ML20196B118
| ML20196B118 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 11/30/1987 |
| From: | Kirk W UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20195F344 | List: |
| References | |
| 28966, NIS-87-12-6, NUDOCS 8802090181 | |
| Download: ML20196B118 (44) | |
Text
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In Reply Please Refer To:
JAN 121987 >
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Mr. Leland C.
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Fuel cycle safety Branch r'.
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Div. of Fuel Cycle & Medical, & Commercial Use safety U.S. Nuclear Regulatory Commission Washington, D.C.
20555
,i subject:
Application for Renewal of NRC License sWM 4368 Docket No.70-371 h
Ref:
(1) Letter W.F.
Kirk to W.T.
Crow dated January 22, 1986 (2) Letter W.
T. Crow to W.
F. Kirk dated March 25, 1986 (3) Letter W.
F.
Kirk to W.
T. Crcw dated April 11, 1986 I
(4) Letter W.
F. Kirk to W. T. Crow dated July 11, 1984 (5) Letter G. Vern Diedrick to W. T. Crow, Financial Surcty l
for Decommissioning Montville Plant, Licer.se $NM-368 dated June 6, 1986 7
(6) Letter W.
F.
Kirk to W.
T. Crow dated September 5, 1986 (7) Draft License conditions informally transmitted to UNC at a meeting with NRC on December 10, 1984 (4) Meeting, NRC-UNC February 4-5, 1987 l
(9) Letter W.
F.
Kirk to L. C.
Rouse dated October 16,1987 t
l The following raendments have been incorporated into this portion of the renewal: 5,8t,10, 11, and 12.
l
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j (10) Letter W.
T. Crow to W.
F.
Kirk dated Aug. 26, 1986
)
(11) Letter W.
T.
Crow to W. F.
Kirk dated sept.27, 1986 i
(12) Letter W.
T. Crow to W. F. Kirk dated Feb.
9, 1987 l
(13) Letter L.
C.
Rouse to W.
F. Kirk dated June 16, 1987 l
(14) Letter L.
C.
Rouse to W.
F.
Kirk dated Sept.
3, 1987
Dear sir:
l t
The modifications contained herein complete the information requested I
by Ref (7) and (s). Please insert the enclosed pages into the I
appropriate places of the subject submittal 'Jhich was transmitted by reference (1) and augmented and revised by References (2), (3),
I (4),(5),(6), and (9).
I t
l l
In addition, Pages 4-22 and 4-28 are revised to acconodate improved product handling. These changes are supported by Pages 15-40 Rev. 3 and 13-94 Rev. 2 which replace the corresponding pages submitted with j
Ref. (9).
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&unriutNi1AL UNCNavalProducts We have also revised page 1-2 to allow for the potential presence of plutonium as a contaminant in sealed uranium-containing tubes.
We reques c that prior to issue of the renewal license, that agreement be reached on the period of time necessary to implement the specific changes to existing licence, very p ly
- ours, b.{b s?
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W.
F. KIRK, Manager Nuclear and Industrial Safety Enclosure UNCL ASSIFIED WHEN C ENCLOSUof ? *S Ft"Tiet.
SONFIDENIlAL
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A UNC Commny
UNCLASSTIEJ ATTACHMENT To UNC LETTER DATED NOVEMBER 30, 1987 Disposition of NRC proposed conoitions transmih.I to UNC in draft form dated 12/10/86, and discussed at an hP.:-UNC meeting on 2/4 and 2/5/87, are tabulated below:
7.A Except for laboratory standards, the chemical.tnd physical forms of the Uranium 235 as received shall be as specified in Table 4.3.1.1, Chapter 4, of the application dated January 22, 1986 and supplements specified in Condition 9.
7.A Comment incorporated in Section 1.4 with addition of up
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to 350 g. of Uranium 235 without restriction.
l 7.C The chemical and physical forms of the source material shall be as specified in Section 1.4 of the application dated January 22, 1986 and supplements specified in Condition 9.
i Receipt and/or use of thorium material other than packaging for delivery to a carrier is not authorized.
[
7.C Not incorporated. Authorized Use statement in item 9 j
below will control sufficiently.
9.
Authorized Use For use in accordance with the statements, representations and conditions in Chapters 1 through Chapter 8 of the licensee's application dated January 22, 1986, and supplements dated March 21, April 11, June 6, July 11, August 26 (Cor.fidential; pages are dated August 25), and September 5, 1986, except as specifically provided otherwise by this license.
9.
Asid - and any supplements made, or amendments issued to the existing license up to the date of issue of a new license.
10.
Authorized Place of Use The licensee's existing facilities in Montville, Connecticut. The facilities are Building M (Figure E-423000, Rev. 7), Build.ing A (Figures E-423001, Rev. 8 and E-423002, Rev. 10), Building B (Figures E-423003, Rev. 3 and E-423004, Rev. 7), East Plant (Figure E-423013, Rev. 14), Ant.ex III (Figure D-423014, Rev. 0), M Building I
Annex (Figure 423035 Rev. 0) and the used liquid treatment facility south of Building B.
10.
Figure 9.6.4 has been made Figure 1.1 on page 1-la.
L&C_ ASS?EJ
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L7Ubifl[.d 11.
In cdditicn to tha perm:ntnt c:mbero cf tho Scfcty Committco specified in Section 2.3 of the license application, membership shall include the Vice Presidents of Operations, Engineering, and Quality Control The President may appoint a member to serve as an alternate to a Vice President provided that the alternate possesses a bachelor of science degree in engineering or a physical science and has 10 years of industrial experience, including at least two years of nuclear fuel manufacturing experience.
12.
The Safety Committee shall meet at least quarterly and, in addition to the activities specified in Section 2.3 of the license application, shall review reports of inspections and audits which the a.
license required be conducted and semi-annual effluent reports required by 10 CFR 70, b.
review all violations of regulations and license conditions and unusual events having scfety significance as well as associated investigation reports. Particular attention shall be paid to the corrective actions and follow-up evaluations conducted to measure the effectiveness of the corrective cetions, a.nd provide the Division President with reports of its c.
findings and recommendations within 30 days of each meeting.
11.
See Section 2.3.2 An Executive Safety Committee has and been established to include personnel and activities 12.
requested by the NRC.
13.
The minimum qualifications for the positions of Executive Vice President, V4.ca President of Operations, Vice President of Engineering and Vice President of Quality Control shall be a Bachelor of Science Degree in engineering or a physical science and 2 years experience in nucl.ar fuel plant operation with special nuclear material.
14.
The minimum qualifications for the individual in the position of Director, Technical Services shall be a Bachelor of Science degree in engineering or a have 8 years of management experience, physical science and including 5 years in a nuclear facility, f13.
The NRC requirements are inconsistent with personnel and qualifications specified for other SNM licenseen. For 14.
example, another licensee has qualifications only for the Operations Manager (a bachelor's degree plus 3 years experience in the nuclear field) and Materials Manager (a bachelor's degree or equivalent plus 3 years experience in the nuclear field). This Materials Manager is basically equivalent to UNC's Director of Technical Services.
No other requirements are specified for operating or engineering personnel, p pi p n. -. - s J1 L
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u n V 6J~ w Vi! h. s UNC qualification requirements for nuclear safety personnel are equivalent or greater than the requirements in this other licensee's license.
However, we have added the NRC specified personnel qualification as a target rather than as a requirement.
