ML20207P162

From kanterella
Jump to navigation Jump to search
Application for Amend to License SNM-1067.Amend Revises App I Pages to Reflect Transfer of Responsibilities from Nuclear Labs to Nuclear Fuel Organization.Fee Sent Under Separate Cover Per 10CFR170.31
ML20207P162
Person / Time
Site: 07001100
Issue date: 11/06/1986
From: Lichtenberger
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To: Crow W
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20207P163 List:
References
27610, NUDOCS 8701150124
Download: ML20207P162 (81)


Text

e-76-/M6 RETURN TO 396-SS License SNM-1067 Docket 70-1100 c-SP November 6, 1986 8

Y, RECEIVED 9.

g NOV171986 %

2 U. S. Nuclear Regulatory Commission

/{UELEAR REGULATO U.

{

Washington, DC 20555 cgott Attention:

Mr. W. T. Crowe, Acting Chief 9

9 g

Uranium Fuel License Branch 4

W Division of Fuel Cycle and Material Safety, NMSS

.,9

Subject:

SNM-1067

Dear Mr. Crowe:

Certain responsibilities for the nuclear laboratories have been transferred to the nuclear fuel organization. Accordingly, the license pages shown in Appendix 1, copy attached, have been changed and the revised pages are hereby submitted for your review and approval.

Please note that the amendment request is considered to be an administrative typechange and the license fee, as required by 10 CFR 170.31, has been sent directly to the License Ac Manage-ment Branch under separate cover.

Very truly yours, Y

clL uibAU~

4' H. V. Lichtenberger

(

DOCg Vice President, Nuclear Fuel Usung

\\\\

t Nov13198g pg2 HVL:avk W ss 8DW Attachment Applicant........./..........

k 2

< \\ occq7 s

Check ilo.. O.$.2 4 T) c of ce t.

Date Checn Lcdd. /4/.[.b.h..

nececm.... %.......

Power Systems 1000 Prospect Hill Road (203) 688-1911 Combustion Engineering, Inc.

Post Office Box 500 Telex: 99297 8701150124 861106 Windsor Connecticut 06095-0500

{DR ADOCK 0700 0

J

e

(

^

co m at vo.

2 Al-rt m or w o.

LL.M R ausnaa.7 _ u i l 8 6 rcuF

[

eea FCAF LPD3 I & E EEF. __

sums _/

fcIC.

GI G DATE //[3Yb ot bN -

l'

r October 22, 1986 Licann SNM-1067 Docket 70-1100 APPENDIX I__

DELETED PAGES ADDED PAGES PAGE NO.

REV.

DATE PAGE NO.

REV.

DATE I.1-1 3

9/16/83 1.1-1 4

10/22/86 I.1-2 4

11/30/84 1.1-2 5

10/22/86 1.1-3 3

11/30/84 I.1-3 4

10/22/86 I.1-4 2

4/06/82 I.1-4 3

10/22/86 I.2-1 2

4/06/82 I.2-1 3

10/22/86 I.2-2 2

4/06/82 I.2-2 3

10/22/86 I.2-3 4

6/15/84 I.2-3 5

10/22/86 I.2-4 4

6/15/84 I.2-4 5

10/22/86 I.2-5 2

4/06/82 I.2-5 3

10/22/86 I.2-6 4

6/15/84 I.2-6 5

10/22/86 1.2-7 4

6/15/84 I.2-7 5

10/22/86 I.2-8 4

6/15/84 I.2-8 5

10/22/86 I.2-9 3

9/16/83 I.2-9 4

10/22/86 I.2-10 3

9/16/83 I.2-10 4

10/22/86 I.2-11 2

4/06/82 I.2-11 3

10/22/86 I.2-12 4

6/15/84 I.2-12 5

10/22/86 I.2-13 2

4/06/83 I.2-13 3

10/22/86 I.2-14 4

10/05/83 I.2-14 5

10/22/86 I.2-15 2

4/06/82 I.2-15 3

10/22/86 I.2-16 4

6/15/84 I.2-16 5

10/22/86 I.2-18 5

6/15/84 I.2-18 6

10/22/86 I.2-19 4

9/20/85 I.2-19 5

10/22/86 I.2-20 3

9/20/85 I.2-20 4

10/22/86 I.2-21 2

4/06/82 I.2-21 3

10/22/86 I.2-22 2

4/06/82 I.2-22 3

10/22/86 I.2-23 4

6/15/84 I.2-23 5

10/22/86 I.2-24 1

10/22/86 I.3-1 4

6/15/84 I.3-1 5

10/22/86 I.3-2 5

6/15/84 I.3-2 6

10/22/86 I.3-3 3

4/05/84 I.3-3 4

10/22/86 I.3-4 2

4/06/82 I.3-4 3

10/22/86 I.3-5 3

5/16/85 1.3-5 4

10/22/86 1.3-6 2

4/06/82 I.3-6 3

10/22/86 1.3-7 3

9/16/83 I.3-7 4

10/22/86 I.3-8 2

4/06/82 I.3-8 3

10/22/86 I.3-9 4

10/05/83 I.3-9 5

10/22/86 I.3-12 3

9/16/83 I.3-12 4

10/22/86 I.3-14 2

4/06/82 I.3-14 3

10/22/86 I.4-3 4

4/05/84 I.4-3 5

10/22/86 I.4-4 3

4/05/84 I.4-4 4

10/22/86 I.4-5 2

4/06/82 I.4-5 3

10/22/86 I.4-11 2

4/06/82 1.4-11 3

10/22/86 I.4-12 2

4/06/82 I.4-12 3

10/22/86 I.4-18 2

4/06/82 I.4-19 3

10/22/86 I.6-1 2

4/06/82 1.6-1 3

10/22/86

Octcber 22, 1986 License SNM-1067 Docket 70-1100 APPENDIX I DELETED PAGES ADDED PAGES PAGE NO.

REV.

DATE PAGE NO.

REV.

DATE II.1-1 3

9/16/83 II.1-1 4

10/22/86 11.1-3 2

4/06/82 II.1-3 3

10/22/86 II.1-4 2

4/06/82 II.1-4 3

10/22/86 11.1-5 2

4/06/82 11.1-5 3

10/22/86 II.1-6 2

4/06/82 11.1-6 3

10/22/86 II.1-7 2

4/06/82 II.1-7 3

10/22/86 II.1-10 2

4/06/82 II.1-10 3

10/22/86 11.1-12 2

4/06/82 II.1-12 3

10/22/86 II.2-2 2

4/06/82 II.2-2 3

10/22/86 II.3-1 2

4/06/82 II.3-1 3

10/22/86-II.3-2 2

4/06/82 II.3-2 3

10/22/86 11.3-3 4

6/15/84 II.3-3 5

10/22/86 II.3-3A 1

10/22/86 11.3-6 2

4/06/82 II.3-6 3

10/22/86 II.3-7 2

4/06/82 II.3-7 3

10/22/86 II.3-8 2

4/06/82 II.3-8 3

10/22/86 II.3-9 2

4/06/82 II.3-9 3

10/22/86 II.3-10 2

4/06/82 II.3-10 3

10/22/86 II.3-11 2

4/06/82 I1.3-11 3

10/22/86 II.3-12 2

4/06/82 11.3-12_

3 10/22/86 II.3-15c 3

1/21/85 II.3-15C 4

10/22/86 II.3-15D 3

1/21/85 II.3-15D 4

10/22/86 II.3-16 2

4/06/82 II.3-16 3

10/22/86 II.3-17 2

4/06/82 II.3-17 3

10/22/86 II.3-18 2

4/06/82 II.3-18 3

10/22/86 II.3-19 2

4/06/82 II.3-19 3

10/22/86 II.3-20 2

4/06/82 II.3-20 3

10/22/86 II.3-28 2

4/06/82 II.3-28 3

10/22/86 II.3-29 2

4/06/82 II.3-29 3

10/22/86 II.3-30 2

4/06/82 II.3-30 3

10/22/86 II.3-31 2

4/06/82 11.3-31 3

10/22/86 II.3-34 2

4/06/82 II.3-34 3

10/22/86

o PART I. LICENSE CONDITIONS 1.0 Standard conditions and Special Authorizations 1.1 Name Combustion Engineering, Inc., is incorporated in the State of Delaware with its corporate offices at 900 Long Ridge Road in Stamford, CT.

The location where licensed activities will be conducted is at 1000 Prospect Hill Road in Windsor, CT.

1.2 Location The mailing address for all license correspondence is:

Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, CT 06095 Licensed activities shall be conducted primarily at the Nuclear Fuel Manufacturing facility (Building #17) and an adjacent warehouse and shipping dock (Building #21).

Additional activities shall be conducted in Buildings 1, 1A, 2, 2A, 5, 6, 16, and 18.

