ML20202G443
| ML20202G443 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 11/24/1997 |
| From: | Elliott G FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30994, NUDOCS 9712100035 | |
| Download: ML20202G443 (103) | |
Text
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F R AM ATOME COG EM A FU E LS D 20)
November 24,1997 Mr. Michael A. Lamastra Licensing Section 2 Licensing Branch Mall Stop T8D14 Division of Fuel Cycle Safety & Safeguards Office of Nuclear Materials Safety & Safeguards United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Lamastra:
Subject:
Organizational Changes (TAC No. L30994)
References:
1)
Docket No. 701201, SNM 1168 2)
Framatome Cogema Fuels' Correspondence dated June 9, 1997, from G.F. Elliott, Manages, Safety & Licensing, to Mr. Michael F. Weber, NRC Branch Chiet 3)
NRC's Correspondence dated October 30,1997, from Mr.
M. A. Lamastra, NRC Licensing Section 2, to G.F. Elliott, Manager, Safety & Licensing in becordance with your correspondence dated October 30,1997, regarding required additionalinfor nation prior to final action (Reference 3 above), Framatome Cogoma
- Fuels (FCF) is terubmitting our amendment request with the requested information provided.
The requested additionalinformation in the attachment to your letter dated October 30,1997, is identified in Attachment 1 with FCF's Responses. Attachment 2 details the changes in each chapter. All of the changes are indicated by a side bar for this amendment.
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Si), copies of the requested changes are included. Should you have any questions regarding the proposed changes, please feel free to contact me at (804) 832 5202.
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Sincerely, l
FRAMATOME COGEMA FUELS Lynchburg anufacturing Facility
.sf Gayle Elliott Manager, Safety & Licensing r
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Page 1 of 3-1.
Section 1.3 should be modified to reference the date of renewal and current expiration date.
Response
Section 1.3 has been revised to show FCF's Materials License i
designation and expiration date.
2.
Section 2.1 should be modified to include the duties and responsibility of the Quality Manager.
Response
Section 2.1 has been revised to include '.he Quality Manager.
Although the Plant Manager has ovr all authority, the Quality Manager has dual responsibility since the Safety & Licensing organization falls under his leadership organizationally.
5.
Section 2.6 should be modified to clearly state that following proc 6dures is mandatory.
Response
Section 2.6 has been reworded to state "Appliceslo procedures shall be available in the work area and adherence to procedures is required of all personnel."
4.
Section 3.2.2.4 should be modified to reference which industrial standard will be fohowed in tietermining the flow rate for each fume hood. (e.g.,
industrial Ventilation: A Manual of Recommended Practice, American Conference of Governmental Industrial Hygienists).
Response
Section 3.2.2.4 has been modified to add the aforementioned industrial standard.
5.
Section 4.1.1 should be changed from "American Nuclear Standard" to "American National Standard."
Response
Section 4.1.1 was revised to change "American Nuclear Standard" to "American Natlocal Standard."
6.
Section 4.1.7 should be changed from " safe geometry" to " favorable geometry" to be consistent with the rest of the document.
Response
Section 4.1.7 was revised to change " safe geometry" to
" favorable geometry" for consistency.
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h Page 2 of 3 7.
Section 4.2.3.3 should be modified such that the second paragraph should ratioct that there are four basic cross section librarles and a supplementary set which is not used at Lynchburg Manufacturing Facility. Thus, the fif th numbered item should be deleted.
Response
Section 4.2.3.3 was mod fled to reflect the four basic cross section libraries and a supplementary set which is not used at the LMF. The fifth numbered item was deleted.
8.
Explain why in Section 4.2.4.7 you changed the last bullet from "other accumulations of SNM" to " storage rack."
Response
Section 4.2.4.7 was revised from "other accumulations of SNM" to *stora0e rack" to clarify for conservatism and to be consistent with other sections of our license which states a 12' separation from other accumulations of SNM is required, t
9.
Explain the differences in Sections 4.2.4.2, 4.2.4.4 and 4.2.4.5, between
" nuclear safety restrictions" and
- nuclear safety conditions." If there are no i
differences, please modify the appropriate sectionr. for consistency.
Response
Gections 4.2.4, 4.2.4.2, 4.2.4.4, 4.2.4.5 and 4.2.4.6 were revised to state " nuclear safety controls" for consistency.
10.
The following sections contain rninor typographical errors and should be modified:
l l
Section 4.2.3.3, change " fro" to *from" and change "first four" to "the four."
Response
Section 4.2.3.3 was revised to address the aforementioned changes.
Section 4.1.6.2, change " box at time" to
- box at a time."
Response
Section 4.1.6.2 was revised to address the aforementioned change.
Section 4.2.1, (1) in the first paragraph, change " provide" to "provided."
(2)in the third paragraph, add the comma back in after " processing."
l l
Response
Section 4.2.1 was revised to address the aforementioncd l
changes.
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l Page 3 of 3 l
10.
(Continued)
Section 4.2.4.7, change 'atter prepared" to "after being prepared."
Response
Section 4.2.4.7 was revised to address the aforementioned change.
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Page 1 of 7 Chap. Papa Earl Changa Table of Contents Added to show number of pages in each. cense chapter, revision number and date of each chapter.
1 11 11 Added Rt. 726 Mt. Athos Road (2 places).
1.2 Changed NNFD RL to Nuclear Technology Center.
12 1.3 Updated to show Meterials License designation and expiration date.
15 1.7.1 Added ";" after ' MATERIAL" in first paragraph.
Changad 20 years to 25 years.
16 1.7.4 Eliminated exhibit since NRC Guidelines are adequately referenced.
2 All Header Changed B&W Fuel Company to Framatome Cogema Fuels.
2-1 2.1.1 Added reference to Quality Manager in first paragraph. The Plant Manager as overall authority, however, the Quality Manager has dual responsibility since the Safety & Licensing organization falls under his leade ship.
Deletea teview and approval of H S procedures from bulleted items under first paragraph. Review and approval authority rests in accordance with the administrative procedure for H S procedures.
Changed CNFP to LMF. Revised LMF management structure to show Safety Review Board Chairman and Manager of Safety & Licensing reporting directly to the Manager of Quality. Also revised to show how organizational structure at LMF reports to FCF President. Additionally, revised to show Nuclear Criticality Specialist reporting on a dotted line to the Manager of Quality. 'This restructure will allow for complete independence of Licensing functions from the production organizations.
Page 2 of 7 Chan.P.aoa P_ata.
Chance 2
2-2 2.1.2 Omitted reference to Field Operations. This r lanizetion no longer reports to the Plant B. nager.
2.1.3 Changed CNFP to LMF.
2-3 2.2.2 Added to delineate the requirements for Quality Manager to whom Safety & Licensing Manager now reports; renumbered subsequent paragraphs.
2.2.3 Reworded first sentence em "The manager to whom the section reports shall..." to "The Safety &
Licensing manager shall..." Changed Plant Manager to Quality Manager.
2-4 2.2.4 Changed CNFP to LMF.
2.2.6 Changed CNFP to LMF.
2.2.7 Changed Plant Manager to Quality Manager.
2-5 2.2.7 Changed BWNT to Framatome Technologies, Inc.
2.3 Changed " surveys" to " survey" in fifth bullet.
Revised to show Safety Review Board (SRB)
Chairman reporting to the Manager of Quality in
(
lieu of Plant Manager. This restructure will allow for complete independence of SRB functions from the production organizations.
2-7 2.4 Changed CNFP to LMF. Changed " Plant Manager" to " President."
2-8 2.6 Changed "shall be" to "is" in third sentence.
Eliminated the statement " Deviation from written procedures for the handling of radioactive materials sha!! be approved by the Manager, Safety & Licensing, or their qualified designee"in first paragraph. Written procedures are to be followed and will not be deviated from.
Page 3 of 7 Chan.Page P_BIL Change 2
29 2.1 Changed signoff of NMC procedures from the Mai.sger of Production and Materials Control to the Manager nf SNM Accountability and Inventory in first paragraph. There is no longer a Manager of Production and Materials Control. Changed
" Quality Assurance" to " Quality" in second paragraph.
2.7 Changed CNFP to LMF.
2-10 2.7 Under independent Audits, Changed CNFP to LMF.
2-11 2.7 Changed the requirement that independent auditor's reports are submitted to the Manager of Quality. Additionally, changed the requirement that designation of the independent auditors is the responsibility of the Manager of Quality. This will assure independence between the Safety &
Licensing functions and production organizations.
2.9 Changed CNFP to LMF.
3 All Header Changed B&W Fuel Company to Framatome Cogema Fuels.
3-1 3.1.1 Changed CNFP to LMF.
3.1.2 Changed CNFP to LMF.
3.1.3 This was a section title change only (from Radiation Work Permit (RWP) Procedure to Radiological Work Permit (RWP).
3.1.4 Eliminated reference to " format".
3-2 3.2.1 Changed " Step-of" to " Step-off".
3-4 3.2.2.1 Eliminated "for gross alpha" to broaden focus.
3.2.2.2 Added "..from fuel manufacturing operations.." to segregate from SERF activities.
1
I Page 4 of 7 Chan.Paga Pa Change 3
3-6,7 3.2.2.4 Added reference to industrial standard in first paragraph after bullets. The current second and third paragraphs were moved (were last two paragraphs) for better clarity. Current last paragraph was second paragraph. Eliminated
" Minimum face velocities for hoods and similar enclosures shall be 100 LFM whenever hcod work involving dispersible radioactive particulate Is being performed." Changed " Minimum velocity at the point of entrance to " elephant trunk" drops shall be 1300 LFM and shall be measured weekly when the area is in operation" to " Minimum flow rates on elephant trunk drops will be 1000 LMF "
37 3.2.3 Clerification and added commitment to ALARA.
3-8,9 3.2.4.4 Clarification and changed NRC licensed facility to licensed facility.
39 3.2.5 Clarification of how radiologicaily control areas and contaminated areas (RCA/CA) are determined.
3-10 3.2.6 Renamed section title. Clarification of how bloassay program is used to verify exposure or the lack of exposure.
4 All Header Changed B&W Fuel Company to Framatome Cogema Fuels, 4-1 4.1.1 Changed "American Nuclear Standard" to "American National Standard."
4-2 4.1.2 Changed CNFP to LMF. Eliminated redundant section number under first paragraph (typographical error).
4-4 4.1.3.3 e Changed reference of 4.1.6 to 4.1.7.
4-5 4.1.6 Changed CNFP to LMF.
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Page 5 of 7 t
Chan. Papa h
Change 4
45 4.1.6.2 Changed "..contain six cardboard boxes.." to
...contain up to six cardboard boxes.." (2 places) in accordance with container certificate. Changed
" box at time" to " box at a time."
4-6 4.1. 6.3 Changed section title from Pellet Loading Room to Pellet Vault Storage for clarity.
4.1.6.4 Divided section 4.1.6.3 into two sections for consistency with sections. Titled section " Fuel Rod Loading" for clarity. Renumbered subsequent paragraphs.
4.1.6.5 Changed "without spilling them out" to "without spillage."
4-7 4.1.7 Changed " safe" to " favorable."
4.2.1 Changed " provide" to "provided" in first sentence.
Clarified from ".. pellets, pellet chips powder.." to
" pellets and pellet chips / powder.."
4-8 4.2.1 Changed CNFP to LMF. Changed Quality Assurance to Quality. Repositioned comma after
" processing"In first sentence of second paragraph.
4-10 4.2.3.2 Changed CNFP to LMF (3 places).
4-11,12 4.2.3.3 Changed CNFP to LMF (3 places). Revised second paragraph.
4-12 4.2.3.3 In first paragraph, changed B&W to FCF. Changad CNFP to LMF. Changed "first four" to "the four."
In second paragraph, changed "123" to "44."
Changed CNFP to LMF.
4.2.4 Changed " conditions" to " controls" for consistency.
Changed CNFP to LMF.
4.2.4.1 Changed " shipment" to " shipping containers" for clarity.
Page 6 of 7 Chan.Page Para.
Change 4
4-13 4.2.4.1 Added last three bullets for clarification.
4-14 4.2.4.2 Changed " conditions" to " controls" in first sentence of second paragraph. Clarified last bullet for consistency.
4-15 4.2.4.3 Changed "..12 horizontally..." to "..12" horizontally..."
4.2.4.4 Changed " nuclear safety restrictions" to " nuclear safety controls." Changed "4.00" to "4.0" for consistency (2 places).
4-16 4.2.4.5 Changed " nuclear safety restrictions" to " nuclear safety controls."
4-17 4.2.4.5 Changed " nuclear safety restrictions" to " nuclear safety controls."
4.2.4.6 Clarified first bullet. Added "A.." to last sentence on page.
4-18 4.2.4.6 Changed " restrictions" to " controls."
4.2.4.7 Reworded second paragraph for clarity.
4-19 4.2.4.7 In last bullet, changed "other accumulations of SNM" to " storage rack" for conservatism and consistency. Other accumulations of SNM require a 12' separation distance.
4.2.4.8 Changed CNFP to LMF.
4-21 4.2.4.9 Changed reference under Vacuum Cleaners from 4.2.1.1 to 4.2.1.
5 All Header Changed B&W Fuel Company to Framatome Cogema Fuels.
6 All Header Changed B&W Fuel Company to Framatome Cogema Fuels.
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Page 7 of 7 i
Chan.Page
- EAIA, Change 6
6-1 6.1.4 Changed CNFP to LMF, 6-3 6.2 Changed CNFP to LMF (3 places).
6.2.3 Changed CNFP to LMF.
6-4 6.2.6 Changed CNFP to LMF (2 places).
65 6.2.4 a Eliminated "...as defir id in a-d above."
7 All Title Changed B&W Fuel Company to Framatome Cogema Fuels.
7-1 7.1 Changed section number from 7.0 to 7.1 for consistency with other chapters of license.
Changed B&W Fuel Company to Framatome Cogema Fuels in first paragraph and second paragraph. Changed Commercial Nuclear Fuel Plant to 1.ynchburg Manufacturing Facility in second paragraph Revised reporting requirement.
8 All Title Changed B&W Fuel Company to Framatome Cogema Fuels.
81 8.1 Changed section number from 8.0 to 8.1 for consistency with other chapters of license.
Changed CNFP to LMF (2 places). Changed BWFC to FCF.
FRAMATOME CO2EMA FUELS - LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 70-1201 TABLE OF CONTENTS PARTI CHAPTER I.lCENSE CONDITIONS PAGES BEL DATE 1
Standard Conditions &
1-1 thru 1-6 15 11 24 97 Special Authorizations 2
Organization & Administrative 2-1 thru 211 9
11-24-97 3
Radiation Protection 3-1 thru 310 5
11 24-97 4
Nuclear Criticality Safety 4-1 thru 4-21 9
11-24-97 5
Environmental Protection 5-1 thru 5-3 3
06-09 97 6
Special Processes 6-1 thru 6-5 4
06-09-97 7_
Decommissioning Plan 7-1 5
06-09 97 8
Radiological Contin 0ency Plan 8-1 6
06-09-97 PART11 CHAPTER SAFETY DEMONSTRATION PAGES HEE DATE 9
General Information 9-1 thru 910 4
06-09 97 10 Facl!ity Description 10-1 thru 10-15 4
12-30-96 11 Organizetion and Personnel 11-1 thru 11-32 10 06-09-97 12 Radiation Protection 12-1 thru 12-10 3
12-30-96 13 Environmental Safety 13-1 thru 13-4 2
12 30-96
- Radiological 14 Nuclear Criticality Safety 14-1 thru 14-10 4
12-30-96 15 Process Description & Safety 15-1 thru 15-37 5
12 30-96 Analysis 16 Accident Analysis 16-1 thru 16-13 3
12 30-96 Table of Ccntents November 24,1997
FRAMA TOME COGEMA FUELS - L YNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTI - CHAPTER 1 - STANDARD CONDITIONS O SPECIAL AUTHORIZATIONS 1.1 Licensee Name. Address. and Coroorste InformatiQQ Name and Address of Licensee Framatome Cogema Fuels Lynchburg Manufacturing Facility At. 726 Mt. Athos Road P. O. Box 11646 Lynchburg, Virginia 24506-1646 State of incorooration Framatome Cogema Fuels lr a partnership of Virginia Fuels, Inc. and Cogema Fuels, Inc. The partners and the resultant partnership are organized and exist under the laws of the State of Delaware.
Princloal Offices Framatome Cogema Fuels P. O. Box 10935 Lynchburg, Va. 24506-0935 Framatome Cogema Fuels Lynchburg Manufacturing Facility Rt. 726 Mt. Athos Road P. O. Box 11646 Lynchburg, Va. 24506-1646 1.2 Site Location The Framatome Cogema Fuels, Lynchburg Manufacturing Facility is located on a 76 acre site in Campbell County, Virginia approximately 4 miles from the Lynchburg City ilmits. The Lynchburg Manufacturing Facility is adjacent to the Babcock and Wilcox NNFD and Nuclear Technology Center l
plant sites. The physicallayout of the Lynchburg Manufacturing Facility is as shown in Figure 9.1 which illustrates the principle features within the Lynchburg Manufacturing Facility perimeter fence.
Page: 1-1 November 24,1997 Revision: 15
FRAMATOME COTEMA FUELS - LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI - CHAPTER 1 - STANDARD CONDITIONS & SPECIAL AUTHORIZATIONS 1.3 Licenne Number and oeriod of License The Lynchburg Manufacturing Facility license is designated as SNM 1168, Docket 70-1201. The expiration date is September 30, 2000.
1.4 Nuclear and Bv oroduct Materials Possession Limits 1.4.1 15,000 kilograms of 885U contained in Special Nuclear Material of a pellet form and with a maximum U enrichment of 5.1% ssU.