Personnel currently in those positions noted in comments 13 and 14 are considered to be "grandfathered".
In particular, the Vice President of Operations does not meet the education requirements, but does have over 25 years of management experience in a nuclear facility.
15.
Within 60 days of the date of this license, all written procedures for activities involving licensed materials, as a minimum, shall be approved by the Manager, Nuclear and Industrial Safety, and, depending upon the Department (s) having responsibility for the activity, i.e.,
either the Vice President of Operations; the Vice President of Engineering; the Vice President of Quality Controit or the Director, Technical Services. Approval of the procedure shall be indicated by signature and shall be an integral part of the written procedure.
15.
The NRC requirements for approval of docuuents ara inconsistent with requirements specified for other SNM licensees. For example, another licensee handles approvals as follows: "Procedures for routine operations and mainteaance are reviewed and approved by Supervisor of the work area involved".
Another licensee only lists requirements for approvals related to nuclear safety personnel.
Still another license is required to have nuclear safety personnel giving written approval to only chances in procedures.
Since many thousands of documents exist for "activities involving licensed materials" together with revisions, it is not practical to have such an all inclusive approvals. We will incorporate a requirement (see paragraph 11.4.2) that documents containing nuclear criticality control requirements be approved by safety personnel (Director of Technical Services or the Manager of Nuclear and Industrial Safety or Nucloar criticality specialist) and operations, Engineering, or Quality control personnel having a degree in Science or Engineering and at least 2 years experience in nuclear fuel manufacturing, or personnel with a least 5 years experience in a nuclear fuel manufacturing plant.
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i 16.
An cyprovcd preceduro cutherising the cctivity chn11 bo cvoilchio et tho work ototion for personnel performing 1
activities with licensed saterials.
I 16.
See Section 4.1.5 and 11.4.2.1.
17.
All NIS department activities which. are performed to satisfy requirements'of the license shall be performed in accordance with approved written procedures.
Approval shall be indicated, as a minimum, by signature of the Manager, i
l Nuclear and Industrial Safety and the Director, Technical i
Services.
The signature approval shall be an integral part of the written procedures.
Approved procedures shall be immediately available at the work station for NIS personnel
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performing the NIS activity.
1 17.
Written NIS procedures supplementing detailed license requirements are developed when necessary. Presently t
procedures exist for conducting internal criticality j
contrel inspections, requests for changes in j
criticality controls and health physics task l
instructions. Section 11.4.5 has been modified to incorporate appropriate require.nents.
4 18.
All written procedures in the condition above shall be reviewed and approved annually (maxinua interval of 13 months) b and the Director, Technical Services.y the Manager, NIS, l
l l
18.
Procedures are revised and approved as needed. We consider this commint inconsistent with requirements placed on other NRC licensees.
l l
19.
Nuclear Criticality Safety inspections shall be performed by 1
an individual possessing, as a minimum, the qualifications
)
of a Nuclear criticality Safety Engineer specified in
]
Section 2.2 of the license application.
l 19.
For the compliance type of inspection being performed 1
we consider that the use of any NIS professional person is satisfacto n. Again we note that this condition is inconsistent with other SNM licensees.
1 20.
Nuclear Criticality Safety and Health Physics inspections i
shall be performed monthly (maximum intervals of 5 weeks).
1 The inspections shall follow a written inspection procedure j
which has been approved by the Manager, Nuclear and Industrial Safety.
All opera;ing shifts and process areas shall be inspected during each inspection.
Daring discussions with the NRC, the words "during each inspection" were replaced with "at least once every 3 i
months".
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20.
Secticn 2.7.3 cttt03 th0t cuch in:pecticn3 will b3 perfcrued monthly. There iu no technical justification for a "maximum interval of 5 weeks".
The requirement for a written inspection procedure has'been incorporated. All operating shifts and operating i
process areas should be inspected during each 3 month period.
The requested conditions are inconsistent with those of other NRC licensees.
i 21.
Records of each Nuclear Criticality Safety or Health Physics inspection shall be maintained for a minimum period of 2 years. The written record shall include the inspection plan and procedures, the inspector's identification and inspection findings (Report), the individuals taking corrective actions, the corrective actions, and the date when eckrective actions were completed.
21.
Inspection records will be retained for 2 years.
Section 2.9 has been so modified. The content of the records will be specified in the procedure referenced in 2.7.3.
1 22.
Within one week of completion of the inspection, copies of each Nuclear criticality Safety and Health Physics Inspection Report shall be provided to the Vice Presidents
)
of operations, Engineering, and Qunlity controls the Director, Technical Services, and.all members of the Safety i
Committee.
1 22.
Provision has been made for distribution of results and follow-up to the President and members of his staff.
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See Section 2.7.1 revised.
23.
The annual Health Physics Audit eshall not be performed with r
j a nuclear insurance inspection plan or by nuclear inr.urance personnel.
j 23.
The annual health physics audit will be performed by qualified professional personnel, see Section 2.7.4.
24.
Copies of the Health Physics Audit report shall be provided to all Safety Committee members within 30 days of the completion of the audit.
24.
The written results of the H.P. audit vill be provided in a reasonable time.
Any items requiring immediate action will be discussed at the time of the audit and promptly acted upon.
25.
Before contractor and teaporary employees are allowed access to restristed areas, such employees shall be given the same indoctrination training in radiation safety and nuclear criticality safety as given to new employees.
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25.
5 ction 2 5.5 hoc bacn reviccd to provida training cypreprioto to tho octivity to bo portform:d end cxperienco of tho cccort that 1o previded.
This requiremant has not been imposed on some other SNM licensees.
d 26.
Refresher training in nuclear criticality safety shall be f
provided on an annual (at least every 13 months) frequency.
l The content of the nuclear safety training program shall be reviewed and approved annually by the Director, Technical Services.
26.
Re-orientation training will be provided as stated in Section 2.5.3. Inconsistent application (as compared to other licensees) of an annual retraining of all 5
employees in nuclear criticality safety is being i
specified by the NRC.
Section 2.5.1 has been modified to provide for approval j
of the nuclear safety training program by the Director, Technical Services.
i 27.
The airborne radjoactivity of the breathing zone air in the operating work area whers unclad licanted material is i
precessed or where the operation potentially could result in worker's exposure to radioaccive material exceeding concentrations specified in 10 CFR 20.103, shall be i
j monitored continuously end analyzed for radioactivity by the following frequency:
f hERA Frecuency
'(
l Sectioning crea, decontamination Each working l
facility, metallogical sample shifu preparation lab, and waste packaging area l
All o'.her areas of Building B-South Weekly i
t 27.
This iten has beer incorporated in 3.2.3.1 except for the metallurgical sample preparation lab. This change is justified becatse of the nature of the operations performed in the P et Lab.
All preparations are wet, l
thus eliminating t he potential for significant airborne i
activity. Derived air concentrations for this area havs L
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continuously been less than 10% MPC.
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28.
Tha liccn:Co chS11 r00x20ino tha location of tho fixcd air samples for representativens is in detennining the airborne radioactivity level of workers' breathing zone air when process or equipment changes are made.
28.
The comment has been incorporated in Section 3.2.3.1.
29.
Notwithstanding the words in Sections 3.2.7.1 and 3.2.7.3 of the application, all personnel who regularly work in an area where bioaesay measurements are required shall partf-ipate in the bioassay program for both urine nample and in-vivo lung count.