License No. SNM-1067, Docket 70-1100 Rev. 4 Date:

10/22/86 Page: I.1-1

1.3 License Number Activities are covered by the License SNM-1067; Docket 70-1100.

1.4 Possession Limits & Location Combustion Engineering, Inc., requests authorization to receive, use, possess, store and transfer at its Windsor site, the following quantities of radioactive materials.

Isotope Form Quantity Location 1.) Uranium enriched Uranium 500,000 Kg U Manufacturing-Bldgs.

to<4.1%yggght Oxides

  1. 17 & #21 & storage in percent U trailers adjacent to Bldgs. #17 & #21. Bldg:

1, 1 A, 2, 2A, 5, 6, 16 and 18.

235

  • 2.) Uranium enriched Any 4800 gms U Bldg.

1, 1A, 2, 2A, 5, to less than 20 6, 16, 17, 18 & 21

-wgjghtpercent (Bldg. 17 & 21 235 U

limited to 350 gm U each for enrichments exceeding 2$5). weight 1

percent U

  • 3.) Natural and/or Any 10,000 KgU Bldg. 1, 1A, 2, 2A, 5, Depleted Uranium 6, 16, 17, 18, & 21.

238 4.) Pu Encapsul-5 sources, each Building #17 ated containing les338 Neutron than 2.0 gm Pu Sources 5.) Pu Any Form 160 micrograms Bldg. 1, 1A, 2, 2A, as analytical 5, 6, 16, 17, 18 samples

& 21 6.) Encapsulated U0 20 sources, each Bldg.

1, lA, 2, 2A, 38 Neutron Sources c,ontainig35 1.7 gm U

& 21 235 7.) Uranium enriched Residue 1000 gms U Windsor Site to or greater than 2g3geightpercent U

License No. SNM-1067, Docket 70-1100 Rev. 5 Date: 10/22/86 Page: I.1-2

1.5 Definition, Any d finitions which cro not d fin d in standard referencos (e.g.,

ANSI-N-1.1-1976, "American Standard Glossary of Terms in Nuclear Science and Technology" or Title 10 of the Code of Federal Regulations) or that are unique to activities described in this license applications shall be defined where first used in the application.

1.6 Authorized Activities The primary activities carried out in buildings at the Windsor site include, but are not limited to the following:

Bldg. #1 & 1A -

Storage and use of small quantities of Radioactive Material (<350 Gms U235)

Bldg. #2 & 2A -

Product Development Activities.

Bldg. 5 - Product Development Activities.

Bldg. 6 - Waste water processing from manufacturing and product development activities.

Bldg. 16 -Same as Building #5.

Bldg. 17 -Manufacture of fuel assemblies utilizing low enriched uranium (up to 4.1 weight percent U235) in the form of uranium oxide powder, pellets, rods, and in assemblies.

Bldg. 18 -Product Development Activiles Bldg. 21 -Storage of SNM in shipping containers.

Windsor Site - Residue from prior operations, not to exceed 350 gms 235 U

in any one location.

Additional locations to be separated from one another by a minimum of 12 feet.

1.7 Exemptions and Special Authorizations Licensed activities in Bldgs. 1, lA, 2, 2A, 5,

6, 16 and 18 shall License No. SNM-1067, Docket 70-1100 Rev. 4 Date: 10/22/86 Page: I.1-3

obe of a product development nature and the materini may ultimately be returned to the Nuclear Fuel Manufacturing facility.

These transfers shall not require the issuance of applicable NRC transfer documents, but shall be transferred in accordance with the provisions of this license, and shall be L

hcndled as a departmental transfer and shall be controlled by the Fundamental Nuclear Material Control Plan (FNMC) referenced in Section 9.0 ohthisapplication.

i i

t I

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.1-4

2.0 GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 2.1 Licensee's Policy Combustion Engineering's long standing commitment to safety of the work place is evidenced by corporate management's continued emphasis and support of all aspects of Health and Safety throughout the corporation.

An integral part of the overall corporate Health and Safety program specifically in the Nuclear Power Systems Division, is management's commitment to keep radiation exposures to employees and the general public as low as reasonably achievable (ALARA).

(See Section 3.1.2 for detail).

It is management's intent to be in compliance at all times with all applicable federal and state regulations and the license requirements stated herein.

2.2 Administrative Responsibilities and Controls The lines of authority for the control of Special Nuclear Material in the possession of the Nuclear Power Systems Division follow the same paths of authority as all other operations'with several modifications dictated by the problems associated with handling Special Nuclear and Source Material.

Operations covered by this license are: Buildings 17/21, nuclear fuel manufacturing (NFM-W) which is a low enrichment UO2 fuel fabrication operation where powder is pelletized, pellets are loaded into rods which are then assembled into fuel bundles, and buildings 1, 1A, 2, 2A, 5, 6, 16, & 18 where product development activities are carried out.

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.2-1

The Senior Vice President, Nuclear Power Systems is responsible for all activities carried out in both Nuclear Fuel Manufacturing and Product Development.

He has delegated the responsibility for all activities carried out under License SNM-1067 to the Vice President, Nuclear Fuel.

2.1.1 Product Development The Director of Product Development is responsible through the Vice President, Nuclear Fuel for the accountability, nuclear criticality safety, and radiological safety related to all Special Nuclear and Source Materials received and used in product development.

He assures compliance with federal and state regulations and the requirements and limitations set forth in the license.

In this position, the Director of Product Development assures that all operations involving nuclear materials have been analyzed to establish the required safety limits and controls.

In addition to providing the above safety restrictions the Director of Product Development is responsible for the surveillance of all activities in which radioactivity is involved to ensure that the health and safety standards set forth in the license application are met.

He has the necessary authority to halt any operation which falls License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.2-2

outsids those limits, and ha in re=ponsible for indicating what remedial action is necessary to bring the operation within acceptable limits.

The basic organization structure o

is shown in Figure 2.2.1.

2.2.2 Nuclear Fuel Manufacturing The Plant Manager reports to the Vice President, Nuclear Fuel and is responsible for the accountability, nuclear criticality safety and radiological safety related to all Special Nuclear and Source material received by Nuclear Fuel Manufacturing and used in any manufacturing process.

He assures compliance with federal and state regulations and the requirements and limitations set forth in the license during all phases of manufacturing.

In this position, the Plant Manager has delegated to the Production Manager and the Engineering Manager responsibility to assure that all operations involving nuclear materials have been analyzed to establish the required safety limits and controls. The Manager, NLSA&S or Nuclear Criticality Specialist shall assist the Engineering Manager and Production Manager by actually performing the analysis required and establishing the appropriate controls.

In addition, the Supervisor, Health Physics and Safety shall assure that the required safety limits and controls are being followed by the use of License No. SNM-1067, Docket 70-1100, Rev. 5 Date: 10/22/86 Page:I.2-3

daily internal audits.

The. Health Physics and Safety Supervisor is responsible for the surveillance of all Nuclear Fuel Manufacturing activities in which radioactivity is involved to ensure that the health and safety, as well as criticality standards set forth in the license, are met.

He has the necessary authority to halt any operation which falls outside those limits, and is responsible for indicating what remedial action is necessary to bring the operation within acceptable limits.

However, if the operation is halted because of criticality safety considerations, the Health Physics & Safety Supervisor will contact the Manager, NLSA&S, the Nuclear Criticality Specialist, or the Nuclear Safety Committee who shall determine necessary corrective actions to be taken.

The basic organizational structure for Nuclear Fuel Manufacturing is shown in Figure 2.2.1.

2.2.3 Independence of Safety Personnel The Director of Product Development reports to the Vice President Nuclear Fuel.

The Manager, Nuclear Licensing, Safety, Accountability, and Security, the Nuclear Criticality Specialist, the Engineering Manager, and the Production Manager all report to the Plant Manager, Nuclear Fuel Manufacturing.

The Production Manager will enforce all safety related rules and procedures; He will interact as necessary to ensure uniform compliance.

License No. SNM-1067, Docket 70-1100, Rev. 5 Date: 10/22/86 Page:I.2-4

Conflicte of interest cro thua minimized cnd indep ndance of safety personnel is assured.

2.3 Nuclear Safety Committ,ee A Nuclear Safety Committee comprised of engineers and scientists, representing all areas of the Nuclear Power Systems Division nuclear and scientific community, has been organized and assigned as one of its responsibilities the function of providing assurance to management that nuclear manufacturing operations are carried out in a safe manner.

The Committee acts in a staff capacity reporting to the Senior Vice O

President, Nuclear Power Systems.

The functions of the Committee are to:

Assure an independent review and approval of all Nuclear Criticality Safety aspects of process and equipment changes not covered by Tables 4.2.5 and 4.2.6 related to nuclear safety.

