of review in this SRP is " Guidance on Fire Protection for Fuel Cycle Facilities," Federa/ Register 57 (No.154),35607-35613, August 10, 1992, which presents the staff's position regarding fire protection for fuel cycle facilities.

National Fire Protection Association (NFPA) standards and codes most appropriate for existing GDP certificate holders to use are listed below. However, other codes may also be applicable j for spec;fic hazards or plant configurations. The reviewer does not need to check applicant )

compliance with all aspects of each standard, in cases where the reviewer considers that the applicant's commitments are deficient or missing, NFPA standards will set the acceptable minimum performance level.

NFPA 10 Portable Fire Extinguishers NFPA 13 Installation of Sprinkler Systems NFPA 15 Water Spray Fixed Systems for Fire Protection NFPA 16 Deluge Foam-Water Sprinkler and Foam-Water Spray Systerns NFPA 20 Centrifugal Fire Pumps NFPA 22 Water Tanks for Private Fire Protection NFPA 24 Installation of Private Fire Service Mains and Their Appurtenances NFPA 25 Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems ,

NFPA 30 Flammable and Combustible Liquids Code l NFPA 45 Fire Protection for Laboratories Using Chemicals NFPA 51B Fire Prevention in Use of C"tting and Welding Processes NFPA 72 National Fire Alarm Code NFPA 101 Life Safety Code NFPA 220 Standard Types of Building Construction ,

NFPA 231 General Storage NFPA 232 Protection of Records '

NFPA 600 Private Fire Brigades NFPA 780 Lightning Protection Draft NUREG-1671 11-6 l

Fire Safety The applicant may also use OSHA reguletions (29CFR PART 1910) as criteria for various aspects of the facility fire protection program. The applicant should clearly describe the basis (NFPA, OSHA, etc) for specific numerical criteria in the facility fire protection program. Such criteria may include design parameters, inspection frequencies, training frequencies and etc.

11.5.3 Regulatory Acceptance Criteria To be acceptable, the application should address the issues in the following paragraphs 11.5.3.X, and the applicant should provide commitments to performance as described in these paragraphs such that the reviewer concludes, with reasonable assurance, that the performance criteria are met.

11.5.3.1 Organization and Conduct of Operations The reviewer should find a detailed discussion in the Safety Program Description providing the following information:

1. Oroanization and Manaaement (i. The specific responsibilities, and required skills and knowledge, of all facility l positions involved in plant fire safety functions and activities are clearly identified in a formal, documented plant policy that includes a functional organization chart that shows the position and authority of personnel involved in fire safety in relation to the i overall plant organization.

b. A single, senior management plant position is assigned the overall responsibility for i plant fire safety. This position is not necessarily a full-time fire safety position only, in an organization where this position does not include responsibility for manual fire- I fighting activities, a formal means of effective liaison and communication is  ;

established to coordinate fire safety efforts of all groups (both onsite and offsite, as appropriate). l

2. Training and Qualifications

a. Qualifications and experience are specified for all positions involved in fire protection functions and activities that affect plant fire safety.

b. All site personnel are suitably trained and instructed in the general fire safety program of the plant.

c. Specialized fire safety training is provided for plant personnel involved in operations and maintenance work at the facility.

d. Specialized fire protection and fire-fighting training is provided for emergency response team members.

3. Fire Prevention Prooram

a. Administrative procedures are established and implemented for control of 11-7 Draft NUREG-1671 ,

l Fire Safety combustible materials. The procedures establish controls for storage, handling, transport, and use of combustible solids, liquids, and gases. For areas identified as important to plant fire safety, the procedures establish controls for combustible construction materials and interior finish, in-situ and transient combustible materials, combustibles associated with normal facility processes and operations, and combustibles introduced during maintenance or modification activities.

b. Controls are established to minimize the accumulation of transient combustibles, particularly packaging materials. Transient combustible materials are removed as soon as the activity is completed (or at regular intervals) or are temporarily stored in suitable containers. Accumulation of combustible materials is not permitted in areas identified as important to plant fire safety. Maintenance, contamination control or other activities which can introduce significant transient combustibles into areas important to safety, should be approved by the facility fire safety organization.

c. A detailed permit-to-work system is established and implemented to control activities that could introduce combustible materials or sources of lgnition or that could degrado fire protection features (passive or active) important to plant fire safety.

These controls include specific provisions for hot-work activities (e.g., welding and cutting) and trained fire-watch personnel.

11.5.3.2 Fire Protection Features and Systems The reviewer should find a summary discussion, in the Safety Program Description, providing the following information:

1. Lightning protection for plant buildings determined to be important to plant fire safety is provided in accordance with the applicable provisions of NFPA Standard 780.

2. A reliable means of liquid containment and/or drainage is provided for all plant facilities.

3. An automatic fire detection system covers areas of the plant important to safety. The appropriate choice of fire-detector type (smoke, heat, flame, or gas), location of I equipment, area of coverage, and electrical circuit supervision are determined in accordance with the applicable provisions of NFPA Standard 72. A sprinkler system, designed and maintained in accordance with NFPA 13 and NFPA 25 may be considered an automatic fire detection system.

4. A reliable fire-alarm system designed and installed in accordance with the applicable provisions of NFPA Standard 72 is provided in the facility.

5. An adequate and a reliable water supply system, designed in accordance with NFPA standards, is provided for fire protection use. The system consists of the water source, dedicated storage facilities, fire pumps, a distribution-piping network, sectional isolation valves, and fire hydrants, as applicable to the facillty. The design and installation of the fire pumps, where provided, are in accordance with the applicable provisions of NFPA Standard 20. The design and instaliation of the distribution piping, valves, and fire hydrants are in accordance with the applicable provisions of NFPA Standard 24.

Draft NUREG-1671 11-S O

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6. Fire-suppression systems and equipment are provided to protect areas determined to i be important to safety. The desian and installation of fire-suppression systems and l equipment are in accordance with the applicable provisions of appropriate NFPA l standards. j I

l 11.5.3.3 Manual Fire-Fighting Capability {

l The reviewer should find a detailed discussion in the Safety Program Description providing the l following information:

1. Plant documentation provides a clear description of the manual fire-fighting capability l proposed. Manual fire-fighting capability may be provided solely by a well-trained and I

fully equipped onsite fire emergency response team, by qualified offsite resources, or by a coordinated combination of the two approaches, as appropriate for the facility.

2. A specific plant position is identified to provide coordination and liaison with offsite fire-fighting resources and to establish a clear line of authority at the fire scene, when any reliance is placed on offsite response.

l 3. Where reliance for manual fire-fighting capability is placed on offsite resources (either for a partial or full response), a forma' agreement is executed that documents the assistance provided by the offsite organization (s). The agreement provides a l description of the minimum fire-fighting manpower and equipment to be provided during l /' fire emergencies and the estimated response time.

4. Where manual fire-fighting capability is provided by an onsite fire emergency response team, the team is identified as being established, equipped, and trained to achieve one i of the following objectives as defined in NFPA Standard 600: l l a. Incipient-stage fire fighting l b. Advanced exterior fire fighting only

c. Interior structural fire fighting only

d. Both advanced exterior and interior structural fire fighting

5. A pre-fire plan is developed for each area of the facility determined to be important to l plant fire safety, including those areas that present a fire exposure to areas important to l plant fire safety. The pre-fire plan supplements the information provided in the Emergency Preparedness Plan. As a minimum, the pre-fire plan identifies access and

, egress routes; location of structures, systems, or components determined to be

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important to plant fire safety; special radiological and toxic hazards; automatic and manually operated fire-suppression measures provided in each fire area; restrictions on the use of specific fire-suppression agents because of nuclear criticality or other concerns; and location of vital heat-sensitive components or equipment.

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i Fire Safety 11.5.3.4 Fire Hazard Analysis / Fire Hazard Survey (FHA /FHS)

If an FHA or FHS is provided to support the Hazard / Accident Analysis, the reviewer should find a summary discussion in the Fire Safety Program Description providing the following information:

1. A comprehensive, systematic FHA / FHA should be integral with the Hazard / Accident Analysis (HAA) (Chapter 5.0 of this SRP). The FHA /FHS reflects current conditions throughout the facility and is reviewed and updated as necessary at defined, regular intervals to document that fire protection measures are adequate to ensure plant fire safety. In addition, the FHA /FHS is revised to incorporate significant changes and modifications to the facility, processes, or inventories, as needed. The level of detall provided in the FHA /FHS reflects the complexity of the facility and the anticipated consequences from fire events (an FHS will normally not contain consequence analysis).

2. For the purpose of the FHA /FHS, the facility is divided into designated fire areas along logical lines, such as functional areas defined by fire-rated barriers or clearly defined spatial separation. Compartmentalization of the facility is identified on drawings showing the locations and fire-resistance ratings of passive fire protection measures such as fire barriers, closures in fire-barrier openings, and locally applied separating elements.

3. As a minimum, for each designated fire area, the following fire hazards shouid be evaluated for potential fire severity and consequent damage:

a. Fire load from solid combustible materials (both quantity and configuration) including those materials of construction,in-situ materials, and anticipated transient combustible materials.

b. Flammable and combustible liquids and gaves used in the process (quantities or flow rates). In the GDPs, the FHA should descr!oe the lubricating and hydraulic oil systems including layout, capacities, operating and emergency procedures and special fire protection features.

c. Process chemicals and materials (both quantity and location) that could present a toxic or radiological hazard or that could significantly affect health or the quality of the environment through a release as a result of a fire emergency. I

d. Potentialignition sources.

4. For each designated fire area determined to be important to plant fire safety, the FHA /FHS provides evaluations of the postulated accident sequences caused or aggravated by fire. Either quantitative or qualitative methods may be used. Where quantitative analytical methods are used, all input data and assumptions are documented.

5. The FHA /FHS defines those fire protection measures that provide reasonable l assurance that the defined consequences of an accident sequence will not occur or will be mitigated. For the identified fire protection measures, the applicant should specify Draft NUREG-1671 11-10

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(d compensatory measures to be implemented on a temporary basis in the event the Fire Safety identified measures do not work. Both the compensatory measure (s) and the time schedule for implementation are established in the application.

11.6 Evaluation Findings The reviewer should verify, on the basis of the information provided by the applicant, along with any other basis, such as an inspection of the applicant's facilities by the staff or by third-party, independent assessments, that the 10 CFR Part 76 requirements have been satisfied and that the information is consistent with the guidance in this SRP. If the applicable criteria are satisfied, the reviewer should document the result of the review in an SER, showing clearly how the applicant meets or exceeds the acceptance criteria in each of the above areas.

The SER concludes with a determination that the applicant's proposed equipment, facilities, and procedures provide a reasonable level of assurance that adequate fire protection is provided and maintained for those SSCs determined to be important to plant fire safety including protection of site personnel, the public, and any significant effect on the quality of the environment.

11.7 Implementation l Except in those cases in which the applicant proposes an acceptable alternative method for i complying with specified portions of the Commission's regulations, the method described herein >

should be used by the staff in its evaluation of conformance with Commission regulations.

11.8 Reference U.S. Code of Federa/ Regulations, Title 29, Part 1910, " Occupational Safety and Health Standards."

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t 1 P 12.0 EMERGENCY MANAGEMENT PROGRAM 12.1 Responsibility for Review 12.1.1 Primary: Emergency Management Specialist 12.1.2 Secondary: Certification Project Manager i l

12.1.3 Supporting: Region lli Emergency Preparedness inspector l l

12.2 Purpose of Review i

The purpose of this review is to confirm that the applicant has committed through an l emergency management program to establish an emergency plan to protect the public, the 1 workers, and the environment during operational emergencies at the facility. The emergency  !

plan provides an organized plan of action, identifies authorities and responsibilities of i emergency response personnel and organizations, and identifies the manpower and equipment  !

available during operational emergencies.

12.3 Areas of Review The staff will review the applicant's submittal for an acceptable level of evidence of planning for emergency preparedness directed at situations involving real or potential radiological or chemical hazards. Review of an application for certification will address those design features, facilities, functions, and equipment that may affect some aspect of emergency planning or the capability of an applicant to cope with plant emergencies. In addition, the review should address coordination with offsite organizations. The review is made against requirements in 10 CFR 76.g1 and the guidance contained in the acceptance criteria below, or acceptable

' requirements are met for justification that an emergency management program is not needed.

12.4 Review Procedures 12.4.1 Acceptance Review The staff review hhould start after a determination has been made by the primary certification Project Manager that the contents of the application, as required by 10 CFR Part 76.35,

" Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to emergency management for GDP facilities, have been included-see Section 12.5.1, ' Regulator /  ;

l Requirements," and that the topics discussed in Subsection 12.3, " Areas of Review," have been addressed.

if significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the primary reviewer starts the application review .

I 12.4.2 Safety Evaluation .

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Emergency Management Program The review consists of an evaluation of the emergency planning information submitted by the applicant using the Acceptance Criteria provided below. Although the bulk of this information should be found in the Emergency Management program section of the application, the primary and secondary reviewers should gain familiarity with the site, including the emergency planning zones, demography, land use, plant design and layout, and major accidents postulated by the applicant presented in relevant sections of the SAR.

It should be recognized that the detailed application of the acceptance criteria will, in many instances, require the reviewer to exercise judgment. The reasonableness and adequacy of the factors involved should be viewed in the light of general emergency planning and response experience, bearing in mind that the broad objective of radiological emergency plans is to protect the public by mitigating the potential health and safety consequences of radiation exposure. Ideally, such plans would ensure neither an overreaction nor an under reaction to unexpected events. Reviewers should be particularly alert, however, to provisions that may result in a possible under reaction to a serious event.

The final step in the review is the primary reviewer's writing of a Safety Evaluation Report. The SER should summarize the conduct of the review, identifies what material in the application forms the basis for a finding of reasonable assurance with respect to the acceptance criteria for an acceptable emergency plan, and presents the bases for license conditions that are necessary to conclude that reasonable assurance is achieved.

12.5 Acceptance Criteria 12.5.1 Regulatory Requirements Section 76.35(f) requires the applicant to submit an emergency plan that meets the requirements of 10 CFR 76.91.

Section 76.91 describes the type of information to be included in the " Emergency Plan." r 12.5.2 Regulatory Guidance Policy and Guidance Directive 84-14, SRP for Emergency Plans for Fuel Cycle and Materials j Licensees, March 1994 )

I Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities," January 1992.

12.5.3 Regulatory Review Criteria The assessment of the adequacy of the applicant's emergency management program should i be based on the requirements in 10 CFR 76.91 and the specific criteria given in the following l sections of the SRP. An acceptable emergency management program should be comprised of

! the following functional areas.