29.
Section 3.2.7.1 states that all employees in limited control or controlled areas do par':icipate in the urine sampling programs. However, this section and 3.2.7 has been revised to improved the clarity.
Section 3.2.7.3 has been modified to incocporate the comment.
30.
The licensee shall conduct in-vivo lung counts for exposure control based on the frequency specified in Tables 2 and 3 of Regulatory Guide 8.11, "Application of Bicassay For Uranium," June 1974.
31.
Notwithstanding the partial restriction of the workers as stated in Section 3.2.7.3 of the application, a worker shall be restricted from areas containing airborne radioactive material if the in-vivo result is greater than one maximum permissible dose commitment.
'f 30.
Section 3.2.7.3 has been modified to incorporate the and
- comments, 31.
g 32.
Notwithstanding Secticn 3.2.6.2 of the application, the lunch room area shall be surveyed for contamination each day. If contamination was found, the survey frequency shall be increased to each shift until Health Physics Specialist i
has determined that the daily frequency may be resumed.
32.
The lunch room area is not arsociated with the non-encapsulated processing area.
Ptrsonnel must remove their protective clothing and shoe covers, and wash and monitor cofore leaving the work area (B-South) and going to the lunch roca area in A-Building, based on these conditions and the lack of any contamination being detected in the lynch areas over 12 years of operation, there is no hazard. However, Section 3.2.6.2 has been revised to provide for daily
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33.
Tha lic:n:CO'c rc:pirCto g prctectiCn progrCO ch0ll ba conducted in accordance with 10 CFR 29.103.
33.
Section 3.2.8.2 indicates conducting reouired respiratory protection programs in compliance with 10 CFR 20.103(c) through (g).
Section 3.2.8.1 addresres the use of respiratory devices to achieve ALARA goals and no credit is taken for the protection that may be achieved. Under these conditions, cospliance with 30 CFR 20.103(c)-(g) is not required.
Section 3.2.8 and 3.2.8.2 have been revised to indicate appropriate compliance to 10 CFR 20.103.
34.
The licensee shall collect a representative semple of the air effluent from each process stack or other point of release for areas where licensed material is handled. At maximum 13-month intervals, the licensee shall conduct a study to verify that the saspling of air effluents is representative.
The records of this study shall be kept at least fo.' 2 yeare.
34.
Section 4.1.1 han been reworded to clarify stack sampling. Other items are considered inconsistent with requirements applied to other licensees.
35.
The air effluents shs11 be sampled continuously and be analyzed for radioactivity at least weekly.
After 6 months, the licensee may collect a weekly sample every quarter from all release points except in Building B South, provided that the analysis results for the six month period are less than 25% of MPC.
35.
Section 5.1.1 providen for the weekly analyses and tne application of 25% Hpc per 10 CFR 20 limits.
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UNC NiVAL PRODUCTS I'
Licen o SNM-368 Chapter 1 Page 1-1 Date:11/30/87 j
Docket No.70-371 Rev. 2 i
i 1, Standard condillons and Snecial Authorizatiang 1.1 Nate. Address and cornerate Ir. formation UNC Naval Products is a segment of UNC Defer.se Group of UNC, Inc.
l The unclassified mailing address of UNC Naval Products ist 67 l
Sandy Desert Road, Uncasville, Connecticut 06302-0$$1. The Classified majling address tr? P.O. Box 981, Uncasville, Connecticut C6382-0981. Attention: Dccument Custodian.
i UNC,Inc. is a Delaware Corporation loccted at 175 Admiral Cochran Drivs Annapolis, MD 21401-7394 1he principal officers are t'.$. citizens. No dominant control or ownership is associated wio. assy alien, fornian corporation or t
fereign government.
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r Principal officers are Qiven in Paragraph 9.1.
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1.2 Site Location
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The 201 acre UNC site is locattd in the northeast corner of the l
town of Montville, New London County, Connecticut. It is bounded i
on the east by the Thames River, en the north by Trao ng Cove, l
and on the west and south by privately owned land. The nearest site boundary is to the north, at a distance of about 650 feet from the affluent stackr. The nearest residence is about 1400 feet to the west.
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Operations conducted at tha Montville site are located in f
buildings designated as follows (Sea Figure 1.1) l I
i Building A Building B Buildinc C-Building h East Plant Bui3 ding s, T, and tvher auxiliary j
buildings I
Building C is an office-typa building, Specific Operations in other buildings are discussed in Chapter 15. Basic operations j
performed at Montville are as described in Section 1.5. The poh4ession or use of SNM in any area or building is not permitted I
unloss it conforms to NRC Requirements (e.g., nuclear alarms, security).
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fi l h' 4 1 U % w u,w; UNC NAVAL PRODUCTS License SNM-368 Chapter 2 Page 2-1 Date:11/30/87 Docket No.70-371 "ev.1
- 2. ORGANIZATION AND ADMINISTRATION 2.1 Oraanizational Responsibilities and Authority "We shall work in a safe manner at all times" is the Policy of UNC.
The President of UNC Naval Products has implemented this statement to all employees by organization, communication, procedures, and training.
The President of UNC Naval Products reports to the Sector President -
Defense / Telecommunications of UNC,Inc., and has overall responsibility for the safe operation of the facilities.
Responsibility for safety, nuclear materials, security, and data processing has been delegated to the Director cf Technical Services.
Responsibility for implementing the safety programe has been delegated to the Manager, Nuclear and Industrial Safety. The Vice Presidents of Operations, Engineering,and Quality Control and the Manager, Nuclear Materials Control are responsible for enforcing and apply'ng the rules and program conditions for nuclear criticality safet and radiological safety which have been established by the Manager, NIS.
The organization of UNC Naval Products provides for administration, l
production, technical support, and nuclear and industrial safety functions, security and nuclear materials management. This is shown on the Organization Chart, Figure 11.1.a.
Typical lines of responsibility leading to the President of UNC Naval l
Products are shown in Figure 2.1.
Key to any safety program is the supervisor in a line organization, or the project leaders and ongineers in a technical staff organization. In the manufacture of nuclear reactor components,both groups are important to the safety related tasks of training personnel, process and equipment design and use, supervisory review l
and enforcement of requirements and procqdures.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 2 Page 2-3 Date:ll/30/87 Docket No.70-371 Rev.1 2.1.1 Oraanizational Positions - Functional Desqriotion (as related to Nuclear Safety)
President has overall responsibility for the safe operation of UNC Naval Products facilities.
f Director. Technical Services has been delegated responsibility for nuclear criticality safety, radiological safety, environmental controls, nuclear materials, security,and data processing.
Manaaer, Nuclear and Industrial Safety (NIS) provides nuclear criticality safety, health physics, environmental controls, industrial safety and fire prevention, for UNC Naval Products. The Department's assigned responsibilities include:
Establishment of nuclear and industrial safety policy and programs.
Preparation of, maintenance,and compliance with regulatory agency licenses.
Instruction and training of all personnel in handling and movement of SNM, proper Health Physics and Industrial Hygiene procedures.
On-site nuclear criticality safety and health physics control functions independent of, but parallel to the functions of operating personnel.
Technical support services, as related to nuclear criticality safety and health physics, for review of proposed additions to or modifications of process equipment.
Coordination of Emergency Services.
The department organization is shown on Figure ll.l.L.