A qualified person designated by the Chairman of the Committee performs the independent criticality safety reviews.

The independent reviewer shall meet the minimum qualifications of a nuclear criticality specialist.

The two years' experience in outside-of-reactor nuclear criticality safety shall be with methods relevant to the nuclear safety analysis of the operation under review.

Audit all manufacturing operations involving SNM annually, with no more than 13 months between audits.

This audit must include as a minimum, a review of the nuclear criticality and radiological safety programs and their application and to assure that management policies are consistent with the License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.2-5

objectiva of maintaining occupational rcdiation exposures os low cs reasonably achieveable.

The Committee member who reviews the criticality safety program shall be a person other than the one who is authorized to perform the monthly criticality safety audit.

The audit reports shall be sent to the Vice President, Nuclear Fuel with copies to the Senior Vice President Nuclear Power Systems and operational supervision.

Reviews and approves applications for SNM license renewals and amendments affecting nuclear criticality safety prior to submittal to NRC.

2.4 Personnel Selection (Approval Authority) for Key Positions 2.4.1 Product Development - The Director of Product Development has approval authority for the following key positions:

Manager-Core Materials Development, Manager-New Product Development, and Health Physics Technician.

e o

2.4.2 Nuclear Fuel Manufacturing - The Plant Manager, Nuclear Fuel Manufacturing has approval authority for the following key positions:

Engineering Manager, Production Manager, Production Superintendent, Manager-Nuclear Licensing, Safety, Accountability, & Security, Nuclear Criticality Specialist, and Health Physics & Safety License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page:I.2-6

Supervicor, c

2.4.3 Nuclear Safety Committee - The Senior Vice President, Nuclear Power Systems has the approval authority for members of this committee.

2.5 Education and Experience Requirements for All Key Safety and Operations Personnel o

a 2.5.1 Plant Manager, Nuclear Fuel Manufacturing - The qualifications for this position shall be a Bachelors Degree in one of the sciences or engineering and five years experience in nuclear fuel fabrication facilities.

In addition, at.least three years supervisory experience is a

required as well as an understanding of nuclear criticality safety, health physics, and industrial safety aspects of fuel handling and knowledge of' administrative controls imposed on nuclear fuel handling operations.

2.5.2 Manager-Nuclear Licensing, Safety, Accountability, & Security (NLSA&S)

The minimum qualification for this position shall be a l

Bachelors Degree in one of the sciences or engineering and a L

minimum of three years experience in positions which demonstrate sufficient judgement and analytical capability License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page:I.2-7

to estcblieh and maintain technically cound end offectivo health physics, industrial safety, nuclear material accountability and security programs; and to establish and maintain an effective nuclear criticality and radiation program.

2.5.3 Supervisor-Health Physics and Safety - The minimum qualifications for this position shall be a Bachelors Degree in one of the sciences, engineering, or equivalent.

A minimum of two years experience in radiation safety protection in positions which demonstrate sufficient judgement and capability to establish and maintain an effective nuclear criticality and radiation safety program for the types of activities authorized by License SNM-1067.

2.5.4 Radiation Specialist - The minimum qualifications for this position shall be a Bachelors Degree in one of the sciences, engineering or equivalent and a minimum of two years experience in Radiation Safety Protection.

2.5.5 Nuclear Criticality Specialist - The minimum qualifications for this position shall be a Bachelors Degree in one of the engineering or equivalent and three years scienes s,

experience in outside-of-reactor nuclear criticality safety or nuclear fuel manuf acturing facility criticality safety.

Experience in outside-of-reactor nuclear criticality safety or nuclear fuel manufacturing cri*.f-ality safety shall be with methods of analysis similar to those required for analyzing the types of activities authorized by License SNM-1067.

License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page:I.2-8

o 2.5.6 Nuclonr Mntarials M3negar - The minimum qualifications for this position shall be a Bachelors Degree in one of the sciences or engineering, and two years experience in nuclear materials management.

2.5.7 Production, Quality Control, or Engineering Managers - The minimum qualifications for these positions are a bachelors degree in one of the sciences or engineering and three years experience in nuclear fuel fabrication facilities.

He must have an understanding of the criticality and. health physics aspects of fuel handling and a knowledge of administrative controls imposed on fuel handling operations.

~2.5.8 Production Superintendent, Supervisors - The minimum qualifications for all Supervisors are a High School diploma (or equivalent) and two years of manufacturing experience.

The Production Superintendent will have a High School diploma (or equivalent) and at least two years of manufacturing experience in radioactive materials handling.

2.5.9 Nuclear Safety Committee Membership - The minimum qualifications required for the Committee as a whole shall be as follows:

Committee members must be highly competent senior staff members.

Committee members must be capable of evaluating radiological and/or nuclear safety and must have had at least seven (7) years experience in the nuclear industry and a Bachelor of Science degree in Engineering or one License No. SNM-1067, Docket 70-1100, Rev.4 Date: 10/22/86 Page:I.2-9

4 e

of the sciences.

Committee members must not be directly involved in the production or product development facilities utilizing the nuclear material.

An individual must disqualify himself if there is a a

conflict of interest with the production or product development groups.

The Committee member or the Consultant to the Committee who performs the independent criticality safety review shall meet the minimum qualifications for a Nuclear Criticality Specialist and shall not be the person who is authorized to conduct the monthly criticality audits and shall not be the initial reviewer.

The Committee member or the Consultant to the Committee who performs the independent radiological safety review shall meet the minimum qualifications for the Manager-Nuclear Licensing, Safety, Accountability &

Security and shall not be the person who is authorized to conduct the monthly radiological safety audit and shall not be the initial reviewer.

2.5.10 Radiological Engineer / Senior Radiological Engineer - These personnel shall meet the qualifications for a Radiation Specialist.

2.5.11 HP Technicians - The minimum qualifications for HP Technicians to approve RWP'S shall be 1 year experience in the Health Physics aspect of working with unclad Uranium.

License No. SNM-1067, Docket 70-1100, Rev.4 Date: 10/22/86 Page:I.2-10

2.6-Training 2.6.1 Initial Training All new employees (whether they are new hires or transferred from within the company) shall attend a formal training session prior to working in restricted areas.

This will cover principles of radiation safety (including ALARA practices), nuclear criticality safety, industrial safety, emergency procedures, applicable state & federal regulations (i.e., 10 CFR Parts 19 & 20), and additional information pertaining to their job.

Specialized training for radiation protection and nuclear criticality safety shall be commensurate with the extent of the employees contact with radioactive materials.

All personnel who will be working with radioactive materials must complete a test to ascertain the effectiveness of the training.

All trainees shall satisfactorily complete the test'in accordance with established criteria before being allowed to handle radioactive materials without direct supervision.

All training will be conducted under the direction of the Health Physics & Safety Supervisor for manufacturing i

and Product Development.

Records of all formal training sessions shall be kept and will include the date held, subject matter covered, attendees, instructor, and the i

results of the method used to ascertain the effectiveness of the training.

2.6.2 Periodic Retraining - All production personnel who work License No. SNM-1067, Docket 70-1100, Rev.3 Date: 10/22/86 Page:I.2-11

with rcdio:ctive matericls shall attend a formal ennual safety training session, with no more than 13 months between training sessions.

This training session will include as a minimum the topics covered in the initial training sessions.

In addition this session shall emphasize problem or potential problem areas, involving the topics covered, or any other safety related areas.

NFM-W also maintains a comprehensive system of operating procedures which include the appropriate safety precautions.

Informal training (not documented with lesson plans, etc.) is conducted by production Supervisors on a continual basis as needed to assure that personnel are properly following approved procedures.

The ultimate responsibility to follow the operating procedure lies with the employee.

Any change which alters the employees responsibility or actions in regards to safety (criticality, radiation, or industrial) must be approved by the Supervisor, Health physics and Safety, or the Manager NLSA&S who will assure the appropriate training is conducted prior to implementation.

This also includes changes to the emergency procedures which affect employee actions in an emergency situation.

All maintenance personnel shall attend formal training sessions annually, not to exceed 13 months between sessions.

If they have not attended this training, they may enter the restricted area only with a trained escort.

Maintenance training sessions will cover the same topics as the production personnel session.

License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page:I.2-12

Sp:cial emphasis will be givsn to tha internal conttmination of equipment.

Salaried personnel who enter restricted areas shall attend a formal training session annually not to exceed 13 months between sessions.

These sessions will be directed toward observation and supervision in restricted areas rather than actual handling of radioactive material.

The topics listed in the initial training shall be discussed with emphasis on the supervisory aspects of these topics.

Product Development Personnel shall conduct formal retraining of all personnel who handle radioactive material at least every 2 years not to exceed 25 months.