I l 12.5.3.1 Site and Facilities Description Draft NUREG-1671 12-2 l

Emergency Management Program Acceptance should be based on the verification that the applicant has committed to provide in i the " Emergency Plan," a summary of the site and facilities description consistent with the {

summary information provided in chapter 1.0 of this SRP. The information should be of I suffic!ent depth to provide perspective about the facility and the licensed activity such that the adequacy and appropriateness of the applicant's emergency planning, emergency organization, and emergency equipment can be evaluated. The review should verify that the applicant has provided, in the emergency plan, descriptions of onsite emergency facilities. The descriptions should contain the principal and any altemative locations onsite from which control and assessment for an emergency will be exercised. To ensure the adequacy and readiness of the emergency facilities the following design information should be considered in the SAR.

1. Emergency facilities are identified by location and purpose of the facility.

2. . Emergency facilities, equipment, and resources are adequate to support emergency response operations, based on the following:

a. Facilities of adequate size and appropriate location are designated, equipped, and ready for emergency use.

b. Adequate backup facilities required by the emergency plan and supporting documents are available and ready for use.

c. Appropriate equipment and supplies necessary to support emergency response O' activities are accessible during accident conditions.

d. Emergency equipment is inventoried, tested, and serviced on a periodic basis to ensure accountability and reliability.

e. Sufficient reliable primary and backup communications channels are available to accommodate emergency needs. ,

f. Offsite emergency resources are identified, and plans are made to ensure their  !

timely mobilization and use.

g. Engineering materials, such as current as-built drawings and procedures, are readily available in the emergency facilities.

h. Sufficient equipment for personnel protection is available.

3.' Emergency monitoring equipment is available for personnel and area monitoring, as well as for assessing the release of radioactive or hazardous materials to the environment.

4. Onsite facilities are available for initial response level medical treatment and decontamination.

5. Systems are in place, if required, to alert onsite personnel and notify offsite 12-3 Draft NUREG-1671

Emergency Management Program organizations in the event of an emergency.

12.5.3.2 Types of Accidents Acceptance should be based on the verification that the applicant has committed to briefly summarize in the emergency plan each accident for which protective actions may be needed.

The information should be to the degree necessary to ensure the effectiveness of the Emergency Plan. The applicant should provide:

i 1. A brief description of the process and physicallocation where each accident could occur, and for each accident a description of the scenario that has the potential for the greatest radiological / hazardous material impact.

2. A brief description of how the accident could happen (equipment malfunction, instrument failure, human error, etc.).

3. A brief description of complicating factors and possible onsite and offsite consequences.

4. A brief description of nonradioactive hazardous material releases that could impact emergency response efforts.

12.5.3.3 Classification of Accidents Acceptance should be based on the verification that the applicant has committed to appropriate classification in the Emergency Plan of accidents involving potential or actual releases of radioactive or other hazardous material. The applicant's proposed classification system should be described. The system should include the following two classifications as specified in 10 CFR 76.91(c)

• " Alert": Events that may occur, are in progress, or have occurred, that could lead to a release of radioactive materials or hazardous materials, incident to the process, but that the release is not expected to require a response, by offsite response organization, to protect persons offsite.

• " Site area emergency": Events that may occur, are in progress, or have occurred that could lead to a significant release of radioactive materials or hazardous materials, incident to the process, that could require a response, by offsite emergency response organizations, to protect persons offsite.

For each accident treated by the Emergency Plan, the proposed classification and the emergency action levels (EALs) are identified at which an alert or site area emergency will be declared. The plan should not classify a transportation accident more than 1.6 km (1 mile) from l the facility.

1 12.5.3.4 Detection of Accidents l

Draft NUREG-1671 12-4 O

Emergency Management Program Acceptance should be based on the verification that the applicant has committed to providing in the Emergency Plan, adequate means for detecting, and alerting operating staff of, accidents as contained. The information should be to the degree necessary to ensure the effectiveness of the Emergency Plan. The applicant should address the following areas:

1. For each accident, identification of the equipment and/or procedures for detecting and alerting the applicant of the accident.

2. For each item of equipment and/or procedure identified in item 1 above, indication how the accident will be detected, and at what stage of the accident.

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3. For each item of equipment identified in item 1 above, identification of a procedure '

for maintenance and/or calibration.

4. Identification of procedures for identifying other dangers to safe operations (e.g.,

severe weather wamings).

12.5.3.5 Mitigation of Consequences Acceptance should be based on tha verification that the applicant has committed to provide in the Emergency Plan adequate measures for mitigation of consequences for each type of accident identified in Subsection 12.5.3.3 above. Adequate measures include:

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g 1. For each accident treated in the Emergency Plan, a brief description of the means I and equipment provided for safe shutdown and for mitigating the consequences of each type of accident. Mitigation of consequences should address both workers onsite and offsite, as well as the public offsite.

2. In the event of a waming of impending danger from an accident initiator:

a. A description of the criteria that will be used to determine whether a single process or the entire facility will be shut down.

b. A description of the steps that will be taken to ensure a safe orderly shutdown of a single process or the entire facility.

c. A statement of the approximate time required to accomplish a safe shutdown of processes.

12.5.3.6 Assessment of Releases Acceptance should be based on the verification that the applicant has committed to provide in the Emergency Plan, adequate means of assessment of releases of both radioactive material and hazardous chemicals for each type of accident identified in Subsection 12.5.3.3 above. An acceptable submittal should include:

s 1. A description of the procedures to be used to assess the releases of radioactive 12-5 Draft NUREG-1671 l

1 Emergency Management Program material and/or hazardous chemicals by estimating or measuring the release rate or source term.

2. A description of the procedure used to obtain onsite and offsite data to confirm projected doses.

3. A list of references of any computer code used to project doses to the public or i environment.

12.5.3.7 Responsibilities of Applicant Acceptance should be based on the verification that the emergency response organization and administration described by the applicant provide reasonable assurance of effective planning, implementation, coordination with offsite agencies, and control of emergency preparedness activities, and is based on the following:

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a. The organizational structure and responsibilities and authority for each management, supervisory, and professional position are clearly defined, and staffing and resources are described and warranted to be sufficient to accomplish assigned tasks..

b. For facilities located on DOE sites, interfaces with DOE are clearly defined.

c. Interfaces with supporting groups, both onsite and offsite, are clearly defined.

d. Line managers and supervisors observe emerguncy preparedness activities to ensure site readiness to handle emergencies and to identify and correct problems,

e. The onsite emergency response organization as described provides reasonable assurance of effective command and control of the site during the assessment, mitigation, and recovery phase of an accident.

f. Responsibility is assigned for the coordination of onsite and offsite radiation / hazardous material emergency response preparedness.

g. The emergency public information staff provides advance end ongoing information to the media and public on subjects that would be discussed during an emergency, such as radiation, chemical hazards, site operation, and site emergency plans.

h. The schedule of emergency preparedness procedure development provides for availability of procedures to support start-up and operation of new processes / facilities onsite.

l. There should confirmation of mutual cooperation agreerrents existing with local agencies such as fire, police, ambulance / rescue, and medical units.

i J. Timely and effective action is taken to track and correctly identify emergency preparedness deficiencies and their root causes.

Draft NUREG-1671 12-6

O Emergency Management Program U in addition, the applicant has assigned responsibility to assure that the Emergency Plan is developed and maintained current according to the Emergency Management Program and its procedures. Acceptance should be based on the verification of this function and should include:

1. . Identification of the means for ensuring that written Emergency Plan procedures are appropriately developed and implemented by: .

a. Being prupared in such a manner to satisfy the criteria contained in the Emergency Management Program.

b. Controlled within the CM system described in Section 3.1 of this SRP. )

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c. Distributed to all affected parties, including offsite organizations.

2. For maintaining the program, a description of the following is recommended:

provisions for approval of the procedures, making and distributing changes to the procedures, and ensuring that each person responsible for an emergency response function has immediate access to a current copy of emergency procedures.

3. For facilities located on DOE sites, the applicant maintains communication with the DOE organization, to be cognizant of changes to the DOE Site Emergency Plan and the effects on the facility's Emergency Plan.

12.5.3.8 Notification and Coordination Acceptance should be based on the verification that the applicant has committed to provide, in the Emergency Plan, appropriate notification and coordination plans for each type of accident classification described. The notification and coordination should be planned so that unavailability of some personnel, parts of the facility, and some equipment would not prevent the notification and coordination. For facilities located on DOE sites, the notification and coordination plans should include interactions with the DOE organization.

1. The applicant should provide descriptive material that provides reasonable assurance that emergency notification procedures will enable the emergency organization to correctly classify emergencies, notify emergency response personnel, and initiate or recommend appropriate actions, based on the following:

a. Classification of events should be consistent with current Emergency Plan.

b. Notification procedures should minimize distractions of shift operating personnel and include concise messages. Appropriate follow-up messages to offsite authorities should be issued in a timely manner.

c. Information on the nature and magnitude of the hazards should be made available to appropriate emergency response personnel.

12-7 Draft NUREG-1671

Emergency Management Program

d. Radiological and chemical source term data should be made available to the command post, technical support center, emergency operations center, appropriate State personnel, and designated NRC officials.

e. The applicant should provide for offsite field-monitoring team data to be logged, compared with source term data, and used in the protective action recommendation process.

f. Protective action guides should be available and used by appropriate personnel in a timely manner.

g. The emergency public information program should ensure timely dissemination of accurate, reliable, and understandable information. j i

h. Systems should be in place, if required, to alert onsite personnel and notify )

offsite organizations in the event of an emergency. {

2. The applicant should also supply description of how and by whom the following actions should be taken: l

a. Decision to declare an alert or site area emergency,

b. Activation of onsite emergency response organization.

c. Prompt notification, of offsite response authorities, that an alert or site area emergency has been declared, including the applicant's initial recommendation for offsite protective actions (normally within 15 minutes).

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d. Notification to the NRC Operations Center; should be not later than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after  !

a declared emergency. I l

e. Decision on what onsite protective actions to initiate. '

f. Decision on what offsite protective actions to recommend.

g. Decision to request support from offsite organizations including medical assistance for the treatment of contaminated injured onsite workers, when appropriate.

h. Decision to terminate the emergency or enter recovery mode.

3. The applicant should have committed to provide the following to ensure proper j notification and coordination.

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a. A description of the primary and any alternative onsite communication systems. j

b. A description of the frequency of operational tests of the communication 4

Draft NUREG-1671 12-8

i D Emergency Management Program systems.

12.5.3.9 information To Be Communicated Acceptance should be based on the verification that the applicant has committed to provide. in the Emergency Plan, clear, concise information to offsite response organizations, during accident situations previously identified. Areas include:

1. A description of the types of information to be provided concerning facility status, radioactive or hazardous releases, and protective actions.

2. For each accident treated in the Emergency Plan, there should be a description of preplanned protective action recommendations the applicant should make to each appropriate offsite organization.

3. Identification of all offsite officials, including NRC, to be notified, as a function of the classification of the event. For facilities located on DOE facilities, DOE officials should also be identified.

12.5.3.10 Training Acceptance should be based on the verification that the applicant has committed to provide in the Emergency Plan, a training program for both onsite and offsite personnel as part of maintaining emergency preparedness capability.

1. The program should contain performance objectives of the training, as shown in the following examples:

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a. Familiarize appropriate personnel with the Emergency Plan, through related 1 Emergency Management Procedures. I

b. Provide instruction to individuals in their specific duties to ensure effective and expeditious action during an emergency,

c. Provide refresher training.

d. Provide the various emergency organization groups with required training to j ensure an integrated and prompt response to an emergency situation.

2. The program should ensure emergency response personnel possess the necessary '

knowledge, skills, and qualifications. Selection of these personnel is based on the following:

a. The similarity of their emergency response duties to their normal day-to-day authority and responsibilities.

b. Their ability to analyze data and determine appropriate actions in emergency

! 12-9 Draft NUREG-1671

Emergency Management Program situations.

3. The training should include:

a. Information on what might be expected under unusual plant conditions (e.g.,

components and areas with high radiation or contamination levels, magnitudes of radiation or contamination increases, changed nuclide composition, etc.).

b. Diccussion of the procedures applicable to the functional area.

c. A description of the emergency organization and the relationship of the functional area to the entire organization.

d. Communications,

e. Limits of authorities and responsibilities.

f. Protective action decision-making.

g. For a facility located on a DOE site, applicable provisions of the DOE Site Emergency Plan and its interface with the facility Emergency Plan.

4. The program should ensure that local support service organizations that could enter the site (fire / ambulance and rescue) are trained in onsite hazards and site access procedures.

5. The training offered to offsite protective action decision makers includes the relationship between plant conditions and protective measures.

6. The training offered to any mutual-aid pact members such as hospital personnel, ambulance / rescue, police, and fire departments includes the procedures for notification, basic radiation protection, and their expected roles.

7. The applicant has a formally documented and approved Emergency Pian i training / retraining program description (procedure or training manual). The program {

should contain the following elements: i

a. The program should specify the training to be given to each position incumbent .

responsible to perform specific emergency response duties. Such positions l should be specified and should include those personnel who prepare, maintain, and implement the emergency plan.

b. Training should be specified for the use of specialized equipment such as respirators.

c. The program should include team training for those groups of personnel expected to perform coordinated response actions, and this training .should be focused on the most probable accident scenarios.  ;

i Draft NUREG-1671 12-10

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O Emergency Management Program 12.5.3.11 Drills and Exercises Acceptance should be based on the verification that the applicant has committed to conducting periodic drills and exercises in a manner that demonstrates the capability of the organization to plan and perform an effective response to an emergency situation.

= " Exercises" are events that test the integrated capability and a major portion of the basic elements existing with the Emergency Plan and supporting organizations. If the facility is located on a DOE site, the responsible DOE organization should be involved in the exercise. Exercises are conducted on a biennial basis and offsite organizations shall be invited but are not required to participate.

. " Drills" are supervised instruction periods aimed at testing, developing, and maintaining skills in particular operations. Drills should be conducted by individual organizations, independent of the exercises. Offsite organizations are not invited to participate.

1. Periodic drills and exercises should satisfy the fobwing goals and criteria:

a. To demonstrate task-related knowledge through periodic participation by all qualified individuals for each position in the emergency response organization.

b. To assess drill performance against specific scenario objectives, using postulated accidents, that adequately test personnel, equipment, and resources, including previously identified weaknesses.

c. To conduct effective player, controller, evaluator, and observer pre-drill briefings.

d. Data and direction provided by the controllers effectively maintain the time line and do not interfere with the emergency organization's response to exercise scenario events, except where safety considerations are involved.

e. Knowledgeable evaluators are used to identify and record participant performance, scenario strengths and deficiencies, and equipment problems.

f. During exercises simulation is minimized to permit maximum training benefit.

' g. During exercises prestaging of equipment and personnel is minimized to realistically test the activation and staffing of emergency facilities.

h. Emergency exercises demonstrate that resources are effectively used to control the site, to mitigate further damage, and to control radiological / chemical releases; to perform required onsite activities under simulated radiation / airborne and/or waterbome environments and other adverse conditions; to provide accurate assessments and status during an accident; and to initiate recovery. In addition, for facilities located on DOE sites, the emergency exercises demonstrate effective coordination of activities with the responsible DOE organization.