Nuclear Criticality Safety Soecialist administers the nuclear criticality safety program in compliance with Federal regulations, provides evaluations of Nuclear Criticality Safety, and provides regular audits including follow-up with responsible operating mane 7ement. The Specialist reviews and independently checks the nuc; ear safety evaluations and calculations performed by the Nuclear safety Engineer or other Nuclear Criticality Safety Specialists, page 2-3 j!pe! r-4t!..*
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UNC NAVAL PFODUCTS License SNM-368 Chapter 2 Paga 2-4 Date:11/30/87 Docket No.70-371 Rev, 1 Health Physics SoecIalig,t C.dministers the Health Physics and environmental program in complianca with Federal and titate regulations, provides evaluaticn of radiological safe.ty, and performs regular audits including fellow-up with responsible operating management.
Health Physics Technicians perform Spocified health physics and environmental programs:(u.g. air monitoring, smaar survey, bicassay, air and liquid effluent checks, transportation package checks and special work permit issues.).
Nuclear Criticality Safety Encineer ot_3pglear_ Criticality Safety _
Seecialist is responsible for the day-to-day criticality control and verification that equipment, processes, and operations meet the safety criteria explicitly described in the license or an NIS approved internal document. He performs initial criticality safety evaluations, makes any necessary calculations,and proposes them to the Specialist for review. He assists in the training of employees and performs regular inspections including follow-up with responsible operating management.
Manaaer. Nuclear Materials control administers the Nuclear Materials Management Control Program including maintenance of the NRC Fundamental Nuclear Materials Control Plan,and accountability of all SNM at this facility. He has safety responsibility for these functions and assures personnel training, compliance with all safety rules and practices, and obtaining HIS approval prior to introduction of new or modified methods.
Executive Vice President of ODerations manages the Operations and Engineering Departments and has safety responsibility for these functions.
Vice President. ODerations manages manufacturing, facilities, maintenance,and plant services. He has overall safety responsibility for these functions. Safety responsibility is delegated to Operations Department managers, general supervisors, supervisors and employees for on-the-job training, assuring compliance with all safety rules and practices, and obtaining NIS approval prior to introduction of new or modified processes, equipment or facilities.
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UNC NAVAL PRODUCTS
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License SNM-368 Chapter 2 Page 2-6 Date:11/30/87 Docket No.70-371 Rev. 1 i
2.2 Personnel cualifications The Nuclear and Industrial Safety Department Manager shall hold a degree in science or engineering, and have at least ten years experience in a responsible position in the nuclear industry, at least three years of which have been in an activity which would develop an understanding of nuclear criticality safety, health physics, and industrial safety and fire prevention problems.
l Nuclear and Industrial Safety Department criticality and Health Physics Specialists shall have a degree in science or engineering and at least three years experience in a responsible nuclear engineering or health physics position,at least two years of which is professional experience in the area of their specialty.
The Nuclear criticality Safety Engineer shall have a degree in science or engineering with at least one years experience in performing nuclear criticality safety assessments and calculations.
Nuclear and Industrial Safety Department Consultants shall meet the same requirements as listad for the specialists.
Health Physics Technicians progress from an entry level (grade 4 or 6), to grade 8 and to Senior H.P. Technician (Grade 10).The minirum qualifications for entry level is a high school diploma. The minimum of one years satisfactory performance in the entry level is necessary before promotion to Grade 8: with 3 years of satisfactory performance required to become Grade 10.
The Nuclear Materials Control Manager shall have a college degree or equivalent and at least three years experience in the nuclear field and shall have demonstrated sufficient judgement and capability to manage the nuclear materials control function.
The Director of Technical Services shall have a degree in Science or Engineering with at least eigh*. years of management experience, including 5 years in a nuclear facility.
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.s UNC NAVAL PR'ODUCTS
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License SNM-368 Chapter 2 Page 2-7 Date:11/30/87 Docket No.70-371 Rev. 1 The minimum qualifications of Vice Presidents, Managers,and Supervisors who are responsible for employees handling nuclear materials are:
a.
2 years of work experience at UNC Naval Products or another facility engaged in the handling of formula quantities of nuclear materials, b.
or specific approval by the President, a Vice President, or Department Manager, and the NIS Manager recognizing the competency and/or training given to an individual, and his/her demonstrated judgment and capability to manage or supervise the function.
c.
UNC will endeavor to have the Executive Vice President of Operations and Vice President of Operations, Engineering or Quality Control possess a degree in Science or Engineering. In the case of exceptional individuals not possessing a degree, UNC will provide for information, a resume of their experience and other qualifications.
2.3 Safety Review Committee 2.3.1 Nuclear Safety and Health Review Committee (NSHRC)
The NSHRC considers new and revised facilities, equipment, and processes involving radioactive materials and assures appropriate safety, health,and environmental controls have been evaluated for items that are beyond the approval authority of indiyidual NIS specialists. The criteria for review by the NSHRC are:
- a. Any change or addition requiring a license amendment.
[
- b. Any new or modified core / reactor design unlike a previously approved design, l
- c. Any new or modified fuel process or new types of fuel processing l
equipment unlike previously approved processes or equipment. A new process is one which involves different feed materials whose safety has not been evaluated, may introduce a new element of safety, or may affect the physical or chsmical properties of the radioactive bearing materials.
- d. The relocation or decommissioning of a previously approved fuel l
processing area.
- e. Radiological safety or control systems, except those system changes that do not reduce the margin of safety previously approved l
for the operation.
- f. Situations where an average increase of more than 50% in current l
average surface contamination levels is projected by the radiological safety evaluation (increase may not cause levels to exceed regulatory or license action levels)
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.s UNC NAVAL PRODUCTS License SNM-368 Chapter 2 Page 2-8 Date:11/30/87 Docket No.70-371 Rev. 1
- g. Situations where an average increase of more than 25% in current I
airborne contamination levels are projected by the radiological safety evaluation (increase may not cause levels to exceed regulatory, or license action levels)
- h. Where an exhaust is required to meet airborne contamination levels
- i. conditions where uranium effluent levels are projected by the l
radiological safety evaluation to increase b monthly plant average for the previous year.y more that 25% of the j.Other changes not specifically covered in items a-1, but which are j
judged by the Nuclear Criticality Safety or Health Physics Specialist to contain an element that should be reviewed by the NSHRC Permanent members of the NSHRC are the Manager-NIS, Nuclear criticality Safety Specialist, Health Physics Specialist, Industrial Safety Specialist, and selected personnel with qualifications appropriate to evaluate the agenda items.The special NSHRC members are selected by and report to the Manager, Nuclear and Industrial Safety in their NSHRC capacity.
The annual ALARA report on radiological exposures and monitoring shall be reviewed and recommendations made to the President for l
implementation.
2.3.2 Executive Safety Committee This committee has responsibility for overview and coordination a.
of all UNC Naval Products Safety Programs. Moetings are held at least once per calendar quarter, with the agenda determined by the chairman and includes review of results of inspections and audits which the license requires to be conducted; semi-annual effluent reports required by 10CFR70; violations of regulations and license conditions; unusual safety events, together with corrective actions, b.
The Executive Safety Committee includes the following permanent members:
President, UNC Naval Products Chairman Executive Vice President, Operations -
Vice Chaire.an Vice President, Operations Vice President, Quality Control Vice President, Engineering Director Technical Services Manager, Nuclear & Industrial Safety (NIS) c.