All work in the laboratory which involves radioactive material requires an RWP.

This system allows for continual control-of personnel handling radioactive material.

The effectiveness of all retraining is determined by the instructor questioning the personnel on an individual basis to determine their understanding of each topic.

Records of all formal training sessions shall be kept and will include the date held, subject matter covered, attendees, instructor and the results of the method used to ascertain the effectiveness of the training.

2.6.3 Specialized Training Health Physics Technicians - Health Physics Technicians for Nuclear Manufacturing, or Product Development shall receive the initial training (see 2.6.1), and will be instructed by the Supervisor, Health Physics and Safety License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: I.2-13

. - =

as appropriate, in the use of instruments, the evaluation of o

contamination, environmental' sampling, and other aspects relevant to their assignments.

Health Physics Technicians will also receive sufficient training in criticality control to enable them to carry out their auditing functions.

The training in criticality control shall to, as a minimum, a review of all limits and controls set forth in this license.

Specific details of the H.P. Technician training are outlined in the Nuclear Licensing & Safety Procedures Manual.

Formal annual retraining (not to exceed 13 months) of the H.P. Technicians for manufacturing and product development shall be conducted by the Supervisor, Health Physics & Safety and shall include a review of the topics described above.

9 9

In addition, specific problem areas and changes in federal regulations, or license requirements are emphasized.

The effectiveness of this training is. determined by the i

instructor questioning the H.P. Technicians to determine their understanding of each topic.

Records of all formal training sessions shall be kept and will include the date held, subject matter covered, attendees, instructor, and the results of the method used License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 Page:I.2-14

to ascertain the effectiveness of the training.

2.7 Operating Procedures 2.7.1 Product Development 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

  • radioactive materials assures that appropriate safety procedures are followed.

Written health and safety restrictions for all operations on radioactive materials shall be provided in the form of approved Radiation Work Permits or approved detailed procedures, and appropriate operational limits are posted in the vicinity of work stations.

The supervisor, Health Physics or the H.P. Technician, will approve RWP's based on the personnel doses which are involved with the work to be performed.

All RWP's shall be reviewed monthly by an individual having the minimum qualifications of The supervisor-Health Physics and Safety.

Product Development has simple mass limited areas separated 17 4 minimum of 12 feet, making criticality safety an easily mm. aged program.

Changes in criticality areas by Product Development personnel shall be formally described and submitted to the Manager, Nuclear Licensing, Safety, Accountability & Security in writing for review and approval.

He also determines whether the proposed changes in these areas can be approved License No. SNM-1067, Docket 70-1100, Rev.3 Date: 10/22/86 Page:I.2-15

internally or whether a license amendment is required.

All approval documents and records of evaluations are maintained in sufficient detail to permit independent review of the analyses and that such records are maintained for at least six months after termination of the operation evaluated.

2.7.2 Nuclear Fuel Manufacturing

- It shall be the responsibility of the Plant Manager (NFM) to assure that all operations involving radioactive materials have written procedures which include the appropriate cafety requirements and are followed.

Written operating procedures are provided by the cognizant engineering supervisor for all operations, including equipment clean-up during enrichment changes.

These include all criticality and radiological safety restrictions, and limits, and must be approved by the Manager, NLSA&S, the Nuclear Criticality Specialist, br the Supervisor, Health Physics and Safety prior to the start of any operation.

To assure all operating procedures are maintained current and all superseded documents are removed from circulation, all procedures must be processed through the central document control system.

This system also assures that appropriate approvals.are on all procedures prior to issuance.

All approved operating procedures shall be available in the related work area.

Before the cognizant engineering supervisor may initiate License No. SNM-1067, Docket 70-1100, Rev.5 Date: 10/22/86 page:I.2-16

criticolity ecfety which fall within the critoric of S:ction 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 mnendment 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 the Product Development will be formally audited as follows:

Operations will be audited on a quarterly and

  • annual basis by an individual, independent of Product Development, who meets the minimum qualifications of the Health Physics & Safety Supervisor.

For the quarterly audit, he will verify the adequacy of the Radiation Protection Program and that all designated limits and controls are being followed.

One of the four quarterly audits performed shall be used to fulfill the requirements for the annual audit.

License No. SNM-1067, Docket 70-1100, Rev.6 Date: 10/22/86 Page:I.2-18

For the annual audit, with no more than 13 months between audits, 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 quarterly and annual 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.

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 writing to the Supervisor Health Physics and Safety.

Once each month for radiological 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

Specialict.

He ahn11 audit for compliance with all-regulations and operational procedures and shall assess the adequacy of the radiological safety program.

His findings shall be documented and submitted to the Plant Manager - Nuclear Fuel Manufacturing.

Once each month for nuclear criticality safety by an

' individual who meets the minimum qualifications of:

The Manager of Nuclear Licensing, Safety, Accountability and Security; or the Nuclear Criticality Specialist.

The 3

Manager NLSA&S or the Nuclear Criticality Specialist shall audit for compliance with all regulations and operating procedures, and shall assess the adequacy of

+

the established criticality safety program.

Audit findings shall be documented and reported to the Plant Manager-Nuclear Fuel Manufacturing.

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.

Follow-up actions on audits of Product Development will be the responsibility of the Director, Product Development and for audits of the manufacturing facility, it will be the 4

responsibility of the Plant Manager, Nuclear Fuel Manufacturing.

All audits shall include a section for previously identified items requiring corrective action and the action taken to correct such items.

License No. SNM-1067, Docket 70-1100, Rev. 4 Date: 10/22/86 Page:I.2-20

~....

_. -... _. _ _ _ _ _. ~, - _.. _ _ _

2.9 Investigations and Raporting of Off-Normal Occurrences Any unusual events that could lead to radiation health and safety problems shall be reported to the Plant Manager, Fuel Fabrication, or 0

to the Director, Product Development as appropriate.

The NRC shall be notified of such occurrences.

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 1 CFR 73.71 for events that significantly threaten or lessen the ef fectiveness of safeguards.

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

THIS PAGE INTENTIONALLY LEFT BLANK t

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page

.2-22

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100, Rev. 5 Date: 10/22/86 Page:I.2-23

FIGURE 2.2.1 i

NUCLEAR f

I POWER SYSTEMS DIVISION i

SENIOR VICE PESIDENT NUCLEAR SAFETY Cow 41TTEE i

E i

NUCLEAR FUEL OiAIRPERSON i

i j

QUALITY CONTROL VICE PRESIDENT i

.I

]

MANAGER QUALITY ASSURANCE ENGINEERING MANAGER l

j l

I I

I I

NUCLEAR FUEL FUEL ENGINEERING PRODUCT DEVELOPMENT MJCLEAR FEL PRODUCTS MJCLEAR MANUrACTURING CRITICALITY PLANT MANAGER DIECTOR DIRECTOR DIECTOR SPECIALIST I

i MANUFACTURING PRODUCTION NUCLEAR LICENSING, SAFETY, ACCOUNTABILIT1 ENGIEERING AND SECURITY l

MANAGER MANAGER MANAGER HEALTH PHYSICS l

TECHNICIAN l

grngTABILITY HEALTH PHYSICS l

J.

SPECIALIST SUPERVISOR i

I i

I LICENSE NO. SNM-1067 Docket 70-1100 Rev. 1 Date:

10/22/86 Page: 1.2-24

J 3.0 R-diction Protection 3.1 Administrative Requirements 3.1.1 Radiation Work Permit Procedures Product Development

- All work with o'

radioactive materials in the Product Development will require a radiation work permit (RWP).

a The Health Physics technician l

or the Supervisor, Health Physics and Safety shall establish radiological requirements and set individual exposure limits.

(

o o

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 j

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 4

License No. SNM-1067, Docket 70-1100, Rev. 5 Date: 10/22/84 Page:I.3-1

th2 Work wn3 complOtCd in a COticftctory m nntr prior to restart of the related operation.

Written operating procedures for the Health and Safety group are provided and followed in the manufacturing facility and in Product Development.

Any changes in or new operating procedures for the Health Physics and Safety group are approved by the Manager, NLSA&S, the Nuclear Criticality Specialist, or the Plant Manager, Fuel Fabrication in the manufacturing facility, and by the Director, Product Development for those in Product Development.

3.1.2 ALARA Commitment C-E management is committed to maintaining radiation exposures to personnel as low as reasonably achievable (ALARA).

Product Development assures that the ALARA concept is met by the following:

A Radiation Work Permit (RWP) program that controls all operations involving the handling of radioactive material is utilized with approvals required at various exposure levels to assure all exposures are kept at ALARA.

An audit of the Product Development with emphasis on the ALARA goals is performed annually as stated in Section 2.8.1.

The major emphasis of this audit will be to review all changes implemented by management to achieve ALARA and to make recommendations to assure continued I

adherence to the ALARA concept.

