ML20205F158
| ML20205F158 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 03/18/1987 |
| From: | Sheeran R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 27975, NUDOCS 8703310101 | |
| Download: ML20205F158 (16) | |
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q MAR 191987 F-g U.S.NucttAR RICULATORY -
License SNM-1067 CCysa Docket 70-1100 j
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hisanen March 18, 1987
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IECE"/r0 U. S. Nuclear Regulatory Commission
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Washington, DC 20555 Attention:
Mr. W. T. Crowe. Acting Chief, Uranium Fuel License Branch Division of Fuel Cycle and Material Safety, NMSS
Subject:
Changes to SNM-1067
Reference:
Le tter from II. V. Lichtenberger, CE, to W. T. Crowe, NRC, dated k
February 18, 1987
Dear Mr. Crowe:
During a telephone conversation on March 10, 1987 N. Ketzlack of your organization and I discussed the subject License changes attached to the ref erenced letter.
It was agreed during the conversation that certain additional changes would be made.
Accordingly, a new submittal, containing the agreed upon changes is attached for your review and approval.
Picase note that only certain pages in the referenced submittal were changed and these have been indicated by an asterisk on Appendix I.
Very truly yours, k
9 R. E. Sheeran Manager, Nucicar License, Safety, 00C5Lil0 Accountability, and Security UBK RES/laf 9
MAN 19 Attachment
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PDR ADOCK 07001100 C
PDR t2'79'7s Combust on Eng neenng Inc 1000 Prospect HlIl Road (203) 688 1511 Post Office Box 500 Tetex 9 9297 Windsor. Connecticut 06095
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ThJ Senior VicaiPrCCidant, Nuclocr Pow:r Systems in rc ponsible for all activities carrieE out in both Nuclear Fuel Manufacturing and C
Product Develpppent.
He has delegated the responsibility for all O
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activities carried out under License SNM-1067 to the Vice President, Nuclear Fuel.
0 2.2.1 Product Development c
The Director of Product Development is responsible through 0,'
the Vice President, Nuclear Fuel for the accountability, o
nuclear criticality safety, and radiological safety related s }. O toallShecialNuclearandSourceMaterialsreceived o
and used in product development.
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9, He as5dres compliance with federal.and state regulations and o
the requirements and limitations set forth in the license.
In thisoposition, the Director of Product Development o
assures that all operations involving nuclear materials have been analyted to establish the required safety limits and controls.
The Manager of Nuclear Licensing, Safety, Accountability, o
and Security is responsible for the surveillance of all activities in wl.ich radioactivity is involved to ensure that I
.the health and safety standards set forth in the license n.
application are met.
He has the necessary authority to halt any operation which falls
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.i License Wo. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.2-2
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~I to ascerta nlthe effectiveness of the training.
7; 5
t t-Operating Proce'dures i
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2.7 s
2.7.1
' Product Development
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Product Development, because of the nature of the work to' be performed, does not utilize standard. operating procedures.
The use of. Radiation Work Permits (RWP's) for-all work with x
radioactive materials assures that appropriate safety procedures are followed.
Written health and safety restrictions for all operations on i
radioactivematerialsshallbeprovidedinthefor)of approved Undiation Work Permits or approved detailed y
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procedures, and appropriate operational limits are posted in the vicinity of work stations.
The manager NLSA&S or the
~ supervisor, Health Physics & Safety will approve RWP's-based S
on the personnel doses which are involved with the work to be performed.
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All RWP's shall be reviewed weekly by an individual having l-the minimum qualifications of The Supervisor-Health Physics
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and Safety.. Product Development has simple slab or mass limited areas.
The mass limited areas shall be separated by a minimum of 12 feet, making criticality safety an easily managed program.
Changes in criticality areas by Product Development personnel shall be formally described and submitted to the Manager, Nuclear Licensing, Safety, g Accountability & Security in writing for review and approval.
He also determines whether the proposed changes in L
these areas can be approved License No. SNM-1067, Docket 70-1100, Rev.3 Date: 10/22/86 Page:I.2-15 b
e 8
criticality safety which fall within the criteria of Section 4.2 provided that an independent review is performed by'the Nuclear Safety Committee or persons designated by that Committee.