285 Chemical form to be uranium oxide.
1.4.2 100,000 kilograms of uranium as depleted or natural material in powder or pellet form and composed of uranium oxides.
1.4.3 1000 kilograms total of uranium but not to exceed 50 kilograms in a single container as natural UF, for storage only.
1.4.4 Up to 10 curies of encapsulated by-product material contained in one or more sealed sources. Atomic numbers 3 to 83 inclusive.
1.4.5 Up to 6.0 grams of encapsulated plutonium contained in one or more sealed sources.
1.4.6 Up to 3.0 milligrams of Californium-252 contained in one or more sealed sources.
1.4.7 Up to 350 grams u without limit on chemical, physical, or 23s isotopic composition, for analytical and laboratory purposes.
1.4.8 Up to 1000 curies of by-product material (including transuranic elements) as contamination associated with field service activities, with operations to support nuclear plants, and/or as waste.
1.4.9 Up to 5.0 curies of Americium-241 in one or more sealed sources.
1.4.10.Up to 1 microcurie of standard samples for instrument calibration purposes. Atomic numbers 3 to 96 inclusive.
1.4.11 Receive, rod load, download, store and ship enriched reprocessed uranium containing plutonium and other trar.auranic isotopes provided that the concentration of transuranic isotopes in such 5 90: 1-2 November 24,1997 Revision: 15
FRAMATOME COGEMA FUELS LYNCH:URG MANUFACTURING FACillTY USNRC LICENSE SNM-1168, DOCKET 701201 PARTI - CHAPTER 1 - STANDARD CONDITIONS & SPECIAL AUTHORIZATIONS uranium shall be limited to that specified in ASTM specification C996-90. Framatome Cogema Fuels shall obtain shipper certification that the uranium is within the limits for transuranics of ASTM specification C996-90.
1.5 Authorized Activities 1.5.1 Fabrication of nuclear power fuel assernbiles starting by inserting fuel pellets into rods, through fuel assembly bundling, packaging and delivery of fuel assemblies to a carrier for transport, and repair of returned assemblies.
1.5.2 Disposal of various solid, liquid, and altborne wastes resulting from the authorized activities excluding onsite burial.
1.5.3 Laboratory operations such as but not limited to chemical analysis, metallographic analysis and testing.
1.5.4 Field Operations activities involving equipment, processes, laboratory operations and areas contaminated with authorized quantitles of by product materials to include decontamination, maintenance, refurbishment, storage, transportation, and testing of contaminated equipment, tooling and components.
1.5.5 Storage of nuclear materials in various forms and facilities appropriate to safety.
1.5.6 Activities of a process and product development nature.
1.5.7 Maintenance of the facilities and equipment under adequate control to assure safety, 1.5.8 Possession of authorized by-product, source, and special nuclear materials in packages approved pursuant to 10 CFR 71 for the purpose of delivery to a carrier for transport, and in private carriage between NRC licensed facilities within the United States.
1.6 Glossarv of Terms - The following definitions apply to terms used within this license.
Page: 1-3 November 24,1997 Revision: 15
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FRAMATOME COEMA FUELS - LYNCH:URG MANUFACTURING FACillTY l
USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI -- CHAPTER 1 STANDARD CONDITIONS & SPECIAL AUTHORIZA TIONS 1.6.1 Baffling / Shielding - When used in the context of moderation control, a technique for secondary containment and control in the event of a water pipe rupture.
1.6.2 Calculated Safe Array - A calculated safe array is defined for nuclear safety purposes as having a K.,,10.87 for normal operating conditions and a K.,, & 0.95 under assumed accident conditions. The K,., values for these calculated safe array will also consider statistical and methodologicallimits of error.
1.6.3 Calculated Safe Unit - A calculated safe unit is defined in terms of nuclear safety as having a K.,, & 0.87 for normal operating conditier.s and a K,,,10.95 under assumed accident conditions.
The staustical and methodologicallimits of error will be considered when determining K.,,,
1.6.4 Controlled Area - An area that has the potential for radio contaminants above the unrestricted release limits specified in 1.7.4 of this document.
1.6.5 Fuel Assembiv/Assembiv - A grouping of fuel rods into a rigidly restrained configuration suitable for use in reactors.
1.6.6 Fuel Pellet / Pellet - Right circular cylinders of uranium oxide that have been compacted. They may be sintered or unsintered.
1.6.7 Fuel Rod / Rod - Tubing that has been loaded with fuel pellets.
1.6.8 Geometrically Safe Container - A container with a dimension of 9 5/8 inches ID x 11 inches high, or other cylinder demonstrated to be safe, authorized for uranium in any form.
1.6.9 1_vnchburg Manufacturing Facilitv-The manufacturing fuel plant of the Framatome Cogema Fuels Fuel Company.
1.6.10 Quallfled Designee - An individual who at the minimum possess the qualifications of the position that they are filling in for in the absence of the normally assigned individual.
Page: 1-4 November 24,1997 Revision: 15
FRAMATOME COGEMA FUELS - LYNCICURG MANUFACTURING FACILITY USNRC IICENSE SNM-1168, DOCKET 70-1201
. PARTI - CHAPTER 1 GTANDARD CONDITIONS & SPECIAL AUTHORIZATIONS 1.6.11 Radiation Worker - An employee whose job has a significant potential for exposure to radiation or who is required to handle SNM.
1.6.12 Removed From Service - Process equipment which is removed from production for replacement repairs or modifications which may affect safety related controls, or which is in " storage" for a period of 4 months or more whether or not modifications have been undertaken. " Removed from service" is not taken to include equipment which remains on line but is infrequently used, or which is temporarily bypassed as a result of routine process requirements.
1.C.13 Safe Mass - The maximum safe mass, independent of geometry, degree of water moderation, and reflection is defined as 850 grams of U 235.
1.6.14 Safe Volume - Defined as 14-liter maximum capacity for 4,10 w/o uranium in any form.
1.G 15 Inha - Zircaloy or stainless steel tubing used as fuel pellet cladding.
1.6.16 Uncontrolled Area - An area where the contamination levels do not exceed the limits specified in 1.7.4.
1.7 Snecific Exemotions and Soecial Authorizations 1.7.1 Postinos A continued exemption is requested from the labeling and posting requirements of 10 CFR 20.1902(e) and 20.1904(e) because of the nature of our operation. The intent of this section is met by posting areas which house or temporarily store radioactive material with signs incorporating the radiation symbol and with the warning:
" CAUTION RADIOACTIVE MATERIAL; ANY AREA OR CONTAINER l
WITHIN THIS PLANT MAY CONTAIN RADIOACTIVE MATERIAL".
This exemption is based on practicality and/or experience and has been applied effectively at Lynchburg Manufacturing Facility for the past 25 years.
l Page: 1-5 November 24,1997 Revision: 15
FRAMA TOME COGEMA FUELS - LYNCH:URS MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 1 - STANDARD CONDITIONS & SPECIAL AUTHORIZATIONS 1.7.2 Storage of UF Cylinders UF, cylinders may be stored outside the main building in a planar array. This storage area is exempt itom the criticality monitoring requirements of 10 CFR 70.24.
1.7.3 Storage of Fuel Within Shioning Containers Fuel may be stored in NRC licensed shipping containers. They are exempt from the criticality monitoring requirements of 10 CFR 70.24 provided:
The containers and contents have been subject to the inspections and determinations required by 10 CFR 71, Subpart D.
The containers are sealed, properly identified, and meet shipment requirements.
A minimum of 38" edge to edge separation is maintained between the loaded container array and other accumulations of SNM.
The loaded container array has a minimum separation of 12 feet.
1.7.4 Free-Release Limits Framatome Cogema Fuels is authorized to release equipment and-material from the controlled areas to the uncontrolled areas in accordance with " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for By Product, Source or Special Nuclear Material",
USNRC, August 1987.
Page: 16 November 24,1997 Revision: 15
FRAMATOME COGEMA FUELS LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 2 - ORGANIZA TION AND ADMINISTRA TIVE 2.1 Organfrational Resoonsibilities andAuthorltv 2.1.1 Management it is the responsibility of the Plant Manager and Quality Manager to assure the safety of the operation and compliance with license conditions. Control shall be established by:
designation of responsibility to qualified personnel review of program effectiveness prompt correction of nonconforming conditions The LMF management structure is as shown in Figure 2.1.
l FCF PRESIDENT l
l LMF PLANT QUALITY NUCLEAR CRITICALITY MANAGER MANAGER SPECIALIST l
' PRODUCTION
- MANAGER, MANAGERS SAFETY &
LICENSING l
OPERATIONAL HEALTH SUPERVISORS SAFETY SECTION (e.g., Manufacturing Engineering, Fuel Manufacturing, etc.)
Page: 2-1 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS LYNCH ~URG MANUFACTURING FACILITY USNRC LICENSE SNM 1168 DOCKET 701201 PARTI - CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE 2.1.2 Production Manaaers Production managers report directly to the plant manager with the exception of the Manager, of SERF-3 & 4. SERF-3 & 4's-organization is discussed in section 2.2.7. Production managers are responsible for managing operational area supervisors and are responsible for production functions. The managers of Manufacturing Engineering and Fuel Manufacturing are production managers.
The Production managers shall have, at a minimum, a Bachelor's Degree in Science or Engineering, followed by two years experience in the nuclear industry.
2.1.3 Ooerational Area Suoervision Operational area supervision is that supervision directly responsible for the control of materials, personnel, equipment, and activities in specific areas. Those responsibilities include assuring that approved control procedures developed by Health Safety shall be available in writing to operators and other concerned personnel and shall be adhered to.
Minimum qualification of operational area supervision shall include:
(a)
A high school education and a minimum of 2 years experience in the nuclear industry. Experience shall include the practical application of criticality control techniques and a familiarity with the applicable specific limitations imposed on LMF operations.
2.1.4 The Health-Safetv Secthtrl The Health Safety Section shall be responsible to interpret the license conditions, provide monitoring facilities, develop safe operation guidelines, maintain training programs, and review and approve operating procedures to a;sure safe operation and license compliance. These responsibilities include maintenance of nuclear safety and radiation safety with the approval authority limited to authorized specific or generallicense conditions. The Health-Safety Pa9e: 2-2 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS LYNCH:URG MANUFACTURING FAClllTY USNRC LICENSE SNM 1160, DOCKET 70-1201 PARTI - CHAPTER 2 - ORGANIZA TION AND ADMINISTRA TIVE section shall not be directly rotponsible for the performance of manufacturing operations.
The Manager, Safety and Licensing or their quallfled designee shall be responsible to provide management with assurance of the effectiveness of the safety program by maintaining an audit program that includes periodic inspection of controls and operations, reports to management, follow-up or nonconforming conditions and necessary documentation (see Audits, Section 2.7).
2.2 Personnel Education and Exoerlence Reautrements 2.2.1 Plant Manager The Plant Manager shall have a Bachelor's Degree in Science or Engineering, a minimum of 10 years experience in the nuclear industry, and 5 years experience in management.
2.2.2 Qualltv Manager The Quality Manager shall have a Bachelor's of Science, a minimum of 10 years experience in the nuclear industry, and 5 years experience in management.
2.2.3 Manager. Safetv & Licensing The Safety & Licensing manager shall have a Bachelor's Degree and a minimum of five years experience, which would develop an understanding of nuclear and radiation safety. Such experience shall be of a nature which demonstrates to the Quality Manager sufficiant judgment and capability to establish and maintain an effective nuclear criticality and radiation safety program for the activities authorized by the license.
2.2.4 Health Phvsicist The Health Safety Section shall include a person who shall act as the p' ant Health Physicist. This person shall have a Bachelor's Degree in Science or Engineering.
Page: 2-3 November 24,1997 Revision: 9
FRAMA TOMC COGEMA FUELS. LYNCH.~.UR3 MANUFACTURING FA Clll1Y USNRC LICENSE SNM>1168, DOCKET 70-1201 PARTI - CHAPTER 2 ORGANIZATION AND ADMINISTRATIVE A minimum of 2 years experience in applied health physics is required along with sufficient formal training that provides an understanding of the health physics and nuclear safety hazards involved at the LMF.
2.2.5 Health Safetv Monitors Health-Safety Monitors set up and conduct routine monitoring, sample collection and analytical tests in the plant to determine whether the amount of radioactivity is within acceptable limits and assists in verifying the radiological and industrial safety of employees.
The Health Safety Monitors shall have, as a minimum, a high school diploma or GED equivalent with six months of experience as a radiation monitor. They may fulfill the experience requirements on the job as a Health Safety Monitor trainee.
2.2.6 Nuclear Criticality Safetv Snecialist The Nuclear Criticality Safety Specialist is organizationally independent of the LMF, with no interest in plant operations, other than the nuclear criticality safety aspects. The Nuclear Criticality 74afety Specialist is responsible for evaluating the basic nuclear e Gelity safety limitations upon which plant safety was originally assessed, potential changes, validity of assumption, and accuracy of results.
The minimum qualifications for the Nuclear Criticality Safety Specialist shall be a Bachelor's Degree in Science or Engineering and a minimum of two years experience in nuclear reactor physics and one year experience in nuclear criticality analysis or two years experience performing nuclear criticality safety analyses or a Master's Degree in Nuclear Engineering and one year experience performing nuclear criticality safety analyses.
2.2.7 SERF-3 & 4 Oroanization Regulatory compilance to include all facets of safety of the SERF-3
& 4 facilities will be the responsibility of the Quality Manager in which he may delegate the responsibility to the Manager, Safety Page: 2-4 November 24,1997 Revision: 9
FRAMATOME CO:EMA FUELS LYNCH:URG MANUFACTURING FACil/TY USNRC LICENSE SNM-1168, DOCKET 701201 PARTI - CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE and Licensing. Tne safaty organization described in Section 2.2.3 and 2.2.4 shall be responsible for implementation of the safety program. The SERF 3 & 4 Manager will be responsible for all service and support activities and will report to the management of Framatome Technologies, Inc.
2.3 Saletv Review Board The Safety Review Board reviews the following as a minimum on a quarterly basis:
New or revised facilities Analysis of equipment and processes involving hazardous materials Maintenance of fire safety The continuing effectiveness of established controls and safeguards Maintencnce of ALARA criteria (review of quarterly air sample, review of surface contamination survey anomalies etc.)
Safety-related audit and inspection findings l
Other items (such as abnormal occurrences) that Safety Review Board l
l members wish to discuss.
l The Safety Review Board Chairman shall have a Bachelor's Degics in Science or Engineering and a minimum of five years experience in responsible positions which would develop an understa.nding of nuclear and l
l radiation safety.
l The Safety Review Board Chairman shall be directly respunsible to the I
Quality Manager for the proper conduct of the Safety Review Board. The Quality Manager and Plant Manage'shall be kept informed in writin0 of f
Safety Review Board action. The permanent membership of the Board shall l
consist of representatives from production management !.section 2.1.2),
Manager, Safety and Licensing and others as deemed necessary by the Chairman. Technical representatives of outside consulting organizations shall be included as necessary.
Board meetings may be convened at the discretion of the Safety Review Board Chairman, but shall be hela at least quarterly. The Safety Review Board Chairman shall decide whether or not the necessary disciplines are present during a board meeting to evaluate the item (s) under consideration.
There shall be a minimum of 4 Safety Review Board members present during a board meeting, i
Page: 2-5 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS a LYNCH.~UR3 MANUFACTURING FAClllTY USNRC LICENSE SNM 1968, DOCKET 70-1201
- PARTls CHAPTER 2 a ORGANIZATION AND ADMINISTRATIVE-^
Records of Safety Review Boaro proceedings, including supporting -
calculations and approvals, shall be retained for 2 years n.inimum after the completion or termination of the subject activity..
An ar;nual ALARI, report shall be prepared under the direction of the Manager, Safety and Licensing. The report shall be submitted to the Safety Review Board in which they will review to determine: 1) if th' <e are any _
upward trends daveloping in personnel exposures (internal and external) for identifiable categories of workers, types of operations, or effluent releases;
- 2) If exposures and releases might be lowered in accordance with the ALARA concept; and 3) if equipment for effluent and exposure controls is belne properly used, maintained, and inspected. ' A copy of the report shall be sent to the Plant Manager along with the results of the review and recommendations.
At least every two years, the Safety Review Board shall evaluate the effcctiveness of the radiation / nuclear safety training program, i
2.3.1 Pre onerational Evaluations
(
Naw operations and facilitlea and major operational changes require t,
Health Safety to perform an evaluation prior to initial operation to ensure that adequate radiation, nuclear, ilre, and chemical protection is established.
l The Safety Review Board Chairmua reviews all pre operational evaluations which involve hazardous materials and determines if Board review is necessary.
l in the case of minor changes where existing safety practice remains the same,-the Safety Review Board Chairman may-determine that Board review is not necessary. Safety Review Board members shall be kept appraised of actions taken by the L
Safety Review Board Chairman on such minor changes. Where other than minor changes are involved, the Safety Review Board review and approval process shall be conducted in accord with procedures approved by the Plant Manager.
L l
l Page: 2 6.
November 24,1997 Revision: 9
- FRAMATOME COGEMA FUELS - LYNCH:URG MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE 2.4 Annroval Authority for Personnel Selection Personnel selection for the FCF staff level positions shall be approved by the President.
2.5 Itaining Initialindoctrination of employee, to nuclear and radiological safety shall be the responsibility of Health-Safety and shall conform with 10 CFR 19. Initial indoctrination training shall, as a minimum, include the following topics:
license conditions federal regulations operating procedures e
radiation safety nuclear safety emergency procedure chemical and fire safety o
The extent and depth of the training, relative to the detailed aspects of the radiation, chemical, fire and nuclear safety programs, is dependent on the employee's job assignment and potential exposure to radioactive materials as determined by Health-Safety.