12-11 Draft NUREG-1671

Emergency Management Program

i. Emergency drills demonstrate adequacy of specific operations, including: 1) 4 personnel protection measures, including controlling and minimizing hazards to l individuals during events such as fires, medical emergencies, mitigation ectivities, search and rescue, and other similar events; 2) onsite communications i effectively support emergency response activities; and 3) emergency public information organization disseminates accurate, reliable, timely, and understandable information.

2. The applicant should make provisions for biennial onsite exercises to test response to simulated emergencies and for conducting quarterly communications checks with offsite response organizations. Quarterly communications checks must include the check and update of all necessary telephone numbers.

3. Critiques should be conducted in a timely manner and evaluate the appropriateness of the Emergency Plan, procedures, facilities, equipment, personnel training, and overall effectiveness. The Emergency Plan should include a follow-up plan for correcting identified weaknesses and improving training effectiveness.

12.5.3.12 Recovery and Plant Restoration Acceptance should be based on the verification that the applicant has committed to developing, in the Emergency Plan, plans for restoring the facility to a safe status. The recovery and restoration plans should include:

1. Assessment of the damage to and the status of the facility's capabilities to control radioactive material or hazardous chemicals.

2. Determination of the actions necessary to reduce any ongoing releases of radioactive or other hazardous chemical and to prevent further incidents.

3. Accomplishment of the tasks to meet any required restoration action.

4. A description of the key positions in the recovery organization.

12.5.3.13 Hazardous Chemicals Acceptance should be based on the verification that the applicant certified that it has met responsibilities under the Emergency Planning and Right To Know Act of 1986, Title Ill, Public Law 99-499.

12.5.3.14 Comment from Offsite Response Organizations Acceptance should be based on the verification that the applicant allowed offsite response

! organizations expected to respond in case of an accident 60 days to comment on the l emergency plan. The applicant should provide any comments received from offsite response organizations to the NRC with the emergency plan.

Draft NUREG-1671 12-12 O

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l Emergency Management Program 12.5.3.15 Changes to the Emergency Plan The applicant should be reminded that they may make changes to an approved emergency plan without prior Commission approval as long as the changes do not decrease the effectiveness of the emergency plan and the changes are fumished to the NRC, in accordance with 976.5, and to affected offsite response organizations within 6 months after the change is made.

12.6 Evaluation Findings 12.6.1 Introduction The staff's review should verify that sufficient information has been provided in the SAR to satisfy the intent of 10 CFR Part 76 requirements with respect to the Emergency Management Program and that the information is consistent with the guidance in this SRP.

If the Emergency Plan and procedures satisfy the content requirements in Part 76, and the acceptance criteria described in this SRP, the staff should include a finding in the safety evaluation report that the Emergency Plan and procedures demonstrate that an acceptable Emergency Management Program has been established for responding to the radiological l hazards of an accident involving certified material and to any associated chemical hazards directly incident thereto.

On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

12.6.2 Sample Evaluation Findings The staff has reviewed the Emergency Management Program for (name of facility). On the basis of the following findings, the staff concludes that the Emergency Management Program is acceptable for development, implementation and maintenance of an Emergency Plan and meets the requirements of 10 CFR 76.91.

The applicant has appropriately addressed the functional areas involved in the Emergency Management Program. The information contained in the Emergency Management Prog am describes procedures for the development of an acceptable Emergency Plan. The Emergency >

Plan contains a description of licensed activities, the facility, and the types of accidents that might occur; information on classification of postulated accidents and procedures for notifying and coordinating with offsite authorities; information on emergency response measures and equipment and facilities available to respond to an emergency; and how the applicant should maintain emergency preparedness capability including records and reports. In addition the plan contains plans for restoring the facility to a safe condition.

Meeting the staff's requirements given above provides an acceptable basis for the finding that, insofar as the Emergency Management program is concerned, the applicant meets the technical requirements associated with Part 76 12-13 Draft NUREG-1671

1 Emergency Management Program 12.7 References U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

U.S. Environmental Protection Agency,400-R-92-001," Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," May 1992.

U.S. Nuclear Regulatory Commission, NRC/FCSS Policy and Guidance Directive FC 84-14, Rev.1, " Radiological Contingency Planning Requirements and License Application Reviews,"

March 1994.

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities," January 1992.

U.S. Nuclear Regulatory Commission, NUREG-0696, " Functional Criteria for Emergency Response Facilities," February 1981.

O Draft NUREG-1671 12-14 1

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O tj 13.0 SECURITY AND SAFEGUARDS l

l 13.1 Material Control and Accounting 13.1.1 Responsibility for Review 13.1.1.1 Primary: Material Control and Accounting Specialist 13.1.1.2 Secondary: Certification Project Manager s 13.1.1.3 Supporting: Inspector l 13.1.2 Purpose of Review The purpose of this review is to establish that the Fundamental Nuclear Material Control Plan (FNMCP) submitted by the applicant is adequate to detect the loss or theft of special nuclear material by describing how the plan meets the nine general performance objectives of 10 CFR 74.33 for material control and accounting (MC&A).

13.1.3 Areas of Review

1. The staff reviews the description of the material MC&A management structure.

2. The staff reviews the description of the program for measurement of source material (SM) and special nuclear material (SNM).

3. The staff reviews the description of the measurement control program which ensures measurements of SM and SNM are accurate.

4. The staff reviews the description of the physicalinventory program.

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5. The staff reviews the description of the detection program which designed to detect I unauthorized production of SNM.

6. The staff reviews the description of the item control program for keeping inventory of SN l and SNM.  :

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7. The staff reviews the description of the resolution program that resolves shipper receiver l I

differences. (SRDs).

8. The staff reviews the description of the audit or assessment program.

9. The staff reviews the description of the recordkeeping program. l 13.1.4 Review Procedures i O I l

V 13-1 Draft NUREG-1671

Security and Safeguards The staff review should start with a determination by the primary reviewer that the content of the application as required by $76.35," Contents of Initial Application" and 676.36," Annual Renewal" with respect to [ subject area] for GDP facilities has been included--See Section 13.1.5.1 " Regulatory Requirements, and that the topics discussed in Subsection 13.1.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the application should be requested to submit additional material before the staff resumes the application review.

1. The staff reviews the MC&A management structure to ensure (a) clear overall responsibility for MC&A functions, (b) independence of MC&A management from production responsibilities, (c) separation of key MC&A responsibilities from each other, (d) use of approved written MC&A procedures, and (e) the periodic review of these procedures.

2. The staff reviews the measurement program of SM and SNM to ensure that all candidates of SM and SNM in accounting records are based on measured values.

3. The staff reviews the measurement control program to ensure that (a) measurement biases are estimated, minimized through implementation of the program, and eliminated (if statistically significant) from inventory difference values of record; (b) all MC&A measurement systems are controlled so that twice the standard error of the inventory difference, based on all measurement contributions, is less than tne greater of 5,000 grams of U-235 or 0.25 percent of the active inventory for each total plant material balance; and (c) any measurements performed under contract are controlled so that the applicant can satisfy the requirements of 3(a) and 3(b).

4. The staff reviews the physicalinventory program to ensure that it provides for (a) performing (unless otherwise required to satisfy 10 CFR Part 75) a dynamic (i.e.,

nonshutdown) physical inventory of all in-recess uranium and U-235 at least every 65 days and performing astatic physical inventory of all other uranium and U-235 contained in enriched, normal, and depleted uranium located outside or the enrichment processing equipment at least every 370 calendar days (with static physical inventories being conducted in conjunction with a dynamic physical inventory of in-process uranium and U 235 so as to provide a total plant material balance at least every 370 calendar days); and (b) reconciling and adjusting the book inventory to the results of the static physical inventory and resoMng, or reporting an inability to resolve, any inventory difference that is rejected by a statistical test (which has a 90 percent power of detecting a discrepancy of a quantity of U-235 established by NRC on a site-specific basis) within 60 days after a start of each static physical inventory.

5. The staff reviews the detection program to determine if the program is independent of production and it provides a high degree of assurance of detecting (a) production of uranium enriched to 10 wt% or more in U 235 to the extent that SNM of moderate strategic significance could be produced within 370 calendar days, (b) production of uranium enriched to 20 wt% or more in U-235, and (c) unauthorized production or uranium of low strategic significance.

Draft NUREG-1671 13-2

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Security and Safeguards !

6. The staff reviews the item control program to determine it will assure that (a) current I information is maintained for items with respect to identify, uranium and U-235 content, and stored location; and (b) items are stored and handled, or subsequently measured, in a manner so that the amount of U-235 involved in any unauthorized removal of items, or uranium from items, greater than 500 grams of U-235 will be detected. Exempted from 6(a) and 6(b) are applicant identified items each containing less than 500 grams of U.

. 235 up to a cumulative total of 50 kilograms of U-235 and items existing for less than j 14 calendar days. i l 7. The staff reviews the resolution program to determine it assures that any shipper-receiver differences (SRDs) are resolved that are statistically significant and exceed 500 grams of U 235 on (a) an individual batch basis and (b) a total shipment basis for all SM and SNM.

8. The staff reviews the audit or assessment program to determine that it (a) independently l l assesses the effectiveness of MC&A system at least every 24 months, (b) documents I the results of the above assessment, (c) documents management's findings on whether the MC&A system is currently effective, and (d) documents any actions taken on recommendations from prior assessments.

9. The staff reviews the description of the recordkeeping program to determine that the l program shall establish records which will demonstrate that the performance objectives l of 10 CFR 74.33 haw been met and that the program will maintain those records in an I

auditable form, avdable for inspection, for at least 3 years, unless longer retention time j is required by 10 CFR Part 75. The program must specify what form those records will

! be kept. I l 13.1.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

l-13.1.5.1 Regulatory Requirements Section 76.36 (c) requires that the application for renewal reference information from previous l

applications, statements or reports filed with the Commission, provided that the reference is l

clear and specific; and contain any proposed changes in the existing certificate of compliance

and hier alja any proposed changes in the Fundamental Nuclear Material Control Plan (FNMCP).

13.1.5.2 Regulatory Guidance Regulatory Guide 5.6.7, " Material Control and Accounting for Uranium Enrichment Facilities Authorized to Produced Special Nuclear Material of Low Strategic Significance," December 1993.

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l Security and Safeguards 13.1.5.3 Regulatory Review Criteria NRC staff should use the following MC&A regulatory review criteria, or information demonstrating acceptable alternatives, it its review of the SAR, where acceptability should be risk-informed and performance based.

13.1.5.3.1 Performance Objectives Performanc9 objectives and associated general system features and capabilities would be found acceptable if they meet the format and criteria specified on pages 3-7 of NUREG/CR-5734, November 1991. Using a risk-informed, performance-based approach, reviewers should give high priority to the detection program, which should provide high assurance of detecting both illicit production of enriched uranium and unauthorized removal, including possible clandestine theft or diversion.

13.1.5.3.2 Organization The applicant's organization for developing and implementing the MC&A program -including procedures and training and qualification programs - would be found acceptable if they meet the format and criteria specified in Section 1 of NUREG/CR-5734, November 1991. The organization's management structure particularly should demonstrate the separation or over checks built into the system. In addition, it should address interactions between the two GDPs, which work in tandem.

13.1.5.3.3 Procedures Procedures would be found acceptable if they meet the format and criteria specified in Section 1.3.2 of NUREG/CR-5734, November 1991. In addition, procedures should address special problems that might arise between the two GDPs, working in tandem, e.g., a shorter term measurement bias and its effects on inventories, transfers, loss indicators, and investigations.

13.1.5.3.4 Measurements Measurement programs would be found acceptable if they meet the format and criteria specified in Section 2 of NUREG/CR-5734, November 1991. Additional applicable acceptance criteria are listed in Section 2.5 of NUREG-1065, Rev. 2, November 1995.

13.1.5.3.5 Measurement Control Measurement control programs would be found acceptable if they meet the format and criteria j specified in Section 3 of NUREG/CR-5734, November 1991. Additional applicable acceptance I criteria are listed in Section 3.6 of NUREG-1065, Rev 2, November 1995. Furthermore, l interactions between the two GDPs, working in tandem, should be considered in the identification, control, and investigation of bias effects. The applicant must demonstrate the 4

adequacy of annual (or other rate) updating of key measurement variances. l l

Draft NUREG-1671 13-4 9 l

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Security and Safeguards 13.1.5.3.6 Statistics Statistics programs would be found acceptable if they meet the format and criteria specified in Section 4 of NUREG/CR-5734, November 1991. Bias correction acceptance criteria, which are not covered by NUREG-5734, are provided in Section 4.3 of NUREG-1065, Rev. 2.

November 1995.

13.1.5.3.7 Physical inventories Physical inventories would be found acceptable if they meet the format and criteria specified in Section 5 of NUREG/CR-5734, November 1991. Additional applicable acceptance criteria are listed in Section 5.7 of NUREG-1065, Rev. 2, November 1995, particularly in the use of sampling plans, in estimating residual holdup and in determining detection quantities for inventory difference response action levels. Section 5.4 of NUREG/CR-5734 addresses the need for the FNMCP to contain sufficient information showing how the total in-process inventory .

for both uranium and U-235 is obtained. This should include a key description of the dynamic I inventory methodology, including cutoff and inventory minimization procedures, particularly those cases involving higher than expected enrichments and the traceability and documentation i of software for calculating cascade inventories. '

13.1.5.3.8 ftem Control item control measures would be found acceptable if they meet the format and criteria specified in Section 6 of NUREG/CR-5734, November 1991. More specific applicable acceptance criteria are listed in Section 6.7 of NUREG-1065, Rev. 2, November 1995, e.g., regarding the detection of falsification, information on the chemical form and quantity of material, the updating of item records, and exemptions.

13.1.5.3.9 Shipper-Receiver Comparisons The program for shipper-receiver comparisons would be found acceptable if it meets the format and criteria specified in Section 7 of NUREG/CR-5734, November 1991, and the acceptance criteria in Section 7.5 of NUREG-1065, Rev. 2, November 1995, particularly hypothesis tests for detecting and acting on significant Pipper-receiver differences on the basis of both individual transfers and trends over a series of shipments. Particular attention should be given to interactions between the two GDPs in tandem, especially biases that could affect inventory difference determinations at both facilities. Special attention should be given to the power of sampling plans used to determine receipt quantities, particularly in assuring the detection of

. significant uranium or U-235 content shifts for either an extended or shorter time, particularly in the absence of stable conditions.