Records of the meetings shall be maintained for at least one year.
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UNC NAVAL PRODUCTS Lic0nco SNM-368 Chnptor 2 Page 2-9 Date:11/30/87 Docket No.70-371 Rev.1 i
2.4 Acoroval Authority For Personnel Selection All personnel in safety-related staff positJ)ns and the Safety Review Committee are approved by the President an>! neneral Manager of UNC Naval Products.See paragraph 2.2.7.b also.
The assignment of individuals to the NIS Department is approved by at least two (2) levels of management above the assigned positions.
2.5 Trainina 2.5.1 General Training programs concerning the safety aspects of handling source and special nuclear materials shall be established on a Division-wide basis. Indoctrination and training for new security cleared employees (persons on the employment roll less than 2 months) shall be provided. Reorientation for those already in the enploy of UNC Naval Products shall be given at least every 2 years, except that employees working with radioactive materials in readily dispersible form shall be trained at least annually in nuclear criticality safety and radiation protection. These portions of the training program shall be given or supervised by specialists in the field of safety involved.
The training program shall be approved by the Director, Technical Services.
2.5.2 Indoctrination and Trainina The indoctrination and training of new employees in the safety aspects of the fuel fabrication process shall be conducted by, or under the supervision of, specialists in the topic covered.
An indoctrination shall be given on the basic concepts of radiation, protective action and devices, atomic fission and chain reaction control methods in general. Specific methods used to control NPD operations are presented with emphasis on following the safety restrictions on mass, dimension, or concer.'. ration. Other topics shall include the radiation detection and alarm system, its sound, and action to be taken in such emergency; company safety regulations and action in event of fire, explosion,or other non-nuclear emergency.
l Written examinations shall be given to monitor employee l
understanding. A record is kept of training received. The indoctrination shall be completed prior to access of new employees to licensed material or restricted areas.
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UNC NAVAL PRODUCTS L'icOnno SNM-368 Chapter 2 Page 2-10 Date:11/30/87 Docket No.70-171 Rev.1 Further training ot the new employee shall be continued by the supervisor, who is responsible for instruction in all aspects of the particular assignment. Health physics and nuclear criticality aspects are routinely included as a part of the regular department safety meetings. A minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> indoctrination and training shall be given to each new employee. Documentation shall be provided to assure compliance 2.5.3 Re-Orientation NPD shall conduct mandatory refresher training in radiation protection, nuclear criticality safety, and emergency procedures at least every two years, except that employees working with radioactive materials in readily dispersible form shall be trained at least annually in nuclear criticality safety and radiation protection.
Documentation shall be provided to assure compliance. A written test shall be given to each individual to evaluate the effectiveness of the refresher training.
2.5.4 On-The-Job Trainina Instruction specific to the proper and safe performance of a job shall be given to new area personnel (i.e. new hires or transfers) by the responsible supervisor. The supervisor shall assure himself that each employee who works under his cognizance shall be able to do all activities in compliance with applicable nuclear criticality limits, health physics requirements, industrial safety methods,and management approved manufacturing instructions / procedures.
Continuing review of each employee shall be made by the supervisor.
Additional training shall be given as deemed necessary.
Frequent area inspections by NIS personnel shall detect groups or individuals that may require additional explanation and training. The added special training shall be documented.
2.5.5 Visitor / Contractor A program shall be established for providing an appropriate amount of instruction, commeasurate to the activity and escort provided, as determined by the Nuclear and Industrial Safety Department, for a short term visitor or contractor. Any contractors having independent and unaccompanied access to restricted areas shall receive the same indcctrinaton as given to new employees.
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!'t UNC NAVAL PRODUCTS Lican2O SNM-368 Ch;ptor 2 Page 2-11 Date:11/30/87
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Docket No.70-371 Rev.2
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2.6 Ooeratina Procedures Activities involving materials under this license shall be performed in accordance with approved written procedures.
UNC is contractually required to use routing instructions (Route Cards) for each item manufactured.
These Route Cards identify the controlled procedure (s) required for each operation and inspection which is performed.
Issuance of all product related route cards and procedures is controlled by the Process Information Control Centers.
All Route Cards involving fuel or fuel look alike shall carry a criticality limit, or reference a posted criticality limit, and shall be approved by NIS.
Revisions to these Route Cards shall also be approved except where those revisions have no impact on product handling.
For example, a revision to change a contract identifier, a part number, correct a typographical error, or a records step is not approved by NIS.
All fuel work locations shall be posted with criticality limits and controls.
These postings shall be issued by NIS, and shall be inspected on a scheduled basis.
Additional NIS procedural controls are necessary for certain product stream operations, and are therefore contained in the Manufacturing Operating Procedures (MOP's) covering those operations.
MOP's containing NIS information (criticality, radiation, or industrial safety) shall be approved by NIS.
All MOP's shall be available at the work locations. Non product operations involving fuel (waste handling, etc.) shall be covered by procedures approved by NIS. These procedures shall also be available at the work locations.
Most operations involve fuel in which the necessary safety instructions are contained in the Route Cards or posted limits previously discussed.
Accordingly, these require no additional safety related instructions, and are therefore not subject to NIS approval.
2.7 Insoections and Audits 2.7.1 General A continuing re-appraisal of the safety program shall be provided through a system of daily checks, regular inspections, and audits.
Violations are corrected on the spot with the concurrence of the cognizant Specialist and/or Manager of NIS and recorded. If corrective action requires additional time to complete, a record of the violation shall be prepared and maintained until corrective action is complete. For daily checks, inspections and audits, all observed violations including corrective action initiated and/or completed shall be documented; such information is provided to the President and appropriate membors of his Staff; a quarterly review of results is provided to the Executive Safety Committee. A planned schedule of regular inspections and audits shall be established by the NIS Manager.
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e 6O UNC NAVAL PRODUCTS License SNM-368 Chapter 2 Page 2-12 Date:11/30/87 Docket No.70-371 Rev.1 2.7.2 Daily Checks Daily checks and visits shall be made routinely by Health Physics Technicians who make general observations in addition to their radiation survey functions. A technician shall report observed problems to the area Supervisor, and the Supervisor shall take appropriate action as required. Violations shall require a written notice and correction.
2.7.3 Insoections Plant inspections of Health Physics and Criticality Control shall be performed by personnel meeting the respective qualifications identified in paragraph 2.2. An inspection follows a written procedure approved by the Manager, NIS. Inspections shall be documented. These inspections shall be performed as follows:
Epnction By Minimum Frecuency Health Physics NIS Professional Personnel 1/ month (a) (c)
Nuclear Criticality Safety NIS Professional Personnel 1/ month (a)(b)
Operating Production, Process, or Quality Continuing with Procedures and Control Engineering NMC being Records Control annually including Nuclear Materials Control NOTE:
(a) All plant facilities shall be inspected within each year.
(b) All operating process areas and operating shifts shall be inspected during each 3 month period.
(c) Each operating shift should be inspected within each year.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 2 Page 2-14 Date:11/30/87 Docket No.70-371 Rev.1 2.9 Records Nuclear criticality and radiological safety analyses are retained for at least six months after the approved operations are discontinued.