Trends in radiation exposure, contamination levels, and airborne l

concentrations will be reviewed and recommendations made l

l where necessary.

l License No. SNM-1067, Docket 70-1100, Rev. 6 Date: 10/22/86 Page:I.3-2 l

l

The quarterly cudit of Product D valopmsnt includag c review of the radiation safety program to assure the 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 radiological safety program on an annual basis.

This includes a review of all changes implemented by management to achieve ALARA.

The Comn.ittee 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

Covsrall or Leb Coat Special shoes or shoe covers Safety glasses Additional protective clothing shall be worn as prescribed by the Health Physics personnel both in Product Development and in the Manufacturing facility.

3.2.2 Monitoring Requirements (Personnel)

All personnel must wash their hands before exiting the contaminated area and monitor as a minimum their hands, c

exposed areas of the body and personal clothing with the :

alpha personnel monitor located at the change line.

The frequency and control levels of personal. clothing and body surfaces shall be as follows:

PERSONAL CLOTHING AND BODY SURFACE ALPHA ACTIVITY CONTROL LEVELS

~

Surface Alpha dpm/100cm2 i

Min. Survey Frequency Personal Indistinguishable from Before leaving contamin-

Clothing, twice background ated area and when con-Body Surfaces tamination is observed (Hair,. Face, on body surfaces.

Hands)

If levels are greater than the control levels, the individual shall promptly notify a member of the Health j

Physics staff and shall not leave the contaminated area until they respond.

4 l

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.3-4

,w.,,.-..--

.------.<ws-n,.,,.m,__

en,_

....e.,,,_.,..,,,,....e-,

,,-,---,.,-----e,.,-

~

3.2.3 V:ntilntion-Rrquirementa Nuclear Fuel Manufacturing Ventilation in the Manufacturing facility (Building #17) is provided by four separate exhaust systems as described-herein:

FA-1 Powder Preparation and Pressing - This system has a capacity of 12,100 CFM and incorporates prefilters and a double bank of 12 absolute filters, each 99.97%

efficient at 0.3 microns.

The air exhaust from this system which is either returned to the unclad fuel area or released from the plant is sampled 100% of the time and analyzed each day, j

FA-2 Furnace H2 Burnoff - This system has a capacity of 1340 CFM and incorporates prefilters and a single bank of 4 absolute filters, each 99.97% efficient at 0.3 microns.

The air. exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

i FA-3 Pellet Grinding and Rod Loading - This system has a capacity of 17,500 CFM and incorporates prefilters and a 4

doubic bank of 16 absolute filters, each 99.97%

efficient at 0.3 microns.

The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

FA-4 Recycle Powder Area - This system has a capacity of 6000 CFM and incorporates prefilters and a double bank of 6 f

absolute filters, each 99.97% efficient at 0.3 microns.

2 The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

License No. SNM-1067, Docket 70-1100, Rev. 4 Date: 10/22/86 Page:I.3-5

N Tha.ceptcity of thm ventilation. systems have been matched to provide a negative pressure differential between the Pellet Processing Facility and all surrounding. work areas.

The direction of air flow'shall be checked monthly and documented.

If airborne activity results, averaged over a two week period, exceed 25% of the applicable concentration listed in Table II, Column I of 10 CFR 20 Appendix B for air 4

being discharged to an unrestricted area (from manufacturing or Product Development Operations), an' investigation will be conducted and corrective action taken.

In addition, to assure our releases remain as low as reasonably achievable, a quarterly limit of 18 uci in. gross alpha activity of total uranium in plant gaseous effluents shall be maintained.

If the radioactivity in plant gaseous effluents exceeds 18 uC1, a report which identifies the cause for exceeding the limit and the corrective actions to be'taken to reduce release rates shall be submitted to the NRC within 30 days.

Also, if 1

the parameters important to a dose assessment change 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.

The 18 uci/qtr. limit would

[

result in a lung dose to an individual at the nearest resid-i ence of (conservatively) less than 0.10% of the 25 mrem / year i

t

~

standard as specified in 40 CFR 190.

Ventilation system filters and/or prefilters will be changed, t

i rotated, or knocked down whenever a pressure drop of 4 inches l

of water is measured across the combination of the prefilter and first bank of absolute filters.

The pressure drop for all 4 l

l l

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 Page:I.3-6

cyctcm3 chn11 be ch;ckcd weakly cnd d:cumentcd.

Whnn tha face velocity at a ventilated hood drops below 100 fpm, the hood filters or ventilation system filter will be changed, brushed, or knocked down to increase the air flow to 100 fpm minimum or the hood will not be used to handle radioactive material.

Face velocities will be checked weekly in the manufacturing facility and monthly in Product Development.

Any work on filter change involving any of the four fixed air systems in manufacturing shall be performed under an RWP.

following all filter changes or other movement of filters, both the Supervisor and H.P. Technician shall inspect the placement of the absolute filters for proper sealing.

In addition, air samples will be taken and counted immediately after 1/2, 2, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of operation to assure the absolute filters are adequately filtering the exhaust air.

The adequacy of the sampling techniques to obtain representative samples will be verified quarterly in the Manufacturing facility and annually in Product Development.

Product Development Airborne wastes are released from Product Development as a result of airborne activity during handling and transfer of UO2 powder for chemical analysis purposes, production of special R&D test fuel, and metallographic examination of production fuel and special test fuel.

All airborne waste is exhausted from Product Development (Building #5) via seven individual stacks.

The exhaust is continuously monitored whenever operations involving dusting or release of radioactive material are in l

License No. SNM-1067, Docket 70-1100, Rev. 4 Date: 10/22/86 Page:I.3-7

progrcza.

All Ottcka ur:d for thJ cxhzusting cf rcdic ctiva effluents are equipped with sampling connections.

All but o

one of the stacks has absolute filters.

The one exception o

is the environmental test laboratory stack (Stack #7).

O Product Development (Building #5) exhaust stacks typically have the following flows:

Stack No.

Area Monitored Flow (ft3/ min.;

1 Chemistry (No longer in use) 6200 2

Hot Chemistry Lab 3100 3

Emission Spectroscopy Lab 2000 o

5 Radiochemistry Lab, Environmental 2610 Labs & Vault 6

Ceramics Lab (Rm 222), Metallo-2125 graphic Lab 7

Environmental Test labs (No longer 2000 in use) 8 Ceramics Lab (Rms. 224 A & B) 4500 Air from systems Nos. 2,3,5,6 and 8 pass through single banks 0

of absolute filters (99.97 percent efficient for >0.3 micron particles), and are vented to the atmosphere.

Continuous sampling is provided immediately upstream from the discharge o

point.

o o

O The environmental test lab is connected to System No. 7.

However, the system is not presently being used.

Ventilation system filters and/or profilters will be changed, rotated, or knocked down whenever a pressure drop of 4 inches of water is measured across the combination of the profilter and License No. SNM-1067, Docket 70-1100 Rev. 3 Date: 10/22/86 Page: I.3-8

firct btnk of cbcoluto filtoro.

Tha pracsura drcp for all cyst:ma chn11 be chscksd monthly and documantsd.

When the faca valocity-et a ventilated hood drops below 100 fpm, the hood filters or ventilation system filters will be changed, brushed, or knocked down to increase the air flow to 100 fpm minimum or the hood will not be used to handle radioactive material.

Face velocities will be checked monthly in Product Development.

The filters in these stacks shall be tested either by 1) counting samples immediately after 1/2 hour of operation or 2) DOP testing the filters in accordance with ANSI standards. Such testing shall be done after all filter changes or movement of the filters.to assure they are adequately filtering the exhaust air.

The results of these tests shall be documented.

Each ventilating filter system described in Section 3.2.3 shall be equipped with an instrument that measures the pressure drop continuously.

3.2.

Instrumentation capabilities of radiation detection and measurement instrumentation shall be as follows:

Alpha Countin,g System 10 - 10,000 dpm Alpha Survey Meters 0 - 50,000 counts per minute Beta-Gamma Survey Instruments

.05 mR/hr - 200 mR/hr Neutron Survey Instruments

.5 - 5,000 mrem /hr A sufficient number of the instruments, meters and systems listed above shall be maintained operational to adequately conduct our Health Physics program.

Additional instrumentation is maintained for emergency use as outlined in Part I Section 8.

The detectors for the criticality alarm system are calibrated quarterly and following any repair that affects the accuracy of the measurements.

All other instruments are calibrated twice per year and following any repair that affects the accuracy of the measurements.

The calibration of the survey instruments shall meet the specifications described in Section 1.11 of Regulatory Guide 8.24, " Health Physics Survey During Enriched License No. SNM-1067, Docket 70-1100 Rev. 5 Date 10/22/86 Page:I.3-9

individunlo cnd cquipment.