13.1.5.3.10 Assessment and Review of the Material Control and Accounting Program The program for assessing and reviewing the MC&A program would be found acceptable if it meets the format and criteria specified in Section 8 of NUREG/CR-5734, November 1991, as well as the acceptance criteria specifically listed in Section 8.4 of NUREG-1065, Rev. 2, 13-5 Draft NUREG-1671

f Security and Safeguards November 1995. The selection of assessment team members should assure independence, especially if they are including members of the MC&A staff from the other GDP, working in tandem.

13.1.5.3.11 Program for Precluding and Detecting Unauthorized Production of Enriched Uranium The program for precluding and detecting the unauthorized production of enriched uranium would be found acceptable if it meets the format and criteria specified in Section 9 of NUREG/CR-5734, November 1991 and detection criteria in Section 85505-03.03 of K/ITP-468.

Scenarios shall include potential SNM withdrawal / removal paths where resulting diversion path analyses would provide a framework for an overall risk-informed, performance-based MC&A program.

13.1.5.3.12 Resolving Indications of Unauthorized Production of Enriched Uranium and of Missing Uranium The program for resolving indications of missing uranium and of the unauthorized production of enriched uranium would be found acceptable if it meets the format and criteria specified in Section 10 of NUREG/CR-5734, November 1991. In addition, the certificate holder shall have ready and provide informational aid for assisting in investigations and the recovery of missing uranium or for assisting in the investigation of unauthorized enrichment, as stipulated in Section 11 of NUREG/CR-5734, November 1991.

13.1.5.3.13 Recordkeeping The program for recordkeeping would be found acceptable if it meets the format and criteria specified in Sections 11 and 12 of NUREG/CR-5734, November 1991, which inter gl.ig includes over checks for detecting missing or falsified data and records, and reports including the assurance of the integrity of computerized information systems and calculations. In addition, acceptance criteria in Section 11.3 of NUREG-1065, Rev. 2, November 1995, shall be met, particularly required systems capabilities for tracing records back to original source data.

13.1.6 Evaluation Findings 13.1.6.1 introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of 76.36," Annual Renewal," requirements with respect to the [ subject area) and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. the staff can document its review as follows:

13.1.6.2 Evaluation Findings 13.1.6.2.1 Evaluation Findings for Performance Objective Draft NUREG-1671 13-6

Secli'v and Safeguards  !

The staff has reviewed the performance objectives and general system features and capabilities for (name of facility] according to SRP Section 13.1.5.3.1.

The applicant has adequately described and documented perforrence objectives and associated system features and capabilities, and the staff finds that the applicant is in compliance with those parts of $76.36 relating to that area. Moreover, the applicant would meet ,

objectives specified in K/ITP-478, July 1992, yig. Inspection Objectives 85501-01 to 85509-01. '

13.1.6.2.2 Evaluation Findings for Organization The staff has reviewed the organization for [name of facility) according to SRP Section 13.1.5.3.2.

i The applicant has adequately described and documented this organization, and the staff finds j that the applicant is in compliance with those parts of $76.36 relating to that area. Moreover, i the applicant would meet management structure criteria specified in Section 85501-03.03 on pages 2-11 of K/ITP-478, July 1992.

13.1.6.2.3 EvalJion Findings for Procedures The staff has reviewed the procedures for (name of facility) according to Section 13.1.5.3.3.  ;

The applicant has adequately described and documented facility procedures, and the staff finds td the applicant is in compliance with these pans of $76.3S relating to that area. Moreover, the applicant would meet procedures criteria for major MC&A functions in Section 85501-03.0328 of K/ITP-478, July 1992.

13.1.6.2.4 Evaluation Findings for Measurements  ;

The staff has reviewed the measurement systems programs for (name of facility) according to Section 13.1.5.3.3.

The applicant has adequately described and documented measurements to be performed, and the staff finds that the applicant is in compliance with theso parts of $76.36 relating to that aree.

Moreover, the applicant would meet measurements criteria in Section 85502-03.03 on pages 14-19 of K/IT' ~478, July 1992.

13.1.6.2.5 Evaluation Findings for Measurement Control The staff has reviewed the measurement control programs for (name of facility) according to Section 13,1.5.3.

The appiscant has adequately described and docamented measurement control, and the staff l finds that the applicant is in compliance with these parts of 976.36 relating to that area. I Moreover, the applicant would meet measurement control criteria in Section 85503-03.03 on pages 22-29 of K/ITP-478, July 1992.

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Security and Safeguards 13.1.6.2.6 Evaluation Findings for Statistics The staff has reviewed the statistics program for (mane of facility] according to Section 13.1.5.3.

The applicant has adequately described and docurnented the statistics program, and the stafi finds that the appUcant is in compliance with these parts of 676.36 relating to that area.

Moreover, the applicant would meet statistical criteria specified in relevant sections of K/ITP-478, July 1992, particularly Sections 85503-03.0326 for calculating standard deviations 85504-03.0324 for establishing control limits, 85504-03.0325 for trend analyses and 85504-03.0326 for inventories.

13.1.6.2.7 Evaluation Findings for Physical Inventories The staff has reviewed the physical inventory program for [name of facility) according to Section 13.1.5.3.7.

The applicant has adequately described and documented the conduct of physical inventories, including response actions on resulting inventory differences, and the staff find 3 that the applicant is in compliance with these parts of $76.36 relating to that area. Moreover, the applicant would meet physicalinventory criteria in Section 85504-03.03 on pages 33-40 of K/ITP-478, July 1992.

13.1.6.2.8 Evaluation Findings for item Control The staff has reviewed the item control program for (name of facility) according to Section 13.1.5.3.

The applicant has adequately described and documented item control measures, and the staff finds that the applicant is in compliance with these parts of 676.36 relating to that area.

Moreover, the applicant would meet item control criteria in Section 03.03 on pages 50-59 of K/lTP-478, July 1992.

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13.1.6.2.9 Evaluation Findings for Shipper-Receiver Comparisons The staff has reviewed the program for shipper-receiver comparisons for [name of facility) according to SRP Section 13.1.5.3.9.

The applicant has adequately described and documented this program for shipper-receiver comparisons, and the staff finds that the applicant is in compbnce with these parts of 676.36 relating to that area. Moreover, the applicant would meet criteria for shipper-receiver comparisons specified in Sections 03.0321 (Evaluation of SRDs) and 03.0322 (Resolution of SRDs) of K/ITP-478, July 1992. The latter (subparagraph 6) specifically calls for NRC verification that SRD data is subjected to trend analysis to detect measurement b!as and/or cumulative materialloss.

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13.1.6.2.10 Evaluation Findings for Assessment and Review of the Material Control and Accounting Program '

The staff has reviewed the program for assessing and reviewing the MC&A Program for [name of facility) according to SRP Section 13.1.5.10.

The applicant has adequately described and documented the Program for the Assessment and I Review of the MC&A Program, and the staff finds that the applicant is in compliance with those parts of 976.36 relating to that area. Moreover, the applicant would meet criteria in Section 85508-03.03 on pages 72-75 of K/ITP-468, July 1992.

13.1.6.2.11 Evaluation Findings for Precluding and Detecting Unauthorized Production of Enriched Uranium The staff has reviewed the program for precluding and detecting the unauthorized production and withdrawal of enriched uranium for [name of facility) according to SRP Section 13.1.5.3.11.

The applicant has adequately described and documented the program for precluding the unau;horized production and removal of enriched uranium, and the stati finds that the applicant is in compliance with those parts of 976.36 relating to this area. Moreover, the applicant would meet criteria in Section 85505-03.03 on pages 42-48 of K/ITP-468, July 1992.

f 13.1.6.2.12 Evaluation Findings for Resolving Indications of Unauthorized Production of Enriched Uranium and of Missing Uranium The staff has reviewed the program for resolving indications of missing uranium and of the unauthorized production of enriched uranium for [name of facility) according to SRP Section 13.1.5.3.12.

The applicant has adequately described and documented the program for resolving indications of missing uranium and of the unauthorized production of enriched uranium, and the staff finds that the applicant is in compliance with those parts of 976.36 relating to that area. Moreover, the applicant would meet criteria in Sections 85507-03.0323 to 85507-03.0327 on pages 64-70 of K/ITP-468, July 1992.

13.1.6.2.13 Evaluation Findings for Recordkeeping The staff has reviewed the program and controls for ensuring an accurate and reliable record system for [name of facility) according to SRP Section 1301.5.3.13.

The applicant has adequately described and documented the recordkeeping program, and the staff finds that the applicant is in compliance with those parts of 976.36 relating to that area.

Moreover, the applicant would meet criteria in Section 85509-03.03 on pages 78-82 of K/ITP-468, July 1992, which includes, inter-alia, assurance as to the completeness and accuracy of physical inventory (NRC Form 327) and other reports.

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Security and Safeguards 13.1.7 References U.S. Code of Federal Regulations, Title 10, Parts 74, " Material Control and Accounting of I Special Nuclear Material."

U.S. Code of Federal Regulations, Title 10, Part 76," Certification of Gaseous Diffusion Plants."

Fundamental Nuclear Material Control Plan, Paducah Gaseous Diffusion Plant. (Contact the Paducah Project Manager for the latest revision.)

Fundamental Nuclear Material Control Plan, Portsmouth Gaseous Diffusion Plant. (Contact the Portsmouth Project Manager for the latest revision.)

U.S. Department of Energy, DOE /ORO-2026, " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant." (Contact the Paducah Project Manager for the latest revision.)

U.S. Department of Energy, DOE /ORO-2027," Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant."(Contact the Portsmouth Project Manager for the latest revision.)

Material control and accountability inspection reports since March 3,1997.

Compliance Evaluation Report for the Renewal of Certificate of Compliance GDP-1. (Contact the Paducah Project Manager for the latest revision.)

Compliance Evaluation Report for the Renewal of Certificate of Compliance GDP-2. (Contact the Portsmouth Project Manager for the latest revision.)

Draft NUREG-1671 13-10 9

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i Security and Safeguards 13.2 Physical Security and Transportation Protection of Special Nuclear Material of Low Strategic Significance at GDP Facilities 13.2.1 Responsibility for Review 13.2.1.1 Primary: Physical Protection Specialist 13.2.1.2 Secondary: Certification Project Manager 13.2.1.3 Supporting: Region 3 Physical Protection inspector 13.2.2 Purpose of Review The purpose of this review is to confirm that the applicant that has the authority to possess, use or transport special nuclear material of low strategic significance (SNM LSS), has established a physical and transportation protection plan to protect the SNM-LSS from theft.

13.2.3 Areas of Review The staff will review the applicant's submittal for an acceptable level of evidence of planning for thefts of SNM-LSS.

13.2.4 Review Procedures The staff review should start after a determination has been made by the primary certification Project Manager that the application as required by 676.35, " Contents of initial application" and 676.36, " Annual renewal" with respect to physical and transportation protection for GDP facilities has been included--See Section 13.2.5.1 " Regulatory Requirements, and that the topics discussed in Subsection 13.2.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to  !

submit additional material before the primary reviewer starts the application review.

13.2.5 Acceptance Criter!a The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

13.2.5.1 Regulatory Requirements Section 73.67(f) and 73.67(g) describe the type of information that should be included in the Physical and Transportation Protection Plans. The applicant must meet the general performance objectives of 10 CFR 73.67(a), submit a physical security plan per 10 CFR 73.67(c), and comply with the measures for physical protection of SNM LSS as required by O 13-11 Draft NUREG-1671 l

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Security and Safeguards Q73.67(f) for fixed sites, and (g) for in transit.

Section 73.71, Reporting of Safeguards Events, describes how and when events should be reported and maintained.

13.2.5.2 Regulatory Guidance Regulatory Guide 5.59, Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance, February 1983 Regulatory Guide 5.62, Reporting of Physical Security Events 13.2.5.3 Regulatory Review Criteria The assessment of the adequacy of the applicant's physical and transportation protection plan should be based on the requirements in 10 CFR 76.117 and the specific criteria given in the following sections of the SRP.

If the applicant should at any time increase its possession limits so that they possess formula or moderate quantities of SNM, different regulations within Subpart E apply. Subpart E,76.113 addresses formula quantities of SNM and 76.115 addresses moderate quantities of SNM.

Regulatory requirements and guidance are the same for moderate quantities of SNM but different for formula quantities of SNM. See the division's senior physical protection specialist for the specific regulatory requirements and guidance that would apply.

An acceptable physical and transportation protection program should be comprised of the following functional areas.

13.2.5.3.1 Storage or Use of Material Acceptance should be based on the verification that the applicant has committed to store or use the material within a controlled access area (CAA). The applicant should describo:

a. The CAAs and normal routes of ingress and egress into each CAA.

b. The means of providing isolation of the CAAs and how entry is channeled through established access control points in the CAA and the means and criteria used at established control points for controlling access into the CAA.

c. The types of material used in each CAA.

13.2.5.3.2 Control of Access to a CAA Acceptance should be based on the verification that the applicant has committed to control personnel and vehicular access into the controlled access area to detect unauthorized Draft NUREG-1671 13-12 O

Security and Safeguards penetrations, activities or unauthorized removal of SNM-LSS from the CAA. The app 5nt should describe: i

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a. Procedures for detecting and responding to unauthorized penetrations or activities. A description of any intrusion detection devices used, type of annunciation and location, and tamper resistant features should be included.

b. Procedures used for searching personnel and packages that could be used for theft or sabotage.  !

c. Procedures used for escorting uncleared visitors into CAAs.-

'13.2.5.3.3 Response to Unauthorized Entry Acceptance should be based on the verification that the applicant has committed to responding to actual or perceived unauthorized penetrations or activities in the controIIed access area. The applicant should describe the security organization that will be responsible for assessing and -

responding to any unauthorized penetrations or activities.

13.2.5.3.4 Response Procedures

, Acceptance should be based on the verification that the applicant has developed response procedures for dealing with threats of thefts or thefts of the SNM-LGa The applicant should also commit to retaining a copy of the current response procedures as a record for three years after the close of period for which the applicant possesses the special nuclear material. Copies of superseded material much be retained for three years after each change. The applicant should describe:

a. Events for which procedures will be developed.

b. Expected response for each event identified. l

c. Expected duties and responsibilities of the security organization and management involved in the response.

d. Local law enforcement assistance available, their response capabilities and any l

agreement made with them to respond.

l 13.2.5.3.5 Transportation Protection Acceptance should be based on the verification that the applicant has: I

a. Procedures for advance notification for shipment and confirmation of arrival for each shipment of SNM-LSS.

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I Security and Safeguards

b. Procedures for use of containers and seals, along with a description of the seals, during transport and inspections prior to shipment, and on receipt of shipments of SNM-LSS.

c. Arrangements for the in-transit physical protection of the SNM-LSS, and has response procedures for dealing with threats of theft or thefts of this material, and has made arrangements to conduct a tace investigation of any shipments that is lost or unaccounted for, and to notify the NRC Operations Center within one hour after loss, recovery or accounting for such lost shipment.