The Manager NLSA&S, Nuclear Criticality Specialist or, the Supervisor Health Physics & Safety determine whether a change can be made within the' framework of the license or whether an NRC amendment is required for the proposed change.
2.8 Audits All' audits shall be performed in accordance with a written plan.
2.8.1 Product Development
- Operations in Product Development will be formally audited as follows:
Once each working day by-a Health Physics Technician for Health Physics Compliance and Criticality Compliance.
He shall submit his findings in writing to the Manager NLSA&S Operations will be audited on a monthly basis by an individual, who meets the minimum qualifications of the Manager NLSA&S or the Supervisor of Health Physics and Safety.
He will verify the adequacy of the Radiation Protection Program and that all designated limits and controls are being followed.
License No. SNM-1067, Docket 70-1100, Rev.6 Date: 10/22/86 Page:I.2-18
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. 0 He will review records of radiation exposure, contamination levels and airborne concentrations for trends and abnormalities.
His review will determine whether the appropriate corrective actions have been implemented to assure all exposures are maintained as low as reasonably achievable (ALARA).
The findings of the monthly audits shall be documented and copies submitted to operational supervision, to the Vice President - Nuclear Fuel and to the Senior Vice President -
Nuclear Power Systems.
The reports shall include items for correction, if necessary, and the action taken on items from previous audits.
Once each year by the Nuclear Safety Committee-The committee will review all aspects of the criticality and Radiological Safety Programs and will transmit their report in writing to the Vice President - Nuclear Fuel with copies to the Senior Vice President, Nuclear Power Systems and Operational Supervision.
2.8.2 Nuclear Fuel Manufacturing Operations - Operations at the Nuclear Fuel Manufacturing facility will be formally audited as follows:
Once each working day by a Health Physics Technician for Health Physics compliance and criticality compliance.
He shall submit his findings in writ.ing to the Supervisor Health Physics and Safety.
Once each month for ra'diological safety by an individual who meets the minimum qualifications of a Radiation License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page: I.2-19
2.9-Investigations and Reporting of Off-Normal Occurrences Any unusual events that could lead to radiation health and safety 0
problems shall be reported to the Plant Manager, Fuel Fabrication, or to the Director, Product Development as appropriate.
The NRC shall be-notified'of such occurrences including any event that would significantly decrease the effectiveness of the Radiation or Nuclear Criticality Safety Program.
It is the intent of combustion Engineering, Inc. to be in compliance with the reporting requirements of 10 CFR Part 21 for reporting of defects and noncompliance and 10 CFR 73.71 for events that significantly threaten or lessen the effectiveness of safeguards or for events that significantly threaten or lessen the effectiveness of Nuclear Criticality or Radiological Safety.
2.10 Records Records relating to health and safety shall be retained indefinitely.
Such records shall include plant alterations or additions, abnormal, and off-normal occurrences and events associated with radioactivity releases, criticality analyses, audits and inspections, instrument
- calibration, ALARA findings, employee training and retraining, personnel exposures, routine radiation surveys, and environmental surveys.
License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.2-21 m
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I FIGURE 2.2.1 NUCLEAR POWER SYSTEMS i
DIVISION SENIOR VICE PESIDENT NUCLEAR SAFETY CubMITTEE I
NUCLEAR FUEL 04AIRPERSON QUALITY CONTROL VICE PRESIDENT i
MANAGER l
QUALITY ASSURANCE ENGINEERING I
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i NUCLEAR FUEL FUEL ENGIEERING PRODUCT DEVELO9ENT MKl LEAR FEL NUCLEAR MANUFACTURING PIEEUCTS CRITICALITY l
PLANT MANAGER DIECTOR DIRECTOR DIECTOR SPECIALIST i
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l MANUFACTURING PRODUCTION NUCLEAR LIGNSING l
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ENGIEERING
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SAFETY,ACCOUNTABILIT1 I
AND SECURITY l
MANAGER MANAGER MANAGER 1
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1 A000LMTABILITY HEALTH PHYSICS AND SAFETY SPECIALIST SUPERVISOR t
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i License No. SNM-1067 Docket 70-1100 Rev. 1 Date:
10/22/86 Page: I.2-24 2
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'f 93.0- Radiation Protection.
- 3i 1_ Administrative Requirements.
-3.1.1:
' Radiation:WorkJPermit-Procedures AN ProductfDevelopment-
- All' work with radioactive materials in the Prod 6ct Development will require
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- a. radiation work permit'.(RWP).