Records of violations, abnormal incidents, instrument calibration, and employee training and retraining are retained for at least 1 year. Inspection, audit, and ALARA reports are retained for a minimum period of 2 years. Records of personnel exposure and radiation surveys are retained as required by applicable NRC regulations.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 3 Page 3-4 Date:11/30/87 Docket No.70-371 Rev.1 3.2.2.2 Filters and Scrubbers Before it is exhausted from the building.Jhe contaminated and potentially contaminated dry air from the controlled areas shall be filtered by high efficiency particulate filters with 199.95%
efficiency for 0.3 micron particles, or scrubbed to assure that air concentrations do not normally exceed 25% of the 10 CFR 20 Appendix B Table 2 limit.
If air is recycled la a controlled area, an evaluation shall be performed to determine whether this air requires additional filtration to protect personnel.
Recycled air shall not be used in areas if airborne radioactive material exists in concentrations which, averaged over the number of hours in any week during which individuals are in the area, exceed 25%
of the amounts specified in Appeadix B, Table 1, Column 1 of 10 Part 20.
The minimum frequency for measuring airborne contamination of radioactivity in recycled air snall be at least weekly.
Pressure drop acrocs each filter bank shall be measured and recorded on a monthly basis. Filters shall be changed when the P is 24 in.
of water. This change may be deferred over a short term in order to coordinate with production or maintenance schedules provided Health Physics personnel can monitor and verify that such deferral will not adversely impact the area local exhaust or air flow as defined in 3.2.2.1, and airborne concentrations as defined in 10 CFR 20. The evaluation shall be reccrded.
3.2.3 Work Area Air Samplina 3.2.3.1 Airborne Concentrations Process and breathing zone air samples shall be taken in sufficient numbers and frequency to comply with internal Health Physics requirements as stated in 3.2.3.2. The limits and guidelines of 10 CFR 20.103 "Exposure of Individuals to Concentrations of Radioactive Material in Restricted Areas" shall be followed.
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i.e t,. b UNC NAVAL PRODUCTS License SNM-368 Chapter 3 Page 3-4a Date:11/30/87 Docket No.70-371 Rev.0 The room air in all areas where non-capsulated licensed material is processed or where the operation could result in worker exposure to radioactive material exceeding those concentrations specified in 10 CFR 20.103 shall be regularly sampled and analyzed for airborne concentration of radioactivity according to the following frequency:
AREA FREOUENCY Sectioning area, Each working shift decontamination facility, and waste packaging area All other areas of Weekly Building B-South The airborne concentration level in the work area will be evaluated by the data measured from all operating sampler stations in each work area.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 3 Page 3-5 Date:11/30/87 Docket No.70-371 Rev.1 If lapel samplers are used in determining the concentration level in workers' breathing zone air, the samplers shall be worn by all workers in the work station. Additionally, the samples must be counted for radioactivity on a daily basis.
If fixed air sampling equipment is used to determine concentration in workers' breathing zones, the locations of the fixed air sampling heads shal: be re-examined for their representativeness of workers exposure at least once every 12 months or when process and equipment changes are made that could affect the representativeness of the monitoring.
- 3. 2. 3. 2 Action Levels Analyses of the air samples are made after natural activity has had sufficient time for decay, at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after sampling completion.
Action levels for the data acquired by each fixed air sampler representing a work station are:
Result Action A. Weekly average exceeding 25%
(1) Investigate and report of 10 CFR 20, App.B, Table I corrective action levels.
taken B. Monthly average exceeding (1) Investigate and report 25% of 10 CFR 20, App.B, Table corrective action I levels.
taken.
(2) Consider work restrict-ion or installation of engineering controls.
C. Quarterly average exceeding (1) Invantigste an.d report 25% of 10 CFR 20, App.B, Table corrective action I levels, taken.
(2) Impose work restriction, engineering conurols, or respirator use in accordance with 10 CFR 20.103.
(3) Increase bioassay sample collection frequency.
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UNC NAVAL PRODUCTS LicOn00 SNM-368 Chapter 3 Page 3-12 Date:ll/30/87 Docket No.70-371 Rev.1 Permissible contamination levels shall be established by Health Physics and/or Qualit Physics as necessary.y Control and shall be evaluated by Health Currer.tly enforced levels are presented in Section 12.8.4. A plan layout identifying the defined controlled areas, limited control areas, clean areas of the facility and all the access points to the controlled areas is presented in Section 12.14.
3.2.6.2 Action Leve,.s and Survev Frecuencies the following survey frequencies and action levels shall be maintained,for the program to control surface contamination:
General surveys shall be taken at regular intervals to assure that personnel are not exposed to radiation hazards and in order to locate and control any radioactive contamination. The frequency of such surveys shall be dependent on initial Health Physics evaluation of operations with subsequent review Minimum survey frequency shall be as described below for removable surface contamination.
Action level (removable)
Minimum and action when the level Plant Area Su rvey Frecuency is exceeded Sectioning Area Daily
} 5000 dpm /100cm2 End of DeCon Area Shift
[
clean up Chemistry Lab -
Bi-weeklyj 10,000 dpm /100 cm2 Immediate (Controlled Portions).
clean up and sample preparation rm.
Other controlled Weekly
- 1 500 dpm /100 cm2 End of areas and limited
(
shift controlled areas, cleanup s
1000 dpm/100 cm2 Immediate clean up i
a Lunch Area, Bldg. A Daily 30 dpm/100 cm2 Immediate clean up
),
Clean Areas Monthly Page 3-12
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UNC NAVAL PRODUCTS Lic nco SNM-368 Chapter 3 Page 3-13 Date:11/30/87 Docket No. 70"371 Rev.1 3.2.7 Bioassuv Prg,qGE All personnel who regularly work in an area where bioassaf measurements are required shall participate in the bioassay program for both urine sample and in-vivo lung count. The UNC HP bicassay program shall meet or exceed the recommended bioassay program in Regulatory Guide 8.11.
Sampling frequency in the bioassay program will be increased according to the last quarterly average airborne uranium concentration as specified in Table 3 of Regulatory Guide 8.11 "Application of Bioassay for Uranium".
3.2.7.1 Urine Analysis The extent of the bioassay program performed shall be based on the uranium quantity, form, degree of contamination confinement, and air sampling test results, a.
Bioassav Frecuency (Urinei All e.mployees shall have l'. cine bioassay r mples taken at the start and termination of employmen*,.
Those personnel who regularly work in an area where bioassay measurements are required shall participate on a frequency as specified in Tables 2 and 3 of Regulatory Guide 8.11, "Application of Bioassay for Uranium", June 1974.
b.
Action Levels:
Level Actions 50 d/m/ liter Health Physics Evaluation l
100 d/m/ liter Work restriction and Health Physics evaluation until 50 d/m/ liter f
100 d/m/ liter constant continued work restrictionst for 3 sampling periods intense evaluation Urine bio-assay samples shall be collected from the persons involved i
following any incide'.c which may cause or threaten to cause an j
oVer-exposura. If such a urine analysis indicates the potential for 50% or more of the maximum permissible lung burden for i
non-transportable uranium, a ceasonably prompt in-vivo count shall be performed.
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1 UNC NAVAL PROUJCTS Licence SNM-368 Chapter 3 Page 3-14 Date:11/30/o7 Docket No. 70 ',71 Rev.1 3.2.7.2 Fecal Analysis Focal Analysis shall be used for evaluation studies of suspected local airborne exposures which result frou or could result from an incident such as a fire, spill, equipment malfunction, high air sample, or other departure from normal operations.