Th3 pellct chop io the cnly plcca in th3 m:nufccturing fccility th2t h ndica uncicd U02.

Thio portion of the facility is kept at a negative pressure as described in Section 3.2.3.

Therefore, continuous air sampling shall be conducted in this area only.

o Product Development 0

All operations in Product Developments which involve UO2 powder or the potential for worker exposure to airborne uranium exceeding the limits specified in 10 CFR 20.103, shall be sampled with breathing zone samplers 100% of the time.

Samples shall be analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after each operating shift.

A one MPC action level and a minimum flow o

rate of 1400 cc/ min. shall be used for Product Development operations.

3.2.6 External Exposure (Dosimetry Requirements)

Each individual who enters a restricted area under such circumstances that he is likely to receive a dose in any calendar quarter of 25 percent of the applicable value specified in 10 CFR 20.101(a) shall be supplied with a TLD badge and indium foil for purposes of personnel dosimetry.

Badges will be processed monthly.

When a high exposure is suspected, the individual's badge will be sent out for immediate processing.

All visitors will be supplied with indium foil badges.

Area TLD badges and neutron foils are also strategically placed throughout the facility for the purpose of recording background radiation levels as well as o

radiation resulting from a criticality accident.

The TLD badges will also be processed monthly during normal operations and immediately following a criticality accident.

Procedures to determine high radiation License No. SNM-1067, Docket 70-1100, Rev. 4 Date: 10/22/86 Page: I.3-12

2)

Lung Burd;n>200ug U235 Taka cbova c rr:ctiva cction, cnd in addition, remove the individual from further exposure to airborne radioactivity.

3.2.8 Contamination Surveys 3.2.8.1 Contaminated Areas (Pellet Shop Building #17 &

0 Contaminated Areas of Product Development)

Removable Alpha Contamination Action to be Taken 10,000 dpm/100 cm2 Immediate Clean-Up 5,000 dpm/100 cm2 24-hour Clean-Up contaminated areas shall be surveyed on a weekly basis.

Material fixed on processing equipment or on surfaces shall be limited as required to control airborne radioactivity and external radiation exposures.

3.2.8.2 Clean Areas (other plant areas, office areas, lunch areas)

Removable Alpha Contamination Action to be Taken Alpha Level 100 dpm/100 cm2 Immediate Clean-Up 50 dpm/100 cm2 24-hour Clean-Up

  • 10 dpm/100 cm2 Immediate Clean-up
  • (lunch rooms only)

Other manufacturing areas, office areas, and the warehouse (Bldg. 21) shall be surveyed on a monthly basis.

The lunch rooms shall be surveyed once a day, as a minimum.

Fixed Alpha Contamination Monthly fixed alpha contamination levels in the non-contaminated areas (and for release of equipment from contaminated areas) shall be less a

than 500 dpm/100 cm2 average.

License No. SNM-1067, Docket 70-1100, Rev. 3 Date: 10/22/86 page: I.3-14

CommittCo.

H2 ch211 mest tha minimum qu211ficOticn3 fcr n Nuclear Criticality Specialist and shall not be the initial 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.

l 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 to 3.5 wt.% U235, j

4.1.7 Audits O

4.1.7.1 Product Development - Nuclear criticality safety for 0

all Product Development operations shall be limited to quantities smaller than a minimum critical mass with the exception of one slab limited storage area l

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, slab, geometry, etc.)

t shall not be permitted.

Thus, the nuclear 1

0 criticality safety program in Product Development consists of simple mass limits.

The quarterly f

radiological safety audit of laboratory operations required by section 2.8 shall include verifications to assure that all nuclear safety limits are being o

adhered to.

An annual audit of License No. SNM-1067, Docket 70-1100 Rev.5 Date: 10/22/86 Page: I.4-3

o Product Devaltpment ch311 be c:nductcd in Ccc:rd2nca with the requirements of section 2.8.

4.1.7.2 Nuclear Fuel Manufacturing Operations - Operations at the Nuclear Fuel Manufacturing facility shall be formally audited for nuclear criticality safety as required by the audit schedule in section 2.8.

4.1.8 Training and Retraining - All training and retraining with respect to nuclear criticality safety shall be conducted in accordance with the requirements of section 2.6.

4.2 Technical Requirements 4.2.1 Preferred Approach to Design - It is the intent of Combustion Engineering to use physical controls and permanently engineered safeguards on processes and equipment in the establishment of nuclear safety limits wherever practical.

Use of administrative controls in'the establishment of safety limits will be minimized.

4.2.2 Basic Assumptions and Analytical Methods - Written health and safety restrictions for all operations on radioactive material shall be provided in the form of approved Radiation Work Permits or approved detailed procedures, and appropriate operational limits shall be posted in the vicinity of work stations in both the manufacturing facility and Product Development.

Each operation on fissile material in the 235 Product Development shall be limited to 350 gm U for 235 235 uranium enriched to more than 5% U

, and to 740 gms U for-235 uranium enriched to 15% U

, and License No. SNM-1067, Docket 70-1100 Rev.4 Date: 10/22/86 Page: I.4-4

T l

chcIl be esparcted from_cny othsr ficcilo' mat 0 rial by 12 fest.

Rods containing sintered U02 pellets enriched to'a maximum of I

o 4.1% U235 shall be stored in Buildings #2 or'#5.

Storage of material in Building #2 shall be limited to a single slab less; a

than 3.7 inches thick.

F o

-A-continuous log shall be maintained for each mass limited I

' work station or storage area in Product = Development to assure j

that the limit is maintained and that.the-enrichment of all i

material is recorded.

No additional criticality controls are ;

t j

8-required for Product Development.

Criticality safety of the less complex manufacturing 3

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 1

)

spaced using the surface density' method.

l The remaining manufacturing operations are evaluated using two dimensional transport and/or 3 dimensional Monte. carlo codes, j

The sixteen group Hansen-Roach cross section library is used f

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 L

validated in accordance with the criteria established in l

Regulatory Guide 3.41 " Validation of Calculational Methods for:

)

Nuclear Criticality Safety".

Specific validations are provided in Part II of this application.

1 i

License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: I.4-5

ch011 be indicated with a colcrcd lina.

Tha lina may be crossed by carts only to permit an operator to transfer that SIU to an available storage position.

4.2.7 Structural Intecrity Policy - All storage racks, furnaces, containment, and processing equipment which provide nuclear safety limiting parameters shall be designed to assure against failure under normal and reasonable overload conditions and under conditions of shock or collision foreseeable in the plant area.

All equipment designed shall incorporate a minimum safety factor of 3.0.

All equipment design shall conform to standard design practices, thereby assuring adequate structural integrity.

Materials of construction shall be selected to assure, as far as possible, resistance to fire and corrosion.

The individual engineer responsible for the purchasing or design of the new equipment shall assure that the minimum safety factor of 3 has been incorporated into the design of the equipment.

The minimum qualifications for engineers shall be a bachelors degree in engineering or related fields.

4.2.8 Zoninc for Fire Protection - An overhead sprinkler system as well as portable extinguishers are located throughout the fuel' 0

manufacturing facilities and Product Development.

Onsite and offsite fire protection service personnel have been instructed l

to use only portable dry chemical extinguishers in the Bldg.

l

  1. 17, to maintain the highest possible margin of nuclear criticality safety.

Fire hoses shall not be permitted in l

Bldg. #17.

4.2.9 Criticality Alarm System - A criticality alarm system which meets the requirements of 10 CFR 70.24 (a) (1), Regulatory Guide l

License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: I.4-11

8.12, " criticality Accid;nt Alcrm Syctcm" chall be maintcined o

in Product Development areas and the manufacturing facility.

O The detectors operate in the range of 1-10,000 mR/hr.

The locations of the detectors within the manufacturing facility are shown in Figure 4.2.1 and within the laboratories in Figure 4.2.2.

The radiation intensity is shown on a central panel located in the Health Physics office for the manufacturing facility (Bldg. #17), and in the main hallway 0

in Bldg. #5 of Product Development and in the HP office in 0

Building #2.

There is an alarm which serves as a local and general audible radiation evacuation alarm.

When the alarm is~

sounded, the Emergency Plan is immediately put into effect.

The monitors are connected to the emergency power system, which is supplied to all emergency lights and alarms in the L

event of a general power failure within the facility.

This electrical system renders the alarm system operative at all times.

This system is tested for operability quarterly.

Operation is further enhanced by visual observation by Health Physics personnel.

Alarm operational tests of the radiation monitors are performed monthly by Health Physics personnel.

A radioactive source is used to perform these tests.

The entire system is calibrated quarterly and following any repair that affects the accuracy of the measurement.