13.2.5.3.6 Export and import Shipments The reviewer should verify that if the applicant is planning on importing or exporting SNM-LSS NRC has approved importing or exporting. The applicant should comply with the appropriate requirements in 13.2.5.3.5 listed above.

13.2.6 Evaluation Findings 13.2.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of 676.36, " Annual renewal," requirements with respect to the Physical and Transportation Protection plans and that the information provided is consistent with the guidance in this SRP chapter. If the Physical and Transportation Protection Plans and associated procedures satisfy the content requirements in Part 76, and the acceptance criteria described in this SRP chapter, the staff should include a finding in the safety evaluation report that the Physical and Transportation Protection Plan and associated procedures demonstrate that an acceptable Physical and Transportation Protection Program has been established for responding to threats or thefts of SNM-LSS.

On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

13.2.6.2 Sample Evaluation Findings The staff has reviewed the physical and transportation protection plans for [name of facility) according to the SRP sections 13.3,13.4 and 13.5. On the basis of the following findings, the staff concludes that the physical and transportation protection plans are acceptable for implementation.

The applicant has adequately described and documented physical and transportation protection and has provided a plan to address those parts of 676.117 relating to physical and transportation protection. Meeting the staff's requirements given above provides an acceptable basis for the finding that, insofar as physical and transportation protection is concemed, the applicant meets the associated requirements with Part 76, Subpart E.

Draft NUREG-1671 13-14

Security and Safeguards 13.2.7 References 1

U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants." l U.S. Nuclear Regulatory Commission, Regulatory Guide 5.59, " Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance," February 1983.

U.S. Code of Federa/ Regulations, Title 10, Part 73.71, " Reporting of Safeguards Events."

U.S. Code of Federal Regulations, Title 10, Part 73, Appendix G, " Reportable Safeguards Events."

U.S. Nuclear Regulatory Commission, Regulatory Guide 5.62," Reporting of Physical Security Events."

U.S. Nuclear Regulatory Commission, Regulatory Guide 5.15, " Security Seals."

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Security and Safeguards 13.3 Protection of Classified Matter 13.3.1 Responsibility for Review 13.3.1.1 Pe! mary: Classified Matter Specialist-Division of Facilities and Security 13.3.1.2 Secondary: Certification Project Manager 13.3.1.3 Supporting: None 13.3.2 Purpose of Review The purpose of this review is to confirm that the applicant has the authority to use, process, store, reproduce, transmit, transport, or destroy National Security information (NSI) and/or Restricted Data (RD).

13.3.3 Areas of Review The staff will review the applicant's submittal for an acceptable level of protection for using, processing, storing, reproducing, transmitting, transporting, classifying and safeguarding classified information.

13.3.4 Review Procedures The staff review should start after a determination has been made by the primary certification Project Manager that the application as required by 976.35, " Contents of initial application" and

$76.36, " Annual renewal" with respect to classified material at GDP facilities has been included-

-See Section 13.3.5.1 " Regulatory Requirements," and that the topics discussed in Subsection 13.3.3, " Areas of Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to submit additional material before the primary reviewer starts the application review.

13.3.5 Acceptance Criteria l The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to  ;

this SRP are listed in the following sections.

1 l 13.3.5.1 Regulatory Requirements The applicant must address the requirements in 76.60(l) that require the applicant to comply with 10 CFR Part 95. The requirements for security facility approval and for safeguarding of National Security Information (NSI) and Restricted Data (RD) are contained in 10 CFR Part 95.

Draft NUREG-1671 13-16 l

O Security and Safeguards 13.3.5.2 Regulatory Guidance

" Standard Practice Procedures Plan Standard Format and Content for the Protection of

~ Classified Matter for NRC Licensee, Certificate Holder and Related Organizations." Contact the Division of Facilities and Security for the most current version.

I 13.3.5.3 Regulatory Review Criteria The assessment of the adequacy of the applicant's Classified Matter Plan should be based on 10 CFR Part 95. The information provided should be of sufficient depth to provide perspective about the adequacy and appropriateness of the applicant's Classified Matter Plan. Acceptance should be based on the verification that the applicant has committed to provide in the Classified Matter Plan, a summary of the applicable sections of Part 95.

13.3.6 Evaluation Findings 13.3.6.1 Introduction The staff's review should verify that sufficient information has been provided in the application for renewal of certification to satisfy the intent of $76.36, " Annual renewal," requirements with respect to the Classified Matter Plan and that the information provided is consistent with the

( guidance in this SRP chapter. .The staff should be able to determine that the applicant has provided sufficient information to determine if the applicant can use, process, store, reproduce, transmit, transport, or destroy NSI and/or RD in connection with NRC activities, in a manner that will provide adequate protection and prevent unauthorized access. The reviewer should i verify that the applicant will not be using, processing, storing, reproducing, transmitting, l classifying, transporting, or destroying Top Secret information since no such information is authorized under Part 95. If the Classified Matter Plan and assraiated procedures satisfy the applicable provisions of $76.60(l), and the acceptance criteria described in this SRP chapter, the staff should include a finding in the safety evaluation report that the Classified Matter Plan ,

and associated procedures demonstrate that an acceptable program has been established for l using, processing, storing, reproducing, classifying, transmitting, transporting, and destroying NSI and RD.

On the basis of this information, the staff should be able to conclude that this evaluation is 1 complete. The staff can document its review as follows:

13.3.6.2 Sample Evaluation Findings The staff has reviewed the Classified Matter Plan for (name of facility] according to SRP Section 13.3, Protection of Classified Matter. On the basis of the following finding, the staff concludes that the Classified Matter Plan is acceptable for implementation.

The applicant has adequately described and documented 1% protection of classified matter and 13-17 Draft NUREG-1671 L

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Security and Safeguards has provided a plan to address those parts of 10 CFR Part 95 relating to classified matter ,

protection. Meeting the staff's requirements as given above provides an acceptable basis for the finding that, insofar as classified matter protection is concerned, the applicant meets the applicable requirements within Part 95, and therefore 676.60(l).

13.3.7 References U.S. Code of Federa/ Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

U.S. Code of Federal Regulations, Title 10, Part 95, " Security Faci'iity Approval and Safeguarding of National Security Irdormation and Restricted Data."

" Standard Practice Procedures Plan Standard Format and Content for the Protection of Classified Matter for NRC Licensee, Certificate Holder and Related Organizations." (Contact the Division of Facilities and Security for the most current version.)

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14.0 DECOMMISSIONING FUNDING

PLAN AND FINANCIAL ASSURANCE MECHANISMS 14.1 Responsibility for Review 14.1.1 Primary: Low-Level Waste and Decommissioning Projects Bran'ch (LLDP) 14.1.2 Secondary: Special Projects Branch 14.1.3 Supporting: Office of the General Counsel(OGC) l 14.2 Purpose of Review The purpose of this SRP section on decommissioning funding is to present the regulatory requirements and regulatory guidance and to establish the acceptance criteria and review procedures to be used by reviewers. The reviewer must ascertain that the funding requirements, as specified by the regulations, have been assured to enable the applicant to dispose of the waste and depleted uranium and for decontamination and decommissioning )

activities which are the responsibility of the Corporation.

14.3 Areas of Review O The staff will evaluate the financial assurance methods required by 10 CFR Part 76, with b respect to the decommissioning cost estimate and accompanying documentation submitted by the applicant to ensure that sufficient funds will be available to carry out those portions of the ultimate decommissioning of the facility for which it is responsible. Items to be submitted include a plan outlining the ultimate disposal of the waste and depleted uranium and the decommissioning activities which are the responsibility of the Corporation, a cost estimate, and the financial assurance mechanisms.

$4.4 Review Procedures 14.4.1 Acceptance Review The staff will review the financial mechanisms and accompanying documentation submitted by the applicant by comparing them with the checklists in Regulatory Guide 3.66. In addition the wording of the mechanisms will be compared to the language suggested in Regulatory Guide 3.66 to ensure that the appropriate information has been submitted.

On the basis of its review, the staff may request that the applicant provide additional information or modily the submittal to meet the acceptance criteria in Section 14.5 of this SRP.

14.4.2 Financial Evaluation The staff will review the financial mechanisms submitted by the applicant by using the general g and specific procedures provided in the following sections.

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1 Decommissioning Funding Plan 14.4.2.1 General Evaluation Procedures Applicable to All Financial Mechanisms The staff will use the checklists in Regulatory Guide 3.66 to ensure that the mechanisms contain all the necessary components. If there are questions about the wording of the chosen financial method or about appropriate documentation, the reviewer will consult the certification project manager.

The staff will check signatures and verify that the parties signing the various documents are authorized to represent the firm in the transaction if the applicant is a partnership, the ,

signatory must indicate that person is signing for the partnership, that is, by using words such as "for the partnership" or "for the company." If the applicant is not an individual and power of attomey is needed for a signature, a copy of the power of attorney should be attached to the financial assurance mechanism.

The staff will determine whether the financial assurance mechanism is complete, and will be in effect at the proper time, and if the value is consistent with cost estimates provided in the decommissioning funding program description.

14.4.2.2 Financial Assurance Mechanisms Evaluation Procedures The staff will review the financial assurance mechanism submitted by the licensee by using the general and specific procedures provided in the following sections:

1. Escrow Accounts The staff will ensure that an executed copy of the escrow agreement is provided by the applicant and that the amount of the fund is at least equal to the cost of decommissioning The staff will review the checklist (Regulatory Guide 3.66) to verify that the licensee has satisfied the conditions necessary for ensuring financial responsibility for decommissioning using this mechanism.

2. Cash Deposits. Certificates of Deoosit. and Govemment Securities l

The staff will ensure that the applicant has submitted a trust agreement or documentation pertaining to the applicant's activities licensed pursuant to 10 CFR Part 76. The staff will verify that the applicant has deposited assets such as cash, certificates of deposit, or government securities with a third party such as a trust fund.

The staff will ensure that the amount of the cash deposit, CD, or govemment security is at least equal to the cost of decommissioning.

CDS may be either negotiable or nonnegotiable. If a negotiable CD is used the staff must verify that the CD is the property of a trust or escrow account Draft NUREG-1671 14-2 O

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Decommissioning Funding Plan established in accordance with decommissioning rules and guidance. If a nonnegotiable CD is used, the staff must verify that the CD names the trust or escrow account as payee (unless a State agency that can hold the funds will serve as trustee)._

The staff will review the checklist of criteria in Regulatory Guide 3.66 to verify that the applicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning using one of these mechanisms.

3. Trust Funds (includina Standbv Trusts)

The staff will ensure that the applicant has provided information so that the staff can verify that the bar$'. navings and loan association, or other financial 1 institution has the authority to act as trustee and that the trust operations are i regulated and examined by a Federal or State agency. To determine whether the trustee is authorized to act as trustee the staff will refer to a list, published by the Comptroller of the Currency, of financial institutions that are federally authorized to act as trustee, or will contact the applicable bank regulatory agency to determine State authorization. To determine whether the trustee's operations are regulated and examined by a Federal or State agency, the staff will refer to a list maintained by the Federal Deposit Insurance Corporation (FDIC) of all Federally regulated financial institutions, or will call the applicable state banking regulatory agency for verification of State regulated entities. For foreign banks with U.S. branches, the staff will contact the applicable State banking regulatory agency.

Where standby trusts are used, the staff will verify that the trustee is qualified to act as trustee by following the same method discussed above for verifying trusts.

It will also verify that the standby trust agreement is an originally signed duplicate and that a certificate of acknowledgment accompanies the bond or letter of credit.

The staff will ensure that the amount of the trust fund is at least equal to the cost of decommissioning.

The staff will review the checklists in Regulatory Guide 3.66 to verify that the applicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning using these mechanisms.

4. Surety Bonds The staff will ensure that a standby trust fund agreement accompanies the bond and that it complies with the suggested wording and documentation in Regulatory Guide 3.66.

The staff will ensure that the applicant has submitted information showing that 14-3 Draft NUREG-1671

i Decommissioning Funding Plan the surety is listed as an acceptable surety in the most recent edition of Circular i 570 of the U.S. Department of the Treasury and that the surety company is licensed in the State where the bond v/ill be executed. i The staff will verify that the applicant reviewed the broker's or agent's power of attorney to ensure that the broker or agent is authorized by the surety to issue  ;

bonds in the necessary amount.

The staff will ensure that documentation provided by tne applicant shows that the applicant will be responsible for notifying the NRC if the surety company intends to cancel or if it goes bankrupt.

The staff will ensure that the pens' sum of the bond is an amount at least equal to the cost of decommissioning.

The staff .ill review the checklist of criteria in Regulatory Guide 3.66 to verify that the pplicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning.

5. Letters of Credit The staff will ensure that the applicant has submitted information so that it can verify that the bank, savings and loan association, mutual savings bank, or credit union issuing the letter of credit has authority to issue letters of credit, and that the letter-of-credit operations are regulated and examined by a Federal or State agency. The staff will refer to a list maintained by the FDIC of all Federally regulated financial institutions or will call the applicable State banking regulatory agency for verification of State regulated entities. In addition, for foreign banks with U.S. branches, the staff will contact the applicable State banking agency.

The staff will ensure that the amount of the guarantee is at least equal to the cost of decommissioning.

The staff will ensure that a letter of credit addressed to the NRC is submitted I stating that the letter of credit is subject to the most recent edition of the Un!/orm Customs and Practice for Documen:ary Credits, published by the International Chamber of Commerce, or the Uniform Commei 'ial Code, by Lawyer's Cooperative Publishing Company.

The staff will ensure that a standby trust fund agreement accompanies the letter of credit and that it compiies with the suggected wording contained in Regulatory Guide 3.66. l l

The staff will review the draft " sight draft" using Appendix D of this standard l review plan to ensure that the terms of the letter of credit and the terms of the sight draft are consistent.

Draft NUREG-1671 14-4 O. '

g Decommissioning Funding Plan The staff will review the checklist of criteria in Regulatory Guide 3.66 to verify that the applicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning.

6. Insurance The staff will ensure that documentation of the insurance policy is provided by the applicant and that the amount of the fund is at least equal to the cost of decommissioning.

The staff will review the checklists in Regulatory Guide 3.66 to verify that the applicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning using this mechanism.

7. External Sinkina Fund The staff will ensure that documentation is provided by the applicant which indicates that a fund in the form of cash deposits in an escrow account, trust agreement, certificate of deposit, or govemment securities has been established.

The staff will ensure that documentation of a surety method (e.g., letter of credit, surety bond, or insurance) is supplied when this mechanism is used.

The staff will ensure thatdocumentation of the external sinking fund and surety method is provided by the applicant and that the amount of the fund is at least

-equal to the cost of decommissioning.

The staff will review the checklists in Regulatory Guide 3.66 to verify that the applicant has satisfied the conditions necessary for ensuring financial responsibility for decommissioning using this mechanism.

14.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this SRP are listed in the following sections.