Actions to be based upon diagnostic results include:
selection of subsequent measurement techniques and frequencies a
- b. imposition or removal of vork restrictions c.
referral to a physician
- d. the physician's decision to attempt acceleration of the nuclide elimination process 3.2.7.3 In-Vi'ro Countina In-vivo counting of employees as a method of assessing the internal Ceposition of enriched uranium shall be considered a part of the overall bit-assay program.
Employees potentially subject to occupational internal deposition of radioactive materials shall be in-vivo counted according to pre-published schedules which shall be established by the Health Physics Section. The Health Physics Specialist shall coordinate the in-vivo counting program In-vivo.ung counts for exposure control shall be based on the frequency specified in Tables 2 and 3 of Regulatory Guide 8.11, "Application of Bioassay for Uranium", June 1974.
Results obtained shall be used in accordance with Regulatory Guide 8.11 recommendations as a basis for restricting employees. If the in-vivo result is greater than one maximum permissible dose commitment, a worker shall be restricted from areas containing airborne radioactive material.
Restriction is implemented immediately upon receipt of the formal in-vivo report. A confirming whole body count at a separate facility may be made to verify the full restriction.
In-vivo counting shall also be used in addition to urine and focal sampling to evaluate accidental internal exposures. Employees known or suspected of having been subjected to concentrations exceeding 40 MPC hours shall be counted at the next scheduled session at the plant site page 3-14
y p o u w.4 5 is UNC NAVAL pro?.UCTS Lic0nco SNM-368 ChCptGr 3 pig 3 3-15 Datat11/30/87 Docket No.70-371 Rev.1 3.2.8 RESPIRATokY PROTECTION. PROGRAM This program is conducted in compliance with 10 CFR 20.103.
The conditions for use of rospiratory protection equipment shall be pursuant to Paragraphs 3.2.8.1 or Paragraph 3.2.8.2 as follows:
3.2.8.1 Respiratory equipment may be issued in non-routine situations by the Health Physics Section in accordance with our ALARA commitments and as an adjunct to a special Work Permit involving absolute filter changes, sump cigan-outs, or other anticipated maintenance operations in controlled areas, provided that:
a.
No allowance shall be made for particle size or the use of respiratory equipment in controlling the individual exposure to a quantity of radioactive material below that quantity which woul:1 result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in 10 CPR 20 Appendix B, Table 1, Column 1 and 10 CFR 20.103.
b.
Air sampling, other surveys,or HP evaluations shall be used to identify the hazard and to evaluate individual exposure.
c.
Increased ssrveillance, limitation of working times, and/or early information air monitors shall be used to maintain intake of radioactive material within any period of seven consecutive days below that which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentration specified in 10 CFR 20 Appendix B, Table 1, Column 1.
~
d.
Health Physics technicians assu: t the adequate fitting of the respirator, instruct the user in its use, and advise the user tNat he may leave the arwa at any time for relief from i
respirator usa.
e.
Under the above conditions compliance with 10CFR 20.103(c) through (g) is not required.
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UNC NAVAL PRODUCTS License SNM-358 Chapter 3 Page 3-16 Date:11/30/87 Docket No.70-371 Rev.1 3.2.8.2 When it is impracticable to apply process or other engineering controls to limit concentrations of radioactive material in air below 25 percent of the amounts specified in 10 CFR 20 Appendix B, Table 1 with concentrations averaged over the number of hours in any week during which individuals are fn the area, other precautionary procedures, such as increased surveillance, limitation of working times, or prevision of respiratory protective equipment, shall be used to maintain intake of radioactive material by any individual within any period of seven consecutive days as far below that intake of radioactive material which could result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentrations specified in 10 CFR 20 Appendix B, Table 1, Column 1 as is reasonably achievable.
Respiratory protection required to. limit the inhalation of airborne radioactive material pursuant to Paragraph 3.2.8.2 will be used in accordance with Regulatory Guide 8.15 "Acceptable Program For Respiratory Protection" and 10 CFR 20.103(c) through (g).
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UNC NAVAL PRODUCTS l
LicOnco SNM-368 Chapter 5 Page 5-1 Date:11/30/87 Docket No.70-371 Rev.1 CHAPTER 5 - ENVIRONMENTAL PROTECTION 5.1 Radioactive Effluent Control Systems 5.1.1 Gaseous Effluents All stacks associated with areas handling nonencapoulated licensed radioactive materials particulates shall be continuously monitored for alpha activity at the point of release. As a minimum, the analysis frequency for alpha activity shall be weekly. Beta / gamma activity shall be monitored and analyzed when necessary. Emissions shall be kept as low as is reasonably achievable below the limits specified in 10 CFR 20.106, Radioactivity in Effluents To Unrestricted Areas.
Tabulations are maintained for the results found from these
. measurements in order to observe trends, establish the quantities of material lost to the outside atmosphere, and to determine the status of air releases in relation to 10 CFR 20 limits and ALARA.
A discitarge concentration averaged over any 60 day Jaterial balance period which exceeds 25% of the 10 CFR 20 limits will require investigation. corrective action will be undertaken if the investigation indicates these levels may be exceeded as an annual average concentration or for obvious system failures.
Corrective action may include such action as equipment repair, equipment raplacement, equipment cleaning, equipment modification and/or equipment addition.
5.1.2 Licuid Effluents Trace amounts of uranium are processed through the radwaste treatment system and released to the Sanitary System. This waste is controlled and sampled prior to discharge.
j Releases shall be kept as low as reasonably achievable below the l
limits specified in 10 CFR 20.303, Disposal by Release into t
Sanitary Sewerage Systems for releases into the municipal sewerage treatment plant.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 9 Page 9-1 Date:11/30/87 Docket No.70-371 Rev.2 CHAPTER 9 - GT.NERAL INFORMATON 9.1 Corcorate Information The corporate organization of UNC, Inc. is presented below.
Further detailing of the organization of UNC Naval Products and the Nuclear and Industrial Safety Department is presented in Chapter 11.
CORPORATE OFFICERS Dan A. Colussy President and Chief Executive Officer Robert J. Waugh Sector President - Aerospace / Aviation G. Vern Diedrick Sector President - Defense &
Telecommunications Paul X. McLain Vice President, Financial Controls Richard H. Lange, Senior Vice President, General Counsel and Secretary Robert L.
Pevenstein,Vice President of Finance Gerald R. Cioci, Treasurer The President, UNC Naval Products reports to the Sector President b of Defense / Telecommunications.
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DD UNC NAVAL PRODUCTS
- Lic n 0 SNM-368 Ch ptor 10 Page 10-1 Date:11/30/87 Docket No.70-371 Rev:2 CHAPTER 10 - FACILITY DESCRIPTION 10.1 Plant Lavout Paragraphs 9.5 and 9.6 in preceding Ch:1pter 9 have presented general cetivity relationships to various buildings. Detailed plant layout information is presented on the drawh.gs listed below:
- 1) Drawing
- 423000 Rev. 7 Building M.
- 2) Drawing
- 423001 Rev. e Building A Part 1
- 3) Drawing
- 423002 Rev. 10 Building A Part 2
- 4) Drawing
- 423003 Rev. 3 Building B Part 1
- 5) Drawing
- 423004 Rev. 7 Building B Part 2
- 6) Drawing
- 423006 Rev. O Building D&S
- 7) Drawing
- 423013 Rev. 14 East Plant
- 8) Drawing
- 423035 Rev. O M-Bldg. Annex Chapter 15 relates processing operations to buildirig locations and equipment.
o Previously sent as an enclosure to our letter W.