The initialindoctrination training shall be reinforced (as appropriate to the Individual's job assignment) by the employee's immediate supervisor or his designee with respect to individual unit safety requiremants, location of emergency exits, contamination control techniques, specific local controls.
and operating procedures, prior to the employee being released to operate independently. The employee's immediate supervisor shall complete a new employee training verification form prior to allowing the employee to operate independently.
A continuing safety training program shall be conducted by Health-Safety to the extent necessary to assure the maintenance of acceptable safety practices. Such training may be conducted on an individual or group basis.
The content of retraining programs may be varied by Health-Safety but will include radiological and nuclear safety as a rninimum. Emphasis is placed on new or revised safety criteria or areas in need of reinforcement. A formal retraining of radiation workers shall be conducted at least annually.
Page: 2-7 November 24,1997 Revision: 9
FRAMATOME COCEMA FUELS LYNCHBURG MANUFACTURING FACil.lTY USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTI CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE Documentation of formal training and retraining shall be maintained by Health-Safety and retained for et least two yet.rs.
Tho Manager, Safety and Licensing shall be responsible to assure that personnel assigned to Health-Safety are properly trained. The exter.t and depth of the training is based on the specific job assignment involved.
Health Safety monitoring personnel shall receive a combination of formal and "on the job" training such that they can successfully demonstrate their proficiency in basic nuclear and radiation physics mon;toring and control techniques and regulatory requirements before being allowed to function without direct oversight.
2.6 Onerating Procedures Written procedures for the conduct of specific operations including maintenance and development of work within the plant are prepared by the functiona! component responsible for that activity and shall be reviewed and approved by production management and Manager, Safety and I.icensing as appropriate. Operating procedures which involve SNM shall be revieweci at least every two years by the appropriate production manager and Manager, Safety & Licensing. Applicable procedures shall be available in the work area and adherence to procedures is required of all personnel. Procedures for operations where nuclear and radiological safety are involved shall include specific reference to applicable safety requirements. Procedure and format shall be such that operations are clearly detailed and specific directions are provided for oparation under both normal and abnormal conditions. Administrative procedures shall supplement operating procedures to ensure proper proceduralimplementation. Procedural control of activities at the LMF are categorized as follows:
Health Safety Procedures developed by Health Safety specify the method by which safety related functions are to be accomplished. The procedures shall encompass all health physics activities required by the license. Such procedures may be for internal Health Safety use or may be intended for general distribution to affected individuals within other components. As a minimum, Heal'h-Safety procedures shall be approved in writing by the Manager, Safety and Licensing as well as approved by affected members of plant management.
Page: 2 8 November 24,1997 Revision: 9 I
FRAMATOME COGEMA FUELS - LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM,1168, DOCKET 70-1201 PARTI - CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE SNM Accountabilltv Nuclear Materials Control procedures provide techniques for the accountability and measurement of SNM. As a minimum, such procedures shall be approved in writing by the Manager, Safety and Licensing and the Manager, SNM Accountability and Inventory.
l 1
Other Plant Grouos Procedures from other plant groups (i.e., Manufacturing, Quality, etc.)
where nuclear, chemical, fire or radiological safety, license conditions, or regulatory requirements are involved require prior approval by the Manager, Safaty and Licensing as well as approval by affected members of plant management.
New operations and major operational changes shall require the written recommendation of the Safety Review Board Chairman prior to implementation, if the chcnge requires revisions to procedures or the local safety rules, these modifications shall be in place prior to implementation.
Revised procedures shall be subject to approvalin the same manner as new procedures. Health Safety procedures shall be reviewed at least annually for technical correctness and applicability. The Manager, Safety and Licensing shall use discretion to assure that the appropriate personnel of Section 2.2 performs the procedure review.
Procedure distribution and control shall be in accord with procedures approved by plant management.
2.7 Audits and insoections An internal Health-Safety inspection program shall be maintained to provide assurance that plant activities are conducted safely and in accord with license specifications. The Manager, Safety and Licensing shall be r;sponsible to assure that the inspection program is conducted effectively.
The internal Health Safety inspection program at the LMF is structured as l
follows:
Pa90: 2-9 November 24,1997 Revision: 9
FRAMATOME CO:EMA FUELS - LYNCH.~URG MANUFACTURING FACILiiY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE Monthlv Safety insoections Health-Safety personnel shall conduct, at least monthly, a formal inspection of plant status relative to safety related functions to include fire safety, except during plant shutdown of a week or longer, inspection results shall be documented, reported to plant management and supervision as appropriate, and will be maintained on file by Health Safety for at least 2 years.
The monthly safety inspections shall be conducted by personnel technically qualified to perform this function and in the application of license specifications.
Informal Daily Insoections Health Safety personnel shall, as part of their routine duties, conduct informal daily inspections of plant activities. These inspections are not formally documented unless adverse findings are identified.
Other Insoections Ventilation, containment, and air cleaning equipment shall be routinely inspected at least annually by Health Safety personnel to assure continued effectiveness and compliance with license specifications.
Indeoendent Audits Independent auditors shall conduct, as a minimum, semi annually nuclear safety, fire safety and health physics inspections at the LMF.
These audits shall be conducted in accordance with written instructions or procedures. The audit scope shall consist of physical inspections and records reviews for the industrial, nuclear, and radiological safety elements of plant activities including:
- effectiveness of procedural controls impacting on operational safety parameters.
- audit of operating records, where such records provide a means of verifying procedural compliance with safety specifications.
- review and evaluation of contamination survey data.
Page: 2-10 November 24,1997 Revision: 9
FRAMA TOME CO:EMA FUELS - L YNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM.1168, DOCKET 701201 PARTI - CHAPTER 2 - ORGANIZATION AND ADMINISTRATIVE
- ascertalning the overall performance of the plant functions in providing adequate controls, surveillance, and follow-up to assure safety and license compliance.
Independent auditor's reports shall be submitted to the Quality Manager for his review. - He will ensure that the proper management reviews the report. The audit report shallinclude any audit findings or recommendations. Actions taken as a result of audit findings shall be documented.
Qualifications of the independent auditurs shall include competence in the areas of health physics or nuclear physics as appropriate at a level at least equivalent to Paragraph 2.2.3 or 2.2.5 respectively.
Designation of the independent auditors shall be the responsibility of the LMF Ouality Manager.
2.8 Investigations and Reoorting Unusual events requiring reporting under NRC regulations shall be investigated as appropriate, with results reported to plant management and NRC. Events not otherwise requiring a report may be reported to NRC based on potential public or media involvement, etc., in order to keep NRC appraised of the situation.
2.9 Records Plant alterations or additions, abnormal occurrences, events associated with radioactive releases, criticality analyses, audits, inspections, instrument calibration, ALARA findings, employee training and retaining, personnel exposures, routine radiation surveys, and environmental surveys shall be maintained on file for a minimum of 2 years or as otherwise required by federal regulation or other license condition, for review by LMF management and regulatory agencies.
Page: 2-11 November 24,1997 Revision: 9
FRAMATOME C:GEMA FUELS - LYNCH ~UR3 MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI - CHAPTER 3 - RADIATION PROTECTION 3.1 Admlnisicative Reautrements 3.1.1 General The business of the LMF incluoes radiation hazards from alpha contamination (fuel fabrication) and from beta gamma contamination (field service work for commercial nuclear utilities).
While the levels of these respective ha;.ards are different, the controls for each are similar.
3.1.2 ALARA lt is the policy of the LMF to maintain occupational exposures to r.idiation and radioactive contamination in effluents as low as reasonably achievable. The responsibility for implementation of the ALARA policy is designated to the Health-Safety section.
3.1.3 Radiological, Work Permit (RWP)
Radiological W:-
Permits (RWP) shall be used to define the protective clothir.g and equipment required to perform work involving surface contamination. RWPs shall be used to control all work in a RCA and work involving surface contamination above clean area limits outside of a permanent RCA that is not addressed by an approved operating procedure. RWPs are reviewed for industrial safety and approved by a Health Physicist.
3.1.4 Written Procedures All Lensed activities related to radiation protection shall be conducted in accordance with approved written procedures.
Approval, scope, and distribution requirements are described in Section 2.6.
3.1.5 Postings Local safety rules approved by Health-Safety providing personnel and supervision with specific directions essential to ensuring radiation safety shall be posted in areas where appropriate. Other radiation safety postings or warnings as required by 10CFR20 shall be placed in areas as required.
Page: 31 November 24,1997 Revision: 5
FRAMATOME COGEMA FUELS - LYNCH:URG MANUFACTURING FACil.lTY USNRC iICENSE $NM-1968, DOCKET 701201 PARTI - CHAPTER 3 - RADIATION PROTECTION 3.1.6 Radiation Control Radiation areas shall be posted and controlled according to 10CF!'.20 requirements. Personnel radiation exposures shall be monitored by Health Safety using appropriate devices based on the type of radiation and sensitivity requirements, including thermoluminescient dosimeters (TLD) or self-reading pocket lon chambers (SRD). Dosimetry issue to plant personnel and visitors will be determined basad on the monitoring requirements of 10CFR20. Accidental neutron radiation exposures will be monitored by indium foil issued to personnel as an integral part of the standard identification badge. Other dosimetry will be issued as necessary for unusual circumstances such as source manipulation or work involving highly transient exposure rates.
Extremity exposure monitoring is accomplished using TLD badges as required by 10CFR20. TLDs are processed by a vendor at monthly or quarterly intervals. Immediate processing is available for rapid evaluatR n of exposures. Personnel monitoring reports shall be prepared as required by applicable regulations.
3.2 Technical Raoulrements 3.2.1 Controlled Areas - Personnel Contamination Control Radiologically Controlled Areas (RCA) shall be established by Health Safety as an area used to control work involving surface contamination above uncontrolled area limits. RCAs may contain a
" clean area" which is a potentially contaminated area and one or more Contaminated Areas (CA), which are areas known to be contaminated. Personnel must frisk prior to leaving a RCA or the immediate area adjacent to the RCA boundary Upon leaving a CA, personnel must frisk prior to working in another area of the RCA.
Personnel working in a RCA shall be properly tralned prior to work or be escorted by a qualified worker.
Contaminated Areas shall be designed to include a step off pad or an intermediate change room. The purpose of the step-off pad is to establish a designated area where personnel enter and exit the Contaminated Area. Prior to stepping on the Step-off pad, all protective equipment and anti-contamination clothing shall be removed, in RCAs which do not contain a clean area (i.e., the Page: 3 2 November 24,1997 Revision: S
FRAMA TOME COEMA FUELS - LYNCH:URG MANUFACTURING FACillTY USNRC LICENSE SNM-1168, DOCKET 701201 PARTI - CHAPTER 3 - RADIATION PROTECTION entire RCA is a Contaminated Area), an intermediate change room may be provided in lieu of the step off pad. Guidelines for entry into intermediate change rooms shall be established for each area.
Upon completion of radiological work involving surfeo contamination, personnel will perform a complete wholebody frisk.
Frisking instruments will be provided and maintained by Health.
Safety and will be selected based on the type of radiation or contamination being monitored within the particular area or the scope of work being performed. Friskers shallinclude a visual and audible alarm. The alarm set point will be established as low as possible taking into account the need to minimize the number of false alarms.
Personnel Decontamination Pollev Health Safety shall be notified if contamination above the frisker alarm set point is detected on personnel skin or clothing as they exit from a RCA and when initial decontam! nation efforts fall to reduce the contamination below the alarm set point. Health-Safety shall assist with further decontamination efforts as necessary to reduce the exposure to a level as low as reasonably achievable, consistent with good health physics practice, before releasing the employee.
g 3.2.2 Ventilation Svstem 3.2.2.1 Airborne Effluents to Uncontrolled Areas Airborne effluents to uncontrolled areas shall be controlled to the limits specified in 10CFR20 by means of heat resistant absolute type filters with rated collection efficiencies of 99.95% for O.3 micron DOP particulate. Effluents shall pass through single stage HEPA filtration before release.
Also, recirculated air shall be HEPA filtered prior to reentering controlled areas. Filtration efficiency shall be evaluated in accord with Regulatory Guide 3.2 (Efficiencv Testing of Air-Cleaning Svstems Containino Devices for Removal of Particles,1/8/73) upon installation, and following major maintenance.
Page: 3-3 November 24,1997 Revision: 5
FRAMA TOME COTEMA FUELS - LYNCHBUR@ MANUFACTURING FAClllTY USNRC llCENSE SNM 1168, DOCKET 70-1201 PART!
CHAPTER 3 - RADIATION PROTECTION The minimum acceptable system efficiency shall be 99.9%. The ventilation system shall incorporate the following requirements.
Air recirculated back into the controlled area is sampled on a continuous basis to verify filter effectiveness. Air will not be recirculated if levels are above 25% DAC of 10CFR20 Appendix B, Table 1.
At least one filter housing or bank in each system shall be equipped with a device for monitoring differential pressure. Differential pressure shall be checked weekly and filters replaced when damage is ddent, or when the differential pressure exceeds 4 inches of water.
Gaseous effluents shall be representatively sampled on a continuous basis, and when the facilities are in operational stotus, the samples shall be collected daily and counted after allowing for decay of radon and its daughters.
3.2.2.2 Uncontrolled Area Air Effluent Limits Compliance with the following release limits shall be maintained in order to ensure that airborne releases to uncontrolled areas are maintained as low as reasonably achievable (ALARA).
If the gross alpha radioactivity (excluding radon and its daughters) in planned gaseous effluent discharges from fuel manufacturing operations l
exceeds 10 uCi per calendar quarter, a written report shall be submitted to NMSS and the Regional Office of the Commission within 30 days; identifying the cause for exceeding the limit, and the corrective actions to reduce release rates.
Page: 3-4 November 24,1997 Revision: 5
FRAMATOME C20EMA FUELS LYNCH:UR3 MANUFACTURIN3 FACillTY
\\
USNRC LICENSE SNM 1168, DOCKET 701201 PARTI CHAPTER 3 RADIATION PROTECTION If the gross beta radioactivity in planned effluent discharges exceeds 25% (based on a quarterly everage) of thn corresponding DAC spy.lfied in Table 2 of Appendix B to 10CFR20, an investigation of the system will be conducted to deterrnine the reasons for abnormallevels of release.
If the parameters important to a dose assessment change such that the parameters no longer repres6nt boundary conditions, a report shall be submitted within 30 days which describes the changes in parameters and includes an estimate of the resultant change in dose commitment (Ref.:
Order to Modify License, January 28,1980).
Personnel expusures monitored in uncontrolled areas will be assessed and evaluated according to section 3.2.3.
3.2.2.3 Ventilation Negative Pressure A ventilation wystem will be provided for each Radiolugically Controlled Area to maintain areas of higher contamination at a slight negative pressure to uncontrolled areas. For temporary RCAs, negative pressure does not have to be maintained if HP review determines radiological conditions do not require negative pressure.
3.2.2.4 Hoods and Gloveboxs Hoods or equivalent airborne activity control devices are installed and utilized so as to maintain airborne contamination levels as low as reasonably achievable, consistent with operational requirements. The degree and type of containment required for individual operations shall be determined by Health Safety based on the airborne radioactive particulate generation potentialincluding the:
Page: 3 5 November 24,1997 Revision: 5
FRAMATOME CGEMA FUELS LYNCHBUR3 MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 701201
\\
PARTI CHAPTER 3 RADIATION PROTECTION potential for alternation of physical form or characteristics of the material being processed.
possibility for resuspension based on the morphological characteristics of the material and the nature of the operation.
potential for development of abnormal or unusual conditions.
previous operational history and air sample h
documentation.
Hoods and gloveboxes shall be constructed of fire resistant materials. Windows and viewing ports, when included shall be fire resistant. Exhaust flow rates from gloveboxes shall be such that a minimum negative pressure of 0.25 inches of water is maintained when openings are closed. Each hood or air capturo device shall be evaluated and assigned a specific flow criteria aDainst which its performance will be measured in accordance with industrial standard
- Industrial Ventilation: A Manual of Recommended Practice, American Conference of Governmental Industrial Hygienists" as applicable.
" Elephant trunk" drops shall be used as required for maintenance or non routine activities requirlag exhaust ventilation and where other, more permanent types of containment are not practicable.
t 'imum flow rates on elephant trunk drops will be 1000 LFM.
Except as noted above, clophant trunks shall not be used as a routine control measure without the specific approval of Health Safety.
Air velocity surveys shall be conducted using heated thermocouple enemometers or equivalent.
Higher velocit'es may be required, based on Health-Page: 3 6 November 24,1997 Revision: 5
FRAMA TOME COGEMA FUELS. L YNCHBUR3 MANUFA CTURIN3 FA CillTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI CHAPTER 3 RADIATION PROTECTION Safety survey data. Glovebox negativs pressures, air capture device face velocities, and elephant trunk air flows shall be monitored weekly, except during plant shutdown of a week or longer.
Pressure differential shall be monitored by manometers or equivalent devices.
3.2.3 Work-Area (Controlled Areal Air Samuling To verify the effectiveness of the ventilation systems, contamination control enclosures, or air capture devices, air samples in work areas and at fixed locations will be collected and analyzed. Work area air sampling will be performed in accordance with Regulatory Gulds 8.25, " Air Sampling in the Workplace".
Where monitoring is required, breathing zone alt sample results will be evaluated on a shiftly basis to ensure employee exposures are consistent with estimates for the work operation and within the scope of the company's ALARA goals and policy. Static _or fixed air sample results may be used to support the breathing zone sample evaluation and determine the effectiveness of various air capture systems and contamination control enclosures. The evaluation period for fixed air samples will not exceed a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period during periods of plant operation.
Upon initiation of new operations, non repetitive opera:lons, or operations modified such that previous altborne contamination levels may be affected or are unknown, air sampling shall be used to verify that satisfactory controlis established and maintained.