14.5.1 Regulatory Requirements

$76.35(n) requires that the application include a description of the funding program to ensure that funds will be set aside and available for those aspects of the ultimate disposal of waste and depleted uranium, decontamination, and decommissioning that are the financial responsibility of the corporation. The corporation is required to establish financial surety arrangements to ensure that sufficient funds will be available. Acceptable funding mechanisms include prepayment, surety, insurance, or extemal sinking fur,t.' The arrangements must ensure availability of funds for any actuties that are required to be completed both before and after retum of the facility to DOE in accordance with the lease between DOE and USEC. The O 14-5 Draft NUREG-1671

Decommissioning Funding Plan funding program must contain a basis for cost estimates used to establish funding levels and must contain means of adjusting cost estimates and associated funding levels over the duration of the lease.

14.5.2 Regulatory Guidance U.S. Nuclear Regulatory Commission, Regulatory Guide 3.66, " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72", June 1990 14.5.3 Regulatory Review Criteria The staff will determine if the financial assurance information is acceptable by ensuring that it complies with the checklists provided in Regulatory Guide 3.66.

An Allowable Financial Mechanism is acceptable if it meets the following conditions:

1. The financial mechanism should state whether the principal is a corporation, partnership, or individual and should be in a form to allow the staff to determine if it has been properly signed and notarized and will be effective at the proper time.

2. With regard to signatures on a financial mechanism:

a. The mechanism should be legally binding on all signatories,

b. The applicant must ensure that the parties signing the various documents are authorized to act as representatives for the firm involved in the transactions.

Persons signing on behalf of the corporate principal must designate their legal capacity and should hold the position of president or vice president c: the corporation. If persons other than the president or vice president are signing, a resolution or other certified evidence of authority must be attached to the mechanism that states that the signatories have the authority to sign on behalf of the principal. If needed for a signature, a copy of the power of attomey should be attached to the financial assurance mechanism and the corporate seal should be affixed.

c. If the principal is a partnership, the firm's name must appear in the caption of the financial mechanism.

d. If the principal is joint ownership, but is not a partnership, the firm's name must appear in the caption end all owners must sign the financial statement.

e li applicable, a signature of the attomey-in-fact (representative granted power of attorney) acting on behalf of the issuing organization must appear on the financial mechanism. The financial mechanism must be accompanied by a properly executed Draft NUREG-1671 14-6 O

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( Decommissioning Funding Plan authorization of the power of attorney for the person signing the instrument.

f. If applicable, the financial mechanism must contain the signature of the resident )

agent of the organization issuing the mechanism. The agent must be qualified to do '

business in the State where the facility will be located.

g. Each party must sign his/her own name.

3. The financial mechanism must be issued by an organization that has the legal authority l to execute such an arrangement (e.g., for a surety company, check Circular 570; for other mechanisms, consult the checklists in Regulatory Guide 3.66). .

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4. All financial mechanisms, including the original, any additions, and any replacements, must describe and pertain to the activities certified pursuant to 10 CFR Part 76.

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5. The financial assurance must be open-ended and canrct be canceled without at least 90 days advance notice to NRC.

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6. The mechanism must allow for automatic collection by NRC before its expiration if the applicant cannot provide an acceptable alternative financial assurance mechanism 60 l days after the receipt of notification of cancellation. The mechanism must not require proof of forfeiture.

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7. When the mechanism is a bond or letter of credit, it must be accompanied by a standby trust to receive assets in the event the licensee defaults or goes bankrupt. A standby  !

trust is recommended, but not required, for parent company guarantees. When the mechanism is a govemment security or certificate of deposit, it must be accompanied by either a standby trust or an escrow.

8. The mechanism should specify the NRC as beneficiary.

9. The mechanism, or combination of mechanisms, must be sufficient at all times to cover all the costs of decommissioning.

10. The mechanism must clearly state the terms and conditions under which the applicant may cancel the mechanism and must provide for notification and approval by the State or Federal authority before cancellation by the company.

11. Following NRC's approval of the mechanism, the following related requirements must still be met:

a. The applicant's financial assurance coverage must provide coverage throughout the term of the certificate of compliance. The need for cost estimate adjustments should be examined at every certification renewal.

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Decommissioning Funding Plan

b. If the current cost estimate exceeds the coverage because of inflationary increases or changes in plans, the applicant must arrange to increase coverage and submit evidence of the increase to NRC within 60 days after the cost estimates increase. If cost estimates decrease, the applicant may apply to the NRC for approval of a ,

decrease in coverage.

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c. The applicant may change the financial assurance mechanisms in use with prior written approval from NRC. The new mechanism, if approved, must become effective before or at the time the previous mechanism expires. If a letter of credit, surety bond, certificate of deposit, or govemment security is used, the applicarit must also establish a standby trust fund.

d. An applicant should obtain alternative financial assurance coverage in the event of bankruptcy of the institution acting as trustee or issuing the 'hancial mechanism,

e. The applicant must inform the NRC within 10 days after it or the organization issuing the financial mechanism leams of the applicant's bankruptcy proceedings.

f. If ownership or operating responsibility for the activities is transferred, NRC will not allow the applicant to terminate the original financial mechanism until such time as the new applicant has obtained an acceptable assurance.

g. The applicant is responsible for obtaining another financial assurance mechanism if the financial institution or corporate guarantor gives notice that it intends to cancel.

14.6 Evaluation Findings 14.6.1 Introduction The staff's review should verify that sufficient information has been prov ded in the application for renewal of certification to satisfy the intent of 76.36, " Annual renewal," requirements with respect to the Decommissioning Funding and that the information provided is consistent with the guidance in this SRP. On the basis of this information, the staff should be able to conclude that this evaluation is complete. The staff can document its review as follows.

14.6.2 Sample Evaluation Findings I The staff has reviewed the financial assurance documentation submitted by the applicant for 1 (namo of facility) according to Regulatory Guide 3.66, Standard Format and Content of Financial Assurance Mechanisms Requiredfor Deconunissioning under 10 CFR Parts 30, 40, 70, and 72 (June 1990). The applicant has adequately described the activities and estimated costs for those  !

activif:les that are the financial responsibility of the applicant. Surety arrangements are j adequate to ensure the availability of sufficient funds to perform those activities. The basis for J' all cost estimates is aufficient to support the staff's finding that the estimates are reasonable.

The staff concludes that the decommissioning funding plan meets the requirements of the regulation, and is therefore acceptable.

Draft NUREG-1671 14-8 l

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Decommissioning Funding Plan 14.7 References U.S. Nuclear Regulatory Commission, " General Requirements for Decommissioning Nuclear Facilities-Final Rule," Federa/ Register 53 (No.123), 24018-24056, June 27,1988.

l Internationai Chamber of Commerce, Uniform Customs and Practices for Documentary Credits, 1 Paris, France,1983.

Lawyer's Cooperative Publishing Co., Unifo:m Commercial Code, Rochester, NY,1985.

U.S. Nuclear Regulatory Commission, Regulatory Guide 3.66, " Standard Format and Content of ,

Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," June 1990.

U.S. Department of the Treasury, Circular 570, " Companies Accepted on Federal Bonds,"

Washington, DC, published annually in the Federal Register.

U.S. Code of Federa/ Regulations, Title 10, Part 76, "Ce, ification of Gaseous Diffusion Plants."

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15.0 COMPLIANCE PLAN 15.1 . Responsibility for Review 15.1.1 Primary: Primary issue Subject Area Reviewer 15.1.2 Secondary: SPB Compliance Plan Coordinator 15.1.3 Supporting: Certification Project Manager 15.2 Purpose of Review

. The purpose of this evaluation is to establish that there is reasonable assurance that the applicant has provided an adequate: (1) description of noncompliance with NRC requirements; (2) Justification for continued operation for the period of noncompliance; and (3) plan of action and schedule for coming into compliance with NRC requirements.

1,.3 Areas of Review 15.3.1 Description of Noncompliance The following areas of the applicant's Compliance Plan (CP) and plant operations are reviewed:

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% 1. Regulatory requirement /s applicable to the specific CP issue.

2. Related commitments ar.d statements made in the application documents.

3. Description of the existing plant condition /s of noncompliance.

15.3.2 Justification for Continued Operation (JCO)

The following areas of the applicant's CP and plant operations are reviewed:

1. Technical safety / safeguards basis for continuing to operate during the interim period ,

of noncompliance with NRC requirements. l'

2. Compensatory safety / safeguards measures in place during the interim period of noncompliance with NRC requirements.

15.3.3 Plan of Action The following areas of the applicant's CP and plant operations are reviewed:

1. The actions necessary to bring plant operations into compliance with NRC requirements.

2. The schedule for completing the actions necessary to bring plant operations into compliance with NRC requirements.

15.4 Review Procedures 15-1 Draft NUREG-1671 I

Compliance Plan 15.4.1 Acceptance Review The staff review should start with the primary reviewer's determination that the contents of the application, as required by 10 CFR Part 76.35, " Contents of initial application" and 10 CFR 76.36, " Annual renewals" with respect to the CP, have been included--see Section 15.5.1, i

" Regulatory Requirements," and that the topics discussed in Subsection 15.3, " Areas of j Review," have been addressed.

If significant deficiencies are identified in the application, the applicant should be requested to j submit additional material before the staff resumes the application review.

15.4.2 Safety Evaluation The staff should perform a safety evaluation of the information presented in the application against the acceptance criteria presented in Section 15.5, below. Based on this safety evaluation, a request for additional information or modification of the submittal may be issued, for clarification or elaboration of the information submitted to address the acceptance criteria in Section 15.5 or to provide alternatives that demonstrate an equivalent level of safety or safeguards to those acceptance criteria.

15.4.2.1 Regulatory Requirements The primary reviewer should identify all applicable regulatory requirements (10 CFR) for which the GDPs are in noncompliance. The applicable 10 CFR regulatory requirements for the GDPs are Part 76 in its entirety and those listed in 10 CFR Part 76.60.

15.4.2.2 Application Commitments The primary reviewer should identify all applicable commitments and statements made in the application that show compliance with the applicable NRC requirements but are contrary to actual plant conditions known to the applicant. See Section 15.4.2.1 above. The approved application describes operations and plant conditions as though they are in full compliance with l NRC requirements.

15.4.2.3 Description of Noncompliance Based on the review performed per Sections 15.4.2.1 and 15.4.2.2, the primary reviewer should determine the adequacy of the description of noncompliance contained in the CP. The CP is required to adequately identify all commitments and statements made in the application that show compliance with NRC requirements but are contrary to actual plant conditions known to the applicant.

15.4.2.4 JCO Bases The primary reviewer should ensure that the technical bases contained in the JCO adequately justifies safe operation. According to 10 CFR 76.35(b), USEC was required to submit the CP Draft NUREG-1671 15-2 O

y Compliance Plan

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as part of its certification application. DOE was required to prepare and approve it.

W 4.2.5 Compensatory Measures The primary reviewer should review the compensatory measure /s committed to by the applicant for the interim period of noncompliance. These measures should adequately provide sufficient safety and safeguards for the period of noncompliance.

15.4.2.6 Plan of Action The primary reviewer should ensure that the actions proposed by the applicant are such that completing them would ensure compliance with the applicable regulatory requirements and commitments made in the application.

15.4.2.7 Schedule The primary reviewer should ensure that the schedule proposed by the applicant includes adequate time for implementing the plan of action as stated and is consistent with other related plans of actions contained in other CP issues. At the same time, the schedule should avoid unnecessarily providing for extensive periods of noncompliance. Compliance should be achieved as soon as it is reasonably practical.

15.5 Acceptance Criteria The regulatory requirements, regulatory guidance, and regulatory review criteria applicable to this Section are listed in the following sections.

15.5.1 Regulatory Requirements l The regulatory requirements applicable to this Chapter include:

10 CFR 76.35(b) requires the applicant to provide an initial application demonstrating compliance with applicable NRC requirements, and a plan prepared and approved by DOE for achieving compliance.

10 CFR 76.36 requires the applicant to file an annual application for renewal after NRC's issuance of the initial certificate of compliance.

10 CFR 76.60 identifies other applicable 10 CFR regulatory requirements not specifically contained in 10 CFR Part 76.

15.5.2 Regulatory Guidance There are no specific NRC regulatory guides (RG) applicable to the CP. However, each chapter in this SRP includes the pertinent list of RGs applicable to the review area.

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m Compliance Plan 15.5.3 Regulatory Review Criteria There are no specific review criteria applicable to the CP. However, each chapter in this SRP includes the pertinent review criteria applicable to the review area.

15.6 Evaluation Findings The review should verify that sufficient information has been provided in the SAR and amendments to meet the requirements of 10 CFR 76.36 to support conclusions of the following type, which will be included in the staff's CER.

The staff concludes that the information provided by the applicant with respect to the i Compliance Plan is acceptable and meets the requirements of Part 76. This conclusion is based on the following information: 1

1. The applicant has identified all applicable regulatory requirements (10 CFR) for which the GDPs are in noncompliance. The applicant has also identified all applicable commitments and statements made in the application that show compliance with the applicable NRC requirements but are contrary to actual plant conditions known to the applicant. In addition, the applicant has adequately described all conditions and areas of noncompliance with NRC requirements.

2. The technical bases contained in the JCO prepared and approved by DOE, adequately justifies safe operation. In addition, the compensatory measures committed to by the app;icant for the interim period of noncompliance are adequate.

3. The actions proposed by the applicant are such that completing them would ensure compliance with the applicable regulatory requirements and commitments made in the application. In addition, the schedule proposed by the applicant includes adequate time for implementing the plan of action as stated and is consistent with other related plans of actions contained in other CP issues. At the same time, the proposed schedule does not unnecessarily provide for extensive periods of noncompliance if compliance can reasonably be achieved at much earlier dates.

15.7 Reference U.S. Code of Federal Regulations, Title 10, Part 76, " Certification of Gaseous Diffusion Plants."

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n (v! 16.0 DETERMINATION OF FOREIGN OWNERSHIP, CONTROL, OR DOMINATION, COMMON DEFENSE AND SECURITY, AND RELIABLE AND ECONOMICAL SOURCE OF DOMESTIC I ENRICHMENT SERVICES 16.1 Rasponsibility for Review 16.1.1 Primary: As designated 16.1.2 Secondary: Facilities Security Specialist / Safeguards Technical Analyst 16.1.3 Supporting: Material Control and Accounting inspector / Resident inspector 16.2 Purpose of Review I The purpose of this review is to determine that an applicant for certification is not owned, l controlled, or dominated by an alien, a foreign corporation, or a foreign government; that issuance of a certificate would not be inimical to the common defense and security of the l United States; and that issuance of a certificate woul'1 not be inimical to the maintenance of a reliable and economical domestic source of enrichme nt services.

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16.3 Areas of Review General An application to transfer certificates will be reviewed to examine the changes proposed in the application for the transfer from that which is currently approved or permitted under the existing certificates.