4 4.3 Specific criticality Safety criteria specific criticality safety criteria in addition to the general criteria described in Section 4.2 are necessary to assure nuclear safety for several process operations, as described below:

License No. SNM-1067, Docket 70-1100 Rev. 3 Date: 10/22/86 Page: I.4-12

FIGURE 4.2.2

... _/

-w%m e2

=

e o

i l1 I l I

I II N-F 1

ii

=

y ['-

mata 1

I s

I - ;,,

f M

(

e j

m, u

h; p

m

/t-J E, W' Y k*.a.~t.,

r.

n.,

y

.- f l, l

l

" ^

=^

g.

=

u..

Wd,<

ss,

-- - s** r <e 4.ao m, l

, m) y L

.D, y

l!

I$ "*'

II A i

.t. M sse c f

y-.

al _

%M, j

.E,I l

t

.cuuve 9 O OtutSTRT L..

l I

. ]../

l,7 gg u.

l g

I %

as,

,,3 r.

~

V

, _j%l

- ]s:,.

e!>"'l s

1 I

+...

4' h

a % '3 L. _ _-

D ' t%m -i -

co 1

- l _j ]

T,."' "7J '. -.- ! j' "' :!

l l-l

==

p(

%f-i p,,, g 5--S e [ $m P" l 23.

3

.ng m. @i n,. _'jm l,

[

,u i

u

. _,t u g. U c,,, i J

e u>" a.,

i s <.,-y q F.

eew Q

r 1

l ** ar

'a p X

J,._c. cap.es u__aal,,. g gu. t.

n.

' m'I.m ef

.[.. m.j:j,, -

3=.a.j==

i

.gj._ v ;

j m,....'.

w a-t -

m l,,,

, @'l ^ l y

<l=.

9in L ', "n," ;

..o.,

l, <_

u.

,n 8

s._, l

-i e I.

j... n, i n.-

i i

!A-F

.a=

l$.v.s

,,.o X .L_

I

> ;--i r

4 - _w 6"

.a ea,

. n v... u.

n.

~ + -

I

/

/

A 3- %

I,

/'/

g cena. coa as connioon s.

6 4 6;$

<( r m~-<,l

' M ' ( q.r w. ~:y '. ; " ' ' "...

='4' ;

3rt e r- -

m r

sq s

'o' t I

..,. u.

v.,

..?

~,(,

"F -'ss"E.< C} Li

.. '.-~

N m

w.

as vo 6u

._r. f.)

r n_z _

__r t

.r n.

o,_

a,=____---

.. a

~

KEY PLAN REMOTE READ OUT -

PRODUCT DEVELOPMENT ALi i

COMBUSTION ENGINEERING INC.

bMW b.-

vimwnR CONN 0-oETEcToes LOCATioNsL...."..........~..~"= 4 - a' M",'" /^.".' 02 PEM-5 License No. SNM-1067 Docket 70-1100 Revision:

3 Date: 10/22/86 Page: 1.4-18

6.0 INDUSTRIAL SAFETY 0

The Director, Product Development shall be responsible for compliance with all applicable industrial safety (OSHA) regulations for all activities in Product Development covered by License No. SNM-1067.

The o

Supervisor, Health Physics and Safety shall be responsible for compliance in the manufacturing facility.

7.0 DECOMMISSIONING PLAN Combustion Engineering's Decommissioning Plan dated 1/12/79 was submitted previously is included as Appendix A to this renewal application.

8.0 RADIOLOGICAL CONTINGENCY PLAN Combustion Engineering's Emergency Plan dated 7/30/79 and approved 3/26/82 should be considered part of this renewal application.

This will be superceded by the " Radiological Contingency Planning Information" which shall be submitted under separate cover in accordance with an NRC Order dated 2/11/81.

9.0 FUNDAMENTAL NUCLEAR MATERIAL CONTROL PLAN (FNMC)

Combustion Engineering's FNMC dated February 1980 was submitted June 11, 1980 and should be considered part of this renewal application.

License No. SNM-1067, Docket 70-1100 Rev. 3 Date: 10/22/86 Page: I.6-1

W PART II.

-SAFETY DEMONSTRATION E

j.

- 1. 0 OVERVIEW OF OPERATIONS

. l.1 Corporate Information and Financial Qualifications l.1.1 Name and Address of Licensee:

COMBUSTION ENGINEERING, INC.

1000 PROSPECT HILL ROAD WINDSOR, CONNECTICUT 06095 l

Combustion Engineering is incorporated in the State of Delaware.

Location of Principal Office:

Windsor, Connecticut 1.1.2 Names, Addresses and Citizenship of Principal Officers t

Name Position Address Citizenshipj SANTRY, A.

J.,

Jr.

Chairman and 900 Long Ridge Road U.S.

1.

Chief' Executive Stamford, Conn.

Officer HUGEL, Charles E.

President and 900 Long Ridge Road U.S.

Chief Operating Stamford, Conn.

Officer

ENNIS, T. A.

Vice President 900 Long Ridge Road U.S.

Administration Stamford, Conn.

]

KIMMEL, G. S.

Vice President 900 Long Ridge Road U.S..

Finance Stamford, Conn.

  • ~

KELLY, JAMES Vice President 1000 Prospect Hill Road U.S.

i Power Systems Windsor, Conn.

3

HALLINAN, R. J.

Vice President 900 Long Ridge Road U.S.

Stamford, Conn.

i General Counsel KIAMIE, Mitchell Vice President 900 Long Ridge Road U.S.

l

& Controller Stamford, Conn.

i i

I' i

1 l

License No. SNM-1067, Docket 70-110 Rev 4 Date: 10/22/86 Page:II.1-1

..,._.,..___......,,_.,_.____,_,.,._,.--..,,..._..,,,___.,__,_,.,,,,y_,...-

7,.. - - _,.., _.,

C-E hac organizsd four carvica diviciens (Fintnca, Racecrch, International and Administration) and the following' operating divisions:

Engineering and Construction Group - This group has a broad international involvement in the design, engineering, and construction supervision of projects in the chemical, petrochemical, petroleum, metallurgical and other process industries.

Process Equipment Group - This group manufactures and markets a wide range of energy-related products including oil and gas production processing equipment, heat exchangers, and pollution control equipment.

l Industrial Products Group - This group provides a full range of services in the architectural, engineering, and planning I

disciplines with recognized special competency in environmental engineering, resource recovery and disposal of solid waste, transportation systems and the production of high

{-

temperature industrial ceramic materials for lining furnaces and other heat processing auxiliary equipment.

e Power Systems Group - C-E Power Systems provides fossil and nuclear fueled steam generating equipment, nuclear fuel and components, and air quality control systems for the electric utility industry, and steel transmission structures.

This group also provides industrial steam generating equipment, fuel burning and auxiliary equipment, and chemical recovery I

systems and boilers for pulp and paper mills as well as heavy License No. SNM-1067, Docket 70-110 Rev.3 Date: 10/22/86 Page:II.1-3

thick-wallcd proccuro vaccole for tha chimical, petroch:mical and petroleum processing industry.

The Nuclear Power Systems Division of the power Systems Group has approximately 1200 (as of January 31, 1980) employees, of whom approximately 70% are scientists and engineers.

More than two-thirds of the professional staff have at least five years experience in the nuclear field and approximately 50%

have continued their education beyond the Bachelors Degree level.

This staffing provides competence in the field of nuclear science and technology and extensive experience in the following specific areas:

theoretical and experimental physics, mathematics, reactor analysis, chemistry, metallurgy, instrumentation controls, mechanical design, thermal sciences and nuclear and radiological safety.

Nuclear Products Manufacturing Nuclear Products Manufacturing (NPM) is equipped to provide a variety of services necessary in the development and manufacture of precision reactor components such as fuel rods and assemblies containing low enriched Uo2 and control rods.

Equipment is also available to fabricate certain alloys of metals used for control rods and other special components.

Product Development Product Development maintains complete facilities for the-development, design, analysis and testing of nuclear components and systems.

Product Development License No. SNM-1067, Docket 70-110 Rev.3 Date: 10/22/86 Page:II.1-4

o conaieto of two functional c:ctions:

New Product Development - Establishes experimental basis for fuel design systems, specifies materials for proto-type fuel fabrication; reviews drawings, specification and other documents for prototype fuel performs dynamic and structural testing of reactor components; evaluates test data, and test results; provides in-service inspection and field inspections for fuel.

Core Materials Development - Reviews material specifications; analyzes material problems, recommends materials for specific applications and environments; reviews fabrication and test procedures; develops and maintains chemistry specifications; performs metal-lurgical and chemical testing; analyzes chemistry related problems; predicts the effects of irradiation on material properties; performs irradiated materials testing.