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The Health Physics technician shall. establish.
- radiological requirements and' set individual exposure-limits-whichlshall be approved in writing by the supervisor'of Health Physics and Safety,or:the Manager'NLSA&S.
Nuclear Fuel Manufacturing
.All non-routine maintenance or repair. operations on. equipment in contaminated areas must be covered by a Radiation-Work-Permit.(RWP), including those non-routine maintenance-operations in which the ventilated containment is compromised.
The RWP shall be requested by the cognizant supervisor or engineer.
The RWP will be issued by the Nuclear Licensing, Safety, Accountability, & Security (NLSA&S) group.
It will include all safety requirements, protective clothing and equipment, and health physics monitoring requirements necessary to-assure that the proposed operation is conducted in a safe manner.
RWP's shall be reviewed for their need every 30 days as.a minimum.
A member of the NLSA&S group must also close out on RWP's to assure that License No. SNM-1067, Docket 70-1100, Rev. 5 Date: 10/32/84.Page:I.3-1
The monthly audit of Product Development includes a review of the radiation safety program to assure th'e
-ALARA concept is being followed.
Nuclear-Products Manufacturing - assures that the ALARA concept is. met-by the following:
Trends in personnel exposures, radiation levels, airborne activity levels, surface contamination, effluent releases, and bioassay results are reviewed during the monthly radiological safety audit.
The person performing this audit is responsible for determining any required action necessary to assure adherence to the ALARA concept.
The Plant Manager is
. responsible to assure that these recommendations are implemented.
The Nuclear Safety Committee is responsible for a comprehensive review of the radiologipal safety program on an annual basis.
This includes a review of all changes implemented by management to achieve ALARA.
The Committee is responsible for recommending any additional changes which are necessary to assure continued adherence to the ALARA concept in all areas of the radiological safety program.
3.2 Technical Requirements 3.2.1 Access Controls All personnel entering the unclad fuel handling contaminated areas must do so through the change areas provided for this purpose.
Protective clothing shall be worn as follows:
~ License No. SNM-1067, Docket 70-1100, Rev. 4 Date: 10/22/86 Page:I.3-3
. g.,
Committee.
He shall meet the minimum qualifications for a Nuclear Criticality Specialist and shall not be the initial 1 reviewer.
As stated'in section'4.1.3, all such approvals shall be recorded in a. log maintained under the supervision of the.
Supervisor, Health Physics & Safety..
' 4.1.' 6 Marking'and Labeling of SNM - All~ mass-limited. containers shall be-labeled as to enrichment and content.
All geometry
. limited containers and processes are safe up to the maximum 235 allowable' enrichment of 4.1% U An exception to this would-be the 11" dia. x 40" lg., cylindrical hopper which is' limited 235 to 3.5.wt.% U 4.1.'7 Audits
-4.1.7.1 Product Development
. Nuclear criticality safety for all Product Development operations shall be limited to quantities smaller than a minimum critical mass with the exception of one slab: limited storage area
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in~Both Buildings 2 and 5.
Each such mass limited area shall be isolated from all other fissile-material by at least 12 feet.
Criticality control by any other means.(volume, geometry, etc.)
shall not be permitted.
Thus, the nuclear i
a criticality safety program in Produc't Development consists of simple mass or slab limit.
The E
monthly radiological safety audit of Product Development operations required by section 2.8 shall l
include verifications to assure that all nuclear i
safety limits are being i-adhered to.
An annual audit of License No. SNM-1067, Docket 70-1100 Rev.5 Date: 10/22/86 Page: I.4-3
7 shall be separated from any other fissile material by 12 feet.
Rods containing sintered UO2 pellets enriched to a-maximum of C-4.1% U235 shall be stored in Buildings #2 or #5.
Slab storage.
in Buildings'#2 or #5 shall be limited to maximum height of C
'o 3.7".
O A continuous log shall be maintained for each mass limited work station or storage area in Product Development to assure that the limit is maintained and that the enrichment of all material is recorded.
No additional criticality controls are l
required for Product-Development.
Criticality safety of the.less complex manufacturing operations is based on the use of limiting parameters which are applied to simple geometries.
Safe Individual Units (SIU) shall be selected from Table 4.2.5.