Foreian Ownershio. Control. or Domination Information submitted by the applicant, as specified in " Foreign Ownership, Control, or influence Guidance Documents for the Privatization of the United States Enrichment Corporation," will be reviewed. This information includes, but is not limited to:

1. Portions of securities held by foreign entities or held by means that prevent the identification of the beneficial owner

' Note: the procedures in this SRP for a statutory determination of foreign ownership, control, or domination, are not to be used to determine foreign ownership, control, or influence FOCl) for O lor determ,grantingCl ining F and the granting of access to classified materialaccess to classified m b '

16-1 Draft NUREG-1671

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Determination of Foreign Ownership

2. Management positions held by non-U.S. citizens

3. Ability of foreign entities to control the appointment of management positions

4. Contracts and other agreements with foreign entities

5. Finance and revenue sources involving foreign entities Common Defense and Security The following items will be reviewed for compliance with NRC regulatory requirements to protect the common defense and security:

1. Physical Security Plan

2. Security Plan for the Protection of Classified Matter

3. Fundamental Nuclear Material Control Plan

4. Inspection, event, and resident inspector reports dealing with facility and transportation physical protection, material control and accounting, information security pregrams, and control of classified material L ' ' rmation regarding the impact of the Russian HEU Agreement, and any related contracts, m me financial viability of the applicant

6. An assessment of the performance of the applicant as the executive agent of the U.S. for the Russian HEU Agreement in consultation with members of the HEU Oversight Committee Reliable and Economical Source of Domestic Enrichment Services Assessments of the financial viability of the applicant will be reviewed. The assessments will be based on the actual or estimated credit rating of the applicant, a standard used by the financial community to objectively measure an entity's financial condition, and its ability to meet its obligations, and other economic, financial and business characteristics. The current public credit rating of the applicant, published by a recognized credit rating agency (e.g., Standard &

Poor's, Moody's investor Service, Duff & Phelps, or Fitch), will be reviewed. If (I) the applicant does not have a current public credit rating, or (ii) in the case of a transfer of the certificates, a public credit rating would not apply to the applicant after the transfer, then an assessment of the financial viability of the applicant, based upon an estimate of the applicant's credit rating, will be reviewed. This estimated credit rating will be based on quantitative and qualitative analyses of the financial and business risks of the applicant.

16.4 Review Procedures Draft NUREG-1671 16-2

1 Deterrnination of Foreign Ownership v

The reviewer should determine whether the applicant is subject to any of the criteria set forth in 10 CFR Part 76.22, ' Ineligibility of Certain Applicants." '

16.4.1 Foreign Ownership, Control, or Domination An applicant is considered to be foreign owned, controlled, or dominated whenever a foreign interest has the power, direct or indirect, whether or not exercised, and whether or not -

exercisable, through the ownership of the applicant's securities, by contractual arrangements, or other means, to direct or decide matters affecting the management or operations of the applicant, i

A foreign interest is defined as any foreign government, agency of a foreign govemment, or-representative of a foreign government; any form of business enterprise or legal entity organized, chartered or incorporated under the laws of any country other than the U.S. or its possessions and trust territories; any person who is not a citizen or national of the U.S; and any U.S. interest effectively controlled by one of the above fort,;gn entities.

The reviewer should assess the following items to determine if the applicant is foreign owned, controlled, or dominated:

1. The applicant should provide answers to the following questions. If any of the answers are affirmative, the applicant should furnish detailed information that describes all conditions that exist. The information will be considered in the aggregate and the fact that some of the below listed conditions may apply does not necessarily render the applicant company ineligible for certification,

a. Does a foreign interest own or have beneficial ownership in 5% or more of your organization's voting securities? +

b. Does your organization own 10% or more of any foreign interest?

c. Do any foreign interests have management positions such as directors, officers, or executive personnel in your organization?

d. Does any foreign interest control or influence, or is any foreign interest in a position to control or influence the election, appointment, or tenure of any of your directors, officers, or executive personnel?

e. Does your organization have any contracts, binding agreements, understandings, or arrangements with a foreign interest (s) that cumulatively represent 10% or more of your ,

organization's gross income? ]

f. Is your organization indebted to foreign interests?

g. During your last fiscal year, did your organization derive 5 percent or more of its total revenues or net income from any single foreign interest or in the aggregate 30 percent or O 16-3 Draft NUREG-1671 )

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Determination of Foreign Ownership more of its revenues or net income from foreign interests?

h. Is 5% or more of any class of your organization's securities held in " nominee shares", in q

" street names", or in some other method which does not disclose beneficial owner of equitable title?

1. Does your organization have interlocking directors / officers with foreign interests?

j. Are there any citizens of foreign countries employed by, or who may visit, your offices or facilities in a capacity which may permit them to have access to classified information or a significant quantity of special nuclear material?

k. Does your organization have foreign involvement not otherwise covcred in your answers to the above questions?

2. The reviewer should obtain a foreign intelligence threat assessment. This assessment will be conducted through the Intelligence Community and others, and will be coordinated by the Department of Energy. The reviewer may obtain the assessment by contacting the DCE representative to the HEU Oversight Committee.

3. If the applicant submits any affirmative information listed in section 16.5.1, steps 1.a through 1.k above, or the foreign intelligence threat assessment contains information, that the applicant may be foreign owned, controlled, or dominated, the reviewer shall determine:

a. the nature and extent of foreign ownership, control, or domination, to include whether a foreign interest occupies a controlling or dominant minority position;

b. the source of foreign ownership, control, or domination, to include identification of immediate, intermediate, and ultimate parent organizations; and

c. the type of actions, if any, that would be necessary to negate the effects of foreign ownership, control, or domination to an acceptable level.

4. If it is determined that an applicant company may be considered to be foreign owned, controlled, or dominated, or that additional action would be necessary to negate the foreign ownership, control, or domination, the applicant shall be promptly advised and requested to submit a negation action plan. In cases that involve foreign ownership, a plan may consist of one of the methods described in Chapter 2, Section 2-306, of the NISPOM. When factors not related to ownership are present, the plan shall provide positive measures that assure that the foreign interest can be effectively denied control or domination. Examples of such measures include: modification or termination of loan agreements, contracts and other understandings with foreign interests; diversification or reduction of foreign source income; demonstration of financial viability independent of foreign interests; elimination or resolution of problem debt; assignment of specific oversight duties and responsibilities to board members; adoption of special board resolutions; and other actions that negate foreign control or domination.

Draft NUREG-1671 16-4 j

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r3 Determir@n of For%n Ownership v

5. The reviewer shall arrange to meet with, or otherwise communicate these findings to, the principal members of the HEU Oversight Committee and obtain their comments.

6. The reviewer shall ensure that NRC remains informed regarding foreign owne ship, control, or domination by preparing certificate conditions of the following types:

If, at any time after the privatization date, the Corporation obtains information reasonably indicating changes described in the National Industrial Security Program Operating Manual, DOD 5520.22-M, January 1995 (NISPOM), Chapter 1, Section 3,1-302(h), to the information previously submitted to NRC, described in the NISPOM, Chapter 2, Section 3, 2-302 b. (1) through (11), the Corporation shall notify NRC in writing within 15 days.

If the Corporation enters into negotiations for the proposed merger, acquisition, or takeover by a foreign person, the Corporation shall submit notification to NRC, in writing, within 15 days of the commencement of such negotiations. The submission shallinclude the type of transaction under negotiation (stock purchase, asset purchase, etc.), the identity of the potential foreign person investor, a plan to negate foreign ownership, control, or domination, and copies of any related loan, purchase and shareholder agreements, annual reports, bylaws, articles of incorporation, partnership agreements,  ;

and reports filed with other federal agencies.

16.4.2 Common Defense and Security

1. The reviewer should determine that the applicant's Physical Security Plan and Fundamental Nuclear Material Control Plan have been reviewed and approved by the appropriate NMSS personnel.

2. The reviewer should consult with the Division of Facilities and Security to determine that the applicant's Security Plan for the Protection of Classified Matter has been reviewed and approved.

3. If the applicant has previously been issued a certificate of compliance, the reviewer should ensure that NRC inspection reports and resident inspector reports do not indicate a general failure to protect the common defense and security interests of the United States.

4. The reviewer should consider the impact of executing contracts associated with the Russian HEU agreement on the financial viability of the applicant. The analysis of the applicant's financial viability, described below, should include information concerning the cost of procuring Russian material, the amount of material the applicant has contracted to procure, the costs of enrichtnent services provided by the applicant, and current market prices. This information should allow the reviewer to gauge whether executing such contracts might be a significant economic disadvantage, or favorable to an extent that would motivate the applicant to reduce the production of domestic enrichment services.

5. The reviewer should arrange to meet with, or otherwise consult with, the principal members j of the HEU Oversight Committee to obtain the committee's assessment of the applicant's j 16-5 Draft NUREG-1671 l

r' Determination of Foreign Ownership performance as the U.S. Agent for the Russian HEU Agreement.

6. The reviewer shall ensure that NRC remains informed regarding the applicant's performance as the U.S. agent for the Russian HEU Agreement by preparing a certificate condition of the following type:

USEC, or its successors, as the Executi"e Agent for the United States for implementing the Russian HEU Agreement, shall notify NRC in writing within 15 days, if at any time and for any reason, including actions of third parties, USEC or its successors become aware of, or anticipate, any change in the provisions of, or in the implementation of, the terms of the "Mmorandum of Agreement Between the United States Acting By and Through the Unitec hates Department of State, and the United States Department of Energy and the United States Enrichment Corporation, for USEC to Serve as the United States Government's Executive Agent Under the Agreement Between the United States and the Russian Federation Concerning the Disposition of Highly Enriched Uranium Extracted from Nuclear Weapons," entered into as of April 18,1997.

16.4.3 Reliable and Economical Source of Domestic Enrichment Services issuance of a certificate of compliance should be considered inimical to the maintenance of a reliable and economical source of domestic enrichment services if the applicant does not have a sufficiently strong financial condition to allow the expectation that it can remain viable for at <

least five years.

The review should consist of the following procedures. (if the staff elects to have a contractor conduct these procedures, the staff should review the contractor's analysis and findings and either concur with the findings or specify the staff's basis for taking a different position.)

1. If the applicant has one or more current credit ratings issued by a recognized rating agency (e.g., Standard & Poor's Corp., Moody's, Investors Service, Duff & Phelps Credit Rating Co.,

or Fitch Investors Services, L.P.), the reviewer should determine whether the lowest such rating is of investment grade (e.g., AAA, AA, A, or BBB as rated by Standard & Poor's, or Aaa, Aa, A, or Baa as rated by Moody's) or below investment grade (e.g., BB, B, CCC or lower as rated by Standard & Poor's, or Ba, B, Caa or lower as rated by Moody's).

2. If the applicant does not have a current credit rating issued by a recognized rating agency, the reviewer should conduct an independent analysis to estimate a credit rating and determine whether the estimated credit rating is of investment grade. The estimated credit rating should be based on quantitative and qualitative analysis of information provided by the applicant, including information regarding the applicant's parent company or companies, to the extent that they might affect the financial condition of the applicant.

a. The reviewer should ensure that NRC has received the following information from the applicant:

Draft NUREG-1671 16-6

r Determination of Foreign Ownership (V)

(1) The types, amounts, and holders of debt and the types and amounts of equity of the applicant. In the case of the privatization of USEC, the method of financing to be used to purchase USEC (if applicable), and the types, amounts, and holders of any debt  ;

and the types and amounts of equity of the privatized entity; (2) A five-year business plan addressing the applicant's enrichment business line as well as other anticipated business lines, including alternative enrichment technologies such as AVLIS, that will require investments of capital (including working capital) by the applicant, and the portion of projected revenue, for each of the five years, covered by contracts in existence at the time of the application; 1

(3) All significant business and economic assumptions underlying the plan; I (4) Pro forma financial statements for the applicant for each of the next five years; (5) Current financial statements (if applicable) for the applicant, and in the case of privatization, for USEC, along with an independent certified public accountant's opinion on the financial statements; (6) Identification of the applicant's proposed directors and officers and a discussion of their qualifications to provide financial and business management; C' (7) The organizational structure of the applicant and its relationship to corporate parents and other affiliates; and (8) Information on the financial condition of the applicant's corporate parents, including credit ratings, profiles prepared by the investment industry, and/or audited financial statements reflecting the three most recently completed fiscal years.

b. The reviewer should ensure the items specified above are consistent, and that they provide a comprehensive and reasonable picture of the applicant. If pro forma financial statements are based on inconsistent or unrealistic assumptions, it may be necessary to discuss with the applicant the basis of the projections.

c. The reviewer should quantitatively assess the financial characteristics of the applicant relative to available historical benchmarks. Some corporate financial analysis expertise will be necessary to complete this step. The reviewer may wish to obtain one or more financial texts for reference, such as Standard & Poor's " Corporate Ratings Criteria." The reviewer's analysis should include the following measures:

(1) Size Measures Net sales

- Net income Total assets

- Net worth 16-7 Draft NUREG-1671

1 Determination of Foreign Ownership (2) Capital Structure Ratios Total debt + capitalization

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Total debt + equity Long-term debt + capitalization (3) Coverage Ratios Net income plus depreciation and other noncash items + total debt Pretax income plus interest expense + gross interest Pretax income plus depreciation and other noncash items plus interest expense +

gross interest (4) Profitability Ratios Net income + total assets Pretax income plus interest + total assets Net income + equity Operating income + sales Other ratios and measures, addressing the above categories or other financial characteristics may be used if they provide a measure of the applicant's financial condition (e.g., see " Corporate Ratings Criteria").

d. The reviewer should also consider qualitative factors in light of the financial analysis.

Factors to be assessed include the applicant's competitive position, market environment, quality of management, and financial and business risks. These factors should be considered in proportion to their potential impacts on the applicant.

e. The reviewer should evaluate the financial condition of the applicant's corporate parents and affiliates to the extent that they might affect the applicant's financial condition. The financial condition of corporate parents or affiliates should be should be considered in proportion to the potential impact on the applicant.

f. Based on the preceding steps, the reviewer should establish an estimated credit rating of the applicant. In establishing the estimated rating, the reviewer should first determine what the estimated rating would be if it were based solely on an analysis of the applicant's financial ratios and size measures relative to available benchmarks. The reviewer should then adjust the estimated credit rating based on other considerations identified above.

Adjustments should be proportional to each f actor's potential impacts on the applicant.

Assignment of a specific estimated rating (e.g., AA versus A)is not necessary if the reviewer is able to determine that the estimated credit rating is investment grade.

Assignment of a specific rating may be necessary if the estimated rating is below investment grade.