Records of air sample result investigations including corrective actions taken will be maintained by the Safety and Licensing organization.
3.2.4 Bat'lonctivltv Measurement instruments 3.2.4.1 Portable Instrumentation l
l Portable instrumentation used to evaluate general area radioactivity shall be capable of detecting i
rage: 3 7 November 24,1997 Revision: 5 l
FRAMA TOME C:0EMA FUELS LYNCH: urn MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI CHAPTER 3 RADIATION PROTECTION contamination levels at or below license limits or action levels.
3.2.4.2 Effluent Measurements Analytical capability for evaluation of effluent samples shall be such that instrument sensitivity and sample preparation techniques allow detection of the effluent stream at or below the most restrictive action level or release l!mit.
3.2.4.3 criticalliv Monitoring Svstem A criticality monitoring system shall be maintained in compilance with the appropriate sections of 10CFR70. Response time for the system shall be in accordance with Regulatory Guide 8.5, " Criticality and Other interior Evacuation Slgnals" dated March 1981. The criticality monitorbg system will be functionally tested at least quarterly and detector units calibrated annually.
3.2.4.4 Instrument Calibration All instrumentation shall be calibrated prior to first use, following major maintenance, and at other times as deemed necessary, in any case, all instruments used for documented survey results or monitoring of personnel exposures shall be calibrated at six month intervals. Other instruments used for informational purposes (e.g., self reading pocket dosimeters and frisking equipment used to determine decontamination effectiveness within a known contaminated area) may be calibrated at annual frequencies. Laboratory counting instruments shall be calibratinn checked on a daily basis when in use. Calibration records shall be maintained for a minimum of two years. Calibration shall be performed on site by trained personnel or i
by another facility licensed to perform such work.
i The criticality monitoring system is calibrated as Page: 3 8 November 24,1997 Revision: 5 l
FRAMATOME C:0EMA FUELS LYNCHBUR3 MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 3 RAOIA TION PROTECTION Indicated in section 3.2.4.3. AllInstruments shall be subject to a routine functional test for response to the appropriate type of radiation using a check.
3.2.5 Radiological Surveillance and' Monitoring To monitor the radiological conditions in work areas and ensure the-continued effectiveness of the radiological control program, routine surveys will be conducted. Routine surveys shallinclude surface contamination and radiation levels in and adjacent to Radiologically Controlled Areas (RCA) and Contaminated Areas (CA). Surveys shall also be conducted in uncontrolled areas to monitor the spread of contamination beyond established RCA boundaries. Survey techniques and instrument selection will be based on the isotopes and type of radiation being monitored.
Radiation levels identified above ambient will be posted and controlled as required in 10CFR20. Contamination levels identified will be posted and controlled with regard to isotope and work operation as follows. For Uranium fuel.abrication operations, an item or area will be controlled as a Radiologically Controlled Area and Contaminated Area (RCA/CA) when the alpha contamination levels exceed 200 DPM/100 cm'smearable or 1000 DPM/100 cm' fixed. For SERF operations (by product materials), an item or area will be controlled as a RCA/CA when beta / gamma contamination levels exceed 1000 DPM/100 cm'smearable or 0.1 mR/Hr fixed.
To the extunt practicable, uranium fuel processing and by product material handling will not be performed simultaneously in the same RCA/CA. Alpha smevable contamination levels will be Investigated above 20 DPM/100cm'smearable in by product material work areas.
Contamination levels which exceed those stated above will be evaluated with regard to the type of work to be performed on the equipment or in the area. This Information will be the basis for oavelopment of the Radiological Work Permit and/or design of l
engineering controls for the work activity.
l l
Page: 3 9 November 24,1997 Revision: 5
FRAMATOME C:GEMA FUELS LYNCHBURG MANUFACTURING FAClll1Y USNRC LICENSE SNM 1168, DOCKET 70 1201 PARTI CHAPTER 3 RADIATIONPROTECTION 3.2.6 Paraonnel Ernomura Monitoring Employee exposures shall be determined using a variety of methods based on the operations being performed in each area. Monitoring requirements will be established for uncontrolled work areas and be established by RWPs for entry into Radiologically Controlled Areas (RCAs).
External monitoring for all work areas shall be performed by thermolurninescent dosimeters (TLD) or similer devices. These devices include whole body and extremity dosimeters as required when employees are likely to exceed 10% of the applicable annual limit.
Internal monitoring for fuel fabrication operations shall be performed by measuring air concentrations with lapel air samples, and may be supplemented by routine or diagnostic bloassay measurements for the purpose of verifying the effectiveness of the.
altborne monitoring prograni or when a signif; cant intake is suspected. Bloassay techniques will generally be limited to in vitro urine samples or in vivo lung count measurements. In general, bloassay measurements will not be used to determine exposures for routine operations, in mixed fusion product work areas (SERF RCAs), historical data Indicates that personnel are not likely to receiva in excess of 10%
of the annual Committed Effective Dose Equivalent (CEDE) limit.
For this reason, periodic air sampling in the area and in vivo bloassay will be used to confirm that breathing zone air sampling is not required. Workers will be monitored using in vivo measurements prior to and following work periods at this site or upon termination of employment. This measurement will be performed to confirm that no significant intakes have occurred during work at this facility. For work where intakes are considered possible, specific monitoring requirements (using air monitoring or bloassay methods) will be established by the RWP for the specific task.
Page: 310 November 24,1997 Revision: 5
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FRAMATOME C00EMA FUELS LYNCH:URG MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET ?0 1201 PARTI CHAPTER 3 RADIATION PROTECTION 3.2.7 Use for Unrestricted Handlino (RFUH1 Equipment and areas previously contaminated above the limits specified in section 3.2.5 of this document shall be surveyed and released for unrestricted handling (RFUH) in accordance with "Guldelines for Decontam! nation of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material", USNRC, August 1987, Exhibit A to section 1 of this document.
Page: 311 November 24,1997 Revision: 5
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FRAMATOME C00EMA FUELS - LYNCH:UR3 MANUFACTURIN3 FACillTY l
USNRC LICENSE $NM 1168, DOCKET 'r01201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY l
4.1 Administrative Conditions 4.1.1 Danlon Philonochlan The double contingency principle as defined in the American National Standard ANSI /ANS 8.1 shall be followed in establishing nuclear criticality safety for all equipment, systems and operations.
Process designs shall incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible.
Where possible and practicable, reliance will be placed on equipment design in which dimensions (i.e., favorable geometry) are limited rather than on administrative controls. Where structural Integrity is necessary to provide assurance for safety, the design and construction of the equipment will be made with due regard to abnormal loads, accidents and deterioration.
4.1.2 Criticalltv Safetv Analvses With respect to the overall plant nuclear criticality safety, the Manager, Safety & Licensing is responsible for controlling all modifications and/or additions to any operation, system or equipment.
Nuclear criticality safety evaluations are perforrned by qualified nuclear criticality safety specialists. These specialists must have a B.S. Degree in Science or Engineering and either a minimum of two years experience performing nuclear criticality safety analyses or a minimum of two years experience in reactor physics and one year experience performing nuclear criticality safety analyses.
Individuals not satisfying the above requirements may perform safety evaluations provided the evaluations are approved in writing by a qualified nuclear criticality safety specialist.
All nuclear criticality safety evaluations shall be independently reviewed by an individual meeting the qualifications of nuclear criticality safety specialist as defined above with two years of experience as a Nuclear Criticality Specialist or a PhD in Nuclear Engineering with one year experience in nuclear criticality analysis.
All evaluations shall include an appropriate statement of this
- review, Page: 4-1 November 24,1997 Revision: 9
FRAMATOME C00EMA FUELS LYNCHBUR3 MANUFACTUW.V3 FAClllTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI - CHAPTER 4 - NUCLEAR CRITICAllTY SAFETY Both the arialyzing and reviewing nuclear criticality safety specialist are independent of LMF manufacturing operations. A library of l
validated computer codes and cross sections shall be maintained and utilized for performing nuclear criticality safety evaluations.
Clarifications and conformance of limits established by license or by the nuclear criticality safety evaluation are made by qualified
'j personnelin the Health Safety Section addressed !n 2.2.
4.1.3 Anorovals and Documentation Modifications of product or process are authorized by the Safety Review Board. Operation of the Board and procedures for modification are described below:
4.1.3.1 Authorized Modifications Authorized modifications shal; be limited to the following areas:
a.
Modification of product specifications (except enrichment) as described in 4.2.1 and therefore in the safety criteria for fuel assembly processing, storage and l
packaging, b.
Changes in the SNM handling and fuel rod processing areas limited to:
Relocation or expansion of fines and scrap storage areas Relocation, arrangement, redesign, or addition of equipment Relocation or substitution of individual process units when such changes do not alter the associated fundamental nuclear safety specifications, in these cases, changes from slab control to volume control or substitution of 1
l Page: 4-2 November 24,1997 Revis*on: 9
FRAMATOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FACILITY USNRC LICENSE SNM-1168, DOCKET 701201 PARTI - CHAPTER 4 - NUCLEAR CRITICAllTY SAFETY different process steps shall be permissible as long as nuclear interaction and Individual unit safety criteria are met.
4.1.3.2 Basic criterla Modification of product or process involving SNM may be made without license amendment provided such changes are demonstrated to satisfy the following criteria:
The ilcense conditions specified in this part are not violated.
Nuclear safety calculations (when needed) shall be performed by a method equal to or better than those originally utilized to demonstrate safety for the area and type of operation under consideration. Calcu-lations shall consider both Individual unit and interaction safety.
Nuclear safety evaluation is not required where the anticipated changes does not affect existing nuclear safety control or bases. The Safety Review Board Chairman or his qualified designee determines when a change in product, process, or equipment requires a nuclear criticailty evaluation or license amendment.
4.1.3.3 Review and Acoroval Process The review and approval procedure for plant modifications shall be as follows:
a.
The proposal shall be reviewed by the Safety Review Board Chairman or his quallfled designee for content, completeness, and conformance with previously evaluated conditions, if required, the proposal is forwarded for formal nuclear criticality safety evaluation as described in 4.1.2.
Page: 4-3 November 24,1997 Revision: 9 w Pt er*w w-w w
FRAMATOME COGEMA FUELS LYNCHBUR3 MANUFACTURIN3 FACillTY USNRC llCENSE SNM 1168, DOCKET 70 1201 PARTI - CHAPTER 4 NUCLEAR CRITICAllTY SAFETY
- b. The criticality safety analysis is performed in accord with 4.1.3.2 and results are forwarded in writing to the Safety Review Board Chalrman or his quallfled designee. All criticality safety evaluations are re-vlewed as specified in Part 4.1.2 of this section,
- c. The results and recommendations obtained from the criticality safety evaluations shall be reviewed by the Safety Review Board and/or the Safety Review Board Chairman and the permissibility of the change determined and documented,
- d. Appropriate personnel are notified in writing of the result of the revlew.
- e. The proposed change shall not be implemented until a preoperational audit (Ref. 4.1.7) has been satisfac-l torily completed. The Individual who performed either the nuclear criticality evaluation or the independent review shall participate in the pre-operational inspection, f.
Correspondence, calculations, and other material shall be maintained on file for a minimum of 2 years or six months following termination of the operation whichever is longer, l
i l
4.1,4 Procedures I
l Written procedures approved by plant management shall be utilized for all operations involving SNM. Criticality safety requirements shall be appropriately referenced in these procedures to assure continued safe handling of SNM. The process for approval of plant modifications as described in 4.1.3.2 shall be covered by approved written procedure. Procedure control and distribution is as described in Section 2.6.
l l
Page: 4-4 November 24,1997 ~
Revision: 9
FRAMATOME C 0EMA FUELS LYNCH:UR3 MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI CHAPTER 4 - NUCLEAR CRITICAllTY SAFETY 4.1.5 Pontinna Nuclear safety postings approved by Health Safety shall be maintained specifying nuclear safety parameters that are subject to i
procedural controls.
Area postings may be used for those parts of the process where nuclear safety is maintained by means of " area wide" requirements.
Operations for which specific (dedicated) controls are applicable shall be individually posted.
4.1.6 Dedicated Controls The LMF primary criticality control for SNM prior to fuel bundle assembly is the four inch slab criteria and moderation control. Upon completion of fuel rod fabrication, spacing and moderation control are relied upon. These controls are maintained by the following:
4.1.6.1 Moderation Control All accumulations of liquids and hydrogenous materials are regulated through the local safety rules. The autbo-rized volume per container I;, one gallon with a total volume not to exceed 20 gallons. This criteria is exempt when SNM material is absent For the fuel assembly ar-eas, water lines are baffled.
4.1.6.2 Pellet Receipt Pellets are received by the vendor in approved shipping containers which contain up to six cardboard boxes of fuel pellets. When they are removed from the shipping container, the boxes are stacked two high (8 inch slab) in transit to the conveyor. This only occurs for a very short period of time and only one shipping container (up to six boxes of pellets) e a transferred at any one given 9 conveyor one cardboard time. They are placed c..
t box at a time which initiate. the four inch Lab. There is l
a physical barrier on the conveyor to prevent anything above four inches from entering the pellet loading room.
Page: 4 5 November 24,1997 Revision: 9
FRAMA TOME COGEMA FUELS - LYNCH.~UR3 MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168 DOCKET 701201 PARTI CHAPTER 4 - NUCLEAR CRITICALITY SAFETY 4.1.6.3 Pellet Vault Storage The pellets remain in the box for storage purposes. The vault is constructed with a barrier to prevent double stacking of the boxes. Only if the boxes were manually Ilfted above this barrier could double stacking result a*
this would take great effort on one's part to do and could not be accomplished accidently.
4.1.6.4 Fuel Rod Loading For loadhg purposes, the pellets remain stacked on the corrugated trays in a four inch slab. All hoods, the pellet down draft table and carts are either twenty-eight Inches in width or less or a red line indicates the allowable twenty five Inch width space. The four inch height limitation is also marked in the hoods, i
4.1.6.5 Fuel Rod Fabrication All fuel rod channels are designed to support the four l
inch slab criteria. The rods could not be stacked above l
the four inches in the channels without spillage.
4.1.6.6 Fuel Assembly Room Fuel rods are stored in the four inch channels and the channels are stored on a rack. Local safety rules specify that the channels cannot be stored above or below one another.
The fuel bundle tables are constructed out of granite block weighing approximately 8000 pounds and are spaced in accordance vvith the nuclear criticality evalua-tion and would be impossible to move.
4.1.6.7 Fuel Assembly Storage The assembly racks are constructed to meet the spacing criteria for 4.1%. For enrichments greater than 4.1%,
every other storage space in the rack will be used. A Page: 4-6 November 24,1997 Revision: 9
FRAMATOME C:GEMA FUELS = LYNCH:UR3 MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168. DOCKET 70 1201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY dedicated modified rack with 42 inch center to center spacing will be used for asserr.blies > 4.1 wt%.
4.1.7 Preonarational Testing Specifications and design criteria for purchased or locally fabricated equipment where nuclear and radiological safety considerations are involved shall be approved by a knowledgeable representative of the Health-Safety Section addressed in 2.2. Before being released for production operation, new equipment shall be tested to assure that safety specifications are satisfied. Favorable geometry equipment shall be measured by a knowledgeable person to ascertain that it is of proper dimensions before it is put into service. Where operational safety is based wholly or in part on the use of electrical or mechanical interlocks, the proper functioning of interlocks shall be veritled upon Installation and on an annual basis thereafter. Routine plant inspec-tions place added emphasis on new operations. No equipment is used after being removed from service until an equipment checkout for continued effectiveness of safety related parameters is performed.
4.2 Ischnical Criterla 4.2.1 fr:dividual Units Unless otheiwise provided for, the safety of individual units assumes all SNM is uranium oxide with a maximum assU enrichment of 5.1 wt.%. The material may be pellets erd pellet chips / powder. The most reactive heterogeneous geometry is fuel pellets. Pellet diameters have been varied over the range from 0.2" to 0.5" and it has been found that the most reactive pellet with optimum moderation is about 0.30 inches. Fuel pellets can have any density up to and including the theoretical maximum for uranium oxide (10.96 g/cm').
Certain plant areas utilize slab thickness as a means of nuclear safety.
The 4 inches thick slab is the maximum allowed for any operation in the plant except for the unloading of pellets where an 8 inch slab is allowed during the time that the fuel boxes are being transferred from the shipping 7ntainer to the vault conveyor where the 4 inch slab limit starts. Boxes of fuel pellets come in shipping containers with fuel stacked up to 8 inches high. The size of the 4 inches thick slab is unlimited for enrichments below 4.1 wt% and is limited to a 25 Page: 4-7 November 24,1997 Revision: 9
FRAMATOME C00EMA FUELS LYNCHOUR3 MANUFACTllRING FACillTY i
USNMC lbCENSE SNM-1968. DOCKET 701201 PARTI - CHAPTER 4 NUCLEAR CRtTICAllTY SAFETY j
Inches wide and Infinite length slab with 12" horizontal separation between slabs for enrichments above 4.1 wt% when fuel is in the unclad state. The 4" thick slab size for clad fuelis unlimited for en-richments up to 5.1 wt%. This provision for different nuclear safety i
limits for different enrichments implies knowledgu of the enrichment level of the SNM Involved. As a result, the enrichment of SNM at the LMF must be known at all times. Fuel boxes with enrichments greater than 4.1 wt% will be prominently identlfled, if the enrichment is unidentified, the SNM in question will be stored and handled as if it were the most reactive enrichment authorized (5.1 wt%) pending reestablishment of the identity. Enrichment of SNM la verified by i
shipper's documents and overchecked by Quality and nuclear matsrlal l
- accountability requirements.