These units shall be spaced.using the surface density method.
The remaining manufacturing operations are evaluated using two dimensional transport and/or 3 dimensional Monte Carlo Codes.
The sixteen group Hansen-Roach cross section library.is used for homogeneous systems while the CEPAK Code is used to generate multigroup cross sections for heterogeneous systems.
All calculational methods involving computer codes shall be validated -in accordance with the criteria established in Regulatory Guide 3.4,
" Nuclear Criticality Safety in Operations with Fissionable Materials at Fuels and Materials Facilities."
License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: I.4-5
FIGUltE 3.1.1 NUCLEAR POWER SYSTEMS DIVISION S. T. BREWER SENIOR VIE PE SIDENT-NUCLEAR SAFETY COMITTEE F. BEVILAQUA
~ ~
NUCLEAR FUEL 04AIRPERSON H. V. LICHTENBERGER QUALITY m j
VICE PRESIDENT P. FERWERDA
=
MANAGER QUALI1Y ASSURANCE i
ENGINEERING l
M. GLOTZER N
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I NUCLEAR FUEL FUEL ENGIEERING PRODJCT DEVELORIENT NUCLEAR FE L NUCLEAR MANUFACTURING PRODUCTS CRITICALITY J. PARRETTE R. DUNCAN C. COPPERSMITH R. KLOTZ PLANT MANAGER DIRECTOR DIRECTOR DIECTOR j
SPECIALIST I
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MANUFACTURING PRODUCTION NUCLEAR LICENSING, J
ENGIEERING SAFETY, ACCOUNTABILITi
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P. HUBERT G. KERSTEEN AND SECURITY R. E. SHEERAN j
MANAGER MANAGER MANAGER l
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I ACW UNTABILITY HEALTH PHYSICS AND SAFETY,
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K. BUTENAS J. Vollaro SPECIALIST SUPERVISOR 1
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1 LICENSE NO. SNM-1067 Docket 70-1100 Rev. I Date: 10/22/86 Page:
IL.3-3A
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ROBERT NORMAN DUNCAN BL. S. Metallurgy,~ Massachusetts Institute of Technology, 1955.
Additional Study, Stanford University, Graduate Materials Science
' Courses,. 1964-1968.
Registered Professional Engineer (California) #MT-1047.
' PROFESSIONAL' EXPERIENCE Director,- Fuel Development: Department, Combustion Engineering, Inc. (1974'--
1985), Director, Product-Development, Combustion Engineering, Inc. (1985 to Present).
Responsible for the direction of core materials development for the Nuclear Power Department.. Current responsibility. includes direction of major C-E programs to--develop ~and test. fuel, cladding and control materials.
Functional responsibility includes Materials _ Technology, Fuel Performance
-Testing.and Analysis and Analytical Chemistry.
Responsible for development programs to improve C-E fuel performance by
. planning and' executing-major PED experimental programs in this area.
In addition,. responsible for evaluation _and monitoring of fuel performance in C-E supplied-plants, as required by specific projects.
Responsible for 1
technical integration of these development activities with KWU.
Responsible for negotiating and following. several joint R & D efforts in
-core materials area.
- Manager,-Core Materials, December 1972 to July 1974 Responsible;for the line management of the Core Materials Development organization.
Responsible for the planning and execution of PED projects
-related to fuel testing, examination and performance analysis.
Initiated
'several major fuel irradiation test programs in both test and power 1 reactors.
Responsible for project field support, on-site fuel examinations and plant licensing activities related to fuel performance.
Responsible
-for~the integration of fuel performance related R & D with the appropriate
- KWU programs.
Functional groups reorganized such that fuel and cladding development activities were within one organization.
Staff Assignment Reporting to Director, Nuclear Laboratories May 1972 to December 1972
- In_a' staff _ function, reviewed C-E positions on licensing, prepared and
- reviewed PED programs, participated in early KWU/C-E information exchanges onsfuel performance and planned integrated C-E/KWU irradiation test programs.
Represented C-E in discussions with NRC on the impact of fuel densification.
Planned and initiated an experimental irradiation test
_ program on fuel densification and negotiated agreements for joint programs in~ this area with EEI and others.
Evaluated the impact of C-E participation in the Halden Reactor Project and assisted in the negotiations of the agreements.
License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-13
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