The Product Development staff is comprised of metallurgists, chemists, engineers, and technicians.

Product Development occupies a 14,000 square foot License No. SNM-1067, Docket 70-110 Rev.3 Date: 10/22/86 Page:II.1-5

o croc in Building 45.

O Product Development maintains equipment for mechanical testing, X-ray diffraction, vacuum and inert atmosphere heat treating, radiography, powder processing, and ceramics processing.

1.1.4 Information Known to Applicant Regarding Foreign Control There is no information known to. Combustion Engineering, Inc..

of any control exercised over it by any alien, foreign corporation, or foreign government.

The stock of Combustion Engineering is traded on the New York Stock Exchange.

According to the stock records of Combustion Engineering maintained by its Transfer Agent, The Chase Manhattan Bank, as of December 31, 1979, there were approximately 26,742 stockholders of record, holding _16,337,119 shares of Combustion capital stock issued and outstanding.

Of this number, (See Appendix A) less than 1 percent of all stockholders gave foreign addresses.

1.1.5 Financial Qualifications Combustion Engineering's most recent published financial position is as of December 31, 1979 and is attached as Appendix B.

1.2 Operating Objective and Process - Summary The process at the manufacturing facility begins with receipt of UO2 powder enriched to a maximum of 4.1% U235 from Combustion Engineering's License No. SNM-1067, Docket 70-110 Rev.3 Date:10/22/86 Page:II.1-6

oxida convarsion plant in Hamstito, Mionouri.

Thic powder is than mida up into batches with various additives and pressed into pellets.

The pellets are dewaxed in a furnace where volatile additives are removed.

The pellets then pass through a sintering furnace where they densify and attain the desired characteristics.

Final sizing is accomplished through the use of a centerless grinder.

The finished pelle^.s are then loaded into zirconium tubes which are sealed and combined into finished PWR fuel assemblies.

The assemblies are finally loaded into approved shipping containers and delivered to a carrier for transport to their final destination.

Analytical operations are carried out by Product Development.

These operations may require uranium in any form and enriched to <20% U235.

-1. 3 Site Description 1.3.1 Population The area surrounding Combustion Engineering's 1200-acre site is sparsely populated.

Windsor, Connecticut is the nearest town of significant size, approximately five miles away, with a population of 22,502 and a population density of 760.2 per square mile.

East Granby, Connecticut is the nearest town to the site, approximately three miles away, with a population of 3,532 and a population density of 198.4 per square mile.

The distribution of population in the area is shown in Table 1.3.

Figure 1.3.1 is a map of the general area showing the location of the towns listed in Table 1.3.

i License No. SNM-1067, Docket 70-110 Rev.3 Date:10/22/86 Page:II.1-7

,-r,

=

Hills to thm wast and northwast are a couren of cumm3r l

thunderstorms which, when accompanied by wind and hail, sometimes do condsiderable damage to the crops in the i

Connecticut Valley.

Frequently during the winter, when' rain falls through the cold air. trapped in the Valley, the resultant icing creates hazardous conditions ~for j

transportation and utility installations.

On clear nights.in the late summer or early autumn, cool air drainage into the Valley, plus Connecticut River moisture, produce ground fog.

which sometimes becomes quite dense through the Valley and hampers ground and air transportation.

1.3.4 Geology l

The surrounding area has been subjected to the actions of i

glacial ice.

All dominant geological features are a result of erosion and depositions caused during the Pleistocene era.

i The State of Connecticut has favorable earthquake history.

Ten earthquakes are listed, the first recorded in 1791 and the l

last in 1925.

All of these, with the exception of-the first,

~

were local in nature and of moderate intensity, i

1.3.5 Hydrology i

l The surface drainage in the surrounding area is excellent.

The predominantly sandy nature of the soil and heavy forest cover results in very moderate run-off even after heavy prolonged precipitation.

i The site creek, into which all site effluents are discharged, j

flows into the Farmington River which flows along the j

northwest corner of the Combustion site, shown in Figure 1.3.2.

Two and

+

. License No. SNM-1067, Docket 70-110 Rev.3 Date: 10/22/86 Page:II.1-10 l

1.5 History of Licanaa

)

Combustion Engineering first applied for a license to process low enriched uranium by the methods described in section 1.2 in 1968.

License SNM-1067 was then issued for a period of 5 years by the U.S.

Atomic Energy Commission (AEC).

o a

e License No. SNM-1067, Docket 70-110 Rev.3 Date:10/22/E6 Page:II.1-12

--.g.

y -

7 w

--,_a

-_.y,,e

then connected to the low voltage metal clad switch gear for distribution throught the building.

A further step-down to 208/120 volt is made for lighting and general convenience power.

Emergency power System A diesel generator serves as a back-up emergency power system for both the manufacturing and laboratory facilities.

The generator produces 3-phase, 480 volts, and 200 KW.

The described generator feeds a rated distribution panelboard which has several 100 ampere, 3-phase 480 volt circuit breakers.

The panelboard is switched from normal power to generator (emergency) power by an Asco transfer switch.

Diesel start-up and transfer takes approximately ten to twelve seconds.

A circuit breaker within this panelboard is used to supply emergency 0

power to the manufacturing and product development facilities.

The principal site water supply is provided by the Metropolitan District, the source of city water for the greater Hartford area.

Chemical and radiological analyses for both raw and treated well water have been made, and any changes in composition or activity from any cause will be discovered rapidly.

2.3 Heating, Ventilation, and Air Conditioning (HVAC)

The Building #17 office area, consisting of 4800 square feet is heated and cooled by hot and chilled water respectively supplied by the Windsor site central boiler house.

Office areas have built-in convectors which heat and cool the areas depending on the time of year.

Each office has an exhaust system which ventilates the area and allows fresh air to be brought in.

The main shop area of Building #17 consists of approximately 36,000 License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 page:

II.2-2

3.0 Organization and Personnel Functions of key positions, specifics on education and experience required for key personnel, organization procedures, and unit functions (including safety committees) are described in Part I, sections 2.2, 2.3, 2.4, and 2.5 of this renewal application.

3.1 Organiztion Charts Current Organizational charts and structure are provided in Figure 3.1.1.

3.2 Resumes of Key Personnel Resumes of key personnel are provided in this section on the pages following the above described organizational charts.

License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-1

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-2

THIS PAGE INTENTIONALLY LEFT BLANK I

License No. SNM-1067, Docket 70-1100 Rev.5 Date: 10/22/86 Page:

II.3-3

~

~

FIGURE E

~

NUCLEAR POWER SYSTEMS DIVISION S. T. BREWER SENIOR VI PRESIDENT NUCLEAR SAFETY CDeIITTEE 8

F. BEVILAQUA NUCLEAR FUEL 01AIRPERSON

11. V. LICHTENBERGER QUALITY CONTROL VICE PRESIDENT P. FERWERDA MANAGER QUALITY ASSURANCE ENGINEERING M. GLOTZER MANAGER i

I I

I I

NUCLEAR FUEL FUEL ENGINEERING PRODUCT DEVELOPMENT PRfCLEAR FIEL NUCLEAR MANUFACTURING PRODUCTS CRITICALITY J. PARRETTE R. DUNCAN p

C. COPPERSMITil R. KLOTZ PLANT MANAGER DIRECTOR DIRECTOR DIECTOR SPECIALIST I

1 MANUFACTURING PRODUCTION NUCLEAR LICENSING, ENGIEERING SAFETY ACCOUNTABILITT AND SECURITY P. ITUBERT G. KERSTEEN R. E. SIIEERAN MANAGER MANAGER MANAGER HEALTH PHYSICS R. VEILLEUX j

l l

TE04NICIAN 1

AC00LMTABILITY HEALTH RiVSICS K. ROCCO J. VOLLARO SPECIALIST SUPERVISOR i

LICENSE NO. SNM-1067 Docket 70-1100 Rev. 1 Date: 10/22/86 Page:

II.3-3A

This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86-Page:

II.3-6

i This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Paga:

II.3-7

This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-8

This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-9

This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-10

i This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-11

This Page Intentionally Left Blank License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-12

THIS PAGE INTENTIONALLY LEFT BLANK t

License No. SNM-1067, Docket 70-1100 Rev.4 Date: 10/22/86 Page:

II.3-15C

TtIIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.4 Date: 10/22/86 Page:

II.3-15D

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-16

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-17

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-18

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-19

9 THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-20

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-28

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-29

THIS PAGE INTENTIONALLY LEFT BLANK License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-30

r-THIS PAGE INTENTIONALLY LEFT BLANK I

License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page: II.3-31

n, 3

THIS PAGE INTENTIONALLY LEFT BLANK t

d License No. SNM-1067, Docket 70-1100 Rev.3 Date: 10/22/86 Page:

II.3-2