All operations, except for fuel assembly processing, assume, as an accident condition, the unrestricted presence of water moderation and reflection of variable density. All manufacturing steps, except for the final product (assembled fuel bundles) and where positive controls are present, are assumed to be optimally moderated as an accident condition. The potential presence of other moderators, such as polyethylene, is considered and controlled.
The safety of individual units is based either on a calculation of K.,, or on data from an approved handbook or document. Calculated safe units are those evaluated according to 4.1.3.3 and shown to have a K.,, not exceeding 0.87 under normal conditions and 0.95 under assumed accident conditions considering both statistical and methodology limits of error.
I Calculations of K,,, assume the presence of any nearby reflector, such as a concrete floor.
For simple shapes, safe values are determined by application of the following limits:
Mass:
45% of minimum critical reflected mass Mass:
75% of minimum critical reflected mass when double batching is not credible Volume:
75% of minimum critical reflected volume Page: 4-8 November 24,1997 Revision: 9
FRAMATOME C:0EMA FUELS LYNCHBURG MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168, DOCKET 70 1201
\\
PARTI - CHAPTER 4 NUCLEAR CRITICALITY SAFETY Diameter:
90% of minimum critical reflected cylinder diameter Thickness:
90% of minimum critical reflected slab thickness 4.2.2 Multiola Units and Arraya The safety of rnultiple units and arrays is determined by calculation of K.,, using an Industry recognized validated and benchmarked code such as the SCALE computer code package. Calculated safe arrays are those evaluated according to 4.1.3.3 and shown to have a K.,, not exceeding 0.87 under normal conditions and 0.95 under assumed accident conditions. The maximum allowed K.,, for a postulated accident is equal to the calculated K.,, + 2 sigma where sigma would apply if the calculation was made by a statistical code such as KENO.
The allowed maximum value of 0.95 including bias is considered to have an adequate safety margin based on our benchmark calculations which show that when compared to critical experiments, our blas has not exceeded 0.02 A K.,,in the non conservative direction, in the event that any futre benchmark comparisons show a non conservative bias in excess of 0.02 A K.,,, then the acceptable K,,, would be correspondingly reduced. The accident condition assumes any credible Interspersed moderation of varying density.
The presence of any nearby concrete reflectors is accounted for in calculations of K.,,, The 4 inch thick,25 inch wide finite slabs of fuel pellets in 4.2.1 with enrichments greater than 4.1 wt% must be spaced a minimum of 12 inches apart horizontally.
4.2.3 Technical Data and Calculational Methods 4.2.3.1 1snlated Units or Arrays Acceptable nuclear interaction between individual units and between arrays have been computed using the SCALE computer code package. The generalized relation for acceptable nuclear isolation is given by the following:
The greatest distance across an orthographic projection of either accumulation on a plane perpendicular to a line joining their centers, or a distance of 12 feet, whichever is greater.
Page: 4-9 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS LYNCHBURG MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 4 NUCLEAR CRITICAllTY SAFETY The Safety Review Board Chairman or his qualified designes, with the concurrence of a nuclear criticality safety specialist, shall determine which arrays are more reactive than those used as a basis for the evaluations in this license, in these cases, the Interaction acceptance criteria shall be evaluated on an individual basis by a nuclear criticality safety specialist or it shall be as de-fined in the generalized criteria given abovu.
4.2.3.2 Safe Units The following Individual units are defined for the LMF as safe, independent of the degree of water modera'lon or reflection. All are authorized for uranium in any form up to 5.1 wt.% 8'U enrichment:
8 a.
Safe volume 12 liters maximum capacity b.
Geometrical safe contalnors - defined as a container with a dimension of 8 inches ID by 14.5 inches high, or other cylinders that may be demonstrated to be safe.
885U c.
Safe mass 700 grams d.
Safe size slabs of 4 inches thickness were 885 determined as a function of U enrichment (other than vault storage) for both unciad fuel pellets and clad fuel rods. Stabs are assumed to be infinite in length for all cases. Slabs are to be a minim'>m of 12" above any concrete floor. Concrete is the best reflector that is available at the LMF.
Reflecting material better than concrete such as beryllium or lead are not available in any significant quantitles at the LMF and any significant quantitles of these materials will not be allowed in any of the fuel processing areas.
POR*: 4-10 November 24,1997 Revision: 9
MtAM4 TOME COGEMA FUEL 3. L YNCHOUR3 MANUFACTURIN3 FA CellTY USANC LNl:ENSE SNM.1188 DOCKET 701201 j
PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY t
8 *'U Maximum Slab Enrichment Width Wt.%
Inches A 4.1 Infinite (unciad)
> 4.1 4 5.1 25.0 (unciad) 15.1 Infinite (clad) 4.2.3.3 calculational Methods Computer codes will be used to calculate K,,, of Individual units and of arrays. Computer codes and associated cross section sets are always benchmarked to demonstrate their validity for application at the LMF.
l 4
The particular family of codes may change over time as improvements are reallzed in the calculational methods.
The current computing package in use is the system of l
computer codes for performlng Standardized Computer Analyses for Licensing Evaluations (SCALE) which was developed by ORNL for the USNRC. The LMF's goalis -
l to maintain its computing capability at state of the art for nuclear criticality safety and to assure that all codes and l
cross sections are properly benchmarked and validated.
The SCALE package, Rev 5, has four basic cross section libraries relevant to LMF evaluations. The SCALE package also has a supplementary set which is not used at the LMF.
1.
The Hansen Roach 16 group library which includes the Knight modification, and additional nuclides based upon the 218 group ENDF/B IV cross Jactions set as modified for compatibility for
- SCALE usage; 2.-
The 27 group ENDF/B IV broad group library collapsed from the 218 group ENDF/B IV library; i
Page: 411 November 24 1997 Revision: 9 i
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4
-c s
FRAMATOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY 5AFETY 3.
The 44 group ENDF/B V broad group library collapsed from the 238 group ENDF/B V library; 4.
The 238 group ENDF/B-V broad group library, including ENDF/B VI cross sections from selected nuclides; FCF has made extensive validation celculations against critical experiments using the four cross section sets and has determined that a 0.02 bias added to the calculated value is more than adequate to adjust all validation calculations to a predicted k,,, of unity or greater except for carbon moderated systems which do not apply at the LMF. The critical experiments used for validation have l
Included: a) uranium enrichments ranging from 2% to near 100%, b) optimum and non optimum moderation, c) moderation (H,0) densities ranging from 100% down to 24%, and d) both clean and poisoned lattices.
i Generally the 44 group cross section set is used for enrichments encountered at the LMF. This is done to avoid excessive conservatism and to provide a good treatment of the "U resonance absorption which is 2
particularly important with low enriched material.
4.2.4 Special controls This section outlines those nuclear safety controls conceming plant
(
specific equipment, arrays or areas at the LMF Each area will be addressed separately. Alternative designs satisfying the provisions of 4.1.3.3 may be substituted for any area described in this section, i
l 4.2.4.1 Fuel Pellet Receivino and Temocrarv Storage A single shipment of SNM may be stored in the shipping containers in an array no more reactive than as received i
pending transfer to planned storage facilities. Nuclear interaction between the shipping containers and other SNM will be as specified in Section 4.2.3.1.
Page: 4-12 November 24,1997 Revision: 9 l
FRAMA TOME C00EMA FUELS = L YNCHBUR3 MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI CHAPTER 4 NUCLEAR CRITICAll)Y SAFE 7Y Shipping containers shall be exam!ned for transit damage after receipt and Health Safety notified if damage is found. Health Safety shall examine the damaged con-talners for evidence of water entralnment or other potential hazardous conditions. Damaged containers shall be opened one at a time and the contents pieced in a nuclear safe configuration (i.e., safe slab or 700 grams rasU) in accordance with appilcable storage license conditions. Damaged containers containing SNM shall not be returned to the shipper.
The use of conveyors to transport pellets shall be malr.tained under the safe 4" thick X 25" wide infinite -
length slab criteria outlined in Section 4.2.3.2.
Transport of SNM in this area (other than by conveyor) shall be with carts as follows:
No SNM accumulation shall be positioned above or below any other SNM accumulation; SNM on the cart shall be arranged such that the SNM slab thickness is less than, or equal to,4 inches and less then 25 inches wide.
Other than in transit, a 12' separation distance must be maintained between the edge of the cart and the edge of any other SNM accumulation.
4.2.4.2 Eellet vault storage Handling and storage of SNM with enrichments up to 5.1 wt% in the Pellet Vault Storage area will be as safe geometry slabs with a maximum thickness of 4" and a maximum width of 25" The slabs can be infinite in length.
The vault is made up of several storage cubicles. Each cubicle is separated from each other by at least 8 inches of concrete plus a neutron polson. This neutron poison shall be equivalent to 35 wt % B C in a.168" thick 4
Page: 4-13 November 24,1997 Revision: 9
FRAMATOME C00EMA FUELS a LYNCHBURG MANUFACTL* RING FAClllTY USNRC LICENSE SNM 1168. DOCKET 701201 PARTI - CHAPTER 4 - NUCLEAR CRITICAllTY SAFETY aluminum plate with an overall minimum density of 2.46 gm/cc. Each cubicle may contain a maximum of two tiers of storage shelves. Each storage tier may contain up to five - 18" wide and 19 feet long shelves for safe geometry 4" thick slab storage. Vertical spacing between shelves shall be at least 16 inches. A neutron poison as described above shall be placed on each shelf level except for the bottom. Horizontal spacing between tiers within a cubicle shall be at least 9 feet 11 inches.
Other nuclear safety controls on pellet vault storage are as follows:
Shelves with multiple enrichments are limited to a maximum slab thickness of 4 inches.
The vault is separated from other SNM storage and processing by eight inch thick coners walls.
Material storage and handling in the vault is controlled based on criteria specified by Health Safety personnel. Enrichment determination shall be made utiliz!ng appropriate records or test data.
Reject SNM, collected fines, retainer samples, etc.
may be stored in the vault provided the material does not exceed the 4.0" slab thickness.
Transport of SNM in the pellet vr it area shall be with carts applying the same nuclear safety criteria as described for that area.
4.2.4.3 Fuel Rod LondlDQ The fuel rod loading area is located adjacent to the pellet vault and may involve handling and storage of unclad pellets in areas other than the vault. Nuclear safety in this area is maintained as safe geometry slabs as de-scribed in 4.2.3.2.
Page: 414 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS LYNCHBURG MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168 DOCKET 701201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY i
Other auclear safety controls associated with the fuel rod loading area are:
No SNM accumulation shall be positioned above or below any other SNM accumulation.
SNM in the rod loading area shall be arranged such that the SNM slab thickness is less than or equal to 4 inches and less that 25 Inches wide. The slab is to be spaced 12" horizontally from any other SNM accumulation. The slab will also be spaced a minimum of 12" above any concrete floor.
4.2.4.4 Fuel Rod Processing and Storage Fuel rod processing operations are those performed after the cladding is loaded with UO, pellets. Typically, these functions include welding, leak testing, cleaning, visual and dimensionalInspection, etc. Certain operations may require that the rods be partially or wholly immersed in liquids. These liquids shall be of such a nature that the cladding would not be compromised.
Nuclear safety controls applied to the fuel rod processing area are as follows:
Individual accumulations shall be limited to a 4.0 inch thick slab unless specifically authorized by Section 4.1.3.
No SNM accumulation shall be positioned above or below any other SNM accumulation.
Transport of fuel rods from storage to the assembly area shall be in maximum of 4.0" slab, 4.2.4.5 Fuel Assembiv ProCASSIDS Fuel assen.aly processing operations are those which-consists i f loadino :' al rods into an assembly configuradon,( Min 11ng assemblies, and other Page: 415 November 24,1997 Revision: 9
FRAMATOME C:GEMA FUELS LYNCHBURG MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 4 NUCLEAR CRITICAllTY SAFETY fabrication steps such as alignment, welding, inspection operations, etc.
The actual assembly of rods into bundles (or removal therefrom) shall be performed in an area contalring no sprinkler system or similar facility for general moderation.
Moderating materials in the assembly area shall be limited to only those essential to the operations. Liquid moderators shall be cleaning agents used only for local wiping rather than immersion and shall be controlled by limiting the volume of Individual containers to one gallon not to exceed more than a total of 20 gallons. Water or similar moderator piping that must be in the area shall be protected from accidental rupture by virtue of its location, or by protective guards, and shall have the joints baffled to prevent spraying in process assemblies in the event of a break. The ut.a of polyethylene or similar moderators shall be limited to one sheet per fuel rod channel.
Nuclear safety controls applicable to the fuel assembly processing area are:
A minimum separation of 4 feet shall be maintained between fuel bundle assembly stations.
1 The assembly station equipment shall be such that liquids cannot be retained in and around the in process operation.
Assembly processing operations may be performed without moderation control provided the fuel rods are restralned in the fuel assembly configuration.
Adjacent assemblies shall be separated by a center to center distance of 38 inches.
For the purposes of nuclear interaction control, the fuel assembly processing and fuel assembly storage arrays are considered as a single array.
Adjacent arrays are considered to be no more Page: 4-16 November 24,1997 Revision: 9
FRAMATOME CSGEMA FUELS a LYNCHBURG MANUFACTURING FAClllTY USNRC LICENSE SNM 1168, DOCKET 7021201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY reactive than an array of fuel assemb!!es loaded in adjacent containers as described in 4.2.4.6.
The following nuclear safety controls shall be imposed on fire fighting within the fuel assembly processing area:
The use of hoselines shall be prohibited unless authorization has been received from a management representative of the plant emergency response organization.
Simultanaous app!! cation of more than one hoseline is not authorized.
Area postings shall be maintained at the array perimeter specifying limitations on fire fighting techniques.
4.2.4.6 Fuel Assembiv Storage and Packaging Fuel assemblies may be stored in racks meeting the following spacing and packaging criteria:
Fuel assemblies stored in linear arrays shall have a minimum 21" center to center spacing for enrichments below 4.1 wt% and a minimum of 42" center to center spacing for enrichments above 4.1 wt% but less than or equal to 5.1 wt%
285 l
U.
A minimum of 38" center to-conter spacing shall be maintained between the nearest assemblies of adjacent planar or linear storage arrays.
Fuel assembly dust wrappers, if used, shall be arranged to permit drainags of water from within. Moderation, such as polyethylene, etc., shall not be permitted within the assemblies. No stream sources or sprinklers shall be l
located near the storage array A restriction that l
l prohibits any significant quantity of moderating material l
such as paper, plastic, oil, and etc. Within the fuel l
Page: 417 November 24,1997 Revision: 9
FRAMATOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 116b, DOCKET 701201 PARTI CHAPTER 4 NUCLEAR CRITICAllTY SAFETY assembly shall be promir.ently posted in the boundarles of the assembly storage array.
The following nuclear safety controls shall be imposed on fire fighting within the fuel assembly storage array:
The use of hoselines shW % erohibited unless authorization has bs.,
no., j from a management represNa m of.he plant emergency response olemiiation.
Simultaneous application of more than one hosellne is not authorized.
Area postings shall be maintained at the array perimeter specifying limitations on fire fighting techniques.
4.2.4.7 Eue] Assembiv Shioning CQDtainars Fuel assembly packaging and unpackaging operations involving licensed shipping containers shall be performed within the following limitations:
Fuel assembly packaging shall be in accord with the requirements of the container certificate.
Fuel assemblies in adjacent containers shall have a minimum 18" odge to edge separation distance.
The edge to edge separation distance between fuel assemblies in the storage rack and assemblies in shipping containers shall be a minimum of 38 inches.
Fuel assemblies may be stored in licensed shipping containers after being prepared for shipment. During such storage, the following conditions shall be maintained:
Page: +18 November 24,1997 Revision: 9
FRAMA TOME COGEMA FUELS L YNCH:UR3 MANUFACTURIN3 FActLITY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 4 NUCLEAR CRITICAllTY SAFETY Loaded shipping containers shall be handled using only authorized methods.
Loaded shipping containers shall not be stacked more than two (2) high.
j i
Fuel assemblies stored in NRC licensed shipping containers arc exempt from the criticality monitoring requirements of 10 CFR 70.24 when the following conditions are maintained:
The containers and contents have been subject to the inspections and determinations required by 10 CFR 71, Subpart D.
The containers are sealed, properly identified, and meet shipment requirements.
A minimum of 38" edge to edge separation is maintained between the loaded container array and storage rack.
4.2.4.8 Outside Storage of Radioactive Material UF, cylinders or other radioactive materials in shipping containers rnay be stored outside the LMF main building within the perimeter fence. The area used for such storage shall be prepared and maintained under weed control.
Areas used for UF, cylinder and other radioactive material storage shall be monitored quarterly. No combustibles shall be stored in the area except for timbers / pallets necessary for structural support. Other specific conditions for the area aie as follows:
UF. Cvilnder Storage The UF, area will be kept segregated from other radioactivo material storage areas for ease of handling.
Pa90: 4 19 November 24,1997 Revision: 9
FRAMA TOME C00EMA FUELS. L YNCHBUR3 MANUFA CTURIN3 FA ClllTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI CHAPTER 4 - NUCLEAR CRITICAlilY SAFETY The UF. storage area is enclosed by a barrier (i.e.,
rope, fence, etc.) when cylinders are not being loaded or unloaded.
UF. cylinders shall be equipped with valve protectors during movement and storage.
Enriched..'F. Will be stored in a tingle planar array (natural or depleted U does not require geometric controls for criticality safety).
1 Other Radioactive Material Storage The materialis properly packaged per NRC/ DOT requirements.
Predefined storage areas must be approved by the Safety Review Board.
The loaded containers will be stored in an enclosure (i.e., building, traller, sea container, other type structure, etc.) that will provido protection from the elements.
Natural or depleted uranium does not require geometric controls for criticality safety.