3. If the actual or estimated credit rating is of investment grade, the reviewer should find that Draft NUREG-1671 16-8 O

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(7 Determination of Foreign Ownership the applicant has sufficiently strong financial condition to allow it to remain viable for at least five years, and that issuance of a certificate of compliance would not be inimical to the maintenance of a reliable and economical source of domestic enrichment services. If the l actual or estimated credit rating is below investment grade, the reviewer should consider j whether any other economic, financial, or business characteristics (e.g., contracts adequate  ;

to support the applicant's operations over a five-year time period, financial guarantees provided by a parent company, compelling business prospects) exist that provide reasonable assurance of the applicant's viability for at least five years, if the reviewer finds that such factors exist, and that the applicant is expected to remain viable for at least five years, then the reviewer should find that issuance of a certificate of compliance would not be inimical to the maintenance of a reliable and economical source of domestic enrichment services.

However, if the reviewer finds that such factors do not exist, then the reviewer should find that issuance of a certificate of compliance to the applicant may be inimical to the maintenance of a reliable and economical source of domestic enrichment services.

16.5 Acceptance Criteria 16.5.1 Regulatory Requirements 10 CFR 9 76.22 addresses the ineligibility of applicants for certification if the Commission determines that:

O g 1. The Corporation is owned, controlled, or dominated by an alien, a foreign corporation, or a foreign government; or

2. The issuance of such a certificate of compliance would be inimical to:

a. The common defense and security of the United States; or

b. The maintenance of a reliable and economical domestic source of enrichment services.

10 CFR 9 76.33 provides for NRC to require the applicant to supply additional information as necessary.

10 CFR 9 95.15 addresses the collection of information necessary to determine that the applicant is not owned, controlled, or dominated by an alien, foreign corporation, or foreign government.

10 CFR Parts 76 and 95 contain and reference applicable regulatory requirements necessary to protect the common defense and security.

16.5.2- Regulatory Guidance Regulatory guidance applicable to the areas of review in this chapter are:

p 1. U.S. Nuclear Regulatory Commission, NUREG/CR-5734, " Recommendations to the NRC on

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Determination of Foreign Ownership Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Enrichment Facilities," Nov.1991

2. U.S. Nuclear Regulatory Commission, Reg Guide 5.67, " Material Control arid Accounting for Uranium Enrichment Facilities Authorized to Produce Special Nuclear Material of Low Strategic Significance," Dec.1993

3. U.S. Nuclear Regulatory Commission, " Security Plan Format and Content Guide for NRC Licensees, Certificate Holders, and Reiated Organizations," March 1994 16.5.3 Regulatory Review Criteria i

The application is acceptable if the following criteria are met:

Forelon Ownershio. Control. or Domination After a review of the potential foreign involvement information in accordance with the Review Procedures, section 16.5.1, the reviewer determines that no foreign interest has the ability, direct or indirect, whether or not exercised, to direct or decide matters affecting the management or operations of the applicant.

The following additional criteria are applicable in the case of privatization of USEC:

1. Foreign competitors of USEC are precluded from participating in any acquisition of USEC.

2. Entitics with a substantial commercial relationship with foreign enrichment providers, with respect to uranium and uranium products, are precluded from participating in any acquisition of USEC.

3. Foreign interests own no more than 10 percent of the outstanding voting securities of the applicant.

4. Foreign sourced financing of an acquisition of USEC is no more than 10 percent of the purchase price.

Common Defense and Security

1. The applicant's Physical Security Plan has been reviewed and approved.

2. The applicant's Security Plan for the Protection of Classified Matter has been reviewed and approved.

3. The applicant's Fundamental Nuclear Material Control Plan has been revie ned and approved.

4. If the applicant has previously been issued a certificate of compliance, a review of NRC Draft NUREG-1671 16-10 O

p) Determination of Foreign Ownership inspection reports and resident inspector reports does not indicate a general failure, by the applicant, to protect the common defense and security interests of the United States.

5. Consultation with the principal members of the HEU Oversight Committee indicates that the applicant's performance as the U.S. Agent for the Russian HEU Agreement is acceptable.

Reliable and Economical Source of Domestic Enrichment Services

1. The applicant's current actual or estimated public credit rating is investment grade (e.g.

Standard & Poor's AAA to BBB, Moody's Aaa to Baa); or

2. The applicant's current actual or estimated public credit rating is not investment grade, but  !

other economic, financial, or business characteristics exist that strongly indicate the entity's viability for at least five years.

l 16.6 Evaluation Findings After evaluating the application and the supporting information, and determining the information to be adequate and the acceptance criteria to be met, the reviewer will prepare a statement, similar to the following, for inclusion in the Certificate Evaluation Reports:

On the basis of the staff's review and evaluation of the application for certification, the staff has found no cause to determine that:

1. the applicant is owned, controlled, or dominated by an alien, a foreign corporation, or a ,

foreign government; or

2. issuance of a certificate of compliance would be inimical to the common defense and security of the United States; or

3. Issuance of a certificate of compliance would be inimical to the maintenance of a reliable and economical domestic source of enrichment services.

16.7 References .

U.S. Department of Defense, " National Industrial Security Program Operating Manual (NISPOM)," DOD 5520.22-M, Jan.1995.

U.S. Department of Energy, U.S. Nuclear Regulatory Commission, U.S. Enrichment Corporation, " Foreign Ownership, Control, or Influence Guidance Documents for the Pri'ratization of the United States Enrichment Corporation."

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O APPENDIX A PROCEDURES All activities listed below should be covered by written procedures (except for maintenance activities listed below which may be covered by written procedures, documented work instructions, or drawings appropriate to the circumstances). The list is not intended to be all inclusive nor is it intended to imply that procedures be developed with the same titles as those on the list. This listing shall provide guidance on topics to be covered rather than specific procedures.

1 Administrative Procedures Training Internal audits and inspections investigations and reporting Records management and document control Changes in facilities and equipment Modification design control Security and Visitor control Quality assurance Equipment control (lockout /tagout)

Shift tumover -

Control room activities Communications g Work Control Management control Temporary modification Procedure management Nuclear criticality safety Fire protectum Radiation protection Radioactive waste management Maintenance Environmental protection Packaging and transportation of nuclear material Safety Analysis Chemical safety Operations TSR surveillances Calibration control Code inspections Preventive maintenance System Procedures That Address Startup, Operation and Shutdown Cascade cells .

Coolant Freezer /sublimers O Draft NUREG-1671 A-1 1

Purge cascade Electrical power Ventilation Datum UF6 leak detection Criticality alarms Mass spectrometers Cellleakrates Cell negatives Cascade sampling Cell treatments Deposit monitoring Equipment removal with deposits Cascade shift routines and operating practices Reduction of cascade powerlevel Splitting and remaking the cascade Cylinder burping Product withdrawal operations UF6 cylinder filling UF6 cylinder handling Liquid UF6 handling crane operation UF6 autoclave operations, feeding, heating, sampling and transfer UF6 material handling equipment Decontamination operations Uranium recovery Electrical switching operations Electrical equipment inspections Plant air Plant nitrogen Recirculating cooling water Sanitary water Plant water Chemical trapping Abnormal Operation / Alarm Response Debladed compressor Cellin leakage Loss of cooling Loss of instrument air Loss of electrical power Loss of autoclave containment Loss of criticality alarm system Cellload alarm Cell coolant alarm Fires A-2 Draft NUREG-1671 O

' Maintenance Activities That Address System Repair, Calibration, inspection, and Testing Repair of UF6 smoke detectors Repair of UF6 valves Testing of criticality alarm units Testing of cranes Compressor seal replacement Calibration of process indicating instruments Chemical trap change out Rigging HEPA filter maintenance Safety system relief valve replacement Replacement of compressor motors Replacement of autoclave gaskets UF6 cylinder inspection and testing Liquid UF6 handling crane inspection and testing Emergency Procedures Re'sponse to a criticality Toxic chemical releases (including UF6)

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I I APPENDIX B RECORDS Records must be controlled under the records management system. The following list is an example of the type of records that should be controlled. The list is not intended to be exhaustive or prescriptive in format. For example, in particular instances, different or additional records might be within these groupings.

' Examples of Records:

Construction records i Facility and equipment descriptions and drawings Design criteria, requirements, and bases for safety-related SSCs, as specified by the ,

facility CM system Records of facility changes as specified by the facility CM system Safety analyses, reports, and assessments Records of site characterization measurements and data Records pertaining to onsite disposal of radioactive or mixed wastes in surface landfills Specifications for safety-related procurement items Administrative procedures with safety implications Commu.;ity right-to-know records Change control records for material control and accounting program O Document control records (including classified documents and information)

V Employee complaint, discipline, and employer action records (for protected activities)

Evidence (records) of deliberate misconduct Organization charts, position statements, and qualifications records Safety and health compliance records, medical records, personnel exposure records, etc.

QA records Safety inspections, audits, assessments, and investigations Safety statistics and trends Audits and assessments of safety and environmental activities Calibration and testing data Conditions for operation and documentation of compliance Change control records for safety-significant changes to procedures Human performance deficiencies and human factor improvements -

Operating logs Maintenance records Material balance, inventory, transfer, and disposal records Material storage records Plant operating procedures Records of receipt, transfer, and disposal of source or byproduct materials Operator aids (charts, drawings, etc., used to assist operator in performing job)

Training records "Special Test" records

. Radiation protection (and contamination control) records Radiation Work Permits p

Nuclear criticality control written procedures and statistics B-1 Draft NUREG-1671 1

r Records pertaining to nuclear criticality inspections, audits, investigations, and assessments Records pertaining to nuclear criticality incidents, unusual occurrences, or accidents Records pertaining to nuclear criticality safety analyses Chernical process safety procedures and plans Records pertaining to chemical process inspections, audits, investigations, and assessments Diagrams, charts, and drawings Records pertaining to chemical process incidents, unusual occurrences, or accidents Chemical process safety reports and analyses Chemical process safety training Fire hazard analysis Fire prevention measures, including hot-work permits and fire-watch records Records pertaining to inspection, maintenance, and testing of fire protection equipment Records pertaining to fire protection training and retraining of response teams Pre-fire emergency plans Emergency plan (s) and procedures Comments on emergency plan from outside emergency response organizations Memoranda of understanding with outside emergency response organizations .

I Records pertaining to the training and retraining of personnel involved in emergency preparedness functions Emergency drill records Records pertaining to inspection and maintenance of emergency response equipment and supplies Environmental release and monitoring records Environmental Report and Supplements to the Environmental Report, as applicable

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L APPENDIX C' PROPOSED CONSEQUENCES OF CONCERNS / THRESHOLDS The proposed limits for onsite workers and the general public are guidance for use as consequences of concern in the process hazard analysis that would triggar further accident analysis. The limits would also serve as the thresholds that the accident analysis would use to determine that the sequence of events and established controls are adequate to protect the health and safety of the general public.

Normal operations to anticipated operational occurrences (10' to 10-8):

Onsite werkers should not exceed 10 CFR 20.1201 limits for radiation exposure and 29 CFR Part 1910 Subpart Z for chemical hazard exposure.

Offsite/ member of the public should not exceed 10 CFR 20.1301 limits for radiation exposure and 29 CFR Part 1910 Subpart Z for chemical hazard exposure.

Unlikely events (10'8 to 104 )

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Onsite workers could possible exceed 10 CFR 20.1201 limits for radiation exposure and 29 CFR Part 1910 Subpart Z for chemical hazard exposure but not be exposed to levels that could result in death or serious injury.

Offsite/ member of the public could exceed 10 CFR 20.1301 limits for radiation exposure and l(

29 CFR Part 1910 Subpart Z for chemical hazard exposure but below 5 Rem TEDE or 30 mg uranium in soluble form or below IDLH levels for hazardous chemicals.

Highly unlikely events (<104)

A nuclear criticality.

1 Onsite workers could possible be exposed to levels that could result in death or serious injury.

Offsite/ member of the public could exceed S Rem TEDE or 30 mg uranium in soluble form or be exposed to greater than IDLH levels for hazardous chemicals.

l I NOTE: Frequencies other than the above may be attributed to the terms of unlikely and  ;

I highly unlikely provided adequate justification is provided.

l C-1 Draft NUREG-1671

APPENDIX D SAMPLE SIGHT DRAFT The following is a sample of a sight draft, it is to be used if necessary to draw upon a letter of credit. l

$ Date On sight pay to the order of (Insert standbv trust or other oavee) (payee). (Insert sum in writina) Dollars ($ ) and charge the sum paid to letter of credit Number .

Issuedto .

To:(Insert name and address of bank issuina letter of credit.)

Signature, title, and address of person authorizing payment.

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l NRC FORM 335 u.s. NUCLEAR REGULATORY CoMZISslON 1. REPORT NUMBER y g* (Assigned by NRC, Add Vol., Supp., Rev.,

mi, saan BIBLIOGRAPHIC DATA SHEET "****"'"'""""'*"*""r4 i [} (see unior,ons an ea mers >

kj 2. TITLE AND SUBMLE NUREG-1671 Standard Review Plan for the Recertification of the Gaseous Diffusion Plants

3. DATE REPORT PUBUSHED MONTH YEAR l

Draft Report for Comment February 1999

4. FIN OR GRANT NUMBER 6, AUTHOR (S) 6. TYPE OF REPORT Charles Cox

7. PERIOD COVERED (inchsw Osm:1

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (#Nac. pende Duom orfme or aspcn u.s Nucear segumary conwnese and ms#ng acuress; # contractor ponde name andmanmg aseens)

Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (# Nac. type *Same as aeove; # contractor, proude Nac amsm omes or Repari, u.s Nucear Asguarary commesm  !

andmemng adeoss.) l Same as above

\ 10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 moras orhas)

This NUREG provides guidance to the staff reviewers in the Office of Nuclear Material Safety and Safeguards who perform safety and erwironmentalimpact reviews of the recertification applications for the two gaseous diffusion plants in Paducah, Kentucky, and Portsmouth, Ohio. The standard review plan (SRP) presented in th is NUREG ensures the quality, uniformity, stability, and predictability of the staff reviews. It presents a defined basi s from which to evaluate proposed changes in the

! scope and requirements of the staff reviews. The SRP makes information about c ertification acceptance criteria widely available to interested members of the public and the regulated industry, Each SRP section addresses the responsibilities of persons performing the review, the matters that are reviewed, the Commission's regulations pertinent to specific technical matters, the acceptance criteria used by the staff, how the review is accomplis hed, and the conclusions that are appropriate to summarize the review.,

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12. KEY WORDS/DESCRIPTORS (Usr mann orperosse put we assar iseesicrors m maarmy to reportJ 13. AvAILAeluTY STATEMENT unlimited Gaseous Diffusion Plant

14. SECURITY cLASSIFICAThoN Paducah Plant Portsmouth Gaseous Diffusion Plant (rne esse) unclassified (The asporri n '

unclascified

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15. NUMBER OF PAGES 16 PRICE NRc FORM $35 (249) The form was electroncally produced by Ehte Federal Forms, Inc.

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