F.
Kirk to G.
H.
Bidinger dated August 10, 1984.
10.2 Utilities and Succort Systems 10.2.1 Electric Power Electricity is supplied (13.2 KV, 3 phase) by Northeast Utilities via d dicated 18 70s frcm their Montville power station.
(A) Eneraency Generat7r and Switch Gear 1.
A 400 KW emergency Venerator is located in a separate building adjacent to Door 15 south side of east plant.
2.
The generator's diesel motor will start automatically vnen
'9urchased power is lost to the 800 AMP main circuit breake-J of Panel ' EPM-l' also located in the generator building.
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UNC NAVAL P.tODUCTS License SNM-368 Chapter 10 Page 10-2 Date:11/30/87 Docket No.70-371 Rev.2 3.
Wir.hin a few seconds, the diesel will be up to speed and supplying power to tlose units fed directly from Panel EPM-1.
Other units require Fanual switching to emergency power.
4.
When purchased power is restored and stablilized for five minutes, a motor-driven switch will shift the motor control center back to purchased power. Those units under manual switch control must than be manually returned to regular power.
t (B)
Load on Panel EPM-1 1.
Lights, equipment, 100-ton crane, and air conditioning in Assembly area (on automatic switchi'.g).
2.
Emetgency lighting throughout the plant (on automatic switching).
3.
East Plant oil burners.
4.
Dimensional pickle cranes, Building "A",
"M" (on automatic switching).
5.
Emergency power to "M" Guard Station (CAS) including Portal Monitor (un automatic switching).
6.
10 ton crane over vacuum anneal (manual switching).
7.
2 - 20 HP Savage pumps.
8.
Manual tranofer switch of 400 A Bus Duct in high bay.
9.
Outside security lights.
(C)
B-Buildina 1.
A 135 KW emergency generator is located in "B"
- Building, northwest corner near door #28 alcove.
2.
This diesel generator operates in a manner similar to the unit in East Plant.
3.
This unit supplies emergency power to (a) Internel lights in "A",
"B",
"S" Buildings.
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UNC NAVAL PRODUCTS LICENSE StM-368 CHAPTER 11 PAGE 11-2 DATE: 11/30/07 00CKET NO.70-371 REV:
1 l PRES 80ENT l EXECUTNE VP EXECUTN1 VP OPERATONS FINANCE & PLNMNO RESO ES OUaOTY ENGdNEERNG OPERATONS WATERIALS ggg gg gg DATA REGULATORY PROCES4NG FUNCTCNS NUCLEAR ANO NOUSTRIAL SAFETY NUCLEAR
[
MATERIALS CONTRot.
SECURITY FIGURE 11.L4 0 ) TEC)*ecAL SEmycEs msPCNSSUTES FOR WETY. 64TCN SECURITY, AND GENERAL DEPARTMENT CAGAN1?ATION m CT m cPsPECM m u m RAS DEAM OfECTLY Fu nt PMstENT.
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UNC NAVAL PRODUCTS b Od)b!NE.U L
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, LICENSE SW-368 CHAPTER 11 PAGE 1.1-3 DATE: 11/30/87 DOCKET NO.70-371 REY: 1 l
PRESIDENT DIRECTOR TECM SERVICES MANA08R NUCLEA14 NOUSTRIAL SAPfTY
- U FIRE PROTECTION t
i CONSUI.TANTS
[
r 6
P NUct 8AR & INDUSTRIAL SMETY DEPARThENT ORGANIZAT@
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UNC NAVAL PRODUttS Licen00 SNM-368 Chapter 11 Page 11-4 Date:11/30/87 Docket No.70-371 Rev.1
?.pproval by the Nuclear and Industrial Safety Department shall be in accordance with criteria established by the license which includes a review by qualified individuals.
The mechanism of such approval is described in more detail in the following sections.
Records of such approval shall be maintained for at least 6 i
months after cessation of such operation.
11.4.2 Ocerational Instructions i
Specific written operational instructions, reviewed and approved by NIS, shall be set up to control the handling of special nuclear material. These instructions shall be followed from the receipt of incoming material through all manufacturing phases of the products, up to and including shipment. The documents will contain nuclear criticality limit instructions and will be at work stations.
Approval of operational instructions is by the Director of Technical Services, NIS Manager, or Nuclear Criticality Specialist and operations, Engineering or Quality Control l
personnel having a degree in Science or Engineering ano at least l
2 years experience in nucitar fuel manufacturing or personnel l
with at least 5 years experience in a nuclear fuel manufacturing
]
plant. The operational instructions used are as follows:
5 11.4.2.1 Routino Instruction 1
i These instructions list the process steps which appig to the manufacture and inspection of all components. Each worker must 4
]
have the routing instruction present prior to performing any work on fuel components. He is instructed to review the work routing i
instruction which includes or references th applicable 5
criticality instructions, working drawings, iixtures or tooling numbers, Manufacturing Operating Procedures and Quality Instructions or other prccess documents. At the conclusion of the operation step, the worker signs and dates his performance of the work. Because of the high visibility of the routing instructions and required worker use, NIS criticality control instructions are carried by this int truction.
i 11.4.2.2 Critig'al'tv Control Postina l
Criticality controls are posted in work and storage areas. These criticality centrol signs shall specify applicable requirements.
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UNC NAVAL PRODUCTS License SNM-368 Chapter 11 Page 11-5 Date:11/JO/87 Docket No.70-371 Rev.1
)
11.4.3 Work Details This information is supplied to the werker in the form of Manufacturing operating Procedures, Quality Instructions, Standard Procedures, working drawings,and tooling. These items are listed on the Routing Instructions together with the criticality instructions. Any work performed must meet the criticality instructi.ons. NIJ does not approve "work detail" documents.
11.4.4 Health Physics Task Indtructions and Radiation ProtectioD Instructions a.The documents provide basic instruct. ion to H.P. personnel for various tasks performed under this license. These instructions shall be reviewed and approved by NIS Management.
i
- b. Written instructions for personnel radiation protection shall be prepared, consistent with the rt:quirements of 10 CFR 20 and shall be approved, maintained and adhered to for operations involving the potential for personnel radiation exposure.
Detailed work procedures may be accepted by the H.P. staff.
11.4.5 Nuclear Criticality Control (Internal NIS Dent. Procedures)
Written NIS procedures supplementing decalled license requirements are developed when necessary. Presently procedures exist for conducting internal criticality control inspections, i
and requests for changes in criticality controls. These l
instructions shall be reviewed and approved by NIS managem6nt.
11.4.6 Qg ument Control and Availabilldy Criticality Control Pestings are directly issued by NIS to Shop / Area supervision.
Routing Instructions are issued by the' operations Department (Production Control) with wach part that is manufactured.
Work Details p** 1ade available to plant operators and inspectors vi; a docum6nt control center as presented in attached Division operating Procedure (DoP) No. 24. in Appendix 11.4.6.
11.4.7 Empiqygg Conoliance Work olace adherence to criticality requirements is obtained through the following pregram:
1.
Initial indoctrination as a now employee.
2.
on-the-job training with supervision.
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