4.2.4.9 Miscellaneous criticalltv Controls Laboratorv Ooerations Each laboratory shall be limited to 700 grams '85U with enrichments up to 5.1 wt%. Inventory will maintained by logging materials into and out of the laboratory.
Develonment Ooerations Development operations are of a nature such that specific geometric controls cannot be established in advance. Development operations'shall be amited to either the geometric controls imposed for the manned Page: 4-20 November 24,1997 Revision: 9
FRAMATOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FACILITY USNRC LICENSE SNM-1168, DOCKET 70 1201 PARTI - CHAPTER 4 NUCLEAR CRITICAllTY SAFETY 885 procsssing operations, or 350 grams U limit per accumulation.
Shloning Preparation for shipment and shipping shall be in accord with specific NRC and DOT approvals for the container and materials involved.
Solid Waste Solid wastes generated such as packing media, wiping cloths, etc., but not including reject SNM do not regulre special handling for nuclear safety.
Llould Wasig Liquid wastes containing significant quantitles of uranium i
shall be stored in a safe container limited to 700 grams of 88'U. The container (s) may be stored in the laboratory as a part of the laboratory inventory, as a 4.0" slab in the pellet vault, or in other approved locations.
Shloning Container Storage SNM may be stored in authorized shipping containers in an array that is no more reactive than that specified for the same material under transport conditions.
Vacuum Cleaners Vacuum cleaners used for cleanup / decontamination purposes shall satisfy the safe geometric limits specified in 4.2.1 of this section.
4.2.4.10 Exaporator Sludge The evaporator sumps shall be inspected monthly for sludge accumulation, if the accumulation exceeds one Inch, it shall be removed.
Page: 4 21 November 24,1997 Revision: 9
FRAMATOME COGEMA FUELS - L YNCH:URG MANUFACTURING FAClllTY j
USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTI - CHAPTER 5 - ENVIRONMENTAL PROTECTION N
5.1 Effluent Control Svstems A report providing the effluent results in accordance with section 5 of Regulatory Guide 4.16 dated December 1985 shall be submitted to the NRC semiannually.
5.1.1 Gaseous Effluent Control Gaseous effluents to uncontrolled areas are restricted and monitored as described in Chapter 3.
5.1.2 Llauld Effluent Control Potentially contaminated liquid effluents are processed through an evaporator and released as gaseous effluent through the HEPA
/
filtration system. The release limits are the same as those used for the gaseous effluents to uncontrolled areas as described in Chapter 3.
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5.2 Environmen*at Monitorina An environmental monitoring program shall be conducted to assess the effective control of airborne and liquid effluent releases to unrestricted areas. Environmental monitoring shall be in acc'.rdance with approved procedures which require the generated data to be evaluated against internal action levels. The program as shown on Figuro 5.1 and Table 5.1, provides coverage to areas immediately surrounding the plant and includes locations in the upwind and upstream directions for background comparisons. The sample results are maintained on file.
Page: 5-1 June 9,1997 Revision: 3
FRAMATOME COGEMA FUELS LYNCH ~URG MANUFACTURING FACillTY USNRC llCENSE SNM 1168, DOCKET 70-1201 PARTI - CHAPTER S - ENV!RONMENTAL PROTECTION TABLE 5.1 COLLECTION i AINIMUM MINIMUM SAMPLE TYPI FREQUENC'
- ' AMPLE SAMPLE TYPE OF DETECTABLE LOCATION
& ANALYSli.,! JE TYPE ANALYSIS LEVEL Water E,1,J,K,L Annually 1 liter Grab Gross 2.7x10 'pci/mi Air A,C,F Continuous Contin.
Filter Gross 2.5x10-"pel/mi Weekly L
Soll A,B,D,F,G, Annually 100 Grab Gross 1 p cl/g H
orams Radiation A,B,C,F Ouarterly N/A TLD TLD
~ 10 mrem Reading Sediment E,1,J,K,L Annually 100 Grab Gross 1 p ci/g grams Vegetation A,B,F,H Annually 500 Grab Gross 1 p cl/g grams L
Pag n 5-2 June 9,1997 Revision: 3
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FRAMATOME COGEMA FUELS LYNCHBUR3 MANUFACTURING FAClllTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI - CHAP (ER 6 - SPECIAL PROCESSES 6.1 Nonexemnt Sealed Source Control 6.1.1 Use of nonexempt sources for training and instrument calibration shall be limited to, or under the direct control of, the Health-Safety Section.
6.1.2 Sources utilized as a functional component of devices designated fcr manufacturing and quality control purposes shall be operated only by approved personnel who have been instructed in safe practice b/ Health-Safety. Health-Safety shall provide appropriate monitoring support during maintenance or other operations that may entall increased exposure levels. A register of approved operators shall be maintained in the Health Safety Office.
6.1.3 Maximum whole body exposure rates in any constantly occupied area in the vicinity of operating manufacturing or quality control units utilizing by-product material sources shall not exceed 2 mrem /hr.
6.1.4 in addition to dosimetric devices routinely worn by designated LMF employees, appropriate self reading dosimeters shall be utilized by personnel involved in source manipulation in cases where the exposure may exceed 2 mrem /hr.
6.1.5 Each sealed source shall be tested for leakage at intervals not to exceed six (6) months. In the absence of a certificate from a transferor indicating that a test has been made within six (6) months prior to the transfer, the sealed source shall not be put into use until tested.
6.1.5.1 The test shall be capable of detecting the presence cf 0.005 microcurie of contamination on the test sample. The test sample shall be taken from the source or from appropriate accessible surfaces of the device in which the sealed source is permanently or semi-permanently mounted or stored. Records of leak test results shall be kept in units of micro curies and maintained for inspection by the Commission.
Page: 6-1 June 9,1997 Revision: 4
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FRAMA TOME COGEMA FUELS - L YNCHBURD MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 6 - SPECIAL PROCESSES 6.1.5.2 If the test reveals the presence of 0.005 microcurie or more of removable contamination, the source shall be withdrawn from use and shall be decontaminated and repaired by a person appropriately licensed to make such repairs or disposed of in accordance with Commission regulations. Within five (5) days after determining that any source has leaked, a report shall be filed with the U.S.
Nuclear Regulatory Commission describing the source, the test results, the extent of contamination, the apparent or suspected cause of source failure, and the corrective action taken. A copy of the report shall be sent to the Director the nearest NRC Regional Compliance Office listed in Appendix D of Title 10, Code of Federal Regulations, Part 20.
6.1.5.3 The periodic leak test required by this condition does not apply to sealed sources that are stored and not being used. The sources excerpted from this test chall be tested for leakage prior to any use or transfer to another person unless they have been leak tested within six (6) months prior to the date of use or transfer.
6.1.6 Adequate records shall be maintained to insure effective source documentation, including leak test results.
6.1.7 When not in use, sources shall be stoced in approved secured containers in a manner selected to prevent unauthorized removal or use. Adequate posting of the source container and storage / operation area shall be maintained to insure compliance with appropriate regulations.
Page: 6-2 June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS - LYNCH:UR3 MANUFACTURING FACILITY
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USNRC LICENSE SNM 1168, DOCKET 701201 PARTI - CHAPTER 6 SPECIAL PROCESSES 6.2 Ekg Protection The LMF fire protection program is administered by the Health Safety l
Section with the Manager, Safety and Licensing overseeing the program.
1 LMF utilizes internal Health Safety procedures to ensure adequate fire protection is established, inspected and maintained for new facilities, equipment and/or operations. Internal procedures also provide instruction for our emergency rescue team in the event of a minor or major fire. Our pre fire plan provides a hazard analysis associated with separate plant areas, fire emergency plans, and training. The Plan shall be reviewed by all fire fighPg support agencies and updated accordingly.
Accumulations of combustible materials within the LMF shall be limited to the greatest extent practicable, consistent with operational requirements.
Supervision is responsible for assuring that arens under their cognizance are maintained in accord with good housekeeping and fire prevention practice.
6.2.1 Flammable liquids shall be stored in approved containers.
6.2.2 Fire extinguisher systems compatible with area nuclear safety requirements shal! be installed or provided in accord with insurance and federal regulations The above systems shallinclude portable extinguisher of a type (pressurized water, CO and dry chemical) 2 and size based on the potential hazard. Agents such as "Metl-X" are available in areas where metal fires may occur. Sprinkler systems and other water-type extinguishing systems are not installed in moderation controlled areas.
6.2.3 As part of its emergency program, the LMF organization shall include a " fire brigade" staffed by qualified personnel, familiar with basic fire fighting techniques, the equipment available for their immediate use onsite, and the nuclear safety and health physics considerations that are involved. Fire Brigade members shall be retrained at least annually. The Manager, Safety & Licensing shall have oversight of the fire brigade.
6.2.4 Fire protection water shall be available at all times. There shall be a low pressure detection and alarm device and annual water flow / pressure tests shall be conducted routinely.
Page: 6 3 June 9,1997 Revision: 4
FRAMA TOME COGEMA FUELS - L YNCH:UR3 MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTI - CHAPTER 6 - SPECIAL PROCESSES 6.2.5 Fire protection equipment shall be inspected routinely in accordance with NFPA standards to ensure reliability.
6.2.6 Areas under moderation controls shall be prominently posted and approved fire fighting techniques defined. Deviations from the posted techniques can be approved only by one of the following members of the LMF Emergency Team:
Plant Manager, Emergency Officer, Health-Safety Officer During periods when the plant is not in operation, at least two tours per shift shall be made by a representative of the security force or a LMF employee.
6.2.7 An early warning fire detection / alarm system shall be installed in the S-1 storage facility. The system shall alarm at the continuously manned guard house. Further precautions, detailed in 10.5 of this document, will also be implemented.
6.2.8 A sprinkler system shall be installed and maintained in SERF-3 & 4 In accord with NFPA codes. Further precautions, outlined in 10.5 l
l of this document, will also be implemented.
6.3 Emaraencv Utilities Backup battery power is provided for the criticality alarm, fire alarm, public address system and for emergency lighting. The nature of our operations is such that a loss of utilities simply results in a totally safe halt in j
l operations.
6.4 Radioactive Waste Control The " Guideline for Decontamination of Facilities and Equ:pment Prior to Release for Unrestricted Use or Termination of Licenses for By-Product, Source or Special Nuclear Material", USNRC August 1987, Exhibit A of Chapter 1 shall be used for disposal control of materials or equipment.
Additionally, these guidelines will be followed regarding radioactive waste control:
Page: 6-4 June 9,1997 Revision: 4
FRAMA TOME COGEMA FUELS - LYNCHBURG MANUFACTUE!NG FACillTY USNRC LICENSE SNM-1168, DOCKET 70-1201
' /ARTI - CHAPTER 6 SPECIAL PROCESSES Any item which cannot be thoroughly surveyed due to physical a.
construction, painting, or other reason shall be assumed to be in excess of the above limits and shall be disposed of in a controlled manner, unless indirect methods such as acid etching verify the absence of significant contamination, b.
When possible and practicable, reasonable attempts shall be made to decontaminate all items with " detectable contemination" to a non-detectable level.
6.5 Chemical Safetv 6.5.1 Written procedures shall be used for the implementation of the criteria set forth in 29CFR and 40CFR for chemical safety. This is to include the implementation of a Hazardous Communications Program that defines the proper storage facility, equipment, and chemical handling procedures.
6.5.2 Storage of chemicals in tanks and/or buildings shallincorporate a pressure relief system. Storage shall be maintained an adequate distance from the main plant.
Page: 6-5 June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS - LYNCH:URG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTI - CHAPTER 7 - DECOMMISSIONING PLAN 7.1 Decommissionina Plan Framatome Cogema Fuels shall fulfill the requirements set forth in 10 CFR 70.25 (e) and (f) through the implementation of the Decommissioning Funding Plan submitted to the Commission on March 27,1992 and supplemented on August 23 and October 15,1993, May 10,1994 and November 30,1994.
Framatome Cogema Fuels, Lynchburg Manufacturing Faciln.
.iake no changes to the Plan which would decrease its effectiveness witnout prior approval of the USNRC. Changes, which do not decrease the effectiveness of the Plan, will be reported to the NRC within six months of the change to the Chief, Licensing Branch, NMSS, Washington, D.C.
20555.
If decommissioning efforts are executed prior to plant closure, the affected area may be removed from the Plan. The Plan sbsil be reviewed biennially and revised accordingly.
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l Page: 7-1 June 9,1997 Revision: S i
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FRAMA TOME COGEMA FUELS - L YNCHBURG MANUFA CTURING FA CillTY USNRC LICENSE SNM 1168 DOCKET 70-1201 PARTI - CHAPTER 8 - RADIOLOGICAL CONTINGENCY PLAN 8.1 Radiological Contingency PlaD An evaluation has been performed to demonstrate that the maximum dose to a member of the public offsite due to a release of ladioactive materials from the LMF does not exceed 1 rem effective dose equivalent. With the evaluation and in accordance with the provisions of 10 CFR 70.22(l)(1)(l) and 40.31(J)(1), FCF is not required to maintain an NRC approved Emergency Plan. An emergency plan and implementing procedures for internal use to include an emergency response organization shall be maintained.
If process changes or modifications to the ventilation system occur that could effect the offsite dose projection, LMF shall verify that the evaluation submitted to the Commission on November 9,1993 and supplemented on March 21,1994 and October 18,1995 is still valid and that the dose does not exceed criteria of 10 CFR 70.22 and that the possession of natural uranium does not exceed the limits of 40.31(j)(1).
Page: 8-1 June 9,1997 Revision: 6
-FRAMATOME COGEMA FUELS LYNCH:JRG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 701201
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PARTll - CHAPTER 9 - GENERAL INFORMATION
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9.1 Coroorste Information Framatome Cogema Fuels (FCF) has constructed facilities at the Lynchburg, Virginia site for the purpose of fabricating fuel assemblies for commercial utility nuclear reactors. Framatome Cogema Fuels is a partnership of Cogema Fuels Inc. and Virginia Fuels Inc. that is organized and exists under the laws of the State of Delaware.
9.1.1 Addresses of Princloal Offices Framatome Cogema Fuels P. O. Box 10935 Lynchburg, Virginia 24506-0935 Address of Licensed Activity Frematome Cogema Fuels Lynchburg Manufacturing Facility Mt. Athos Road, Route 726 P. O. Box 11646 Lynchburg, Virginia 24506-1646 9.1.2 Coroorste Officer Information Names &
Office Citizenship Addresses -
J.R. Bohart President USA P.O. Box 10935 Virginia Fuels Inc.
Lynchburg, VA.
24506-0935 M. A. McMurphy President USA P. O. Box 10935 Cogema Fuels Inc.
Lynchburg, VA.
24506-0935 R.B. Hoffman President USA P. O. Box 10935 Framatome Cogema Fuels Lynchburg, VA.
24506-0935 Pa9e: 9-!
June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS - LYNCH URG MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTll CHAPTER 9 GENERAL INFORMATION 9.2 Financial Qualification Framatome Cogema Fuels will, from time to time at a frequency acceptable to NRC, provide a summary of its financial condition sufficient to demonstrate conclusively its aallity to pay the cost of decommissioning its nuclear facility. Such summary willinclude the method by which, and extent to which, provision is being made for this financial obligation.
9.3 Summarv of ooerating Obtective and Process The utilizes uranium oxide in pellet form enriched to a maximum of 5.1%.
UO, pellets are received and loaded into cladding material. The loaded rods are then configured into fuel assemblies for use in commercial power reactors. Plant throughput typically ranges between 150 to 400 MTU/ year. This is based on historical data. The previous license renewal was performed in 1990. Major plant process changes made since then can be described as follows:
1.
expansion of facility for non licensed material 2.
addition of downloading operations 9.4 Site Descriation l
The following are brief summaries of certain physical attributes of the LMF site. The majority of the information expressed was extracted from the environmental reports prepared for Framatome Cogema Fuels (formerly B&W Fuel Company, Commercial Nuclear Fuel Plant) in 1974 and 1976.
9.4.1 Geograohv Framatome Cogema Fuels Lynchburg Manufacturing l'acility is located on a 76 acre site in Campbell County, Virginia, approximately 4 miles from the Lynchburg City limits. The site is adjacent to the Babcock and Wilcox NNFD and Nuclear Technology Center plant sites. The physicallayout of the LMF site is as shown in Figure 9.1. The entire 525 acre site is illustrated in Figure 9.2.
9.4.2 Demograohv Because of the terrain, most of the population within a 5 mile radius of the LMF resides over 3 miles from the site. There are no Page: 9-2 June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS LYNCH:URG MANUFAC% RING FACillTY
~
USNRC LICENSE SNM-1168, DOCKET 70-1201 PART H - - CHAPTER 9 - - GENERAL INFORMA TION e
significant clusters of population within a 2 mile radius of'the LMF.
The closest inhabitants occupy _ residences which are located about
- one-half mile to the ENE.'
Approximately two-thirds of the population within 5 miles of the plant residi between_ the 0 and 5 mile radil in the WSW to WNW -
directions. This includes the eastern portions of the City of Lynchburg and the community of Madison Helgr.ts.
Within a 3 mile radius of the plant, there are only a few public facilities or business activities that attract large numbers. The-neighboring Archer Creek Plant of the Lynchburg Foundry and the NNFD and Lynchburg Technology Center of Babcock & Wilcox are the only other major industries in the immediate vicinity.
Approximately 3000 workers are employed at these facilities, s
9.4.3 Meteorology Since Lynchburg is situated in the valley of the James River and on the eastern edge of-the Blue Ridge Mountains, extreme weather in the area is rare.
LV ere weather at ce Mt. Athos site is generally limited to occasional thunderstorms, with a very low probability of tornadoes.
. According to methods for estimating tornado occurrence, the probability of a tornado actually striking the site in any given year is 3.0 x 10, with a recurrence interval of 3333 years. Since the 4
site is not a coastallocation, the effects of hurricanes would be limited to increased rainfali and possible flooding.
f 9.4.4 Hvdrology
.The LMF site lies on a river bend bounded on three sides by the
. James River and on the southeastern side by Mt. Athos. Hence, the.only waters that could be affected by plant operation or that could influence plant operation are the James River and the ground waters of the site and its immediate environs.
Facilities at the Mt. Athos site utilize several wells to obtain groundwater. -These wells are situated in the northeastern portion of the property along the James River. Water levels at these wells L
Page: %3.
June % 1997 Revision: 4 L
FRAMATOME COGEMA FUELS - LYNCHBURG A1ANUFACTURING FACILITY USNRC L! CENSE SNM-1968, DOCKET 70-1201 PARTN CHAPTER 9 - GENERAL INFORMATION are approximately 465 to 442 feet Mean Sea Level (MSL) and 4
indicate the generally northerly downward-sloping trend toward the river.
The site groundwater supply is stored in three 150,000 gallon tanks located on a hilltop on the property immediately north of the one million gallon service water tank. The LMF utilizes groundwater from these tanks at an average rate of 2500 gallons per day. Hence, the LMF accounts for a very small percentage of the total consumption of groundwater at the Mt. Athos site.
9.4.5 Seismology The central Appalachian region of Virginia is characterized by a moderate amount of low-level earthquake activity which appears as somewhat isolated " clusters" of seismic energy release; there is a central Virginia cluster, a western Virginia-West Virginia cluster and i
a norther Virginia Maryland-West Virginia cluster. The LMF is located in a western part of the central Virginia cluster region
.which is classified as Zone 2 on the Selsmic Risk Map of the United States. On the Modified Mercalli(MM) scale this zone corresponds to an intensity of Vil, which implies building damages to the extent of fallen chimneys and cracked walls. Zone 2 has an acceleration range of 0.065 to 0.14 gravity.
9.4.6 Geologv l
The James River Basin of Virginia includes portions of four physiographic provinces, each of which is characterized by distinct land forms and physical features. These provinces, located west to east, are Valley and Ridge, Blue Ridge, Piedmont and Coastal Plain.
Western or inner Piedmont where the Mt. Athos site property lies is in upland characterized by scattered hills, some of mountainous dimensions, lying eastward from the foot of the Blue Ridge.
i The Mt. Athos site is located on a river bend and generally exhibits a rolling surface of gentle slopes, it is bounded on three sides by the meandering James River and'on the southeastern side by Mt.
Athos. ~ The dominant topographic feature of the site is a hill located approxirnately at the center of the property, the crest of which rises to 693 feet MSL. The ground is inclined toward the Page: 9-4 June 9,1997 Revision: 4
FRAMA TOME COGEMA FUELS - L YNCH:URG MANUFA CTURING FA CILITY USNRC LICENSE SNM-1168, DOCKET 701201 PARTH - CHAPTER 9 - GENERAL INFORMATION river from the hilltop to the river bank, which is at approximately 470 feet MSL. The highest point in the vicinity of the site is the top of Mt. Athos, where the elevation is 890 feet MSL.
9.5 Location of Buildings on Site The physical layout of the LMF site is illustrated in Figure 9.1. The relationship of the LMF to other facilities at the Mt. Athos site is shown in Figure 9.2.
9.6 Maps The following maps are included to clearly define the boundary of the site and the relationship to neighboring areas as well as within the State of Virginia. These are as follows:
Points of interest in the Vicinity of the LMF Figure 9.3 Physical Features Within Five Miles of the LMF Figure 9.4 The Relationship of the LMF to Major Virginia Figure 9.5 Population Centers 9.7 License Historv The following is a chronology of SNM-1168 from initial issue to the present:
Data Descriotion 12/69 SNM-1168 first issued 4/76 First renewal of SNM-1168 6/83 Second renewal of SNM-1168 5/88 Expiration date of SNM-1168 9/90 Renewal of SNM-1168 granted for a ten year period Page: 9-5 June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS LYNCH:UR3 MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTll - CHAPTER 9 - GENERAL INFORMA TION FIGURE 9.1 fUwfsoms C
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Page: 9-9.
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FRAMA TOME COGEMA FUELS - LYNCHBURG MANUFACTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PART11 CHAPTER 9 - GENERAL INFORMATION FIGURE 9.5 8 ',.
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- 11. NORFOLK Page: 9-10 June 9,1997 Revision: 4
FRAMATOME COGEMA FUELS - LYNCICURG MANUFACTURING FACILITY l
USNRC LICENSE SNM-1168, DOCKET 70-1201 l
PARTil - CHAPTER 11 - ORGANIZATION AND PERSONNEL 11.1 Organizational Responsibilities The key organization responsible for maintaining the health and safety aspects at the LMF to include all SERF Facilities is the Health-Safety Section. The Health Safety Section is a part of the Safety and Licensing organization. The Health-Safety Section reports to the Manager, Safety and Licensing. The Manager, Safety and Licensing reports directly to the Quality Manager.
11.2 Key Personnel Function 11.2.1 Overall Program Management Responsibility for planning, coordinating, administering and managing the health and safety aspects of the LMF is vested in the Manager, Safety and Licensing. This position is organizationally parallel to members of the Plant Manager's staff such as the Managers of Manufacturing Engineering and Fuel Manufacturing.
11.2.2 The Health-Safety Section Health-Safety personnel are responsibie for the general surveillance of all plant safety related functions. Specifically, these functions are described as follows:
Maintaining appropriate control of hazardous material, shipments, and receipts.
Supervising and coordinating the hazardous waste disposal program.
Assisting in personnel and equipment decontamination.
Distribution and processing of personnel monitoring equipment.
Maintaining individual exposure records.
Orienting and training LMF personnel in radiological and nuclear safety.
Page: 11 1
. lune 9,1997 Revision: 10 l
FRAMATOME COGEMA FUELS - LYNCHBURD MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTll -- CHAPTER 11 - ORGANIZATION AND PERSONNEL Furnishing consulting services and advice on radiation protection to plant supervision and management.
Generating or acquiring, maintaining, and appropriately distributing all records and reports required by applicable regulations or procedures.
Leak testing on sealed radioactive sources.
Developing and disseminating procedures related to radiation safety and reviewing procedures prepared by other operating sections for regulatory compliance and the adequacy of safety considerations.
The key positions within the Health Safety Section are the Health Physicist, the Regulatory Compliance Officer and the Health Safety Monitors.
L l
11.2.3 Health Phvsicist I
t The Health Physicist is responsible to provide management with assurance of the effectiveness of the entire health and safety l
program from a radiological, nuclear, industrial, and chemical safety l
aspect. This position is responsible for evaluating the potential for exceeding authorized control limits and to recommend appropriate l
restrictions or corrective measures.
The Health Physicist is also responsible for supervising the implementation of the Health-Safety Program to assure that the requirements as defined by license and procedures are carried out.
The Health Physicist reports directly to the Manager, Safety &
Licensing.
l-11.2.4 A <atorv Comollance Officer l
The Regulatory Compliance Officer is responsible for implementing l
the occupational and industrial safety programs to include chemical and fire safety. The Regulator Compliance Officer reports directly to the Manager, Safety & Licensing, i
page: 11-2 June 9,1997 Revision: 10
FRAMA TOME COGEMA FUELS - LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 PARTll - CHAPTER 11 - ORGANIZATION AND PERSONNEL 11.2.5 Health Safety Monitors The Health-Safety Monitors are responsible for conducting routine monitoring, sample collection and analytical tests to determine radiation and contamination levels. The Health Safety Monitors report directly to the Health Pt ysicist.
11.2.6 SERF 3 & 4 Oroanization The SERF 3 & 4 facilities have a Site Manager to oversee the operations of both facilities. His staff includes 2 supervisors and maintenance technicians. The SERF 3 & 4-Manager reports to the Vice-President, FTl Chemistry & Environmental Services who reports to the FTl President.
A health physicist and 2 health safety technicians from the LMF Safety & Licensing organization are also permanently assigned to the SERF 3 & 4 facilities.
11.3 Resumes Resumes from managerial, health safety, and criticality organizations within the LMF are included. These are as follows:
Name litle J.E. Matheson, Jr.Vice-President, Operations (Plant Manager)
A.D. McKim Manager, Quality, Health / Safety & Licensing T.S. Wilkerson Manager, Fuel Manufacturing (Production Manager)
G.F. Elliott Manager, Safety & Licensing G.B. Lindsey Health Physicist D.I. Gordon Sr. Health Physicist L.A. Hassler Senior Principal Engineer P.L. Holman Senior Principal Engineer Page: 11-3 June 9,1997 Revision: 10
FRAMATOME COGEMA FUELS - LYNCH:URG MANUFACTURING FAClllTY USNRC LICENSE SNM-1168, DOCKET 701201 PARTll - CHAPTER 11 - ORGANIZATION AND PERSONNEL NAME:
John E. Matheson, Jr.
TITLE:
Vice-President, Operations (Plant Manager, Lynchburg Manufacturing Facility) h CITIZEN OF UNITED STATES EDUCATION: Lowell Technologies institute BS in Physics - 1968 The Catholic University of America MS in Aerospace Engineering - 1973 The University of Virginia MS in Mechanical Engineering - 1983 Registered Professional Engineer in State of Virginia Va. License No. 0402 012314 EXFFRIENCE: 1997 - Present Framatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - Vice-President, Operations (LMF Plant Manager).
Overall responsibility for all plant operations.
1994-1997 Framatome Cogema Fuels, Lynchburg, Va. -
Manager c" Design & Development. Responsible for the technical content and design basis of all fuel assemblies and components. Managed the design, analysis, configuration management, and design release functions.
1990 -1994 Framatome Cogema Fuels, Lynchburg, Va. -
Contract Manager. Managed the fuel contracts for fuel delivered to Duke Power reactors (7).
Responsible for defining contract needs and issuing release authorizations for manufacturing and design. Coordinated all Framatome Cogema Fuel activities with Duke Power Company including negotiating all contract changes.
1987 - 1990 Framatome Cogema Fuels, Lynchburg, Va. -
Project Manager, High Level Waste. Managed the fuel consolidations project. Designed, developed Page: 11-4 June 9,1997 Revision: 10
FRAMA TOME COGEMA FUELS - L YNCH~UR3 MANUFA CTURING FA CILITY.
USNRC LICENSE SNM 1168. DOCKET 701201 PARTll - CHAPTER 11 - ORGANIZATION AND PERSONNEL and tested machine to consolidate spent nuclear fuel (joint project with SGN in France).
1985 -1987 Framatome Cogemn Fuels, Lynchburg, Va. -
Sunervisor, Fuel Rod Design and Analysis.
Managed the design and analysis function for fuel rods. Lead the development of a code to predict the consequence of pellet cladding interaction.
1978 -1985 Framatome Cogema Fuels, Lynchburg, Va. -
Principal Engineer Fuel Design. Performed various tasks in the design of fuel assembly components, grids, structures, etc. Acted as project leader of several major development projects.
1968-1978 Naval Ordinance Station, Indian Head, Maryland.
Held various positions from an entry level engineer to unit manager for air launciled missiles.
Performed various engineering duties in the design and analysis of tactical rocket motors, in the last position (1975 - 1978) was responsible for the basis design engineering function and logistics support of rocket motors used on all air launched missiles in the U.S. Navy, Page: 11-5 June 9,1997 Revislan: 10
' FRAMA TOME COGEMA FUELS - L YNCHBUR3 MANUFA CTURING FACillTY USNRC LICENSE SNM 1168, DOCKET 70-?201 PARTH - CHAPTER 11 - ORGANIZA TION AND PERSONNEL NAME!
Alvin D. McKim 71TLE Manager, Quality, Health / Safety & Licensing CITIZEN OF UNITED STATES EDUCAT/0N: AS Tool Engineering Technology, ITT - 1967 AS Mechanical Engineering, University of Evansville - 1973 BSBA Indiana State University of Evansville - 1975 Graduate Engineering Cot.rses at University of Evansville EXPER/ENCE! 1997 - Present Frarnatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - Manager,-
Quality. Responsible for quality, safety & licensing of plant operations including; industrial, radiological, and nuclear safety programs; federal, state, and local licensing.
1996-1997 Framatome Technologies, Inc., Lynchburg, Va. -
Director, Corporate Procurement. Responsible for all procurement in support of FTG. This included items from engineered products to MRO to services.
1989-1996 Framatome Technologies, Inc., Lynchburg, Va -
Product Line Manager, Valve Services. Profit and loss responsibility for product line that ranged from seven to fifteen million dollars revenue per year.
Prcduct Line provided valve engineering and diagnostic services to the commercial nuclear industry. Responsibilities included sales, marketing, engineering, field services, and product development.
1982-1989 Framatome Technologies, Inc., Lynchburg, Va -
Unit Manager, Materials and Structural Analysis.
Managed engineering unit responsible for ASME stress, seismic, flow-induced vibration, fracture mechanics, chemical and materials analyses associated with major NSS components and systems. Analyses were in support of plant Paget 11-6 Jr to 9,1997 Revision: 10
FRAMA TOME CO:EMA FUELS - LYNCH ^URG MANUFACTURING FACil.11Y USNRC LICENSE SNM-1168. DOCKET 70 1201 PARTll CHAPTER 11 - ORGANIZATION AND PERSONNEL licensing issues and field repairs / modifications including leak before break; pressure temperature limits; flow evaluations; life extension; SG plugging limits, BJ pump failure analysis; steam generator auxiliary feedwater header repair and modification; steam generator plug, sleeve and stabilizer design analyses, surge line stratification; and internals bolt replacement prograrn. Analyses were performed in accordance with ASME Section XI, USAS 831.7 and USAS B31.1.
1979 -1982 Framatome Technologies, Inc., Lynchburg, Va, -
Supervisor, Component Structural Unit. Technical Supervisor for stress analysis of steam generators, piping and reactor vessels. Successfully supported operating plant field fixes - make-up nozzle and auxiliary feedwater nozzle thermal sleeve failures. This included both stress analysis of field repairs / modifications and licensing support for restart.
Page: 11-7 June 9,1997 Revision: 10 wr
FRAMA TOME COGEMA FUELS - LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM 1168, DOCKET 701201 PARTll - CHAPTER 11 -- ORGANIZATION AND PERSONNEL NAME:
T. Scott Wilkerson i
TITLE Manager, Fuel Manufacturing CITIZEN OF UNITED STA TES EDUCATION: University of Virginia, Charlottesville, Va.
M.E. In Applied Mechanics - 1986 Virginia Polytechnic Institute and State University, Blacksburg, Va.
B.S. In Mechanical Engineering 1978 EXPER/ENCE: 1997 - Present Framatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - ivlanager, Fuel Manufacturing. Unit manager with overall responsible for fuel rod, control component, grid, fuel bundle, and incore detector fabrication.
1992-1997 Framatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - Manager, Manufacturing Engineering. Unit manager with responsibility for manufacturing procedures and processes used for production of nuclear fuel components. Unit provides technical responsibility for equipment design, fabrication methods, process qualifications and evaluation of deviated components. Function includes liaison with vendors, fuel design engineering and customers.
1990 -1992 B&W Fuel Company, Commercial Nuclear Fuel Plant, Lynchburg, Va. - Group Supervisor in charge of the Present Production Engineering Group of the Fuel Mechanical Engineering Unit. As such, responsible for the interface between the design of fuel assemblies and control components and the fabrication facility. All drawings, specifications, and associated docur.ientation for component fabrication are released, maintained, and administered by this group.
1980- 1990 B&W Fuel Company, Lynchburg, Va. - Principal Engineer, entered as an Associate Engineer P$get 11-8 June 9,1997 Revision: 10
FRAMATOME COGEMA FUELS LYNCF 'DURG MANUFACTURIN3 FAClllTY USNRC LICENSE SNM 1168, D:CKET 7 ? 1201 PARTll - CHAPTER 11 - ORGANIZA110N AND PERSONNEL (Engineer 11). Work consists primarily of the mechanical (structural) design testing, analysis, and associated documentation of commercial nuclear fuel assembly structural components and eulated equipment. This work typically involves the use of open shop computer programming as well as large scale structural analysis computer codes such as ANSYS. Project Administrative tasks such as preparing proposals, schedules, presentations, cost estimates, and technical reports are routinely done as necessary. Often this work is in close cooperation with the manufacturing plant; therefore, farniliarity with standard manufacturing practices is also rnalntained.
1978 1980 Lynchburg Foundry, Lynchburg, Va. Associate Engineer, in this capacity responsible for the budget, schedule, design, installation, and startup of capital projects and for solving a variety of mechanical plant engineering problems. Most of the work was in direct support of the manufacturing and quellty control process of the plant. Lynchburg Foundry makes gray and ductile iron castings primarily for the automotivo and heavy equipment industries.
PROFESSIONAL AFFILIA TION:
~
Page: 119 June 9,1997 Revision: 10
l FRAMA TOME C~GEMA FUELS - L YNCHBURG MANUFACTURIN3 FAClllTY
\\
USNRC llCENSE SNM 1168, DOCKET 70 1201 PARTll - CHAPTER 11 - ORGANIZATION AND PERSONNEL NAMEt Gayle F. Elliott TITLE Manager, Safety & Licensing CITIZEN OF UNITED STATES EDUCAT/0N Liberty University, Lynchburg, Va.
M.B. A. - 1990 B.S. In Mathematics - 1988 EXPERIENCE! 1996 Pre,ent Framatome Cogema Fuels, Lynchburg Manufacturing FacilU.y, Lynchburg, Va. - Manager, Safety & Licensing. Responsible for coordineting the technical aspects of radiation control for the fuel manufacturing plant and for the field operations refurbishment facility. Involved in the decommissioning, training, emergency preparedness, and transportation programs.
Responsible for budgeting for the Safety &
Licensing organization. Liaison with regulator agencica.
1993-1996 Frematome Cogoma Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - Technical Specialist 111, Quality Technology. Cognizant engineer for inspection processes, procedures and equipment for burnable poison, control rod, axial power assemblies, recelpt inspection components, fuel and burnable poison pellets. Support Safety &
Licensing with uranium accountability and licensing. Facilitator for Field Services Quality improvement Teams and Quality Steering Team.
1992-1993 B&W Fuel Company, Commercial Nuclear Fuel Plant, Lynchburg, Va. - Group Leader, Manufacturing Engineering. Supervise activities in the Manufacturing Engineering Machining and Special Processes group which includes directing the work for individuals within the group and assuring that milestones and schedules are met for such. Ensure complete, accurate and high quality Page: 11 10
-June 9.- 1997 Revision: 10
FRAMA TOME COGEMA FUELS L YNCHBURG MANUFACTURIN3 FACILITY USNRC LICENSE SNM 1108, DOCKET 70 1201 PARTll-CHAPTER 11 - ORGANIZA TION AND PERSONNEL documentation of all contracts. Provide technical review of documents to ensure all aspects of design criterla are met. Administer presentations for customers and employees of manufacturing processes. Coordinate R&D projects and prepare budget report for manhours and material costs.
1989 1992 B&W Fuel Company, Commercial Nuclear Fuel Plant, Lynchburg, Va. - Technical Specialist II, Manufacturing Engineering. Cognizant process engineer for incore Detector Assemblies and related components. Responsible for weld and braze qualifications, upgrade of fabrication procedures routing documents, establishment of research and development projects to support growth and progress, and troubleshooting.
Provide engineering support of all BWNS related contracts and ensure implamentation of the applicable sections of the ASME Code. Originate and administer procurement of enriched and natural pellets.
1988 - 1989 Educational Leave for of Graduate Studies.
1983 -1988 Babcock & Wilcox, Commercial Nuclear Fuel Plant, Lynchburg, Va. Engineering Alda, Manufacturing Engineering. Responsible for preparing documents for ordering contract materials, i.e. Purchased Materials Lists, Bills of Materials and Engineering Requirements. Initiate Route Cards and Contract Submittal Requirements. Assist in Echo 330 ultrasonic fuelInspection. Perform administrative duties during refueling outages.
1981 -1982 Babcock & Wilcox, Nuclear Power Division, Lynchburg, Va. - AA Tech Co op, Systems Engineering. Responsible for assisting organizotion in various engineering assignments and producing engineering schedules and work authorization reports.
i Page: 11 11 June 9,1997.
Revision: 10 l
l 1.
FRAMA TOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTM CHAPTER 11 - ORGANIZATION AND PERSONNEL NAMEt Gerald B. Lir.dsey TITLE!
Hsalth Physicist CITIZEN OF UNITED STA TES EDUCA TION! Virginia Polytechnic Institute and State University, Blacksburg, Va.
B.S. In Biology - 1975 CVCC Emergency Medical Technician - 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> (Coordinated through Blue Ridge Emergency Medical Service)
EXPERIENCE! 1994 - Present Framatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. Health Physicist and Training Instructor. Additional duties include training on radiation protection.
1986 - 19M Framatome Cogema Fuels, Lynchburg Mandicturing Facility, Lynchburg, Va. Health-Safety Foreman. Duties include standard review r
and implementation, safety training program, plant safety audits, procedure writing, accident investigations.
1985-1986 Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Va - Senior Health Safety Monitor.
1983 -1985 Babcock & Wilcox Company, Lynchburg Research Center, Lynchburg, Va. - H.P. Surveyor for the Building C Decommissioning Project.
1976-1983 Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Va - Quality Assurance Lab l
Technician and Health Safety Monitor.
1969 -1976 Lynchburg General Hospital Emergency Room, Lynchburg, Va, Duties include vital signs, emergency aid, patient care.
MEMBERSHIPS /CERTIFICA TIONS!
National Registry for Radiation Protection Technologists - 12/93 Paget 11 12 June 9,1997 Revision: 10
FRAMA TOME C:GEMA FUELS
- LYNCHBURG MANUFACTURIN3 FACILITY USNRC LICENSE SNM 1168, DOCKET 70 1201 PARTll CHAPTER 11 - ORGANIZA TION AND PERSONNEL NAMEt Darryl L. Gordon 1
TITLEt Sr. Health Physicist CITIZEN OF UNITED STA TES EDUCA TION University of Lowell, Lowell, MA B.S. In Radiological Sciences 1988 EXPER/ENCEt 1991 Present Framatome Cogema Fuels, Lynchburg Manufacturing Facility, Lynchburg, Va. - Sr. Health Physicist. Responsible for Coordination, Management and Technical Development of the Radiation Protection Program for fuel manufacturing and field operations refurbishment divisions. This responsibility includes radiological training, emergency response coordination, compliance with NRC, EPA, State, and Local regulations, procedure development, Bioassay, and ALARA Program.
1988-1991 Portsmouth Naval Shipyard, Portsmouth, NH -
Radiological Control Technician. Responsible for Radiation and Contamination control associated with the overhaul, maintenance, and refueling of Naval nuclear propulsion systems. Established guidelines for various Industrial tradesmen to reduce exposure, minimize radwaste, and prevont spread of contamination to uncontrolled areas, personnel, tools and equipment. Assisted in Processing and disposal of waste, man rem estimates, procedure development, environmental Impact monitoring, decommissioning, and l
radioactive material shipments.
1986-1987 Pennsylvania Power and Light Company, Allentown, Pa. - Health Physicist. As Cooperative Associate, performed various activities to assist the corporate Health Physics organization in support of an operational two unit BWR l
(Susquehanna SES) including resolution of.
Page: 11 13 June 9,1997 Revision: 10 1
FRAMATOME C@GEMA FUELS LYNCH 8URG MANUFACTURIND FACillTY i
USNRC LICENSE SNM 1168, DOCKET 701201 PARTH - CHAPTER I1 - ORGANIZA 710N AND PERSONNEL operational HP problems, ALARA review, LLRW storage facility safety analysis, primary sWem gamma spectroscopy, and man rem ostimates.
Also coordinated the activities of the company's by products materials license including source management and inventory, regulatory compliance, and instrument calibratlon services.
1985 Applied Health Physics, Inc., Holyoke, Ma. -
Health Physics Technician Performed cleanup operations of a large manufacturing facility following a fire involving Polonium 210.
Responsible for air, water, soll, and surface contamination surveys and removal of contaminated plant equipment. Packaged and shipped Radioactive LSA waste and interacted with regulatory officials (NRCIEPA) to monitor the total environmentalimpact of the fire.
MEMBERSHIPS /CERTIFICA TIONS:
Certified Radiological Control Technician -
(NAVSEA 389-0288 Art.108)
Page: 11 14 June 9,1997 Revision: 10
FRAMA TOME COGEMA FUELS o L YNCHBURG MANUFACTURIND FACillTY USNRC LICENSE SNM 1168, DOCKET 70,1201 PART11 CHAPTER 11 - ORGANIZA TION AND PERSONNEL j
NAME!
L. A. Hassler TITLE!
Senior Principal Engineer CITIZEN OF THE UNITED STATES EDUCA TION: University of Va., Charlottesville, Va.
Ph.D. In Nuclear Ergineering - 1973 -
St. Louis University, St. Louis, Mo.
B.S. In Phy s.~cs 1965 EXPER/ENCE! Frematome Cegema Fuels, Lynt.hburg, Va. - Senior Principal Engineer in the Fuel EngineerinJ Section with 24 years experience in the areas of radiation transt, ort, shleiding, and criticality safety.
In the area of criticality safet) he has been involved in the following tasks:
Attendirg ORNL KENOlV training course and KENOVa training Course.
Analysis of the disrupted core at TMl ll and analytical design of the TMl ll defueling canisters using KENOlV program.
On loan for three months the Navel Nuclear Fuel Division (NNFD) criticality safety e Jup. S
.-ted criticality safety analysis for storage at NNFD.
Provided criticality design analysis for the BR 100 spent fuel shipping container using KENOIV program.
Provided criticality analysis for the NNFD SX22 shipping container SARP license submittal.
Provided criticality analysis for the new fuel storage racks for Wisconsin Public Services Corporation and for the spent fuel storage racks for Toledo Edison Corporation.
Provided QA review for the licensing criticality calculations for two types of BWFC new fuel shipping containers.
Paget 11 15 June 9,1997 Revision: 10
_- _ _ - _~
FRAMATOME C00EMA FUELS LYNCHBURG MANUFACTURIN3 FACillTY USNRC LICENSE SNM 1168, DOCKET 70-1201 '
PARTll CHAPTER 11 ORGANIZATION AND PERSONNEL NAME!
P. L. Holman TITLEt Senior Principal Engineer CITIZEN OF THE UNITED STATES EDUCAT/0N! University of Va., Charlottesville, Va.
M.S. In Nuclear Engineering 1978 B.S. In Nuclear Engineering - 1975 EXPERIENCE Framatome Cogoma Fuels, Lynchburg, Va. - Senior Principal Engineer w!th 20 years experience in reactor physics, including the following areas:
Core Follow analysis, Standard Models Development, Fuel Cycle Division for Oconee Units I, ll, Ill, ANO 1 Unit 1, and Crystal River, 4
Licensing, Reload Licensing Analysis Task Engineer, Maneuvering analysis, and Crliicality calculations using Monte Carlo methodology.
Recent criticality work involved licensing the ANFIBWFC IWodel 51032 2 new fuel shipping container and also included separate criticality analyses for new and spent fuel storage racks for NUSCo and the Wisconsin Public Services Corporation. Preceding that l
work was the criticality analysis for the Toledo Edison new and spent fuel storage racks which involved an enrichment limit increase utilizing burnup credit. Additional criticality work involved i
l the analysis for the GPU TMl 2 defueling canisters and the DOE l
100 ton rall barge shipping cask.
(
TECHNICAL PAPERS AND PUBLICATIONS:
"TM! 2 Defueling Canisters Reactivity Analysis", ANS Transactions, 1986.
"Three Dimensional Analyses of a Highly Heterogeneous PWR l
l Using the NOODLE Code", ANS Transactions 1988.
PROFESSIONAL AFFillATIONS:
American Nuclear Society, Virginia Chapter ANS Paget 11-16 June 9,1997 Revision: 10 i
~~
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FRAMA TOME COGEMA FUFLS - L YNCH8URG MANUFACTURIN3 FA ClllTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTll - CHAPTER 11 - ORGANIZA TION AND PERSONNEL 11.4 OccInting Proceduras 1
Written procedures for the conduct of specific operations including maintenance and development of work within the plant are prepared by the functional component responsible for that activity. Health Safety activities are controlled by detailed operating procedures developed by Health Safety to assure standardization and accuracy. All written procedures are reviewed and approved by appropriate representatives of plant management. If SNM or other radioactive materials are involved in an activity, approval by the Manager, Safety and Licensing or his designee shall be required prior to implementation. Likewise all Health Safety procedures are approved by the Manager, Safety and Licensing as well as by affected members of plant management. Health Safety procedures are reviewed periodically and updated accordingly.
Applicable procedures are made available in the work area and adherence to procedure is required of all personnel.
11.5 Training All personnel receive basic training in radiological, Industrial, and nuclear safety upon being hired. This initial training is a cooperative effort involving Human Resources, Health Safety, and the employee's supervisor and is designed to satisfy the requirements of 10 CFR 19.12.
Particular emphasis is placed on the nature of the materials handled, ALARA plant safety program and rules,10 CFR 19 requirements, and the emergency evacuation system. Specific areas covered in the safnty training program are as follows:
11.5.1 Initial Emolovee Training Employees are referred to Health-Safety by the Human Resources Department for initial training in safety. The entire plant safety program is reviewed in some detail with particular emphasis being placed on specific areas depending on the employee's job assignment. A brief discussion of, and famillarization with, the i
general principles of health physics and nuclear safety is included.
The employee is informed of his rights and responsibilities under CFR 19, and OSHA.
Pa9e: 11 17 June 9,1997 Revision: 10
FRAMATOME COGEMA FUELS LYNCHBURG MANUFACTURING FACILITY USNRC LICENSE SNM-1168, DOCKET 70-1201 i
I PARTll - CHAPTER 11 - ORGANIZ/ TION AND PERSONNEL Following the initial Indoctrination depending on the employees work location, they shall receive additional safety training from their immediate supervisor regarding the nuclear and radiological safety requirements of their specific job assignment. Training sessions are documented and filed as part of the employee's Health Safety record.
11.5.2 Emnloves Retraining Continuing training of a general nature is provided as necessary by Health-Safety and supervision. This training may be formalized (i.e., " classes") or informal and conducted as part of routine Health Safety audits. Formalized retraining may be utilized to explain operational changes affecting safety, control of special problems such as increased alrborne activity, or changes in license specifications. The responsibility for determining the necessity for retraining or special training rests with Health-Safety based on plant conditionc or the request of supervision.
Radiation workers are all retrained annually as a routine part of the safety training program. The retraining sessions are documented and kept as part of the employee's Health Safety record, if workers have had similar radiation worker training, the initial training or retraining may be by passed by sucenssful completion of a written exam with a score of 75%.
11.5.3 Specialized Training 11.5.3.1 Resolratorv Protection Training and retraining in the use of respiratory protection devices is provided by Health-Safety as required. Points relating to proper use are covered as the unit is issued and fitted by Health-Safety. This approach provides continuing review of respiratory protection requirements. Should situations arise where frequent use of a respator is necessary, frequent Health-Safety surveillance will assure continued proper application.
Page: 11-18 June 9,1997 Revision: 10
FRAMATOME COGEMA FUELS LYNCH 8URO MANUFACTURING FACillTY
]
i USNRC lbCENSE SNM 1160 DOCKET 70-1201 PARTM
- CHAPTER 11 - ORGAbWZATION AND PERSONNEL 1
11.5.3.2 Emergenev Tamma Training Specialized training for special and emergency response units such as the Fire Brigade, Radiation Monitoring l
Team and First Aid personnelis coordinated by Health-l Safety. Fire Brigade training is conducted by i
representatives of_ Health Safety and/or local Fire 4
Departments and covers the use of fire fighting equipment and agents available at LMF. Radiation Monitoring Ti.m members receive periodic training from _
Health Safety S emergency response techniques, instrument un and maintenance, health physics and nuclear safety fundamentals, respiratory protection and '
contamination control. Annual evacuation drills are l
generally utilized as a training period for the emergency teams. First aid training is given by a quellfled instructor i
and is the standard Red Cross program or equivalent.
11.6 Changen in Proceduras. Facilitian. and Enulomant i
11.6.1 Procadoral Changen i
Procedural changes are initiated by the functional component responsible for that activity. Such procedural changes are reviewed and approved by plant management prior to implementation. If the activity involves SNM or other radioactive materials, the Manager, Safety and Licensing must approve the procedural change prior to implementation.
11.6.2 Facilitian and Enulomant Changes Ch'anges or modificatic,ns to facilities and equipment that have a potential impact on nuclear, radiological, industrial, or chemical safety must be reviewed and approved by the Safety Review Board t
and/or the Safety Review Board Chairman or quellfled designee prior to initiation. The Safety Review Board is described in detail in Chapter 2.0 of Part 1.
t 4
I Page: 11 19 -
. lune 9,1997 Revision: 10
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FRAMA TOME COGEMA FUELS - LYNCHBUR3 MANUFACTURING FAClllTY USNRC LICENSE SNM 1168, DOCKET 70-1201 PARTll - CHAPTER 11 - ORGANIZA TION AND PERSONNEL 11.6.2.1 initiating Changes The responsibility for initiating changes as described in 11.6.2 is usually given to the immediate operational supervisor or manager. The requested change is documented and submitted to the Safety Review Board Chairman for initial review.
11.6.2.2 Analvsis of Changes The Safth Review Board Chairman determines what safety evaluations are needed, if the proposed modification changes the basis on which the nuclear criticality safety was originally assessed, a technical cvaluation by the nuclear criticality safety group will be initiated. The orgenizational structure and minimum qualifications of the nuclear criticality safety group is as described in Chapter 4.0.
Radiation safety evaluations will be performed for new or revised operations to assure personnel protection is maintained. Chemical and industrial safety aspects of proposed modifications will also be evaluated for acceptability. These evaluations are documented and retained as described in 11.6.2.6.
11.6.2.3 Manaaement Review As a minimum, the Safety Review Board Chairman or his quallfled designee shall review all safety analyses performed for the plant modifications prior to implementation. The Safety Review Board Chairman will determine if Safety Review Board approvalis required.
11.6.2.4 Anoroval and Verification of Changes Approval and release of plant modifications for routine l
use is dependent upon satisfactory completion of a pre-operational evaluation. This evaluation is a final verification that the proposed change has been installed l
l consistent with the analyses performed under 11.6.2.2.
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FRAMA TOME COGEMA FUELS - LYNCHBURG MANUFACTURIN3 F AClllTY USNRC LICENSE SNM 1168, DOCKET 701201 PARTll - CHAPTER 11 - ORGANIZATION AND PERSONNEL This evaluation will consider nuclear, radiological, 8ndustrial, and chemical safety as well as license compliance. This evaluation is performed by Health.
Safety personnel and is approved by the Safety Review Board Chairman prior to implementation. Compliance of plant modifications is assured by our existing Health-Safoty controls and audit programs with regard to contamination control, personnel exposures, nuclear safety, chemical and industrial hazards.
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l 11.6.2.5 Records Ni All analyses, evaluations, pre-operational evaluations and other pertinent documentation relating to plant i
modifications will be maintained on file for at least six j
months after termination of the operation.
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